San Diego County Air Pollution Control District Title V Operating Permit Program Evaluation Final Report October 11, 2022


San Diego County Air Pollution Control District
Title V Operating Permit Program Evaluation

Final Report

October 11, 2022

Conducted by the

U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, California 94105

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Table of Contents

Acknowledgments	6

Glossary of Acronyms and Abbreviations	7

Executive Summary	8

1.	Introduction	12

Background	12

Title V Program Evaluation at the San Diego County Air Pollution Control District	13

Description of the SDAPCD	14

The EPA's Findings and Recommendations	17

2.	Permit Preparation and Content	18

2.1	Finding: The SDAPCD has an internal quality assurance process for reviewing draft versions of
permits before they are made available for review by the public and the EPA; however, the
understanding of the review process is inconsistent between various groups and varies with level of
experience	18

2.2	Finding: The SDAPCD's statements of basis do not consistently describe regulatory and policy
decisions the District has made in the permitting process	19

2.3	Finding: The SDAPCD uses template permit documents and maintains template conditions in its
database to provide consistency in its permits	21

2.4	Finding: The SDAPCD does not document whether a requested title V permit modification
meets the criteria under which it is submitted, including confirming whether a change is a modification
undertitle I of the CAA	21

2.5	Finding: The SDAPCD generally references the underlying origin and authority for permit
conditions, but often does not reference the origin of New Source Review (NSR) requirements.

22

2.6	Finding: While the SDAPCD appears to streamline applicable requirements in its title V permits,
the District generally does not provide the necessary streamlining analysis in the statement of basis.

23

2.7	Finding: The SDAPCD clearly identifies locally enforceable conditions in title V permits.24

3.	Monitoring	25

3.1 Finding: While the SDAPCD generally reviews CAM applicability, internal guidance needs to be
updated and staff need training	25

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3.2	Finding: The SDAPCD's title V permits generally contain monitoring that is sufficient to
determine compliance with emissions limits. However, the SDAPCD's statement of basis does not
consistently address periodic monitoring	26

3.3	Finding: The SDAPCD generally includes sufficient recordkeeping requirements as required by
the NSPS and NESHAP regulations	27

4.	Public Participation and Affected State Review	28

4.1	Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services as required by 40 CFR Part
7.35(a)	28

4.2	Finding: The SDAPCD provides public notices of its draft title V permitting actions on its website.
29

4.3	Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit	30

4.4	Finding: The SDAPCD's general practice is to conduct a concurrent public and EPA review. If
comments are received during the 30-day public review period, the permit package is re-proposed to
the EPA for a new 45-day review period	31

4.5	Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application
meetings with potential sources to help identify the scope of potential permitting projects and the
applicability of regulatory requirements	31

4.6	Finding: The SDAPCD notifies tribes of title V permitting actions	32

5.	Permit Issuance / Revision / Renewal	33

5.1	Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog	33

5.2	Finding: The SDAPCD routinely submits proposed and final permit actions to the EPA.33

5.3	Finding: The SDAPCD has authority to use parallel processing to streamline the issuance of
modified NSR and title V permits. However, it is not clear that this processing method is correctly
utilized	34

5.4	Finding: The District does not evaluate the potential emissions from sources without title V
permits to determine if they are major sources or whether such sources need synthetic limits to avoid
title V applicability or other CAA requirements	35

6.	Compliance	37

6.1 Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS)	37

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6.2	Finding: The District's Compliance Division reviews all title V deviation reports, annual
compliance certifications, and semiannual monitoring reports submitted by Part 70 sources.37

6.3	Finding: When potential compliance issues are discovered, the District addresses them prior to
permit issuance. However, the District's statement of basis could be improved to include compliance
history	38

6.4	Finding: The District uses title V compliance certifications and semiannual monitoring reports
to prioritize inspections and initiate enforcement actions	38

6.5	Finding: Compliance staff have the necessary equipment to perform their job duties but find
the procurement process for new equipment to be slow	39

6.6	Finding: While the SDAPCD has a process in their internal database for compliance staff to
request changes to title V permits, it is unclear if it is being used consistently	39

7.	Resources and Internal Management	41

7.1	Finding: The SDAPCD staff report that they receive effective legal support from the District
Counsel's office	41

7.2	Finding: The District tracks title V program expenses and revenue and those funds are spent
solely to support the title V program	41

7.3	Finding: The District permitting and compliance management communicate well and meet
routinely to discuss programmatic issues. However, the results of these discussions are not clearly and
consistently communicated to compliance staff and has resulted in uncertainty regarding outcomes of
issue resolution among compliance staff	42

7.4	Finding: The District lacks a training plan for its permitting and compliance staff	43

7.5	Finding: Permitting staff demonstrated a general lack of knowledge on environmental justice
(EJ) related to permitting and would like the EPA to provide training on this issue	44

7.6	Finding: The SDAPCD faces staffing challenges, one of the symptoms of which is a permitting
backlog, that, with its recent reclassification to a higher nonattainment status, will create additional
resource demands on its title V permitting process	44

8.	Records Management	46

8.1	Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center	46

8.2	Finding: The SDAPCD has improved its written file retention policy. However, most staff
interviewed are not aware of the District's record retention schedules	46

8.3 Finding: The SDAPCD uses an electronic database to track title V permits and continues to make
database improvements	47

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Appendix A. Air Pollution Control Agencies in California	

Appendix B. Title V Questionnaire and the SDAPCD Responses	

Appendix C. U.S. EPA Statement of Basis Guidance	

Appendix D.	Map of Linguistically Isolated Households in the SDAPCD.

Appendix E. Fee Guidances	

Appendix F. SDAPCD Fee Information	

Appendix G. SDAPCD Record Retention Schedule	

Appendix H. Engineering Division Manual of Operating Procedures	

Appendix I. EPA's Response to Comments	

Appendix J. SDAPCD's Draft Report Response	

Appendix K. Titled Base Salary Compensation Study

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Acknowledgments

The EPA Region 9 acknowledges the cooperation of the staff and management of the San Diego County
Air Pollution Control District (SDAPCD). We appreciate their willingness to respond to information
requests and share their experiences regarding the implementation of the SDAPCD's title V program
under the Clean Air Act.

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Glossary of Acronyms and Abbreviations

AB

Assembly Bill

Act

Clean Air Act [42 USC Section 7401 et seq.]

ATC

Authority to Construct

CAA

Clean Air Act [42 USC Section 7401 et seq.]

CAM

Compliance Assurance Monitoring

CARB

California Air Resources Board

CFR

Code of Federal Regulations

CMS

Compliance Monitoring Strategy

District

San Diego County Air Pollution Control District

EJ

Environmental Justice

EPA

U.S. Environmental Protection Agency

EPS

Electronic Permit System

FCE

Full Compliance Evaluation

HAP

hazardous air pollutants

NESHAP

National Emission Standards for Hazardous Air Pollutants, 40 CFR Parts 61 & 63

NOV

Notice of Violation

NOx

Nitrogen Oxides

NSPS

New Source Performance Standards, 40 CFR Part 60

NSR

New Source Review

NTC

Notice to Comply

OEJ

Office of Environmental Justice

OIG

EPA Office of Inspector General

PSD

Prevention of Significant Deterioration

PTE

Potential to Emit

PTO

Permit to Operate

Region

U.S. Environmental Protection Agency Region 9

BAP

Business Assistance Program

SDAPCD

San Diego County Airy Pollution Control District

SIP

State Implementation Plan

SOP

Standard Operating Procedure

Team

EPA Region 9 Program Evaluation Team

we

U.S. Environmental Protection Agency

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Executive Summary

In response to the recommendations of a 2002 Office of Inspector General (OIG) audit, the U.S.
Environmental Protection Agency (EPA or "we") re-examined the ways it can improve state and local
operating permit programs under title V of the Clean Air Act ("title V programs") and expedite permit
issuance. Specifically, the EPA developed an action plan for performing program evaluations of title V
programs for each air pollution control agency beginning in fiscal year 2003. The purpose of these
program evaluations is to identify good practices, document areas needing improvement, and learn
how the EPA can help the permitting agencies improve their performance.

The EPA's Region 9 (the "Region") oversees 47 air permitting authorities with title V programs in the
Pacific Southwest. Of these, 43 are state or local authorities approved pursuant to 40 CFR part 70 (35 in
California, three in Nevada, four in Arizona, and one in Hawaii), referred to as "Part 70" programs. The
terms "title V" and "Part 70" are used interchangeably in this report. The Region also oversees a
delegated title V permitting program in Navajo Nation under 40 CFR part 71 and title V programs in
Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands under 40 CFR part
69, referred to, respectively, as "Part 71" and "Part 69" programs. Because of the significant number of
permitting authorities, the Region has committed to performing, on an annual basis, one
comprehensive title V program evaluation of a permitting authority with 20 or more title V sources.
This approach covers at least 85% of the title V sources within the Region 9 jurisdiction.

The Region initially conducted a title V program evaluation of the San Diego County Air Pollution
Control District (SDAPCD or "District") in 2008 ("2008 Evaluation").1 This is the second title V program
evaluation the EPA has conducted for the SDAPCD. The EPA Region 9 program evaluation team
("Team") for this evaluation consisted of the following EPA personnel: Meredith Kurpius, Air and
Radiation Division Assistant Director; Gerardo Rios, Manager of the Air Permits Office; Noah Smith,
Attorney Advisor; Ken Israels, Program Evaluation Advisor; Sheila Tsai, Program Evaluation
Coordinator; Mario Zuniga, SDAPCD Oversight Team Lead; Lisa Beckham, Program Evaluation Team
Member; Amber Batchelder, Program Evaluation Team Member; Tina Su, Program Evaluation Team
Member; Po-Chieh Ting, Program Evaluation Team Member; Catherine Valladolid, Program Evaluation
Team Member; and Camille Cassar, Program Evaluation Team Member.

The program evaluation was conducted in four stages. During the first stage, the Region sent the
SDAPCD a questionnaire focusing on title V program implementation in preparation for the interviews
(see Appendix B, Title V Questionnaire and SDAPCD Responses). During the second stage, the Team
conducted an internal review of the EPA's own set of SDAPCD permit files. The third stage of the
program evaluation was a hybrid site visit, which consisted of Region 9 representatives visiting the
SDAPCD office in San Diego, California to conduct interviews of the SDAPCD staff and managers in
person and virtually. Because this was a hybrid site visit, some of the interviews were conducted
virtually through video conferencing. The site visit took place March 28-30, 2022. Finally, the fourth
stage involved follow-up and clarification of issues for completion of the draft report.

1 San Diego County Air Pollution Control District; Title V Operating Permit Program Evaluation, dated September 30, 2008.
See https://www.epa.gov/sites/default/files/2015-07/documents/sd-finalreport-93020Q8.pdf.

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We recognize that the District is going through many changes: brand new governance structure, new
governing board and leadership, as well as the recent reclassification for ozone from serious to severe.
The Region's 2022 evaluation of the SDAPCD's implementation of the Part 70 program concludes that
the SDAPCD is implementing a title V program first approved in 2001, but has areas for improvement.

The new District management recognizes this and was already taking steps to improve its
implementation of the program prior to this evaluation. For example, title V permitting workload will
be distributed more evenly among permitting staff and the District is focusing on a more
comprehensive outreach process for its programs, including through the creation of the Office of
Environmental Justice (OEJ). A framework for the new Office of Environmental Justice2 and Public
Participation Plan3 was developed and approved by the new governing board. The SDAPCD is making
positive changes and we hope our findings and recommendations will further assist the District in
improving its implementation of the program.

Overall, the District's title V permits generally contain sufficient monitoring, recordkeeping, and
reporting requirements to determine compliance with emissions limits The District could use some
overall improvement in standardizing and documenting its work processes and permitting decisions in
its supporting documents. This would resolve most of the findings we have related to the support
document that explains the legal and factual basis for permit conditions (referred to as the "statement
of basis"). We also want to emphasize the need for the SDAPCD to evaluate the potential emissions
from each facility to accurately determine a source's major source and/or synthetic minor status. We
recognize the District is actively working on its backlog and currently lacks sufficient resources, but we
also note that the SDAPCD continues to perform full compliance evaluations of all title V sources and
reviews all title V deviation, annual, and semiannual reports submitted by Part 70 sources.

Some major findings we want to highlight from our report are listed below:

1.	Finding: The SDAPCD's statements of basis do not consistently describe regulatory and policy
decisions the District has made in the permitting process. (Finding 2.2)

2.	Finding: The SDAPCD does not document whether a requested title V permit modification
meets the criteria under which it is submitted, including confirming whether a change is a
modification under title I of the CAA. (Finding 2.4)

3.	Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit. (Finding 4.2)

4.	Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services as required by 40 CFR
Part 7.35(a). (Finding 4.1)

2	See https://www.sdapcd.org/content/dam/sdapcd/documents/communitv/environmental-iustice-
/APCD%200ffice%20of%20Environmental%20Justice Draft%20Framework.pdf.

3	See https://www.participatesdapcd.org/About%20the%20Plan/.

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5. Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application
meetings with potential sources to help identify the scope of potential permitting projects and
the applicability of regulatory requirements. (Finding 4.5)

6. Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog. (Finding 5.1)

7. Finding: The District does not evaluate the potential emissions from sources without title V
permits to determine if they are major sources or whether such sources need synthetic limits to
avoid title V applicability or other CAA requirements. (Finding 5.4)

8. Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS). (Finding 6.1)

9. Finding: The District tracks title V program expenses and revenue and those funds are spent
solely to support the title V program. (Finding 7.2)

10. Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center. (Finding 8.1)

Our report provides a series of findings (in addition to those listed above) and recommendations that
should be considered in addressing our findings. As part of the program evaluation process, the
SDAPCD has been given an opportunity to review these findings and consider our recommendations.

In addition, our evaluation also considered whether issues found during our 2008 Evaluation have since
been addressed. As discussed in Findings 2.3, 4.1, and 4.6, the District has corrected issues related to
ensuring permits are signed, publishing public notices in a newspaper of general circulation, and
notifying tribal governments of title V permitting actions. As discussed in Findings, 2.4, 6.6, 7.3, and
7.5, the District has not fully addressed issues related to streamlining NSR and title V actions consistent
with the title V program, ensuring recommendations from compliance staff to improve permit
enforceability are considered in a timely manner, improving communication between permitting and
compliance staff, and improving permitting staff's knowledge of environmental justice.

As part of the program evaluation process, the SDAPCD had an opportunity to review these findings
and consider our recommendations on July 29, 2022, when we emailed an electronic copy of the draft
report to the SDAPCD for comment. We received the SDAPCD's response and comments on August 30,
2022 (see Appendix J). Based on the comments received from the SDAPCD, the EPA made certain
changes in the final report. A copy of the Response to Comments and discussion of changes can be
found in Appendix I.

To better communicate our recommendations and work together on the recommended
improvements, we request an initial kick-off meeting within 90 days of the SDAPCD's receipt of the
final report to discuss developing a workplan. A workplan typically includes specific goals and
milestones that can be used to demonstrate progress. We commit to meet with the SDAPCD regularly

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to discuss progress until both the SDAPCD and the EPA mutually agree the workplan items are
sufficiently complete.

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1. Introduction

Background

In 2000, the EPA's Office of Inspector General (OIG) initiated an evaluation on the progress that the
EPA and state and local agencies were making in issuing title V permits under the Clean Air Act (CAA or
the "Act"). The purpose of OIG's evaluation was to identify factors delaying the issuance of title V
permits by selected state and local agencies and to identify practices contributing to timely issuance of
permits by those same agencies.

After reviewing several selected state and local air pollution control agencies, the OIG issued a report
on the progress of title V permit issuance by the EPA and states.4 In the report, the OIG concluded that

(1) a lack of resources, complex EPA regulations, and conflicting priorities contributed to permit delays;

(2) EPA oversight and technical assistance had little impact on issuing title V permits; and (3) state
agency management support for the title V program, state agency and industry partnering, and permit
writer site visits to facilities contributed to the progress that agencies made in issuing title V operating
permits.

The OIG's report provided several recommendations for the EPA to improve title V programs and
increase the issuance of title V permits. In response to the OIG's recommendations, the EPA made a
commitment in July 2002 to carry out comprehensive title V program evaluations nationwide. The
goals of these evaluations are to identify where the EPA's oversight role can be improved, where air
pollution control agencies are taking unique approaches that may benefit other agencies, and where
local programs need improvement. The EPA's effort to perform title V program evaluations for each air
pollution control agency began in fiscal year 2003.

On October 20, 2014, the OIG issued a report, "Enhanced EPA Oversight Needed to Address Risks From
Declining Clean Air Act Title V Revenues," that recommended, in part, that the EPA: establish a fee
oversight strategy to ensure consistent and timely actions to identify and address violations of 40 CFR
part 70; emphasize and require periodic reviews of title V fee revenue and accounting practices in title
V program evaluations; and pursue corrective actions, as necessary.5

The Region oversees 47 air permitting authorities with title V programs in the Pacific Southwest. Of
these, 43 are state or local authorities approved pursuant to 40 CFR part 70 (35 in California, three in
Nevada, four in Arizona, and one in Hawaii), referred to as "Part 70" programs. The terms "title V' and
"Part 70" are used interchangeably in this report. The Region also oversees a delegated title V
permitting program in Navajo Nation under 40 CFR part 71 and title V programs in Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands under 40 CFR part 69, referred to,

4 Report No. 2002-P-00008, Office of Inspector General Evaluation Report, "EPA and State Progress In Issuing title V
Permits", dated March 29, 2002. See https://www.epa.gov/sites/production/files/2015-12/documents/titlev.pdf.

5 Report No. 15-P-0006, Office of Inspector General Evaluation Report, "Enhanced EPA Oversight Needed to Address Risks
From Declining Clean Air Act Title V Revenues", dated October 20, 2014. See
https://www.epa.gov/sites/production/files/2015-09/documents/20141020-15-p-00Q6.pdf.

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respectively, as "Part 71" and "Part 69" programs. Because of the significant number of permitting
authorities, the Region has committed to performing, on an annual basis, one comprehensive title V
program evaluation of a permitting authority with 20 or more title V sources. This approach covers at
least 85% of the title V sources within the Region 9 jurisdiction.

Title V Program Evaluation at the San Diego County Air Pollution Control District

This is the second title V program evaluation the EPA has conducted for the SDAPCD. The first title V
program evaluation was conducted in 2008. Thus, this evaluation is a follow-up to SDAPCD's 2008
Evaluation. The EPA Region 9 Team for this evaluation consisted of the following EPA personnel:
Meredith Kurpius, Air and Radiation Division Assistant Director; Gerardo Rios, Manager of the Air
Permits Office; Noah Smith, Attorney Advisor; Ken Israels, Program Evaluation Advisor; Sheila Tsai,
Program Evaluation Coordinator; Mario Zuniga, SDAPCD Oversight Team Lead; Lisa Beckham, Program
Evaluation Team Member; Amber Batchelder, Program Evaluation Team Member; Tina Su, Program
Evaluation Team Member; Po-Chieh Ting, Program Evaluation Team Member; Catherine Valladolid,
Program Evaluation Team Member; and Camille Cassar, Program Evaluation Team Member.

The objectives of the evaluation were to assess how the SDAPCD implements its title V permitting
program, evaluate the overall effectiveness of the SDAPCD's title V program, identify areas of the
SDAPCD's title V program that need improvement, identify areas where the EPA's oversight role can be
improved, and highlight the unique and innovative aspects of the SDAPCD's program that may be
beneficial to transfer to other permitting authorities. The program evaluation was conducted in four
stages. In the first stage, the EPA sent the SDAPCD a questionnaire focusing on title V program
implementation in preparation for the interviews. (See Appendix B, Title V Questionnaire and SDAPCD
Responses.) The Title V Questionnaire was developed by the EPA nationally and covers the following
program areas: (1) Title V Permit Preparation and Content; (2) General Permits; (3) Monitoring; (4)
Public Participation and Affected State Review; (5) Permit Issuance/Revision/Renewal Processes; (6)
Compliance; (7) Resources & Internal Management Support; and (8) Title V Benefits.

During the second stage of the program evaluation, the Region conducted an internal review of the
EPA's SDAPCD title V permit files. The SDAPCD submits title V permits to the Region in accordance with
its EPA-approved title V program and the Part 70 regulations.

The third stage of the program evaluation was a hybrid site visit, which consisted of Region 9
representatives visiting the SDAPCD office in San Diego, California to conduct interviews of the SDAPCD
staff and managers in person. Because this was a hybrid site visit, some of the interviews were
conducted virtually through video conferencing. The purpose of the interviews was to confirm the
responses in the completed questionnaire and to ask clarifying questions. The site visit took place
March 28-30, 2022.

The fourth stage of the program evaluation was follow-up and clarification of issues for completion of
the draft report. The Region compiled and summarized interview notes and asked follow-up questions
to clarify the Region's understanding of various aspects of the SDAPCD's title V program.

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Description of the SDAPCD

The SDAPCD's mission is to "improve air quality to protect public health and the environment." The
SDAPCD is currently organized into four divisions: (1) Engineering, (2) Compliance, (3) Monitoring and
Technical Services, and (4) Business Support Services. The five offices/sections/programs at the
SDAPCD include Office of Environmental Justice (OEJ), Rule Development, Mobile Source Incentive,
Information Technology, and Human Resources. Stationary source operating permits, including title V
permits, are issued by the Engineering Division. Compliance and enforcement activities, such as facility
inspections and preparing enforcement cases are handled by the Compliance Division. Source testing is
conducted by the Monitoring and Technical Services Division. The Business Support Services works on
the District's budget and the fees and administrative aspects of permitting.6 The SDAPCD's office is
located in San Diego, California.

Since 1955, the 5-member County of San Diego Board of Supervisors served as the District's governing
board, known as the Air Pollution Control Board. As of March 1, 2021, California Assembly Bill (AB) 423
(Gloria, 2019) amended State law to restructure and expand the governing board of the SDAPCD. AB
423 adds specified duties to the District, requires the California Air Resources Board (CARB) to conduct
a program audit of the District7, separates the SDAPCD from the County governance structure, and
requires the appointment of a new 11-member governing board.8 With AB 423, the SDAPCD is focusing
on a more comprehensive outreach process for its permitting actions and has created the Office of
Environmental Justice (OEJ). A framework for the new Office of Environmental Justice9 and Public
Participation Plan10 was developed and approved by the new governing board on April 14, 2022. In
addition to governing board changes, the SDAPCD recently had several experienced staff retire and
selected new senior leadership and a new Air Pollution Control Officer.

In addition to changes in structure and leadership, the workload associated with the SDAPCD's
implementation of the title V program is expected to increase. Effective July 2, 2021, the EPA
reclassified the San Diego County ozone nonattainment area from "Serious" to "Severe" for the 2008
ozone National Ambient Air Quality Standards (NAAQS) and from "Moderate" to "Severe" for the 2015
ozone NAAQS.11 Upon reclassification, the threshold at which a source is considered a major source
under the Part 70 program for emissions of nitrogen oxides (NOx) and volatile organic compounds
(VOC) dropped in San Diego County from 50 tons per year to 25 tons per year. All major stationary
sources under part D of the CAA are required to obtain a title V permit and have one year from
becoming subject to the title V program to submit an initial title V permit application.12 Thus, an influx

6 See https://www.sdapcd.org/content/sdapcd/about.html.

7 See https://ww2.arb.ca.gov/our-work/programs/san-diego-program-review.

8 See https://www.sdapcd.org/content/sdapcd/about/district-boards/governing-board.html.

9 See https://www.sdapcd.org/content/dam/sdapcd/documents/communitv/environmental-iustice-
/APCD%200ffice%20of%20Environmental%20Justice Draft%20Framework.pdf.

10 See https://www.participatesdapcd.org/About%20the%20Plan/.

11 See 86 FR 29522 (June 2, 2021).

12 The EPA should've been more clear in its ozone reclassification notice and issued a notice of deficiency to the District for
not adequately administering and enforcing the title V program using the new major source threshold. If the EPA
determines a permitting authority is not adequately administering an approved Part 70 program, we will provide

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of initial title V applications is expected for those sources newly subject to the title V program in San
Diego County.

The EPA granted the SDAPCD's title V program interim approval effective December 7, 1995, and full
approval effective November 30, 2001. The EPA also later granted approval of program revisions that
were effective on February 27, 2004.13 On October 21, 2021, the District submitted additional updates
to its title V program that the EPA is currently processing.14

The Part 70 program generally requires that a permitting authority take final action on each permit
application within 18 months after receipt of a complete permit application. Additionally, a permitting
authority must take action on an application for a minor modification within 90 days of receipt of an
application (or 15 days after the EPA's 45-day review period, whichever is later) and the permitting
authority has 60 days to act on requests for administrative permit amendments.15 The SDAPCD's local
rules regarding title V permit issuance contain the same or more stringent timeframes as the Part 70
program.16

Currently, there are 28 sources in the SDAPCD jurisdiction that are subject to the title V permit
program, with the San Diego County's ozone nonattainment area reclassification, the SDAPCD is
expecting at least 12 more title V sources.17 Unlike the conclusion from our 2008 Evaluation, the
District does not currently have sufficient permitting resources18 and is unable to process title V permit
applications in a timely manner that results in a title V permit application backlog.19

SDAPCD's Approach to the Title V Program

Consistent with the other permitting authorities in California, when the EPA approved the SDAPCD's
title V operating permit program, the District had already been implementing an operating permit
program locally for many years. As a result, the title V program was implemented as an overlay to the
District's local permitting program. The existing program requires permits to be issued for individual
pieces of equipment. Each Authority to Construct (ATC) permit is issued prior to the construction of the
emissions unit and typically contains conditions required for the construction and initial operation. The
ATC permit is then converted to a Permit to Operate (PTO) after construction is completed and

notification of the deficiency and, when related to a pollutant in a nonattainment area, apply sanctions as appropriate until
the deficiency is resolved. See CAA section 502(i). After the District has an approved program, sources will be required to
submit a complete title V permit application to the District within 12 months. The program revisions we are currently
processing will clarify which sources must obtain title V permits to resolve this issue. The EPA is also taking steps to ensure
this language is clear in any future reclassifications.

13 See Appendix A, 40 CFR part 70.

14 This revision includes updates to the District's definition for major stationary source. Although the District has revised its
NSR rules to include the correct major source thresholds, the definition in the District's title V rules still contains an error
where the major source threshold for all criteria pollutants is identified as 100 tons per year.

15 See 40 CFR 70.7(a)(2) and 70.7(e)(2)(iv).

16 See the SDAPCD Rule 1410.

17 See Finding 5.4 of this report for more discussion on the District's title V source determination.

18 See Section 7 of this report for more discussion on the SDAPCD's resource management.

19 See Finding 5.1 of this report for more discussion on the District's title V backlog.

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operation of the emissions unit has commenced. During the conversion from ATC to PTO, certain ATC
permit conditions are not retained in the PTO if the ATC conditions are determined to be obsolete or
irrelevant because they were construction related. Furthermore, because these operating permits are
linked to fee payment and renewed annually, new permit conditions can be added or revised each year
as applicable. However, these local PTOs do not meet all the requirements for an operating permit
required by title V of the CAA.

To implement the title V program, the SDAPCD's title V permits are created by including all the local
PTOs and then adding additional sections for facility-wide applicable requirements and title V program
-specific conditions such as semi-annual monitoring, annual compliance certifications, deviation
reporting, and additional monitoring to assure compliance. The result is that title V sources in SDAPCD
have two sets of operating permits with overlapping requirements.

Historically, the SDAPCD only had one title V permit engineer that was assigned all title V permits, and
most of the SDAPCD title V permit actions are performed under the conditions of section 502(b)(10) of
the CAA (known as a "502(b)(10) change"). When a modification is needed, the general process is that
the applicant would submit both an ATC application and a 502(b)(10) change. The ATC/PTO would be
issued first, and the 502(b)(10) change would be incorporated later into the title V permit, typically
during the renewal.

In our view, to evaluate the SDAPCD's title V program, we must also consider the District's ATC/PTO
actions for title V sources because these permit decisions are relied upon to create the District's title V
permits and would typically represent title V permit modifications.20 Throughout this report, when we
refer to the District's title V program, we are also generally considering the local ATC/PTO actions for
title V sources. However, because the SDAPCD uses separate processes for what it considers to be
ATC/PTO and title V permit actions, we will refer to the ATC/PTO permit as the "local permit" to make
the distinction when necessary.21

During our site visit, we learned that the SDAPCD is planning to change how the title V program is
being implemented. Title V permits will no longer be written and revised by a single engineer, instead
the workload will be distributed across permitting staff and more training will be provided. We
acknowledge that the SDAPCD has experienced and is still experiencing many changes; we are
conducting our evaluation based on what we learned, and we hope to assist the District in its title V
program implementation going forward.

Sections 2 through 8 of this report contain the EPA's findings regarding implementation of the title V
permit program by SDAPCD.

20 See Finding 2.4 of this report for more discussion on how the SDAPCD categorize its title V permitting actions.

21 This approach also necessarily affects how title V fees are gathered and spent as the title V fees are viewed as being in
addition to the fees collected for the pre-title V permitting program. See our fee-related finding in Chapter 7 of this
evaluation report.

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The EPA's Findings and Recommendations

The following sections include a brief introduction, and a series of findings, discussions, and
recommendations. The findings are grouped in the order of the program areas as they appear in the
Title V Questionnaire.

The findings and recommendations in this report are based on the District's responses to the Title V
Questionnaire, the EPA's internal file reviews, interviews conducted during the March 28-30, 2022 site
visit, and follow-up emails and phone calls subsequent to the site visit.

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2.

Permit Preparation and Content

The purpose of this section is to evaluate the permitting authority's procedures for preparing title V
permits. Part 70 outlines the necessary elements of a title V permit application under 40 CFR 70.5, and
it specifies the requirements that must be included in each title V permit under 40 CFR 70.6. Title V
permits must address all applicable requirements, as well as necessary testing, monitoring,
recordkeeping, and reporting requirements sufficient to assure compliance with the terms and
conditions of the permit.

2.1 Finding: The SDAPCD has an internal quality assurance process for reviewing draft versions of
permits before they are made available for review by the public and the EPA; however, the
understanding of the review process is inconsistent between various groups and varies with
level of experience.

Discussion: Based on the interviews, we found that all SDAPCD issued permits undergo an
internal review process; however, we received inconsistent answers as to who is involved in the
review process for local and title V permits. This is mostly likely caused by the separate
procedures used for issuing title V and local permits, where, historically, only one staff person
processed title V permits. The SDAPCD maintains a Standard Operating Procedure (SOP) on the
process for issuing local or title V permits; however, many staff were not aware of the SOP. Our
overall understanding is that draft local permits go through a more extensive review process
than the draft title V permits. Local draft permits are sent to the senior engineer in the
appropriate Engineering Division section for review. Then, the draft local permit is sent to the
Compliance Division for review. Senior management does not typically get involved in this
review unless an unresolved issue requires attention, or a cursory review is needed. After the
internal review is complete, the draft local permit is sent to the permittee for review and
comment before it is public noticed. In contrast, the permit review process was less clear when
discussing title V permits during interviews. At a minimum, draft title V permits go to the title V
permit manager for review. We received inconsistent responses about whether the Compliance
Division reviews them or not.

Many pointed out that there has been extensive turnover within the District,22 and
communications have not been as effective due to lack of training. There was an even split in
response between interviewees regarding whether the Compliance Division reviews the title V
permits. Multiple compliance staff also mentioned they have stopped sending comments to the
Engineering Division after repeatedly not seeing feedback being incorporated into permits.23

Recommendation: The EPA acknowledges that the SDAPCD recently changed how it processes
title V permits, and many processes and responsibilities are still in transition. As part of the
transition, the SDAPCD should document the procedure of its quality assurance process and
provide staff training so the process can be implemented consistently. The EPA suggests that

22 See Finding 7.6 of this report for more discussion on employee retention.

23 See Finding 6.6 of this report for more discussion on compliance permit feedback process.

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the comprehensive process used for local permits should serve as a starting point for title V
permits and that the process address how feedback generated in the internal and permittee
review processes are to be considered.

2.2 Finding: The SDAPCD's statements of basis do not consistently describe regulatory and policy
decisions the District has made in the permitting process.

Discussion: 40 CFR part 70.7(a)(5) requires the District to provide "a statement that sets forth
the legal and factual basis for the draft permit conditions" and is commonly referred to as the
"statement of basis". The purpose of this requirement is to provide the public and the EPA with
the District's rationale on applicability determinations and technical issues supporting the
issuance of proposed title V permits. A statement of basis documents the regulatory and policy
issues applicable to the source and is an essential tool for conducting meaningful permit
review.

The EPA has issued guidance on the required content of statement of basis on several
occasions, most recently in 2014.24 This guidance has consistently explained the need for
permitting authorities to develop a statement of basis with sufficient detail to document the
decisions made in the permitting process. The EPA provided an overview of this guidance in a
2006 title V petition order, In the Matter of Onyx Environmental Services, Order on Petition No.
V-2005-1 (February 1, 2006) (Onyx Order). In the Onyx Order, in the context of a general
overview statement on the statement of basis, the EPA explained:

A statement of basis must describe the origin or basis of each permit condition or
exemption. However, it is more than just a short form of the permit. It should highlight
elements that U.S. EPA and the public would find important to review. Rather than
restating the permit, it should list anything that deviates from simply a straight
recitation of applicable requirements. The statement of basis should highlight items such
as the permit shield, streamlined conditions, or any monitoring that is required under 40
C.F.R. § 70.6(a)(3)(i)(B). Thus, it should include a discussion of the decision-making that
went into the development of the title Vpermit and provide the permitting authority, the
public, and U.S. EPA a record of the applicability and technical issues surrounding the
issuance of the permit. (Footnotes omitted.) See, e.g., In RePort Hudson Operations,
Georgia Pacific, Petition No. 6-03-01, at pages 37-40 (May 9, 2003) ("Georgia Pacific");
In Re Doe Run Company Buick Mill and Mine, Petition No. VII-1999-001, at pages 24-25
(July 31, 2002) ("Doe Run"); In Re Fort James Camas Mill, Petition No. X-1999-1, at page
8 (December 22, 2000) ("Ft. James").

Onyx Order at 13-14. Appendix C of this report contains a summary of the EPA guidance to date
on the suggested elements to be included in a statement of basis.

24 Memorandum from Stephen D. Page, Director of the Office of Air Qualtiy Planning and Standards, "Implementation
Guidance on Annual Compliance Certification Reporting and Statement of Basis Requirements for Title V Permits," April 30,
2014. See https://www.epa.gov/sites/production/files/2015-08/documents/2014043Q.pdf.

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In our review, we found that the statement of basis prepared by the District often does not
adequately describe the regulatory and policy issues or document the decisions the District
made in the permitting process. Though there is variation, the District's statement of basis
generally includes: Introduction/Description; Title V Applicability; Applicable Requirements;
Monitoring, Record-keeping, and Reporting; Public Notice and EPA Review; and
Conclusions/Recommendations. While these are the types of categories often found in the
statement of basis for a title V permit, the District does not consistently include the type of
detailed, site-specific information needed in these sections that would allow the reader to
understand the District's legal and factual basis for the terms and conditions in the permit.

For example, the District often includes a list of applicable requirements but does not always
explain why the source is subject to the requirements or whether an otherwise potentially
applicable requirement is not applicable in a particular case. The District could improve this
section by consistently explaining why the source meets the appropriate applicability criteria.
The section should also not be limited to New Source Performance Standards (NSPS) or
National Emission Standards for Hazardous Air Pollutants (NESHAP) but should also include the
applicability of all federal applicable requirements, including Compliance Assurance Monitoring
(CAM), the Prevention of Significant Deterioration (PSD) permit program at 40 CFR 52.2 1 25, the
title IV Acid Rain Program, and State Implementation Plan (SlP)-approved rules.

In addition, the sections dedicated to background and introductory information could be
improved by including a description of the various processes and operations at the source,
relevant historical information, and the current type of permitting action. While the statement
of basis generically describes the changes being made to the permit, the District could improve
by providing more context. It should be clear to the reader why the permit needs to be revised
and that the revisions the District is making are appropriate for the situation. The District could
also consider including a redline/strikethrough version of the permit revisions as part of the
permit record provided during the public participation process to facilitate permit review.
Furthermore, when streamlining multiple applicable requirements, the statement of basis must
explain the requirements being streamlined and how the permit conditions assure
compliance.26

Recommendation: As required by the Part 70 program, he SDAPCD must consistently produce a
statement of basis for each title V permit action (initial permits, renewals, and significant and
minor revisions) and should commit to improving the content of this document for future
permitting actions. We encourage the SDAPCD to work in close coordination with the EPA to
ensure that the statement of basis is adequate for explaining the legal and factual basis of each
action as required by 40 CFR 70.7(a)(5). If the engineering evaluations for local permits contain
applicable analysis for the source's title V permit, then these evaluations should be included in
the package sent to the EPA for its title V permit review.

25	While the SDAPCD does not have an EPA-approved PSD program, PSD remains a potential applicable requirement to title
V sources in SDAPCD. Any EPA-issued PSD permits must be incorporated into the District's title V permits.

26	See Finding 2.7 of this report for more discussion on the SDAPCD streamlining evaluation.

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2.3 Finding: The SDAPCD uses template permit documents and maintains template conditions in its
database to provide consistency in its permits.

Discussion: From staff interviews, most permit engineers refer to previous permitting actions to
ensure consistency between permitting documents, especially for the statement of basis.27 The
SDAPCD also maintains a list of template permit conditions within its permitting database to
assist in permit language consistency.28

The SDAPCD's template title V permit includes a cover page with the Source's general
information, responsible official, and signature from an appropriate District official. The
template title V permit is divided into six sections: Preamble, Regulation XIV Permit
Requirements, Facility-Wide Requirements, Emission Unit Requirements, District-Only
Provisions, and Appendices. During the 2008 Evaluation, the SDAPCD's title V permits were not
signed by an appropriate District official. The District's title V permit template now includes a
District official signature, and the District appears to have resolved its signature issue.

Recommendation: We commend the SDAPCD for promoting consistency between its permit
documents using templates. We encourage the SDAPCD to continue improving the statement
of basis as discussed in Finding 2.2.

2.4 Finding: The SDAPCD does not document whether a requested title V permit modification
meets the criteria under which it is submitted, including confirming whether a change is a
modification under title I of the CAA.

Discussion: When changes are made to a Part 70 source, there are several options for the
method that must be used to incorporate the change into the title V permit under the Part 70
and District regulations. The District has developed an internal guidance document that defines
the criteria to classify the different title V permit revision types and specifies the steps to follow
to determine the appropriate revision track. The guidance also describes the type of supporting
documentation that should accompany each type of permit revision. This guidance document
was provided to the EPA during the file review and should serve as a good resource for the
SDAPCD staff to understand the criteria for classifying title V revisions and to provide consistent
processing of title V permit changes.

During our file review, we requested 5 years of permit files for the various types of permit
modifications (significant modifications, minor permit modifications, administrative
amendments, and off-permit changes/502(b)(10) changes). In reviewing these files, we
discovered the District consistently does not document whether the type of permit
modification requested is correct.

27 See Finding 2.2 of this report for more discussion of the SDACPD's statement of basis.

28 See Finding 8.3 of this report for more discussion of the SDAPCD permitting database.

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Importantly, the District does not document whether 502(b)(10) changes and minor permit
modifications are not modifications under title I of the Act, a minimum requirement for using
these options. Further, such determinations should include consideration of the PSD program
at 40 CFR 52.21 that is implemented by the EPA within San Diego County. The District's rule
that references "PSD" requirements, Rule 20.3, is not an EPA-approved PSD program and does
not use the correct PSD applicability criteria.

Permitting authorities are not required to produce a statement of basis when processing a
502(b)(10) change; however, we believe it would be beneficial for the SDAPCD to document its
analysis verifying that a requested operational change qualifies as a 502(b)(10) change.
Otherwise, the regulated community is encouraged to avoid title V program requirements, and
potentially title I requirements, by submitting every action as a 502(b)(10) change. We also note
that files pertaining to 502(b)(10) changes did not document that the requested changes were
eventually incorporated into the title V permit at the time of the next renewal, nor did the
District respond when title V sources requested notification whether their changes qualified as
502(b)(10) changes.

Due to the lack of documentation, the EPA was unable to fully assess the SDAPCD staff's
understanding of the various permit revision tracks and could not verify whether applications
for permit modifications were categorized and processed correctly pursuant to District and
federal regulations. When these types of decisions are not consistently documented it can lead
to inconsistent implementation of the title V program.

Further, during our 2008 Evaluation we found that the District "streamlines" its NSR and title V
actions but did not consistently follow its own rules in doing so by ensuring adequate EPA and
public review of NSR actions added to the title V permit.29 It is unclear whether in lieu of using
the appropriate procedures in its rules, the District is now instead determining all changes at
title V sources qualify as 502(b)(10) changes. See Finding 5.3.

Recommendation: To ensure permitting staff accurately categorize title V permit actions, the
SDAPCD should document its actions, rationale, and justification for each title V permit action.
The EPA strongly recommends that the SDAPCD consistently review and document whether
submitted 502(b)( 10) changes qualify for this option, including whether such changes are title I
modifications. Since the District is not the PSD permitting authority in San Diego County, the
District should also be coordinating with the EPA on whether new sources or modifications at
existing major sources are subject to the PSD program when conducting this analysis.

2.5 Finding: The SDAPCD generally references the underlying origin and authority for permit

conditions, but often does not reference the origin of New Source Review (NSR) requirements.

Discussion: Each title V permit is required to specify and reference the origin and authority for
each term or condition and identify any difference in form as compared to the applicable

29 See Finding 5.2 in the 2008 Evaluation.

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requirement upon which the term or condition is based.30 In most cases, the origin and
authority for a permit condition can be referenced by citing to the particular rule or regulation.
The District consistently cites a basis for each permit condition; however, its practice of only
citing to "NSR" for NSR requirements is insufficient. It is also unclear whether the District
incorporates requirements from the District's ATC's into the title V permit. Conditions from
ATCs remain federal applicable requirements underthe California SIP regardless of their
inclusion in the PTO.31

For NSR requirements, the authority for the permit condition stems from the SIP-approved NSR
rule. But, because NSR rules likely do not specify the emissions limits and associated
monitoring, recordkeeping, and reporting requirements to which the source is subject to under
the NSR determination, the origin of the title V permit condition is the actual NSR permit issued
to the source. Thus, requirements stemming from NSR rules, or the PSD program at 40 CFR
52.21, should generally cite the underlying rule or regulation as the authority and the specific
NSR permit action as the origin.

Recommendation: To address this finding, the District must develop a plan to revise its title V
permits to assure that each permit cites the appropriate NSR/PSD permits as part of the origin
and authority for a permit term or condition as required by 40 CFR 70.6(a)(l)(i).

2.6 Finding: While the SDAPCD appears to streamline applicable requirements in its title V permits,
the District generally does not provide the necessary streamlining analysis in the statement of
basis.

Discussion: The SDAPCD's title V permits appear to contain streamlined requirements in which
one or more federal/local requirements are subsumed under the most stringent requirement
that applies to an emissions unit. For example, the requirements from the NSPS and the same
or more stringent District rule requirements are sometimes streamlined into a single permit
condition. The District's statement of basis will sometimes state that the streamlined permit
condition is at least as stringent as the subsumed requirements. However, such a blanket
statement does not actually demonstrate that the requirement was accurately streamlined.

Streamlining applicable requirements is an acceptable practice but must be appropriately
documented to assure compliance with all requirements. The EPA most recently provided
guidance on streamlining in 2014 in the EPA's April 30, 2014 memorandum, "Implementation
Guidance on Annual Compliance Certification Reporting and Statement of Basis Requirements
for Title V Operating Permits." The EPA initially provided guidance in our March 5, 1996
guidance document, "White Paper Number 2 for Improved Implementation of The Part 70
Operating Permit Program." 32

30 See 40 CFR 70.6(a)(l)(i).

31 While some ATC requirements not included in the PTO may also not be appropriate for inclusion in the title V permit, this
determination should be documented in the statement of basis.

32 See Appendix C of this report.

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The permit condition should cite to the requirement included in the permit and any subsumed
requirements. In addition, the statement of basis should document how the permit condition
assures compliance with all subsumed requirements.

Recommendation: As required by 40 CFR 70.7(a)(5), if the District wishes to continue its
practice of creating streamlined title V permit conditions, the District must revise its practice by
ensuring the statement of basis provides the legal and factual basis for the permit conditions by
demonstrating that the permit conditions assure compliance with all subsumed requirements.
We further recommend that the District follow the EPA guidance provided above in developing
a process to appropriately streamline applicable requirements.

Finding: The SDAPCD clearly identifies locally enforceable conditions in title V permits.

Discussion: Permit conditions based on state or local rules are only federal applicable
requirements if the rule has been approved by the EPA into the California SIP. Some state and
local rules are only adopted at the local level and have not been, or will not be, approved into
the SIP. State or local rules not approved into the SIP are not federal applicable requirements
under the title V program and are only enforceable at the State or District level. During the file
review, we found that the District's equipment-specific permits to operate were divided into
two main sections: "Federally-Enforceable and District-Enforceable Conditions" and "District-
Only Enforceable Conditions." In creating these sections, the District clearly indicates the
enforceability of all permit conditions.

However, we note that the District's local permits program is part of the California SIP and
permits issued pursuant to these rules are federal applicable requirements (except for certain
requirements, such as state or local air toxics requirements).

Recommendation: The EPA commends the SDAPCD for identifying which conditions are
federally and locally enforceable in their title V permits. The District should continue this
labelling practice and ensure ATC and PTO requirements remain federal applicable
requirements.

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3. Monitoring

The purpose of this section is to evaluate the permitting authority's procedures for meeting title V
monitoring requirements. Part 70 requires title V permits to include monitoring and related
recordkeeping and reporting requirements. See 40 CFR 70.6(a)(3). Each permit must contain
monitoring and analytical procedures or test methods as required by applicable monitoring and testing
requirements. Where the applicable requirement itself does not require periodic testing or monitoring,
the permitting authority must supplement the permit with periodic monitoring sufficient to yield
reliable data from the relevant time period that is representative of the source's compliance with the
permit. As necessary, permitting authorities must also include in title V permits requirements
concerning the use, maintenance, and, where appropriate, installation of monitoring equipment or
methods.

Title V permits must also contain recordkeeping for required monitoring and must require that each
title V source record all required monitoring data and supporting information and retain such records
for a period of at least five years from the date the monitoring sample, measurement, report, or
application was made. With respect to reporting, permits must include all applicable reporting
requirements and require (1) submittal of reports of any required monitoring at least every six months
and (2) prompt reporting of any deviations from permit requirements. All required reports must be
certified by a responsible official consistent with the requirements of 40 CFR 70.5(d).

In addition to periodic monitoring, permitting authorities are required to evaluate the applicability of
Compliance Assurance Monitoring (CAM), and include CAM provisions and a CAM plan into a title V
permit when applicable. CAM applicability determinations are required either at permit renewal, or
upon the submittal of an application for a significant title V permit modification. CAM regulations
require a source to develop parametric monitoring for certain emissions units with control devices,
which may be required in addition to any periodic monitoring, to assure compliance with applicable
requirements.

3.1 Finding: While the SDAPCD generally reviews CAM applicability, internal guidance needs to be
updated and staff need training.

Discussion: CAM regulations, found at 40 CFR part 64, apply to title V sources with large
emissions units that rely on add-on control devices to comply with applicable requirements.
The underlying principle, as stated in the preamble to our 1997 rulemaking, is "to assure that
the control measures, once installed or otherwise employed, are properly operated and
maintained so that they do not deteriorate to the point where the owner or operator fails to
remain in compliance with applicable requirements."33 Per CAM regulations, sources are
responsible for proposing a CAM plan to the permitting authority that provides a reasonable
assurance of compliance with applicable requirements for pollutant-specific emissions units
with add-on control devices.

33 62 FR 54902, October 22, 1997.

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The District reported that there are currently no facilities in its jurisdiction that are subject to
the CAM rule. In the permits we reviewed, we found that the District generally explains CAM
applicability in its statement of basis. However, CAM applicability can evolve over time as a
source makes changes, and thus its applicability should be confirmed during title V renewals
and significant modifications to ensure ongoing compliance. During our interviews, we found
that permitting staff do not have experience determining CAM applicability. In addition,
internal guidance documents may not interpret CAM applicability requirements correctly, as
the guidance is too generalized to ensure criteria in the CAM rule is followed. For example,
internal guidance appears to incorrectly imply that emissions limits with existing monitoring are
not subject to CAM or that being subject to an emissions standard exempt from CAM means
that other standards for the same pollutant/unit are also exempt from CAM.

Recommendation: The SDAPCD should continue to review CAM requirements as it processes
permit renewals and significant modifications and ensure CAM applicability is consistently
reviewed and discussed in the statement of basis. Additionally, CAM training should be
provided for permitting staff, and the District's internal guidance should be updated to provide
more detailed information for determining applicability based on the criteria in the CAM rule.

Finding: The SDAPCD's title V permits generally contain monitoring that is sufficient to
determine compliance with emissions limits. However, the SDAPCD's statement of basis does
not consistently address periodic monitoring.

Discussion: Our file review confirmed that the SDAPCD's title V permits generally contain
appropriate monitoring provisions. Many of the applicable requirements incorporated into the
District's title V permits already contain sufficient monitoring (such as, NSR permit conditions,
SIP-approved rules, NSPS/NESHAP and use of CEMS for large combustion sources). Source
testing, parametric monitoring of control device operation, and associated recordkeeping are
used to assure compliance with emissions limits. During our file review, we discovered some
permits contained daily emissions limits, but did not appear to contain corresponding daily
monitoring/recordkeeping requirements to assure compliance, or the wording of such limits
was too vague to determine whether the emissions limits were daily limits or a monthly
average.

The SDAPCD does not specifically address in the statement of basis whether additional periodic
monitoring is needed. While many applicable requirements may already contain sufficient
monitoring, the District does not document whether additional periodic monitoring is, or is not,
needed to assure compliance. The EPA has issued guidance that reinforces the need to address
periodic monitoring in the statement of basis. Additionally, an Order responding to a petition to
the EPA to object to the proposed title V permit for the Chevron Products Company in
Richmond, California, dated March 15, 2005, directed the permitting authority to reopen the
permit to include either periodic monitoring requirements to assure compliance with

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regulations or to provide adequate justification in the statement of basis explaining why no
periodic monitoring is required.34

Recommendation: The SDAPCD should continue to ensure that all title V permits have
monitoring sufficient to determine compliance, including ensuring daily emissions limits have
monitoring conducted on at least a daily basis. Additionally, the statement of basis should
evaluate the need for adding periodic monitoring when sufficient monitoring is not specified by
an underlying applicable requirement. We recommend the District develop a plan to
incorporate review of periodic monitoring for each title V facility.

3.3 Finding: The SDAPCD generally includes sufficient recordkeeping requirements as required by
the NSPS and NESHAP regulations.

Discussion: During the EPA's review, we found the SDAPCD generally includes sufficient
recordkeeping requirements as required by the NSPS and NESHAP regulations. A specific and
prevalent exception pertains to recordkeeping for determining compliance with diesel fuel
standards in NSPS Subpart Mil and NESHAP Subpart ZZZZ. The SDAPCD generally does not
include a recordkeeping requirement in its title V permits to ensure sources only purchase EPA-
compliant diesel fuel as required by these standards. Maintaining fuel purchase records is a
standard practice to ensure non-compliant fuels are not entering the market.35 After
completion of our fieldwork, the District subsequently provided an example of this
recordkeeping requirement in a permit.

However, as discussed in Finding 2.2, because the statement of basis does not consistently
document permitting decisions, we found it challenging to determine whether a permit has
incorporated all the applicable monitoring and recordkeeping requirements.36 An applicable
requirement may have more than one compliance method and the statement of basis should
make clear how the SDAPCD determined the appropriate requirements to incorporate. During
our interviews, compliance staff also mentioned they sometimes see enforceability issues in
permits while conducting inspections related to monitoring and recordkeeping. See Finding 6.6.

Recommendation: The EPA commends the SDAPCD for including sufficient recordkeeping
requirements as required by the NSPS and NESHAP regulations. For the exception noted above,
during permit renewals, the District should update their title V permits to require records to
assure that only EPA-compliant diesel fuel has been purchased.

34This document is available in the Title V petition database on the EPA website at
https://www.epa.gov/sites/default/files/2015-08/documents/chevron cbe decision2004.pdf.

35 Records that EPA-compliant diesel fuel was purchased ensures that the fuel meets the sulfur content, cetane index, or
aromatic content of 40 CFR 80.510, as required by NSPS Mil and NESHAP ZZZZ.

36 We did, however, find an example where the District incorrectly used the concept of a "replacement unit" to determine
NSPS/NESHAP applicability. The District incorrectly determined that replacement of an existing engine with a new engine
meant that, despite being a new engine, the NSPS did not apply. While the NSR program may have special provisions for
replacement units, those provisions cannot be used to determine NSPS/NESHAP applicability.

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4. Public Participation and Affected State Review

This section examines the SDAPCD procedures used to meet public participation requirements for title
V permit issuance. The federal title V public participation requirements are found in 40 CFR 70.7(h).
Title V public participation procedures apply to initial permit issuance, significant permit modifications,
and permit renewals. The SDAPCD public participation procedures must provide for public notice,
including an opportunity for public comment and public hearing on the draft initial permit, permit
modification, or permit renewal. Draft permit actions must be noticed in a newspaper of general
circulation or a state publication designed to give general public notice; sent to affected states; sent to
persons on a mailing list developed by the permitting authority; sent to those persons that have
requested in writing to be on the mailing list; and provided by other means as necessary to assure
adequate notice to the affected public.

The public notice must, at a minimum: identify the affected source; the name and address of the
permitting authority processing the permit; the activity or activities involved in the permit action; the
emissions change involved in any permit modification; the name, address, and telephone number of a
person from whom interested persons may obtain additional information, including copies of the draft
permit, the application, all relevant supporting materials, and all other materials available to the
permitting authority that are relevant to the permit decision; a brief description of the required
comment procedures; and the time and place of any hearing that may be held, including procedures to
request a hearing. See 40 CFR 70.7(h)(2).

The permitting authority must keep a record of the public comments and of the issues raised during
the public participation process so that the EPA may fulfill its obligation under section 505(b)(2) of the
Act to determine whether a citizen petition may be granted. The public petition process, 40 CFR
70.8(d), allows any person who has objected to permit issuance during the public comment period to
petition the EPA to object to a title V permit if the EPA does not object to the permit in writing as
provided under 40 CFR 70.8(c). Public petitions to object to a title V permit must be submitted to the
EPA within 60 days after the expiration of the EPA 45-day review period. Any petition submitted to the
EPA must be based only on objections that were raised with reasonable specificity during the public
comment period, unless the petitioner demonstrates that it was impracticable to raise such objections
within such period, or unless the grounds for such objection arose after such period.

4.1 Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services as required by 40 CFR
Part 7.35(a).

Discussion: The SDAPCD's jurisdiction includes sources located throughout San Diego County. In
response to California's AB 617 legislation, the District has increased its use of translations and
public outreach in certain communities.37 In addition, the District has created an EJ outreach
position that is designed to carry out the outreach effort to EJ communities. The EPA prepared

37 This effort is known as the Community Air Protection Program. For a description of the District's response to AB 617,
please see https://www.sdapcd.org/content/sdapcd/communitv/communitv-air-protection-program.html.

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a map of linguistically isolated communities within the SDAPCD's jurisdiction in which title V
permits have been or may be issued (see Appendix D). The EPA's map indicates that there are
numerous populations that are linguistically isolated. These linguistically isolated communities
have a significant population density, and thus the SDAPCD should provide translation services
in those communities during the title V permitting process. Section 502(b)(3)(C)(6) of the Act
and 40 CFR 70.7(h) require a Part 70 program to have adequate procedures for public notice.
Using a map like that found in Appendix D may provide additional opportunities to direct the
SDAPCD's translation efforts.38

Further, please see 40 CFR Part 7.35(a) for additional detail regarding federal grantee
obligations in demonstrating compliance with title 6 of the Civil Rights Act of 1964. In addition,
see Appendix D of this report that includes a copy of a recent preliminary decision regarding
this topic dated March 30, 2021 from the EPA's External Civil Rights Compliance Office to Carol
S. Cromer, Director, Missouri Department of Natural Resources.

Recommendation: The SDAPCD should provide translation services for linguistically isolated
communities within its jurisdiction. The SDAPCD should consider directing translation efforts by
using mapping tools as appropriate to assure updated information.

4.2 Finding: The SDAPCD provides public notices of its draft title V permitting actions on its
website.

Discussion: A permitting authority's website is a powerful tool to make title V information
available to the general public. Easy access to information that is useful for the public review
process can result in a more informed public and, consequently, provide more meaningful
comments during title V permit public comment periods.

Currently, the SDAPCD posts relevant title V permit information on its website including, but
not limited to, proposed title V permits, statement of basis, public notices, permit appeal
procedures, and general title V information and guidance.

The District website provides general information to the public and regulated community
regarding the SDAPCD permitting program.39The public can find information regarding the
permitting process, whether a permit is needed for an operation, how to obtain a permit,
application forms, and information about related programs that inform the District's permitting
program.

38	The use of the State of California's environmental justice tool CalEnviroScreen may also assist in learning where best to
deploy translation resources.

39	See https://www.sdapcd.org/content/sdapcd/permits.html and
https://www.sdapcd.org/content/sdapcd/permits/equipment-types/titlev.html

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The SDAPCD's website also provides a list of active projects that are in the public comment
period along with the corresponding draft permit, statement of basis, and public notice that
includes information on how to comment electronically or by mail.40

The SDAPCD maintains electronic mailing lists for title V public notices and for notification of
affected states. Members of the public may sign up for the title V public notice mailing list on
the District's website. However, as discussed in Finding 4.1, the District does not currently
translate notices of proposed title V permit actions in languages other than English as required
by 40 CFR Part 7.35(a). As stated in the introduction, the SDAPCD is developing strategies to
enhance public engagement as part of its AB423 commitment.

Finally, in our 2008 Evaluation, we found that the District had been publishing notices of its
proposed permits in a newspaper, of which circulation was almost solely among the business
community. The District has addressed this issue by publishing its notices of proposed permits
in the San Diego Union-Tribune, a newspaper of general circulation.

Recommendation: We encourage the SDAPCD to continue providing information related to
title V permits to the public via their website and notifying affected states and interested
parties of relevant title V permitting actions via District electronic mailing lists. We also
recommend that the District provide all final title V permits to the public on its website. In
addition, the district should provide translations of notices consistent with the discussion in
Finding 4.1.

4.3 Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit.

Discussion: 40 CFR 70.8(d) provides that any person may petition the EPA Administrator, within
60 days of the expiration of the EPA's 45-day review period, to object to the issuance of a title V
permit. The petition must be based only on objections that were raised with reasonable
specificity during the public comment period.41

San Diego County Rule 1425 contains the required information about the public's right to
petition the EPA Administrator to object to a title V permit. In 2008, we made a finding that the
District was not informing the public of their right to petition when public noticing title V
permitting actions.42 In our review of the District's draft permit packages for the last five years,
including the public notice for the permit action, we found that the District did not inform the
public of the right to petition the EPA Administrator to object to a title V permit at the time of
the site visit in March. However, the District has recently updated its practice and in the latest
public notice, from April 21, 2022, there is new language that incorporates the public petition
details.

40	https://www.sdapcd.org/content/sdapcd/permits/public-notices.html

41	An exception applies when the petitioner demonstrates that it was impracticable to raise those objections during the
public comment period or that the grounds for objection arose after that period.

42	See 2008 Evaluation, Finding 4.5.

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Recommendation: The EPA commends the SDAPCD for revising its public notice templates to
inform the public of the right to petition the EPA Administrator to object to the issuance of a
title V permit. The District should have written internal procedures that ensure this remains an
ongoing practice.

4.4	Finding: The SDAPCD's general practice is to conduct a concurrent public and EPA review. If
comments are received during the 30-day public review period, the permit package is re-
proposed to the EPA for a new 45-day review period.

Discussion: Per section 505(b) of the CAA and 40 CFR 70.8, state and local permitting agencies
are required to provide proposed title V permits to the EPA for a 45-day period during which
the EPA may object to permit issuance. The EPA regulations allow the 45-day EPA review period
to occur either following the 30-day public comment period (i.e., sequentially), or at the same
time as the public comment period (i.e., concurrently). When the public and the EPA review
periods occur sequentially, permitting agencies will make the draft permit available for public
comment, and following the close of public comment, provide the proposed permit and
supporting documents to the EPA.43 When the public and the EPA review periods occur
concurrently, a state or local agency will provide the EPA with the draft permit and supporting
documents at the beginning of the public comment period. As specified in 40 CFR 70.8 and per
SDAPCD's internal guidance, if the SDAPCD receives comments from the public during the 30-
day public review period, the 45-day EPA review would be restarted to allow the SDAPCD to
prepare responses to the public comments, and an updated permit and Statement of Basis, if
applicable, to the EPA. As the permit actions reviewed did not contain public comments, the
EPA was unable to confirm this process is being consistently followed at the District. However,
the procedures for concurrent public comment and response to comments are well
documented in internal District guidance and SOPs.

Recommendation: We commend the SDAPCD for having internal guidance that is consistent
with the requirements of the title V program and EPA guidance, and encourage the District
follow its guidance when public comments are received.

4.5	Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application
meetings with potential sources to help identify the scope of potential permitting projects and
the applicability of regulatory requirements.

Discussion: Under section 507 of the CAA, permitting authorities are required to implement a
small business assistance program to assist small businesses that need title V permits.

43 Per 40 CFR 70.2, "draft permit" is the version of a permit for which the permitting authority offers public participation or
affected State review. Per 40 CFR 70.2, "proposed permit" is the version of a permit that the permitting authority proposes
to issue and forwards to the EPA for review. In many cases these versions will be identical; however, in instances where the
permitting agency makes edits or modifications as a result of public comments, there may be material differences between
the draft and proposed permit.

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During this evaluation, we found that the District has a full BAP to provide assistance to
business owners and operators, small and large, in determining which county, state, and
federal requirements are applicable. The assistance includes coverage of title V small
businesses.

During the interviews, the BAP staff stated that they help small businesses draft permit
applications and review permits to ensure permit records adequately represent the source. This
helps the Permitting staff process permit applications in a timely fashion. The BAP staff also
assist small businesses with compliance demonstrations by conducting mock on-site inspections
and by reviewing the source's draft Annual Emissions Reports to ensure they are adequate
before the reports are submitted to the Compliance and Enforcement Section.

Additionally, the BAP staff helps small businesses with pollution prevention by providing
guidance on control technologies. For example, they help gas stations understand the benefits
of Stage II vapor controls. The District has a BAP website where they describe who they are and
provide forms, calculation sheets, and other information to aid businesses developing permit
applications. Furthermore, the website has a notification feature available for small businesses
in case they want to be made aware when new content is posted on the BAP website.44

Discussions with the BAP staff also indicated that work related to title V sources is tracked so
that time spent working with these sources is appropriately accounted for in tracking title V
fees and revenue.

Recommendation: The EPA commends the District for its efforts to provide assistance to small
businesses and recommends the District continue supporting small businesses by providing
these services through its BAP.

4.6 Finding: The SDAPCD notifies tribes of title V permitting actions.

Discussion: During our 2008 Evaluation, we did not find evidence that the District notified any
tribes in San Diego County regarding title V permit actions. During this evaluation, we found
that this issue has been resolved as the District provides notifications to all tribes in San Diego
County. Of the 18 Indian reservations in San Diego County, two tribes have been approved by
the EPA to be treated in the same manner as a neighboring state for the purpose of "affected
state" notification under section 505(a)(2) of the CAA. 45 Regardless of the affected state status,
the EPA believes that state and local air agencies should notify tribal governments when taking
significant actions that may affect their air quality.

Recommendation: We commend the SDAPCD for notifying tribes and affected states.

44 See https://www.sdapcd.org/content/sdapcd/compliance/business-assistance.html.

45 Additionally, the EPA maintains a map on its website of tribes in Region 9 that have received treatment as a state status
for purposes of section 505(a)(2) of the CAA: https://www.epa.gov/caa-permitting/affected-states-notifications-region-9.

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5. Permit Issuance / Revision / Renewal

This section focuses on the permitting authority's progress in issuing initial title V permits and the
District's ability to issue timely permit renewals and revisions consistent with the regulatory
requirements for permit processing and issuance. Part 70 sets deadlines for permitting authorities to
issue each type of title V permit. The EPA, as an oversight agency, is charged with ensuring that these
deadlines are met as well as ensuring that permits are issued consistent with title V requirements. Part
70 describes the required title V program procedures for permit issuance, revision, and renewal of title
V permits. Specifically, 40 CFR 70.7 requires that a permitting authority take final action on each permit
application within 18 months after receipt of a complete permit application, except that action must
be taken on an application for a minor modification within 90 days after receipt of a complete permit
application.46

5.1 Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog.

Discussion: The District does not consistently process permitting applications in a timely
manner, mainly due to resource constraints and competing priorities. At the time of our
evaluation, the SDAPCD had 28 title V sources and two synthetic minor sources.47 Of these 28
sources, the District indicated 75% of sources have a pending renewal application. During the
interviews, many expressed time constraints on permit issuance for both local permits and title
V permits. Based on the documentation the District provided, there were several permit
applications that have not been processed before the 18-month deadline as required by 40 CFR
70.7. In the last 5 years, about 40% of the title V applications received by the SDAPCD have had
processing times in excess of 18 months. In addition to exceeding statutory permitting
deadlines, delays create issues for the Compliance Division. See Finding 6.1. During interviews,
District staff were confident that once the resources issue is addressed, the permitting backlog
will no longer be an issue.

Recommendation: The EPA acknowledges that the SDAPCD is currently in transition and more
engineers are now being trained and assigned to process title V permit actions. The District
should develop a plan of action for reducing its title V renewal application backlog, as well as to
process the new title V applications that the District will expect to receive as a result of their
new Ozone Non-attainment area classification (See Section 7 of this report for additional
discussion on the District's resources).

5.2 Finding: The SDAPCD routinely submits proposed and final permit actions to the EPA.

Discussion: 40 CFR 70.8(a)(1) and the SDAPCD's EPA-approved title V program require that
proposed and final permits be sent to the EPA.

46 See 40 CFR 70.7(a)(2) and 70.7(e)(2)(iv).

47 See Finding 2.4 of this report for more discussion on the SDPACD's major source determination and Finding 5.4 for more
discussion on the SDAPCD's synthetic minor sources.

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During our review of recent actions, the EPA found that the SDAPCD routinely submits copies of
both proposed and final title V permit actions to the EPA via the EPA Central Data Exchange's
Electronic Permit System (EPS). The EPA oversight team receives the SDAPCD's permitting
notices. These notices generally include the notice of proposed action, the proposed permit,
and the proposed technical support document. However, during our internal file review, we
found several instances where a copy of the statement of basis or technical support document
for minor permit modifications was not included in the submitted permit package (see Finding
2.4).

Additionally, we could not find a requirement in the SDAPCD's title V rules (District Regulation
XIV) that ensures a statement of basis is developed and provided during the public comment
period and the EPA's 45-day review period. In 2020, the EPA revised the Part 70 program at 40
CFR 70.7 and 70.8 to make clear that the statement of basis must be made available to the
public and the EPA.48

Recommendation: The EPA commends the District for submitting its proposed and final permit
actions to the EPA for review. The District should also ensure its proposed permits include a
statement of basis, consistent with 40 CFR 70.7 and 70.8, and should update its title V rules for
consistency with these requirements.

5.3 Finding: The SDAPCD has authority to use parallel processing to streamline the issuance of
modified NSR and title V permits. However, it is not clear that this processing method is
correctly utilized.

Discussion: EPA guidance and regulations allow sources to simultaneously apply for, and
permitting authorities to process, revisions to NSR and title V permits.49 Under this option,
often referred to as "enhanced NSR," NSR permit modifications are subject to the procedural
requirements of the Part 70 program, including a 45-day EPA review period and a 60-day
petition period that allows citizens to petition the Administrator to object to permit issuance.
After the NSR permit has been issued, and the project has been completed, the permitting
authority revises the title V permit to add (or delete) the new or revised NSR conditions via an
administrative amendment. The benefits of consolidating the NSR and title V permitting
processes include reduced permit processing time and the opportunity for the EPA to review
NSR permit actions.

The District appears to understand the enhanced NSR process, dedicating a section of their
Engineering Division Manual of Operating Procedures to Enhanced Authority to Construct
(Appendix H). The EPA supports this practice; however, our file review did not find evidence
that SDAPCD was implementing enhanced NSR. Specifically, we did not find any examples of an

48	See https://www.federalregister.gov/documents/2020/02/05/2020-01099/revisions-to-the-petition-provisions-of-the-
title-v-permitting-program.

49	See 40 CFR 70.7(d)(l)(v) and Appendix C: White Paper for Streamlined Development of Part 70 Permit Applications, July
10, 1995; 11/7/95 letter from Lydia Wegman, OAQPS, to William Becker, STAPPA/ALAPCO; Title V Implementation Q & A,
Region 9, December 1995.

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administrative amendment that incorporated NSR permit conditions into a title V permit.
Instead, the documentation shows that the District routinely incorporates new or revised NSR
permit requirements into title V permits when a title V permit renewal is issued rather than
making administrative revisions at the time of the permit action. Thus, it appears that the
District may incorrectly be allowing 502(b)( 10) changes to be used instead of documenting
enhanced NSR practices. However, as noted in finding 2.4, since there is a lack of
documentation regarding 502(b)(10) decisions, the EPA is unable to determine if that is the
case, or if the District is just not completing their enhanced NSR process at the time of the
permit action.

Recommendation: To address this finding, the District must ensure that the applicable
permitting procedures required by the Part 70 program are followed. We recommend the
District review the Part 70 program requirements related to enhanced NSR and 502(b)(10)
changes and develop a plan to address this finding.

5.4 Finding: The District does not evaluate the potential emissions from sources without title V

permits to determine if they are major sources or whether such sources need synthetic limits to
avoid title V applicability or other CAA requirements.

Discussion: A source may accept a voluntary limit (also known as a "synthetic minor" limit) to
maintain its Potential to Emit (PTE) below an applicable major source threshold and thereby
avoid major NSR permit requirements and/or the need for a title V permit. Sources establish
such a limit by obtaining a synthetic minor permit containing practically enforceable emissions
limitations from the permitting authority.

According to EPA guidance, synthetic minor limits must be enforceable as a practical matter,
meaning they are both legally and practicably enforceable. Additionally, for emissions limits in a
permit to be practicably enforceable, the permit provisions must specify: 1) technically-
accurate limitations and the portions of the source subject to such limitations; 2) the time
period for the limitations (emissions limit averaging period); and 3) the method to determine
compliance, including appropriate and practically enforceable monitoring, recordkeeping, and
reporting requirements.50

In response to a petition regarding the Hu Honua Bioenergy Facility in Hawaii, the EPA stated
that synthetic minor permits must specify: 1) that all actual emissions at the source are
considered in determining compliance with its synthetic minor limits, including emissions
during startup, shutdown, malfunction or upset; 2) that emissions during startup and shutdown
(as well as emissions during other non-startup/shutdown operating conditions) must be
included in the semi-annual reports or in determining compliance with the emissions limits; and

50 Options for Limiting the Potential to Emit (PTE) of a Stationary Source Under Section 112 and Title V of the Clean Air Act
(Act), John S. Seitz, Director, Office of Air Quality Planning and Standards (January 25, 1995).

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3) how the source's emissions shall be determined or measured for assessing compliance with
the emissions limits.51

The District does not have a policy for setting synthetic minor limits but has two local rules,
Rules 60.1 and 60.2, that can be used to limit a source's PTE. These rules are available to
sources seeking to avoid major source status through voluntary requirements. However, the
use of these rules appears limited, and the District does not independently determine the
facility-wide PTE of the sources it regulates. Instead, the District determines major source
status based on actual emissions. While using actual emissions was acceptable for avoiding title
V permitting as part of the EPA's 1995 transition policy, that policy expired in 2000.52

Determining whether a stationary source is a major source and subject to the title V program is
based on potential, not actual, emissions.53 We found during the evaluation that District
permitting staff are generally familiar with calculating the PTE of impacted emissions units
when issuing local permits. And the District closely tracks the actual annual emissions of each
facility. However, the District does not calculate or track a facility's PTE on a facility-wide basis.
Because major source status is based on facility-wide potential emissions, it is challenging for
the District to know when an existing minor source becomes a major source or whether a
source's claim of being a minor source is accurate. This is particularly problematic for the
current situation where the District was recently reclassified as Severe nonattainment for the
ozone NAAQS causing the major source threshold in San Diego County for NOx and VOC to drop
to 25 tons per year. Beyond title V applicability, this issue can also have implications in
determining NSR program requirements and requirements for major sources of HAPs. This also
creates potential enforcement risk for any facility relying on actual emissions to not obtain a
title V permit or a major NSR permit.

Recommendation: The SDAPCD must develop a plan for ensuring the District can determine
title V applicability according to the definition for "major source" under 40 CFR 70.2 by
evaluating the facility-wide PTE. For those facilities with a PTE above the major source
threshold that wish to avoid title V permitting, we recommend the District develop internal
guidance for permitting synthetic minor sources consistent with EPA policy, and that permitting
staff take the EPA's online training for Setting Enforceable Potential to Emit Limits in NSR
Permits.54

51	Order Responding to Petitioner's Request that the Administrator Object to Issuance of State Operating Permit Petition No.
IX-2011-1, Gina McCarthy, Administrator (February 7, 2014).

52	See the EPA's December 20,1999 guidance memorandum 'Third Extension of January 25, 1995 Potential to Emit
Transition Policy." https://www.epa.gov/sites/default/files/2015-08/documents/4thext.pdf

53	See definition of "Potential to emit" at 40 CFR 70.2.

54	https://airknowledge.gov/SI/PERM203-SI.html

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6. Compliance

This section addresses the SDAPCD practices and procedures for issuing title V permits that ensure
compliance with all applicable requirements. Title V permits must contain sufficient requirements to
allow the permitting authority, the EPA, and the general public to adequately determine whether the
permittee is in compliance with all applicable requirements.

Compliance is a central priority for the title V permit program. Compliance assures a level playing field
and prevents a permittee from gaining an unfair economic advantage over its competitors who comply
with the law. Adequate conditions in a title V permit that assure compliance with all applicable
requirements also result in greater confidence in the permitting authority's title V program within both
the general public and the regulated community.

6.1 Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS).

Discussion: The EPA's 2016 Clean Air Act Stationary Source Compliance Monitoring Strategy55
recommends that permitting authorities perform FCEs for most title V sources at least every
other year. For the vast majority of title V sources, the EPA expects that the permitting
authority will perform an on-site inspection to determine the source's compliance status as part
of the FCE. In addition to weekly routine inspections, the SDAPCD has established its inspection
priority, giving emphasis to sources receiving ongoing public complaints, sources with issues of
continued non-compliance, and sources that need follow-up due to a Notice of Violation
(NOV).56 During interviews, District inspectors indicated that quarterly compliance evaluations
and annual full inspections are conducted for all permitted equipment. However, District
inspectors also indicated that the effectiveness of the inspection schedule may be
compromised due to delays in processing open permit applications.

Recommendation: The EPA commends the District's ongoing efforts to perform FCEs of all title
V sources annually.

6.2 Finding: The District's Compliance Division reviews all title V deviation reports, annual
compliance certifications, and semiannual monitoring reports submitted by Part 70 sources.

Discussion: During interviews, the District's compliance staff indicated that all deviation
reports, quarterly monitoring reports, and compliance certifications that sources submit to the
agency are reviewed by inspectors. Supervisors and the Chief of Compliance Division review
reports as necessary. The SDAPCD tracks these reports through their internal database and
reviews these records through their compliance staff and supervisors. If NOVs are warranted
after reviewing a report, the inspectors are required to discuss the documented deficiency with

55 This document is available at: https://www.epa.gov/compliance/clean-air-act-stationarv-source-compliance-monitoring-
strategy.

56 See Inspection Practices and Priorities, SDAPCD Compliance Division Policy and Procedures Manual, Policy number 2.1,
effective date September 1,1998, revised on July 25, 2016.

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the facility prior to issuing the NOV, to explain the nature of the violation, and advise the site to
respond to NOVs timely with the actions needed to return to compliance or prevent future
violations prior. Compliance supervisors will review the violation and associated report and are
responsible for approving NOVs.

In addition, engineering staff indicated that deviation reports and compliance certifications are
typically not routinely reviewed during permit processing. For example, reviewing these
documents as part of the title V permit renewal process could indicate a need to increase
testing frequency or require different monitoring that would ensure compliance.

Recommendation: The EPA commends the SDAPCD's efforts in reviewing and tracking all
deviation reports, quarterly monitoring reports, and compliance certifications. We encourage
the SDAPCD to coordinate the outcomes of compliance issues with permitting staff. See Finding
6.6.

6.3 Finding: When potential compliance issues are discovered, the District addresses them prior to
permit issuance. However, the District's statement of basis could be improved to include
compliance history.

Discussion: The Part 70 program requires that each title V permit contain a schedule of
compliance if necessary.57 This includes ensuring title V permits contain requirements that
ensure sources comply with requirements that have future compliance dates and ensure that
title V permits contain enforceable milestones leading to compliance for those requirements for
which the source is not in compliance. Based on interview responses, the District has not
recently issued permits with compliance schedules. Instead, compliance staff will generate a
citation report, which is sent to the District's Civil Actions Investigator to determine the
corresponding penalty. Pending permit applications are not processed until a facility comes
back into compliance. This practice does not appear to significantly affect or delay the issuance
of permits.

Recommendation: We recommend the compliance section in the District's statement of basis
be improved to include the source's compliance history and the actions being taken to address
compliance issues, as applicable.

6.4 Finding: The District uses title V compliance certifications and semiannual monitoring reports to
prioritize inspections and initiate enforcement actions.

Discussion: Similar to our 2008 Evaluation, the District continues to prioritize inspections and
initiate enforcement actions by using title V compliance certifications and semiannual
monitoring reports.58 The District's Compliance Division has a policy for reviewing annual
compliance certifications and semiannual monitoring reports (which include deviation

57 See 40 CFR 70.6(c)(3) and 70.5(c)(8).

58 See 2008 Evaluation, Finding 6.1.

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reports).59The District uses these title V compliance reports as well as past violations, recent
applications and activities to prioritize and target inspections. Interviewees stated that they
review these reports for compliance issues. They also review the facility's compliance history,
including recent inspections, breakdowns, exceedances, or violations, if any. The District uses
this information to prioritize inspections.

The District has also initiated enforcement actions at title V facilities based on information from
compliance certifications and semiannual monitoring reports. In one example, the District
issued an NOV for a violation identified in a title V report. The violations were related to time
periods when the facility failed to maintain NOx and O2 CEMS per Appendix B of 40 CFR Part 75.
Since the violations were short-term (i.e., not ongoing) and the facility was not out of
compliance at the time of permit issuance, a schedule of compliance was not required.60

Interviewees were generally knowledgeable about the procedures for reviewing title V
compliance reports and were aware of the District's policy for title V report reviewing process,
for issuing a NOV and/or a Notice to Comply (NTC).

Recommendation: The EPA encourages the District to maintain its practice of using title V
compliance reports to prioritize and target inspections and to continue implementing its policy
for reviewing these reports.

6.5 Finding: Compliance staff have the necessary equipment to perform their job duties but find
the procurement process for new equipment to be slow.

Discussion: During interviews, members of the Compliance Division stated that they have
sufficient tools and safety equipment to perform inspections, including hard hats, safety
glasses, safety vests, and an annual voucher for safety shoes. At the same time, employees also
expressed the need for new monitoring equipment as existing equipment, including Thermo
Fisher Scientific analyzers, are experiencing a loss in functionality due to age. Though the
process for equipment repairs and purchases have been initiated, they have been slow.
Compliance staff also mentioned that they could have been supplied with better personal
protective equipment during the COVID-19 pandemic.

Recommendation: The EPA recommends that the District review its equipment needs and plan
in advance for the replacement of old and outdated equipment to expedite the procurement
process.

6.6 Finding: While the SDAPCD has a process in their internal database for compliance staff to
request changes to title V permits, it is unclear if it is being used consistently.

59 See Review of Title VSemiannual and Annual Reports, SDAPCD Compliance Division Policy and Procedures Manual, Policy
number 3.13, effective date April 4, 2002, revised in August 2018.

60 A schedule of compliance is required for Title V sources that are not in compliance with all applicable requirements at the
time of permit issuance. (See 40 CFR 70.5(c)(8)(iii)(C).)

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Discussion: In our 2008 Evaluation, we found that the SDAPCD did not have a clear track record
of utilizing the District's internal Request for Change of Permit Conditions form to make
corrections to title V permits, and that the decisions made by the Engineering Division on such
requests were seldom communicated back to the Compliance Division. The District has since
developed a policy for the use of such request forms. Under the Division policy, compliance
staff are expected to review all permit conditions during the annual inspection and submit a
Request for Change of Permit Conditions form to the Division Chief if a site-specific permit
condition is found to not be clear, enforceable, or consistent with existing rules and/or other
applicable requirements. The Division Chief is responsible for keeping the inspector and their
supervisor informed of any decision.61 For issues identified across multiple permits, the policy
states these issues should be forwarded to the District's Permit Streamlining Committee for
evaluation. However, the District noted that the Permit Streamlining Committee has not existed
for a very long time. The District should consider updating its SOP or restarting the Committee.

During interviews, inspectors said they have used the request change forms in the District's
database system to request changes to the title V permits. Interviewees expressed concern
about the length of time it takes for changes identified to be made and about the Engineering
Division's lack of action on some requests. Compliance staff noted that some permits were not
updated in a timely manner to make the permit conditions enforceable. In some cases, this
resulted in NOVs being issued that compliance staff believe would have been unnecessary if the
permit had included monitoring and recordkeeping that facilitated compliance with the
requirements in the permit.

While the Permit Change Request process appears to be a good mechanism for inspectors to
request correction of obvious errors, or minor administrative changes, compliance staff may
have stopped using the process based on historical lack of response from the Engineering
Division.

Recommendation: Engineering and Compliance Divisions should agree on a realistic Permit
Change Request process, including the types of changes that should be made and the
appropriate timeframe for doing so, so that both Divisions can work together to ensure
enforceable permits. The District should consider updating its SOP or restarting the Permit
Streamlining Committee.

61 See How to Submit Permit Change Requests, SDAPCD Compliance Division Policy and Procedures Manual, Policy number
2.18, effective date February 17, 2016, revised in July 2017.

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7. Resources and Internal Management

The purpose of this section is to evaluate how the permitting authority is administering its title V
program. With respect to title V administration, the EPA's program evaluation: (1) focused on the
permitting authority's progress toward issuing all initial title V permits and the permitting authority's
goals for issuing timely title V permit modifications and renewals; (2) identified organizational issues
and problems; (3) examined the permitting authority's fee structure, how fees are tracked, and how
fee revenue is used; and (4) looked at the permitting authority's capability of having sufficient staff and
resources to implement its title V program.

An important part of each permitting authority's title V program is to ensure that the permit program
has the resources necessary to develop and administer the program effectively. A key requirement of
the Part 70 program is that the permitting authority establish an adequate fee program to ensure that
(1) title V fees are adequate to cover title V permit program costs, and (2) are used solely to cover the
permit program costs. Regulations concerning the fee program and the appropriate criteria for
determining the adequacy of such programs are set forth in 40 CFR 70.9.

7.1 Finding: The SDAPCD staff report that they receive effective legal support from the District
Counsel's office.

Discussion: In our 2008 Evaluation,62 we stated that the SDAPCD staff receive expert,
knowledgeable, and experienced legal support. Since then, the District Counsel in place during
our 2008 Evaluation retired and another District Counsel was hired with equally effective
results. However, as a result of the recent change in leadership, the District, at the time of our
site visit, was in the process of hiring a new District Counsel. At the time of our final report, the
SDAPCD hired a new District Counsel with extensive experience in air quality programs. The
District's legal support is currently in transition but given the record of effective legal support
for the title V program and District management's understanding of the importance of this
function, the EPA expects that District staff will continue to receive effective legal support for
the District's title V program.

Recommendation: The EPA commends the SDAPCD on hiring a new District Counsel with
extensive experience in air quality programs. The SDAPCD should continue to ensure that it
receives effective legal support for the Part 70 program.

7.2 Finding: The District tracks title V program expenses and revenue and those funds are spent
solely to support the title V program.

Discussion: The Part 70 regulations require that permit programs ensure that the collected title
V fees are adequate to cover title V permit program costs and are used solely to cover the
permit program's costs.63 In our 2008 Evaluation, the EPA did not closely review title V fee

62 2008 Evaluation, Finding 7.2.

63 See 40 CFR 70.9(a).

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accounting as the District's program at the time was not experiencing any staff shortages, nor
delays in its permit processing times. In this more recent effort, the SDAPCD provided
accounting data for the prior 3 years. As noted elsewhere in this report, prior to the title V
program, the SDAPCD was already implementing its own permitting program. When the Part 70
requirements took effect, the SDAPCD treated the Part 70 requirements as an overlay to the
existing SDAPCD permitting program. As a result of this approach, the SDAPCD treated the
revenue and expenses associated with the Part 70 program as supplemental to the revenue and
expenses associated with the existing local permitting program. Thus, the combination of their
base permitting program and the additional Part 70 requirements that apply to title V sources
result in the full program as implemented by the SDAPCD. Using an approach based on full cost
recovery, the SDAPCD ensures that it collects fees for its base permitting program and the
supplemental title V costs (including overhead, compliance costs, etc.) that match the expenses
used for implementing the supplemental title V program requirements. See Appendix F for
details regarding their accounting approach.

As discussed in Findings 5.1 and 7.6, the District has a title V permitting backlog and is
experiencing difficulty retaining permitting and compliance staff. Further, Finding 2.4 discusses
that the District's lack of documentation for processing changes as 502(b)(10) changes. While
the District's accounting approach is consistent with the Part 70 program requirements, it is not
clear whether those fees will be sufficient going forward to fully administer the program.

Recommendation: The EPA commends the SDAPCD for their approach to accounting for both
revenue and expenses for the implementation of the title V program. During the evaluation, the
EPA provided the SDAPCD with the most recent EPA policy on title V funding (see appendix E).
We recommend the SDAPCD review the policy to assure their fee program continues to be
consistent with EPA title V fee policy and that fees will be sufficient going forward.

7.3 Finding: The District permitting and compliance management communicate well and meet
routinely to discuss programmatic issues. However, the results of these discussions are not
clearly and consistently communicated to compliance staff and has resulted in uncertainty
regarding outcomes of issue resolution among compliance staff.

Discussion: In our 2008 Evaluation, we found that permitting decisions were not always clearly
communicated among the SDAPCD's engineering and compliance staff.64 During this evaluation,
we found the lack of communication and coordination at the staff level persists. The SDAPCD's
compliance and engineering management continue to hold routine meetings to discuss
permitting and compliance issues; however, such meetings are not held regularly at the staff
level. Although the District's permitting staff indicated that draft permits for unique sources are
sent to Compliance for review, the District's compliance staff indicated that draft permits are
rarely sent to the Compliance Division for review prior to the public comment period.65

64 See 2008 Evaluation, Finding 7.1.

65 See Finding 6.6 of this report for more discussion on compliance permit feedback process.

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Permitting staff, as a practical matter, should be accessible to the compliance staff for
consultation on practical enforceability, applicability determinations, and compliance
determinations. Having a systematic process, especially in cases that involve more than one
group within the District, would reduce the time necessary to resolve complex issues and
minimize potential delays in permit issuance or in appropriate enforcement action.

Recommendation: The EPA commends the SDAPCD's effort to maintain good communication
between permitting and compliance management. However, we encourage the SDAPCD to
promote increased communication and cooperation between permitting and compliance staff,
and to explore ways to improve permitting decisions among SDAPCD's engineering and
compliance staff.

7.4 Finding: The District lacks a training plan for its permitting and compliance staff.

Discussion: In the past, the District assigned one permit engineer to prepare all of its title V
permits. During this evaluation, the EPA noted that the District's current approach is to
distribute the title V workload among multiple permit engineers. The District's current
approach addresses the issue of a significant loss of institutional knowledge when a single
permitting engineer leaves. The District's title V permitting program is experiencing staffing
challenges associated with the varying levels of experience among the permitting staff as they
move to a more distributed workload approach to processing permits. In addition, we identified
several substantive issues related to permit preparation and content indicating a need for
further title V training in order to prepare more effective permits (See Section 2). In interviews,
staff identified title V training, primarily focusing on permit writing and inspections, as
something that would improve the District's title V program. District staff specifically suggested
training on federal regulations (NESHAPs and NSPS), would improve staff's familiarity with
regulatory requirements and help permit writers identify how best to incorporate these
requirements into title V permits. The EPA has separately identified training needs related to
CAM and other critical program elements and policies.

For Compliance, it appears that the amount and content of trainings for inspectors varies from
supervisor to supervisor, and that the Compliance Division has no formal training plan, training
material, or standardized procedure. Training is heavily focused on shadowing experienced
inspectors in the field. Staff and managers acknowledged that they would likely benefit from
standardized training.

Recommendation: The EPA commends the SDAPCD for distributing title V work to more than
one permit engineer. The District should identify core training needs and develop a curriculum
that title V program staff, both permitting and compliance, should complete to enhance title V
program understanding and improve permit writing and compliance determinations.66

66 In other title V program evaluations, the EPA has found good examples of the type of training and curriculum that the
District may find most useful. For example, see Finding 7.4 on pages 33 and 34 of the EPA's "Bay Area Air Quality
Management District title V Operating Permit Program Evaluation Final Report September 29, 2009", which is available on
the EPA's website at https://www.epa.gov/sites/default/files/2015-07/documents/bavarea-final-report9-29-09.pdf.

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Regulatory updates sent by EPA Region 9 can also be shared with staff as it contains relevant
updates to NSPS and NESHAP requirements and can be used as reference material for finding
relevant information on the EPA's website.67 Additionally, the District should encourage staff to
network with staff from other agencies by allowing them to participate in other learning
opportunities such as conferences, workshops and online trainings/webinars.

7.5 Finding: Permitting staff demonstrated a general lack of knowledge on environmental justice
(EJ) related to permitting and would like the EPA to provide training on this issue.

Discussion: As noted in the 2008 Evaluation, the District's permitting staff is generally not
familiar with EJ issues and how these issues may arise in a permitting context.68 As a result,
there is uncertainty about tools that may help them address EJ issues and inform the public
more effectively of permitting actions. In the EPA's prior evaluation, the EPA committed to
providing EJ training but was unable to do so given resource constraints at the time. However,
in January 2022, the EPA held a two-day training for Region 9 permit writers on EPA's EJScreen
tool and provided case studies from across Region 9 for implementing EJ in permitting.

One of the tools available to help anticipate where EJ issues may arise with permitting actions is
the EPA's EJScreen tool. This tool can be used to prepare maps that highlight specific
demographic data for use in focusing outreach, for example. The EPA suggests that the District
examine the maps provided in the appendices to this report (including the linguistic isolation
map - see Appendix D) to familiarize staff with the EJScreen tool and its capabilities in
identifying communities where additional outreach on permitting actions may be warranted.69

Recommendation: We recommend the District permitting and compliance staff coordinate
with the District's new OEJ to assist with EJ considerations in permitting. The EPA will continue
to share new information related to EJ in permitting as it becomes available.

7.6 Finding: The SDAPCD faces staffing challenges, one of the symptoms of which is a permitting
backlog, that, with its recent reclassification to a higher nonattainment status, will create
additional resource demands on its title V permitting process.

Discussion: The results of our interviews suggest that the District should focus on succession
planning to better prepare for the event that staff leave the District. The recent reclassification
of the County to a higher nonattainment classification will result in additional facilities being
subject to title V permitting requirements. The EPA notes that after our field work was
completed, the District shared with us a compensation analysis that was recently conducted for

67 For example, recent updates provide a link to the federal government's new "eCFR" website that can be used to compare
versions of federal regulations to see what has recently changed. This feature can be helpful when working on a title V
renewal action.

68 See, e.g, https://www.epa.gov/sites/production/files/2015-07/documents/ei-permitting-faqs-4.29.pdf.

69 For an overview of the EJScreen tool, please see https://www.epa.gov/eiscreen . For learning resources on EJScreen,
please see https://www.epa.gov/eiscreen/learn-use-eiscreen . CalEnviroScreen, a similar tool available in California, would
provide similar information.

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the Service Employees International Union (SEIU) (Titled Base Salary Compensation Study, by
Koff & Associates, dated September 29, 2021, independently from SEIU and the County of San
Diego, see Appendix K). As a result of this analysis, the County approved a compensation
change for the covered job classifications discussed above in June 2022. In addition, the
SDAPCD, like other agencies, experienced high turnover as a result of the COVID-19 pandemic,
increasing the number of existing vacancies.

Impacts of high staff turnover rate include: (1) a workload situation in which certain key title V
program tasks are or may not be completed in the timeframe required by District rules and the
Part 70 program (see Finding 5.1 regarding the SDAPCD's permitting backlog), and (2) a lack of
institutional knowledge at the staff level within the District's permitting and compliance
programs, and (3) a lack of adequate resources necessary to complete both existing and new
workloads. These impacts will likely be amplified by the County's transition to a higher
nonattainment classification.

Recommendation: Staff turnover can erode an agency's institutional knowledge, which can
create delays in the issuance of title V permits and lead to inconsistent permitting
determinations.70 Based on discussions with the District and the recent compensation analysis
and compensation changes, a next step to address staffing challenges should include a review
of the present permitting program workload and an analysis of the upcoming workload change
associated with the change in the nonattainment classification in order to ensure that the
permitting program can operate effectively and efficiently with adequate staffing.

70 In the EPA's 2008 Evaluation, we noted that the District had considerable experience in its title V program (see findings
2.2 and 7.3 of our 2008 Evaluation).

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8. Records Management

This section examines the system the SDAPCD has in place for storing, maintaining, and managing title
V permit files. The CAA provides that certain documents created pursuant to the title V permitting
program, including the permit application, be made available to the public but also allows some
protections for confidential information.71 The SDAPCD has a responsibility to the public in ensuring
that title V public records are complete and accessible.

In addition, the SDAPCD must keep title V records for the purposes of having the information available
upon the EPA's request. 40 CFR 70.4(j)(l) states that any information obtained or used in the
administration of a State program shall be available to the EPA upon request without restriction and in
a form specified by the Administrator.

The minimum Part 70 record retention period for permit applications, proposed permits, and final
permits is five years in accordance with 40 CFR 70.8(a)(1) and (a)(3). However, in practical application,
permitting authorities have often found that discarding title V files after five years is problematic in the
long term.

8.1 Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center.

Discussion: According to the SDAPCD, they have digitized all their files and any physical files are
archived in a separate records center. During our site visit, most interviewees stated that they
do not normally use any hard copies, and if they do, it is due to personal preference. This
conversion helped greatly during the COVID-19 pandemic.

Recommendation: The EPA commends the SDAPCD on its conversion to all electronic files.

8.2 Finding: The SDAPCD has improved its written file retention policy. However, most staff
interviewed are not aware of the District's record retention schedules.

Discussion: Similar to our 2008 Evaluation, the SDAPCD has a written file retention policy for
retaining, managing, and disposing of official records; however, most staff are not aware of the
District's record retention schedules.72 Previously, for permit-related records, the District's
records retention schedule required that permit files, including title V permit files, be retained
for a total of nine years—two years after completion of a project at the District's office (onsite)

71 This protection, however, is not absolute as the types of information that may be treated as confidential, and therefore
withheld from the public, is limited. Specifically, "[t]he contents of a permit shall not be entitled to [confidential] protection
under section 7414(c) of this title." CAA section 503(e), referring to section 114(c) of the CAA which provides protection of
certain confidential trade secret information - but not emissions data - from disclosure. In addition to the title V program
requirements, confidentiality is also addressed in the EPA's regulations governing the disclosure of records under the
Freedom of Information Act (FOIA). Pursuant to those requirements, information which is considered emissions data,
standards or limitations are also not entitled to confidential treatment. See In the Matter of ExxonMobil Corporation,
Baytown Refinery, Order on Petition No. VI-2016-14 (April 2, 2018) (Baytown Order).

72 2008 Evaluation, Finding 9.2.

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and seven years off-site. The schedule did not specifically address the retention time for title V-
related compliance records, which include compliance certifications, deviation reports and
semiannual monitoring reports. While the District's record retention schedule contained a
general section on compliance and enforcement documents, the schedule only required that
the District retain these documents for up to three years. With the current file retention
policy,73 title V documents are maintained while a permit is still active and then an additional
five years after the permit is terminated. The title V compliance files are also now explicitly
listed with a retention time frame of five years.

Recommendation: The EPA commends the SDAPCD on having a written file retention policy
that complies with the federal regulation. We recommend that the District provide training to
staff on its records management policies.

8.3 Finding: The SDAPCD uses an electronic database to track title V permits and continues to make
database improvements.

Since our 2008 Evaluation, the SDAPCD has replaced its previous permitting database, VAX, to a
web-based Business Case Management System (BCMS). Generally, most District staff believe it
is an improvement from VAX and that it is good at both storing electronic communications and
tracking information. For example, final permitting documents, public comments, and email
exchanges relating to the permit are captured in the database. The BCMS can track compliance
reports and violations, generate site history and productivity reports for inspectors, and create
a priority list of inspections each quarter. The system also currently stores annual/semi-annual
reports, generates site history report, and generates priority list of inspection on quarterly
basis. The system can also generate a report of pending applications and track application
deadlines.

The BCMS was not originally designed for the title V program. For instance, BCMS can generate
a report of all title V applications but cannot distinguish between different types of title V
applications. Further, the BCMS does not currently track synthetic minor74 and title V sources
explicitly. When the EPA requested data on the processing times for the District's title V
permits, the SDAPCD had to wait three weeks to get that query created due to other workload
priorities. However, after the query was created, the turnaround time for similar processing
time requests was significantly shortened. The District continues to work with developers to
upgrade the permit and compliance report generation capabilities.

As mentioned in Finding 2.3, the BCMS stores permit conditions used in permits to help with
consistency from permit to permit. However, if modifications are made to a condition stored in
the database, a new template condition is generated in the database and sometimes it is
difficult to track which template condition to use. When the template permit condition is

73 Appendix G - Record Retention Schedule.

74 See Finding 5.4 of this report. Actual emissions of individual equipment are recorded as the PTE, and facility-wide PTE is
not tracked.

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updated, it also does not universally update all the permit conditions where the template was
used, the District has to manually update each permit that contains that template condition.

Generally, District staff suggested that even though the BCMS is workable, it is generally slow,
not very effective, and information can be difficult to retrieve sometimes. The BCMS has limited
workflow tracking capabilities and ability to track fees and calculations. There's currently no
streamlined process that moves a permit application through different stages of review within
the system.

Recommendation: The EPA encourages the SDAPCD to continue to improve BCMS or explore
other database options to help manage and track its permitting and compliance tasks.

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Appendix A. Air Pollution Control Agencies in California

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Map: California Map for Local Air District Websites

Page 1 of 1

CALIFORNIA MAP FOR LOCAL AIR DISTRICT WEBSITES

The State is divided into Air Pollution Control Districts (APCD) and Air Quality Management Districts (AQMD), which are also called air
districts. These agencies are county or regional governing authorities that have primary responsibility for controlling air pollution from
stationary sources. The following map is for informational purposes and shows the Air District Boundaries. This map can be used to
access local air district websites or an email address for that district if there is no website.

California Air Districts

Local Air District Resource Directory
California Air Pollution Control Officers Association (CAPCOA)
Other Maps on this Website

The Board is one of six boards, departments, and offices under
the umbrella of the California Environmental Protection Agency.
Cal/EPA I MB I CIWMB | DPR | DTSC | OEHHA | SWRCB

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Appendix B. Title V Questionnaire and the SDAPCD Responses

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United States Environmental Protection Agency
Region 9 - Pacific Southwest

https://www.epa.gov/caa-permitting/caa-permitting-epas-pacific-southwest-region-9

Title V Program Evaluation
Questionnaire

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Contents

A.	Title V Permit Preparation and Content	3

B.	General Permits (GP)	7

C.	Monitoring	8

D.	Public Participation and Affected State Review	9

Public Notification Process	9

Public Comments	10

EPA 45-day Review	11

Permittee Comments	12

Public Hearings	12

Availability of Public Information	12

Affected State Review and Review by Indian Tribes	14

E.	Permit Issuance / Revision / Renewal	16

Permit Revisions	16

Permit Renewal Or Reopening	17

F.	Compliance	19

G.	Resources & Internal Management Support	22

Environmental Justice Resources	24

H.	Title V Benefits	26

2

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A.

Title V Permit Preparation and Content

1. For those title V sources with an application on file, do you require the sources to update their applications
in a timely fashion if a significant amount of time has passed between application submittal and the time
you draft the permit? YD NISI

Explanation: The District maintains a permitting database (BCMS) that already contains any updated
information, so there isn't a need to also require the facility to update their application forms. The District
includes any such changes in the statement of basis and proposed permit with an appropriate explanation of
any changes.

a. Do you require a new compliance certification? YD NISI

Explanation: The District has not encountered any recent situations where there were sufficient changes
that warranted an additional compliance certification. However, the District does not rule out requiring one
if a specific case warranted it.

2. Do you verify that the source is in compliance before a permit is issued? YISI ND If so, how?

Explanation: The District conducts periodic inspections of each facility as well as reviewing the operating
conditions relative to the underlying rules. Newly constructed facilities are inspected by a permit engineer
prior to issuance of the operating permit.

a. In cases where a facility is either known to be out of compliance, or may be out of compliance (based on
pending NOVs, a history of multiple NOVs, or other evidence suggesting a possible compliance issue),
how do you evaluate and document whether the permit should contain a compliance schedule? Please
explain and refer to appropriate examples of statements of basis written in 2005 or later in which the
District has addressed the compliance schedule question.

Explanation: The District has not encountered the need for a compliance schedule for the Title V sources in
San Diego County within recent history (current staff is not aware of any such situations in the last ten
years. A more in-depth search of records has not been conducted due to the resources necessary to review
archived records). The District does not require a compliance schedule for minor non-compliance that we
expect to be corrected within reasonable timeframes, and would not withhold issuance of the permit in this
case either. However, if a source was found to be significantly out of compliance, it is likely a compliance
schedule would be required or the permit would not be issued.

3. What have you done over the years to improve your permit writing and processing time?

Promoted training opportunities, ensured that all permit engineers can work on Title V applications, and
formalized procedures on how to issue Title V permits. The Engineering Division also closely work with the
Compliance Division to gain an enforcement perspective when proposing new permit conditions.

4. Do you have a process for quality assuring your permits before issuance? YISI ND Please explain.

Explanation: Each portion of the permit is reviewed by an Engineering Supervisor to ensure that the
requirements are accurate, enforceable, and that the permit contains all applicable requirements. All new
permit conditions are also reviewed by a Compliance Supervisor to ensure they are enforceable. The body
of the Title Vpermit is drafted by an engineer and reviewed by a senior engineer or the engineering chief.
The entire permit is also reviewed by a compliance representative before sending for EPA review and public

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comment. To ensure consistency and accuracy the District also utilizes templates and past examples of
approved permit language to minimize the possibility for errors.

Do you utilize any streamlining strategies in preparing the permit? Please explain.

a. What types of applicable requirements does the District streamline, and how common is streamlining in
District permits?

The District utilizes streamlining extensively and combines eligible requirements from rules including local
prohibitory rules, conditions imposed through NSR, NSPS and NESHAP requirements, and any other
federal or local requirements that are eligible for streamlining. The majority of streamlining occurs during
the initial (non-Title V) review of each operating permit, frequently based on templates or examples ofpast
permits.

b. Do you have any comments on the pros and cons of streamlining multiple overlapping applicable
requirements? Describe.

The benefits of streamlining outweigh the disadvantages in the District's experience. It allows for simplified
permits, and ensures all applicable requirements are incorporated. The only disadvantage in applying the
most stringent requirement is that facilities can challenge the requirement when found in noncompliance
with a streamlined permit term (when they would have complied with one or more of the underlying
requirements if listed separately). However, this disadvantage is mitigated by ensuring the facility is
consulted prior to limits being streamlined. There have not been any situations where streamlining permits
resulted in difficulty enforcing applicable requirements.

What do you believe are the strengths and weaknesses of the format of District permits (i.e. length,
readability, facilitates compliance certifications, etc.)? Why?

The District's permit format includes two separate portions of the permit: the forward section, containing
all requirements specific to Title V including general requirements, and the first Appendix, consisting of the
emission unit specific permits (which are initially drafted, reviewed and issued through the parallel local
permitting program before being integrated into the Title V permit). Each local permit in the Appendix lists
federally enforceable and local only enforceable conditions listed separately. The advantages of this
approach is that it makes clear which requirements apply to the specific emission units, and allows use of
standardized permit language andformat for the forward section, streamlining issuance of the Title V
permit. The disadvantages are that this approach leads to instances of duplicate requirements in the
emission unit specific permits andforward section, and adds a small amount of additional work to process
the two parallel application tracks (local and Title V).

How have the District's statements of basis evolved over the years since the beginning of the Title V
program? Please explain what prompted changes, and comment on whether you believe the changes have
resulted in stronger statements of basis.

The District has seen evolution of the statements of basis over time. In recent history, the statements of basis
have been streamlined, minimizing the amount of review necessary to prepare it. However, based in part on
past EPA comments regarding content of the statements of basis, and contributions from new staff, the
District has recently undertaken an effort to enhance the statements of basis to include more information,
more thoroughly document review process and decisions made, explain monitoring and CAM requirements,
and more clearly focus on highlighting changes to the permits included in the permit action. The District
has implemented these changes and it is in the later phases of fully implementing them. The District expects
these changes to assist EPA and the public in reviewing Title V actions.

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8.	Does the statement of basis explain:

a.	The rationale for monitoring (whether based on the underlying standard or monitoring added in the
permit)? YIEI N ~

b.	Applicability and exemptions, if any?	YIEI N ~

c.	Streamlining (if applicable)? YIEI N ~

Explanation: In most cases, this discussion occurs during review of the underlying local permit and would
be contained in the engineering evaluation for those specific emission unit specific permits, and this detailed
information would be available upon request.

9.	Do you provide training and/or guidance to your permit writers on the content of the statement of basis? YIEI
N ~

a. Do you have written policy or guidance on practical enforceability? YIHI N ~

Explanation: While the District does not specifically identify any guidance for "practical enforceability ",
the Engineering Department's Manual of Procedures (MOP) contains some guidance that addresses
enforceability and drafting ofpermit conditions. The District also utilizes templates for conditions that have
been reviewedfor enforceability, as well as ensuring that these requirements are reviewed both by
Engineering and Compliance Supervisors prior to the permit issuance.

10.	Do any of the following affect your ability to issue timely initial title V permits:

(If yes to any of the items below, please explain.)

a.	SIP backlog (i.e., EPA approval still pending for proposed SIP revisions)	YD N IEI

b.	Pending revisions to underlying NSR permits	YD N IEI

c.	Compliance/enforcement issues	YD N IEI

d.	EPA rule promulgation pending (MACT, NSPS, etc.)	YD N IEI

e.	Permit renewals and permit modification (i.e., competing priorities)	YM N ~

f.	Awaiting EPA guidance	YD N IEI

Explanation: The District does currently have a backlog of permit applications and is actively taking steps
to address this issue. In recent past, the District has experienced challenges with staffing resources to
handle competing priorities - specifically the development and implementation of a new emission inventory
program, implementation of the Hot Spots Program and the requirements under AB617 (Community Air
Protection Program) and AB423 (Gloria 2019). Additionally, the Covid-19 pandemic and retirement of
experienced staff have exacerbated the existing backlog.

Steps currently being taken by the District to address the backlog include revising outdated procedures for
permit review to better utilize technology, developing new guidelines and training additional staff to process

5

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Title Vpermits, and assignment of permit applications across multiple engineers (in the past, most Title V
applications were processed by a single engineer). The District has also added 2 additional positions in the
engineering department to dedicate more resources to the permitting program.

Additionally, the District notes that when resources are impacted, past focus has been on the local
permitting program, which is conducted under SIP approved rules and regulations and results in the
issuance offederally enforceable permits that ensure compliance with all applicable requirements for each
emission unit.

11. Any additional comments on permit preparation or content?

6

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B. General Permits (GP)

1.	Do you issue general permits? Y~ N M

a.	If no, go to next section

b.	If yes, list the source categories and/or emission units covered by general permits.

2.	In your agency, can a title V source be subject to multiple general permits and/or a general permit and a
standard "site-specific" title V permit? YD N ~

a. What percentage of your title V sources have more than one general permit?

3.	Do the general permits receive public notice in accordance with 70.7(h)? YD N ~

a. How does the public or regulated community know what general permits have been written? (e.g., are
the general permits posted on a website, available upon request, published somewhere?)

4.	Is the 5-year permit expiration date based on the date:

a.	The general permit is issued? Y~ N ~

b.	You issue the authorization for the source to operate under the general permit? Y~ N ~

5.	Any additional comments on general permits?

7

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C. Monitoring

1. How do you ensure that your operating permits contain adequate monitoring (i.e., the monitoring required in
§§ 70.6(a)(3) and 70.6(c)(1)) if monitoring in the underlying standard is not specified or is not sufficient to
demonstrate compliance?

SDAPCD reviews monitoring requirements at the stage the emission unit specific permits are issued, which
results in the vast majority of emission units having federally enforceable monitoring prior to being
included in the Title V permit. Monitoring is reviewedfor each emission unit and is a standard part of the
review process for all applications to ensure that each requirement has a monitoring and record keeping
mechanism.

a. Have you developed criteria or guidance regarding how monitoring is selected for permits? If yes,
please provide the guidance. YD N IE

While we do not have specific guidance on monitoring, we utilize standard procedures as part of the permit
review process to ensure that proper monitoring is included in the permit. This includes utilizing standard
sets ofpermit conditions that have been found to have adequate monitoring, basing unique monitoring
conditions on comparable standards in prohibitory rules, NSPS, NESHAP or other relevant examples, and a
required review by compliance personnel for each set ofpermit conditions, which focuses on enforceability,
including monitoring requirements.

2. Do you provide training to your permit writers on monitoring? (e.g., periodic and/or sufficiency monitoring;
CAM; monitoring QA/QC procedures including for CEMS; test methods; establishing parameter ranges)
YM N ~

3. How often do you "add" monitoring not required by underlying requirements? Have you seen any effects of
the monitoring in your permits such as better source compliance?

The District frequently adds monitoring, most commonly for emission limits or permit conditions
implemented through local NSR. In these cases, monitoring usually mirrors similar underlying requirements
where monitoring is required. Monitoring likely results in additional non-compliance simply because the
additional requirements for monitoring may lead to more possibilities to not comply with the monitoring
requirement, but may not necessarily translate into emissions exceedances or emission limit violations.
However, the District expects the additional monitoring does result in lowered emissions and better
compliance with underlying standards that otherwise would not be detected as non-compliant.

4. What is the approximate number of sources that now have CAM monitoring in their permits? Please list
some specific sources.

In current staffs experience, we do not have many, if any, sources that have CAM monitoring. This is
primarily due to these sources being subject to monitoring that exempts them from CAM.

5. Has the District ever disapproved a source's proposed CAM plan?

In current staffs experience, we have not reviewed any proposed CAM plans, so have not had cause to
disapprove or approve any plan.

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I). Public Participation and Affected State Review
Public Notification Process

1.	Which newspapers does the District use to publish notices of proposed title V permits?

San Diego Union Tribune

2.	Do you use a state publication designed to give general public notice? YD N M

3.	Do you sometimes publish a notice for one permit in more than one paper? YD N IHI

Explanation: This District doesn 7 find newspapers notices a very effective form of outreach. This District
utilizes its GovDelivery subscription service to notify the public and stakeholders. It also posts all
notifications on its website.

a.	If so, how common is if for the District to publish multiple notices for one permit?

b.	How do you determine which publications to use?

Only available publication with sufficient circulation.

c.	What cost-effective approaches have you utilized for public publication?

Notices are published on the District's website and sent to established email distribution lists for those with
Title V interest. Most, if not all, engagement the District receives from the public on Title V is through an
electronic method of notification.

4.	Have you developed mailing lists of people you think might be interested in title V permits you propose?
[e.g., public officials, environmentalists, concerned citizens] YIEI N ~

Note: it is an email list, not a physical mailing list.

a.	Does the District maintain more than one mailing list for title V purposes, e.g., a general title V list and
source-specific lists? YD N H

b.	How does a person get on the list? (e.g., by calling, sending a written request, or filling out a form on the
District's website)

Through the District's website.

c.	How does the list get updated?

Automatically when users register.

d.	How long is the list maintained for a particular source?

There are no lists for specific sources

e.	What do you send to those on the mailing list?

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They receive a brief explanation of the source and Title V action, and links to view the full public notice,
proposed permit, application forms and statement of basis posted on the District's website.

5.	Do you reach out to specific communities (e.g., environmental justice communities) beyond the standard
public notification processes? YD N IS

In our experience, most interested environmental justice communities utilize the existing automated email
notification lists to be notified of Title V actions. The District is currently developing a public participation
plan to enhance public outreach and it is implementing multiple requirements from AB423 that promote
transparency and public engagement.

6.	Do your public notices clearly state when the public comment period begins and ends? YIS N ~

7.	What is your opinion on the most effective methods for public notice?

Electronic. The District find that the required newspaper notice is not effective.

8.	Do you provide notices in languages besides English? Please list the languages and briefly describe under
what circumstances the District translates public notice documents? YD N IS

While notices are not provided in other languages the District does have staff to provide information in
other languages as needed. The District will be evaluating its public notices under the public participation
plan.

Public Comments

9.	How common has it been for the public to request that the District extend a public comment period?

Rarely, if ever since the District has not received requests for extending the public comment period. The
District has extended comment periods for major NSR permits on a few occasions. Current staff is not
aware of any instances where an extension of a Title V comment period was requested.

a.	Has the District ever denied such a request? Y~ N IS

b.	If a request has been denied, what were the reason(s)?

If mirroring past practice for requested NSR permits, extensions are generally granted in most cases to
encourage public involvement.

10.	Has the public ever suggested improvements to the contents of your public notice, improvements to your
public participation process, or other ways to notify them of draft permits? If so, please describe.

YD N IS

11.	Approximately what percentage of your proposed permits has the public commented on?

We estimate about 5%, no more than 10%.

12.	Over the years, has there been an increase in the number of public comments you receive on proposed title
V permits? YD N IS

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13.	Have you noticed any trends in the type of comments you have received? YM N ~

Please explain.

We haven't observed a sufficient trend to make any conclusions, but the most recent comments have focused
on toxic pollutant impacts, cumulative emission impacts from closely located sources, and other issues that
aren 7 directly addressable through the Title Vprogram.

a. What percentage of your permits change due to public comments?

The District is not aware of ever changing a Title V permit after public comment other than comments
provided by the permittee. However, the District has on occasion changed conditions after public
comments during review for a major source NSR permit. This has only occurred rarely (<5-10%) and
was related to revising BACT requirements and related emission limits on new power plants.

14.	Have specific communities (e.g., environmental justice communities) been active in commenting on
permits? YD N IHI

15.	Do your rules require that any change to the draft permit be re-proposed for public comment?

YD N m

Explanation: We do not require re-proposal if the changes are administrative or sufficiently minor that a
commentor would not be expected to view the changes as substantive.

a. If not, what type of changes would require you to re-propose (and re-notice) a permit for comment?

Any change that we believe is at all substantive or is noted by EPA to require re-noticing would result in the
District re-proposing the permit. In the past we have few examples of changing permits, but have generally
deferred to conducting a re-proposal in any questionable case.

EPA 45-day Review

16.	What permit types do you send to the EPA for 45-day review?

Initial, Renewal, Major Modification, Minor Modification, Enhanced Authority to Construct

17.	Do you have an arrangement with the EPA region for its 45-day review to start at the same time the 30-day
public review starts? (aka "concurrent review) YIEI N ~

Explanation: Our rules allow for concurrent review and it is our practice to conduct review concurrently.
We also typically consult EPA prior to proposing for any questionable permit decisions to prevent need to
make changes and re-notice.

a.	What could cause the EPA 45-day review period to restart (i.e., if public comments received, etc)?

We are not aware of any situation where the period needed to be restarted, but we would restart any time
that we intend to change the permit and EPA concurs with the need for the review period to restart.

b.	How does the public know if the EPA's review is concurrent?

They could determine this either by seeing and reviewing the rules stating that this is allowable, or by
contacting the District to inquire.

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c. If the District does concurrent review, is this process a requirement in your title V regulations, or a result
of a MOA or some other arrangement?

It is an optional part of regulations and a practice the District considers improves and helps with
streamlining of the permit process.

Permittee Comments

18.	Do you work with permittees prior to public notice? Y|x| N ~

19.	Do permittees provide comments/corrections on the permit during the public comment period? YIHI N ~

Explanation: We encourage permittees to provide comments prior to public notice so that any changes such as
typographical or errors can be made without requiring re-noticing to correct. In the majority of cases this
occurs, but in at least one occasion a source has provided substantial comments afterwards. Additionally,
permittees will normally have already reviewed the equipment specific permit conditions when the operating
permit is issued, so this reduces the needfor comment.

a.	Any trends in the type of comments?

None of note.

b.	How do these types of comments or other permittee requests, such as changes to underlying NSR
permits, affect your ability to issue a timely permit?

In our experience this happens rarely, but when it does it has significantly impacted the timely issuance
of the permit. District staff has recently reviewed the past case where this occurred and staff expects in
the future to have more defined standards for which requests can be entertained and which should be
denied due to the review requirement under the local permit program prior to integration with the Title
V permit.

Public Hearings

20.	What criteria does the District use to decide whether to grant a request for a public hearing on a proposed
title V permit? Are the criteria described in writing (e.g.., in the public notice)?

We do not have a written policy, but would only grant a request if the commentor raised a specific issue
pertinent to the Title Vpermit that would require change of the requirements in the permit or raising a
concern that could result in denying the permit. Current staff is not aware of any requests for a public
hearing in the past 5 years. We recently received an inquiry from a community member regarding a request
for a public comment, but after explaining to them that the issue identified could not be well addressed
through Title V (cumulative health risk impacts from various sources in a low income community), no
formal request for a hearing was made.

a. Do you ever plan the public hearing yourself, in anticipation of public interest? Y~ N M
We have not in the past, but it is a possibility if warrantedfor a specific project.

Availability of .Public Information

21.	Do you charge the public for copies of permit-related documents? YD N IHI

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a. If yes, what is the cost per page? N/A

b.	Are there exceptions to this cost (e.g., the draft permit requested during the public comment period, or
for non-profit organizations)? YD N IEI

c.	Do your title V permit fees cover this cost? YIEI N ~ If not, why not?

22. What is your process for the public to obtain permit-related information (such as permit applications, draft
permits, deviation reports, 6-month monitoring reports, compliance certifications, statement of basis)
especially during the public comment period?

A public information request (PIR) can be filed in person, over the phone or electronically for these
documents. Some (applications, draft permit, statement of basis) are available online during the comment
period. Additionally the District is implementing requirements under AB423 that includes publishing
permitting datasets on its website.

a. Are any of the documents available locally (e.g., public libraries, field offices) during the public
comment period? YD N IS Please explain.

They are available online, but not physically.

23.	How long does it take to respond to requests for information for permits in the public comment period?

For information that is readily available, records are typically available within a few days. High priority is
given to responding to these requests. Information that is not readily available (i.e. requires data analysis or
processing or has been archived) may take longer.

24.	Have you ever extended your public comment period as a result of requests for permit-related documents?
YD N m

This situation has not occurred, but we likely would in the event that we experienced a delay responding to
an information request or there was justification for allowing longer period to review.

25.	Do information requests, either during or outside of the public comment period, affect your ability to issue
timely permits? YD N H

26.	What title V permit-related documents does the District post on its website (e.g., proposed and final permits,
statements of basis, public notice, public comments, responses to comments)?

Proposed permit, statement of basis, public notice, applications. Additionally, as required by AB423, the
District recently began making available the application files for all local permit applications under review,
which would include those located at Title V facilities.

a.	How often is the website updated? Is there information on how the public can be involved?

It is updated as necessary when a public notice is initiated. There is information on how to submit
comments. The District is currently undergoing a large scale revamp of the website (required by AB423)
and this will result in additional information available for Title V in a more user-friendly platform.

b.	Do you provide public commenters with final Title V permit documents?

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Only upon request or if relevant in responding to comment.

27.	Have other ideas for improved public notification, process, and/or access to information been considered?
YIEI N ~ If yes, please describe.

The District is currently developing a Public Participation Plan that will detail communication and
engagement strategies to inform and increase public participation. The Public Participation Plan will be
consideredfor adoption by the District's Governing Board in early 2022.

28.	Do you have a process for notifying the public as to when the 60-day citizen petition period starts?

Y~ N El If yes, please describe.

29.	Do you have any resources available to the public on public participation (booklets, pamphlets, webpages)?
YIEI N ~

The District is currently developing a Public Participation Plan that will detail communication and
engagement strategies to inform and increase public participation. The Public Participation Plan will be
consideredfor adoption by the District's Governing Board in early 2022.

30.	Do you provide training to citizens on public participation or on title V? YD N IE

The District is currently developing a Public Participation Plan that will detail communication and
engagement strategies to inform and increase public participation. The Public Participation Plan will be
consideredfor adoption by the District's Governing Board in early 2022.

31.	Do you have staff dedicated to public participation, relations, or liaison? Y|x| N ~

a.	Where are they in the organization?

The District has a program coordinator position (currently vacant and in the process of being filled) to
serve as the APCD Public Information Officer and Outreach Coordinator. This position is under the
Office of Environmental Justice and it reports to the Deputy Director overseeing that office.

b.	What is their primary function?

To be a spokesperson for APCD, manage media relations, and coordinate outreach activities to increase
public participation and engagement.

Affected State Review and Review by Indian Tribes

32.	How do you notify tribes of draft permits?

Tribes are notified electronically using list of tribes and contact information provided by EPA. One tribe
does not have an email contact, so the notices are mailed.

33.	Has the District ever received comments on proposed permits from Tribes?

The District has not recently received any comments from tribes on Title V permits in current staff's
experience. However, the District has received comments on a proposed NSR permit for a landfill and the
project was ultimately withdrawn prior to approval.

34.	Please provide any suggestions for improving your notification process.

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The goal of the public participation plan is to identify the needs and interest of the public and develop
strategies to meet these expectations. As it relates to permitting actions, presenting information in a clear
and concise manner is critical.

35. Any additional comments on public notification?

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E. Permit Issuance / .Revision / .Renewal
Permit Revisions

1. For which types of permit modifications do you follow a list or description in your regulations to determine
the appropriate process to follow: (Check all that apply)

IEI Administrative amendment?

IEI Section 502(b)(10) changes?

IEI Significant and/or minor permit modification?

~ Group processing of minor modifications?

2. Approximately how many title V permit revisions have you processed for the last five years? 25

a. What percentage of the permit revisions were processed as:

Significant: 0

Minor: 0

Administrative: 60%

Off-permit: 0

502(b)(10): 40%

The percentage provided above represents the applications received and approvedfor the last five years.
It does not include all applications receivedfor the last five years that are pending approved. Some of the
applications pending approval are for minor modifications and are for facilities that subject to renewal.
The District has been processing these minor modification applications at the same time as the renewal
permit is being issued to promote efficiencies.

3. For the last five years, how many days, on average, does it take to process (from application receipt to final
permit revision):

a. A significant permit revision?

b. A minor revision?

No data. We have no data on this because we have not approved any of the above application types. No
significant mods have been received and minor mods are either delayed so they can be included with
renewals or the underlying projects have not been constructed or started operation.

4. How common has it been for the District to take longer than 18 months to issue a significant revision, 90
days for minor permit revisions, and 60 days for administrative amendments? Please explain.

Due to the backlog described under question 10, the District has in some cases exceeded these timelines.
However, with recent changes to the Title V procedures and staff assignments, we are confident that we will
quickly resume timely processing of Title Vpermit revisions.

5. What have you done to streamline the issuance of revisions?

Due to the delay in processing revisions, the District has relied on the strategy of combining multiple
reviews with the renewal. This also has the advantage of minimizing the amount of time spent on the

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projects since many of the steps are the same whether a permitting action includes one or multiple
revisions.

6. What process do you use to track permit revision applications moving through your system?

The District uses a system called the Business Case Management System (BCMS) created by Accela. This
system allows for the generation of reports and searching of records that allows for easy tracking ofpermit
applications and modification status.

7. Have you developed guidance to assist permit writers and sources in evaluating whether a proposed revision
qualifies as an administrative amendment, off-permit change, significant or minor revision, or requires that
the permit be reopened? Y|x| N ~ If so, please provide a copy.

8. Do you require that applications for minor and significant permit modifications include the source's
proposed changes to the permit? Y~ N IHI

Typically, all minor and significant permit modifications require that the applicant first obtains a modified
authority to construct or permit to operate through the local permitting program prior to applying for the
Title V change. In practice, most permittees apply at the same time, so the District waits to process the Title
V application until the local permit is issued so that the conditions in that permit can serve as the proposed
conditions. This approach minimizes the need to renotify or repropose if changes are required after
construction (e.g. removal of initial testing requirements or alteration of monitoring requirements based on
observed operation).

a. For minor modifications, do you require sources to explain their change and how it affects their
applicable requirements? YD N IHI

Many sources do, but frequently they prefer to rely on the District's determination of how changes will
apply.

9. Do you require applications for minor permit modifications to contain a certification by a responsible
official that the proposed modification meets the criteria for use of minor permit modification procedures
and a request that such procedures be used? YIHI N ~

10. When public noticing proposed permit revisions, how do you identify which portions of the permit are being
revised? (e.g., narrative description of change, highlighting, different fonts).

Narrative description.

11. When public noticing proposed permit revisions, how do you clarify that only the proposed permit revisions
are open to comment?

Narrative description of what the project entails, and clarification if a comment is submitted regarding a
portion of the permit that is not open for comment.

Permit Renewal or Reopening

12. Do you have a different application form for a permit renewal compared to that for an initial permit
application? YD N IHI

a. If yes, what are the differences?

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13.	Has issuance of renewal permits been "easier" than the original permits?

YM N ~ Please explain.

In most cases, the renewal permit is based on the original permit, resulting in less time spent establishing
requirements. However, in a few limited circumstances a facility with many emission units may have
experienced so many changes that there is minimal reduction in effort to issue the renewal permit.

14.	How are you implementing the permit renewal process (ie., guidance, checklist to provide to permit
applicants)? YD N ~

The District provides a standard application package online. Facilities subject to permit renewals must
submit complete applications with the requiredfees.

15.	What percentage of renewal applications have you found to be timely and complete for the last five years?

SDAPCD is only aware of two instances in the last 5 years where an application was not timely and complete,
which equates to < 10% of applications.

16.	How many complete applications for renewals do you presently have in-house ready to process?

We currently have 21 open renewals, of which we expect all are complete (not all have had a completeness
determination).

a. Have you been able to or plan to process these renewals within the part 70 timeframe of 18 months? If
not, what can EPA do to help? Y~ N M

The District's current backlog of Title V renewals is primarily due to competing priorities and need to
temporarily focus staff resources in other areas (emission inventory, air toxic hot spots, AB423/AB617).
However, these projects are winding down and a revised process for assigning Title V renewals to a larger
group of staff has recently been implemented which should allow the District to return to timely application
processing.

17.	Have you ever determined that an issued permit must be revised or revoked to assure compliance with the
applicable requirements? YD N IHI

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F. Compliance
Deviations

1. Deviation reporting:

a. Please describe which deviations you require be reported prior to the semi-annual monitoring report?

Breakdowns can be reported within two hours of detection. Deviations that are not due to a breakdown,
but which result in excess emissions specific to cogens andpowerplants must be reported within 10
calendar days of detection.

b. Do you require that some deviations be reported by telephone? YD N IEI

Breakdowns can be reported by telephone or electronically viaAccela Citizen Access (online account
created by facility).

c. If yes, do you require a follow-up written report? YIEI N ~ If yes, within what timeframe?

A follow-up written report is required for breakdowns within 15 calendar days after the breakdown
occurrence has been corrected.

d. Do you require that all deviation reports be certified by a responsible official? (If no, describe which
deviation reports are not certified). Y~ N M

Self-reported deviations that occur prior to the semi-annual monitoring reports can be submitted by
Environmental staff, which may not be the responsible officials.

i. Do you require certifications to be submitted with the deviation report? YD N ISI

ii. If not, do you allow the responsible official to "back certify" deviation reports? YD M N ~

The responsible official certifies deviation reports when the semi-annual monitoring reports and the
annual compliance certifications are submitted. If this is considered "back certifying" then yes.

iii. If you allow the responsible official to "back certify" deviation reports, what timeframe do you allow
for the follow-up certifications (e.g., within 30 days; at the time of the semi-annual deviation
reporting)?

The responsible official must certify at the time of the semi-annual deviation reporting.

2. How does your program define deviation?

Any violation of permit conditions, rules or regulations that are federally-enforceable.

3. Do you require only violations of permit terms to be reported as deviations? YD N M

4. Which of the following do you require to be reported as a deviation (Check all that apply):

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IEI Excess emissions excused due to emergencies (pursuant to 70.6(g))

IEI Excess emissions excused due to SIP provisions (cite the specific state rule)

IEI Excess emissions allowed under NSPS or MACT SSM provisions

IEI Excursions from specified parameter ranges where such excursions are not a monitoring violation (as
defined in CAM)

IEI Excursions from specified parameter ranges where such excursions are credible evidence of an emission
violation

Failure to collect data/conduct monitoring where such failure is "excused":

~ During scheduled routine maintenance or calibration checks

~ Where less than 100% data collection is allowed by the permit
IEI Due to an emergency

~ Other? Describe.

5. Do your deviation reports include:

a. The probable cause of the deviation? Y IEI N ~

b. Any corrective actions taken? Y IEI N ~

c. The magnitude and duration of the deviation? Y IEI N ~

6. Do you define "prompt" reporting of deviations as more frequent than semi-annual? YIEI N ~

7. Do you require a written report for deviations? Y IEI N ~

8. Do you require that a responsible official certify all deviation reports? Y IEI N ~

Com.pl i ance Reports

9. What is your procedure for reviewing and following up on:

a. Deviation reports? Y IEI N ~

b. Semi-annual monitoring reports? Y IEI N ~

c. Annual compliance certifications? Y IEI N ~

10. Please identify the percentage of the following reports you review:

a. Deviation reports - 100%

b. Semi-annual monitoring reports - 100%

c. Annual compliance certification - 100%

11. Compliance certifications

a. Have you developed a compliance certification form? Y IEI N ~ If no, go to question 12.

i. Is the certification form consistent with your rules? Y IEI N ~

ii. Is compliance based on whether compliance is continuous or intermittent or whether the compliance
monitoring method is continuous or intermittent?

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Both

iii.Do you require sources to use the form? Y ISI N ~ If not, what percentage do?

iv.Does the form account for the use of credible evidence? YD N ISI

v. Does the form require the source to specify the monitoring method used to determine compliance
where there are options for monitoring, including which method was used where more than one
method exists? Y ISI N ~

12. Is your compliance certification rule based on:

a. The '97 revisions to part 70 - i.e., is the compliance certification rule based on whether the compliance
monitoring method was continuous or intermittent; ~

b. The '92 part 70 rule - i.e., is the compliance certification rule based on whether compliance was
continuous or intermittent? M

Excess Emissions

13. Does your program include an emergency defense provision as provided in 70.6(g)? Y ~ N ISI If yes, does
it:

a. Provide relief from penalties? YD N ~

b. Provide injunctive relief? YD N ~

c. Excuse non-compliance? YD N ~

14. Does your program include a SIP excess emissions provision? YD N ISI If no, go to 10. c. If yes does it:

a. Provide relief from penalties? YD N ~

b. Provide injunctive relief? YD N ~

c. Excuse noncompliance? YD N ~

15. Do you require the source to obtain a written concurrence from the District before the source can qualify
for:

To our knowledge, a source has never requested these provisions, therefore a written concurrence has not
been necessary.

a. The emergency defense provision? YD N ~

b. The SIP excess emissions provision? Y~ N ~

c. NSPS/NESHAP SSM excess emissions provisions? YD N ~

16. Any additional comments on compliance?

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G. Resources & Internal Management Support

1. Are there any competing resource priorities for your "title V" staff in issuing title V permits? YM N ~
a. If so, what are they?

Currently the largest competing priorities are the implementation of the Hot Spots Program and
implementations of the requirements under AB 423. Other previous efforts such as development of an
emission inventory system, implementation ofAB617, which primarily focuses on environmental justice
issues, contributed to the application backlog. However, the District has implemented processes to address
this backlog.

2. Are there any initiatives instituted by your management that recognize/reward your permit staff for getting
past barriers in implementing the title V program that you would care to share? YD N IE

There are no initiatives specific for the Title V program but the District has an employee recognition award
program to recognize staff. The leadership team also recognizes accomplishments from staff.

3. How is management kept up to date on permit issuance?

SDAPCD's permit system (BCMS) allows for sorting and searching records, as well as preparation of
reports that show up to date status of all applications.

4. Do you meet on a regular basis to address issues and problems related to permit writing? YIHI N ~

5. Do you charge title V fees based on emission rates? YDNS

a. If not, what is the basis for your fees?

Time and material basis. Permits are also assessed a separate emission fee based on emission rate, but
this is not specific to Title Vfacilities.

b. What is your title V fee?

Time and Material fees as specified in District Rule 40.

c. Do you have sources that refuse to pay their title V fee? YD N HI How do you approach these
situations?

6. How do you track title V expenses?

Labor data are maintained in the BCMS permit system of actual time spent.

7. How do you track title V fee revenue?

Title V revenues are tracked as part of regular permit charges, for those facilities that are subject to Title V
Operating Permits and can be identified as Title V through a report from the permits database (BCMS).

8. How many title V permit writers does the agency have on staff (number of FTE's, both budgeted and
actual)?

Engineering Division has 17 Permit Engineer positions. Two of these positions are currently vacant but in
the process of being filled. All engineers can work on District and Title V permits.

9. Do the permit writers work full time on title V? YD N ISI

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a. If not, describe their main activities and percentage of time on title V permits.

Main activities are local permit review.

Estimate 5-10% of time spent on Title V specific applications on average. Additionally, much of the
local permit work at Title V facilities is utilized in preparing the Title Vpermits.

b. How do you track the time allocated to Title V activities versus other non-title V activities?

Labor data is kept in BCMS.

10. Are you currently fully staffed?

No, but are actively working to hire to fill the open positions.

11. What is the ratio of permits to Title V permit writers?

Approximately 4 permits per employee who currently works on Title Vpermitting. However, each employee
is only spending a small percentage of his/her time on Title V applications.

12. Describe staff turnover.

In the last year, staff turnover has been approximately 50% in the permitting group.

a. How does this impact permit issuance?

This has a significant impact on permit issuance since due to required training on the Title Vprogram
and District rules.

b. How does the permitting authority minimize turnover?

The District offers flexible schedules, such as 4/10 schedules, teleworking schedules, opportunities for
advancements, job shadowing program, and training opportunities.

13. Do you have a career ladder for permit writers? YIEI N ~ If so, please describe.

The District uses the following structure: Junior Engineer, Assistant Engineer, Associate Engineer, Senior
Engineer, Chief. New hires are typically made at the assistant and junior levels.

14. Do you have the flexibility to offer competitive salaries? YD N ~

SDAPCD employees are still County employees. The salary ranges are established by County through labor
negotiations. When hiring new employees the District has some flexibility to offer a starting salary within
the specified range based on previous experience and qualifications.

The District has also offered a flex schedule that includes a 4/10 option and various start time, as well as
integrated teleworking opportunities to offer additional benefits to its employees.

15. Can you hire experienced people with commensurate salaries? YD N ~

When hiring new employees the District has some flexibility to offer a starting salary within the specified
range based on previous experience and qualifications.

16. Describe the type of training given to your new and existing permit writers.

District staffprimarily receive training in equipment types, pollutant types, and applicable rules from the
state (CARB) or EPA and through WESTAR coordinated training sponsored by EPA. Additionally, the
engineering division periodically conducts its own trainings for some or all staff. Staff also are expected to
learn through experience and start working on less complex applications quickly after hiring with oversight
from their supervisors and/or more experienced engineers.

17. Does your training cover:

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a. How to develop periodic and/or sufficiency monitoring in permits? YIEI N ~

b. How to ensure that permit terms and conditions are enforceable as a practical matter? YIEI N ~

c. How to write a Statement of Basis? YISI N ~

18. Please describe anything that EPA can do to assist/improve your training.

Training opportunities are always beneficial

19. How has the District organized itself to address title V permit issuance?

The Engineering Division is responsible for reviewing permit applications and issuing permits. The District
does not have a separate group for Title Vpermits.

20. Overall, what is the biggest internal roadblock to permit issuance from the perspective of Resources and
Internal Management Support?

Policies and Procedures in the Engineering Division had not been revised for 5 years, resulting in a lack of
guidance for staff. Since last year the District has been actively revising and creating new procedures as
well as providing training to staff to increase resources for Title V and other programs.

Another challenge the division faced is related to the backlog associated with the Emission Inventory and
AB2588 programs, which took resources away from the permitting program.

Other barriers that have contributed to delays include new team members that have not been fully trained.

Environmental Justice Resources

21. Do you have Environmental Justice (EJ) legislation, policy or general guidance which helps to direct
permitting efforts? YD N ISI If so, may EPA obtain copies of this information?

While there's currently no specific EJ guidance to direct permitting efforts, the APCD Board established an
office of Environmental Justice in late 2020 with 0.5 FTE dedicated to oversee EJ activities and 1FTE
dedicated to public outreach (currently vacant). Since then, the Office ofEJhas been mainly dedicated to
manage the implementation of the State's Community Air Protection Program (AB617). APCD's Office of
EJ is currently working on developing a framework to provide EJ training to APCD staff as well as define
strategies to engage with EJ communities in the San Diego region.

22. Do you have an in-house EJ office or coordinator, charged with oversight of EJ related activities? YISI N ~

The APCD Board established an office of Environmental Justice in late 2020 with 0.5 FTE dedicated to
oversee EJ activities and 1 FTE dedicated to public outreach (currently vacant). Since then, the Office ofEJ
has been mainly dedicated to manage the implementation of the State's Community Air Protection Program
(AB617). APCD's Office of EJ is currently working on developing a framework to provide EJ training to
APCD staff as well as define strategies to engage with EJ communities in the San Diego region.

23. Have you provided EJ training / guidance to your permit writers? YD N ISI

While there's currently no specific EJ guidance to direct permitting efforts, the APCD Board established an
office of Environmental Justice in late 2020 with 0.5 FTE dedicated to oversee EJ activities and 1 FTE
dedicated to public outreach (currently vacant). Since then, the Office ofEJhas been mainly dedicated to
manage the implementation of the State's Community Air Protection Program (AB617). APCD's Office of
EJ is currently working on developing a framework to provide EJ training to APCD staff as well as define
strategies to engage with EJ communities in the San Diego region.

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24.	Do the permit writers have access to demographic information necessary for EJ assessments? (e.g., socio-
economic status, minority populations, etc.) YIHI N ~

Engineers have access to CalEnviroScreen, which is a science-based mapping tool available to staff that
scores California communities by census tract based on environmental, health, and socioeconomic data.
These scores help identify disadvantaged communities where environmental justice issues are prevalent.
Census information on demographics is also available to help complement CalEnviroScreen data.

25.	When reviewing an initial or renewal application, is any screening for potential EJ issues performed?
YD N ISI If so, please describe the process and/or attach guidance.

Because SDAPCD's rules do not have separate requirements based on whether or not a facility is located in
an EJ area, we have not identified a need for such screening.

25

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II.	Title V Benefits

1. Does your staff implementing the title V program generally have a better understanding of:

a.	NSPS requirements? YIEI N ~

b.	The stationary source requirements in the SIP? YIS N ~

c.	The minor NSR program? YIEI N ~

d.	The major NSR/PSD program? YIEI N ~

e.	How to design monitoring terms to assure compliance? YIEI N ~

f.	How to write enforceable permit terms? YIEI N ~

2. In issuing initial title V permits:

a.	Have you noted inconsistencies in how sources had previously been regulated (e.g., different emission
limits or frequency of testing for similar units)? YD N IEI If yes, describe.

b.	Have you taken (or are you taking) steps to assure better regulatory consistency within source categories
and/or between sources? Y~ N M If yes, describe.

3. Based on your experience, estimate the frequency with which potential compliance problems are identified
through the permit issuance process:

Never Occasionally Frequently Often

a.

Prior to submitting an application

~

m

~

~

b.

Prior to issuing a draft permit

~

m

~

~

c.

After issuing a final permit

~

m

~

~

4. Based on your experience with sources addressing compliance problems identified through the title V
permitting process, estimate the general rate of compliance with the following requirements prior to
implementing title V:

This information is not available prior to implementation of Title V. Currently, occasionally there are
compliance issues identified related to NSPS applicability.

Never Occasionally Frequently Often

a.	NSPS requirements

(including failure to identify an NSPS as applicable)^ ~	~	~

b.	SIP requirements	~ ~	~	~

c.	Minor NSR requirements

(including the requirement to obtain a permit) ~ ~	~	~

d.	Major NSR/PSD requirements

(including the requirement to obtain a permit) ~ ~	~	~

26

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5. Do you see a difference in compliance behavior on the part of sources that have to comply with the title V
program? (Check all that apply.)

M Increased use of self-audits?

M Increased use of environmental management systems?

13 Increased staff devoted to environmental management?

M Increased resources devoted to environmental control systems (e.g., maintenance of control
equipment; installation of improved control devices; etc.)?

M Increased resources devoted to compliance monitoring?

13 Better awareness of compliance obligations?

~ Other? Describe.

6. Does implementation of the title V program improve other areas of your program? (Check all that apply.)

~ Netting actions

13 Emission inventories

~ Past records management (e.g., lost permits)

13 Enforceability of PTE limits (e.g., consistent with guidance on enforceability of PTE limits such as
the June 13, 1989 guidance)

~ Identifying source categories or types of emission units with pervasive or persistent compliance
problems; etc.

~ Clarity and enforceability of NSR permit terms

13 Better documentation of the basis for applicable requirements (e.g., emission limit in NSR permit
taken to ~ avoid PSD; throughput limit taken to stay under MACT threshold)

~ Emissions trading programs

~ Emission caps

~ Other (describe)

Because of the robustness of the District's local permitting program, Title V has less of an impact than it
would otherwise.

7. If yes to any of the above, would you care to share how the title V program improves other aspects of your
air program? (e.g., increased training; outreach; targeted enforcement)?

Increased recordkeeping and outreach opportunities

8. Are there aspects of the title V program that you have extended to other program areas (e.g., require
certification of accuracy and completeness for pre-construction permit applications and reports; increased
records retention; inspection entry requirement language in NSR permits). YD N IS If yes, describe.

While the local permit program does share many of the same concepts as Title V, current staff do not
believe that these resultedfrom Title V specifically.

9. Have you made changes in how NSR permits are written and documented as a result of lessons learned in
title V (e.g., permit terms more clearly written; use of a statement of basis to document decision making)?
If yes, describe.

While the local permit program does share many of the same concepts as Title V, current staff do not
believe that these resultedfrom Title V specifically.

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10. Do you use information from title V to target inspections and/or enforcement? YIHI N ~

11. Is title V fee money helpful in running the program? That is, does it help you to provide: (Check all that
apply.)

IEI Better training?

13 More resources for your staff such as CFRs and computers?

M Better funding for travel to sources?

~ Stable funding despite fluctuations in funding for other state programs?

M Incentives to hire and retain good staff?

~ Are there other benefits of the fee program? Describe.

12. Have you received positive feedback from citizens? YD N IE

13. Has industry expressed a benefit of title V? YD N IHI If so, describe.

14. Do you perceive other benefits as a result of the title V program? YIHI N ~ If so, describe.

Increased oversight

15. Other comments on benefits of title V? YIHI N ~

Because of the nature of the District's local permit program which implements a significant amount of the
same requirements as Title V, the benefits of Title V are limited to those areas that are not reflected in the
normal process (public comment, deviation reporting)

Good Practices not addressed elsewhere in this questionnaire

16. Are any practices employed that improve the quality of the permits or other aspects of the title V program
that are not addressed elsewhere in this questionnaire? No

EPA assistance not addressed elsewhere in this questionnaire

17. Is there anything else EPA can do to help your title V program?

EPA staff has been always available when neededfor questions and general assistance, which is greatly
appreciated.

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Appendix C. U.S. EPA Statement of Basis Guidance

Page 51 of 59

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Table of SOB guidance

Elements

Region 9's Febuary 19,
1999 letter to SLOC
APCD

NOD to Texas' part 70
Program (January 7,
2002)

Region 5 letter to state of
Ohio (December 20, 2001)

Los Medanos
Petition Order
(May 24, 2004)

Bay Area Refinery
Petition Orders
(March 15, 2005)

EPA's August 1,

2005 letter
regarding Exxon
Mobil proposed
permit

Petition No. V-2005-
1 (February 1, 2006)
(Onyx Order)

EPA's April 30, 2014
Memorandum:
Implementation Guidance on
ACC Reporting and SOB
Requiremetns for Title V
Operating Permits

New Equipment

Additions of permitted
equipment which were not
included in the application









V





Insignificant
Activities and
portable equipment

Identification of any applicable
requirements for insignificant
activities or State-registered
portable equipment that have
not previously been identified at
the Title V facility









V





Streamlining

Multiple applicable
requirements streamlining
demonstrations



Streamlining requirements

Streamlining analysis



V





Permit Shields

Permit shields

The basis for applying the
permit shield

V

Discussion of permit
shields

Basis for permit shield
decisions

V





Alternative
Operating Scenarios
and Operational
Flexibility

Alternative operating scenarios

A discussion of any
operational flexibility that
will be utilized at the facility.

V





V





Compliance
Schedules

Compliance Schedules







Must discuss need for
compliance schedule
for multiple NOVs,
particularly any
unresolved/outstanding
NOVs

Must discuss need for
compliance schedule for
any outstanding NOVs





CAM

CAM requirements









V





PALs

Plant wide allowable emission
limits (PAL) or other voluntary
limits









V





Previous Permits

Any district permits to operate
or authority to construct permits



Explanation of any conditions
from previously issued permits
that are not being transferred to
the title V permit

A basis for the
exclusion of certain
NSR and PSD
conditions contained in
underlying ATC permits



V





Periodic Monitoring
Decisions

Periodic monitoring decisions,

where the decisions deviate
from already agreed upon levels

(eg. Monitoring decisions
agreed upon by the district and
EPA either through: the Title V
periodic monitoring workgroup;
or another Title V permit for a
similar source). These decisions

could be part of the permit
package or reside in a publicly
available document.

The rationale for the
monitoring method selected

A description of the monitoring
and operational restrictions
requirements

1) recordkeeping and
period monitoring that
is required under 40
CFR 70.6(a)(3)(i)(B) or
district regulation

2) Ensure that the
rationale for the
selected monitoring
method or lack of
monitoring is clearly
explained and
documented in the
permit record.

The SOB must include
a basis for its periodic
monitoring decisions
(adequacy of chosen

monitoring or
justification for not
requiring periodic
monitoring)

The SOB must include a
basis for its periodic
monitoring decisions.

Any emissions factors,
exhaust characteristics, or

other assumptions or
inputs used to justify no
periodic monitoring is
required, should be
included in SOB



V

Facility Description



A description of the facility

V





V





Applicability
Determinations and
Exemptions



Any federal regulatory
applicability determinations

Applicability and exemptions

1) Applicability
determinations for
source specific
applicable requirements

2) Origin or factual
basis for each permit
condition or exemption

SOB must discuss the
Applicability of various
NSPS, NESHAP and
local SIP requirements
and include the basis
for all exemptions

SOB must discuss the
Applicability of various
NSPS, NESHAP and
local SIP requirements
and include the basis for
all exemptions



V

General
Requirements





Certain factual information as
necessary

Generally the SOB
should provide "a

record of the
applicability and
technical issues
surrounding the
issuance of the permit."



V

V

V

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901

February 19, 1999

Mr. David Dixon

Chairperson, Title V Subcommittee
San Luis Obispo County
Air Pollution Control District
3433 Roberto Court
San Luis Obispo, CA 93401

Dear Mr. Dixon:

I am writing to provide a final version of our response to your July 2, 1998 letter in which
you expressed concern about Region IX's understanding of the Subcommittee's tentative
resolution to the 45-day EPA review period issue. I have also included a summary of the
Subcommittee's agreement on two title V implementation issues originally raised by some
Subcommittee members at our meeting on August 18, 1998. Our response reflects many
comments and suggestions we have received during the past several months from members of the
Title V Subcommittee and EPA's Office of General Counsel. In particular, previous drafts of
this letter and the enclosure have been discussed at Subcommittee meetings on October 1, 1998,
November 5, 1998, January 14, 1999, and February 17, 1999. Today's final version incorporates
suggested changes as discussed at these meetings and is separated into two parts: Part I is
"guidance" on what constitutes a complete Title V permit submittal; and Part II is a five-point
process on how to better coordinate information exchange during and after the 45-day EPA
review period.

We will address the letter to David Howekamp from Peter Venturini dated August 7,
1998 regarding permits issued pursuant to NSR rules that will not be SIP approved in the near
future. This issue was also discussed at the August 18 Title V Subcommittee meeting.

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I appreciate your raising the issues regarding the 45-day EPA review clock to my
attention. Your efforts, along with the efforts of other Title V Subcommittee members, have
been invaluable towards resolving this and other Title V implementation issues addressed in this
letter. The information in the enclosure will clarify Title V permitting expectations between
Region IX and the California Districts and will improve coordination of Title V permit
information. It is important to implement this immediately, where necessary, so the benefits of
this important program can be fully realized as soon as possible in the state of Cali fornia as well
as other states across the country.

If you have any questions please do not hesitate to call me at (415) 744-1254.

Enclosure

cc: California Title V Contacts

California Air Pollution Control Officers
Ray Menebroker, CARB
Peter Venturini, CARB

Sincerely,

Matt Haber
Chief, Permits Office

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Enclosure

Neither the guidance in Part I nor the process in Part II replace or alter any requirements
contained in Title V of the Clean Air Act or 40 CFR Part 70.

PART I. Guidance on Information Necessary to Begin 45-day EPA Review

A complete submittal to EPA for a proposed permit consists of the application (if one has not
already been sent to EPA), the proposed permit, and a statement of basis. If applicable to the
Title V facility (and not already included in the application or proposed permit) the statement of
basis should include the following:

additions of permitted equipment which were not included in the application;

•	identification of any applicable requirements for insignificant activities or State-registered portable
equipment that have not previously been identified at the Title V facility,

•	outdated SIP requirement streamlining demonstrations,

•	multiple applicable requirements streamlining demonstrations,
permit shields,

•	alternative operating scenarios,

•	compliance schedules,

•	CAM requirements,

•	plant wide allowable emission limits (PAL) or other voluntary limits,

•	any district permits to operate or authority to construct permits;

periodic monitoring decisions, where the decisions deviate from already agreed-upon levels (e.g.,
monitoring decisions agreed upon by the district and EPA either through: the Title V periodic monitoring
workgroup; or another Title V permit for a similar source). These decisions could be part of the permit
package or could reside in a publicly available document.

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Part II-Title V Process

The following five-point process serves to clarify expectations for reviewing Title V permits and
coordinating information on Title V permits between EPA Region IX ("EPA") and Air Pollution
Districts in California ("District"). Districts electing to follow this process can expect the
following. Districts may, at their discretion, make separate arrangements with Region IX to
implement their specific Title V permit reviews differently.

Point 1: The 45-day clock will start one day after EPA receives all necessary information to
adequately review the title V permit to allow for internal distribution of the documents. Districts
may use return receipt mail, courier services, Lotus Notes, or any other means they wish to
transmit a package and obtain third party assurance that EPA received it. If a District would like
written notice from EPA of when EPA received the proposed title V permit, the District should
notify EPA of this desire in writing. After receiving the request, Region IX will provide written
response acknowledging receipt of permits as follows;

(Date)

Dear (APCO):

We have received your proposed Title V permit for (Source Name') on (Date')
If, after 45-days from the date indicated above, you or anyone in your office has not heard from
us regarding this permit, you may assume our 45-day review period is over.

Sincerely,

Matt Haber
Chief, Permits Office

Point 2: After EPA receives the proposed permit, the permit application, and all necessary
supporting information, the 45-day clock may not be stopped or paused by either a District or
EPA, except when EPA approves or objects to the issuance of a permit.

Point 3: The Districts recognize that EPA may need additional information to complete its title V
permit review. If a specific question arises, the District involved will respond as best it can by
providing additional background information, access to background records, or a copy of the
specific document.

The EPA will act expeditiously to identify, request and review additional information and the
districts will act expeditiously to provide additional information. If EPA determines there is a

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basis for objection, including the absence of information necessary to review adequately the
proposed permit, EPA may object to the issuance of the permit. If EPA determines that it needs
more information to reach a decision, it may allow the permit to issue and reopen the permit after
the information has been received and reviewed.

Point 4: When EPA objects to a permit, the Subcommittee requested that the objection letter
identify why we objected to a permit, the legal basis for the objection, and a proposal suggesting
how to correct the permit to resolve the objection.

It has always been our intent to meet this request. In the future, when commenting on, or
objecting to Title V permits, our letters will identify recommended improvements to correct the
permit. For objection letters, EPA will identify why we objected to a permit, the legal basis for
the objection, and details about how to correct the permit to resolve the objection. Part 70 states
that "Any EPA objection... shall include a statement of the Administrator's reasons for objection
and a description of the terms and conditions that the permit must include to respond to the
objections."

Point 5: When EPA objects to a permit, and a District has provided information with the intent to
correct the objection issues, the Subcommittee members requested a letter from EPA at the end
of the 90-day period stating whether the information provided by the District has satisfied the
objection.

While we agree with the Districts' desire for clear, written communication from EPA, a written
response will not always be possible by the 90th day because the regulations allow a District 90
days to provide information. To allow EPA ample time to evaluate submitted information to
determine whether the objection issues have been satisfied, we propose establishing a clear
protocol. The following protocol was agreed to by members of the Subcommittee:

1.	within 60 days of an EPA objection, the District should revise and submit a
proposed permit in response to the objection;

2.	within 30 days after receipt of revised permit, EPA should evaluate information
and provide written response to the District stating whether the information
provided by the District has satisfied the objection.

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December 20, 2001

CAR-18 J)

Robert F. Hodanbosi, Chief
Division of Air Pollution Control
Ohio Environmental Protection Agency
122 South Front Street
P. 0. Box 1049
Columbus, Ohio 43266-1049

Dear Mr. Hodanbosi:

I am writing this letter to provide guidelines on the content of an adequate
statement of basis (SB) as we committed to do in our November 21, 2001,
letter. The regulatory basis for a SB is found in 40 C.F.R. § 70.7(a)(5) and
Ohio Administrative Code (QAC) 3745-77-08 (A) (2) which requires that each draft
permit must be accompanied by "a statement that sets forth the legal and
factual basis for the draft permit conditions." The May 10, 1991, preamble
also suggests the importance of supplementary materials.

" [United States Environmental Protection Agency (USEPA)]...can obj ect to
the issuance of a permit where the materials submitted by the State
permitting authority to EPA do not provide enough information to allow a
meaningful EPA review of whether the proposed permit is in compliance
with the requirements of the Act." (56 FR 21750)

The regulatory language is clear in that a SB must include a discussion of
decision-making that went into the development of the Title V permit and to
provide the permitting authority, the public, and the USEPA a record of the
applicability and technical issues surrounding issuance of the permit. The SB
is part of the historical permitting record for the permittee. A SB generally
should include, but not be limited to, a description of the facility to be
permitted, a discussion of any operational flexibility that will be utilized,
the basis for applying a permit shield, any regulatory applicability
determinations, and the rationale for the monitoring methods selected. A SB
should specifically reference all supporting materials relied upon, including
the applicable statutory or regulatory provision.

While not an exhaustive list of what should be in a SB, below are several
important areas where the Ohio Environmental Protection Agency's (OEPA) SB
could be improved to better meet the intent of Part 70.

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- 2 -

Discussion of the Monitoring and Operational Requiranents

OEPA's SB must contain a discussion on the monitoring and operational
restriction provisions that are included for each emission unit. 40 C.F.R.
§70.6 (a) and QAC 3745-77-07 (A) require that monitoring and operational
requirements and limitations be included in the permit to assure compliance
with all applicable requirements at the time of permit issuance. OEPA's
selection of the specific monitoring, including parametric monitoring and
recordkeeping, and operational requirements must be explained in the SB. For
example, if the permitted compliance method for a grain-loading standard is
maintaining the baghouse pressure drop within a specific range, the SB must
contain sufficient information to support the conclusion that maintaining the
pressure drop within the permitted range demonstrates compliance with the
grain-loading standard.

The USEPA Administrator's decision in response to the Fort James Camas Mill
Title V petition further supports this position. The decision is available on
the web at

http://www.epa.gov/regionO7/programs/artd/air/title5/petitiondb/petitions/fort
_james_decisionl999.pdf. The Administrator stated that the rationale for the
selected monitoring method must be clear and documented in the permit record.

Discussion of Applicability and Exemptions

The SB should include a discussion of any complex applicability determinations
and address any non-applicability determinations. This discussion could
include a reference to a determination letter that is relevant or pertains to
the source. If no separate determination letter was issued, the SB should
include a detailed analysis of the relevant statutory and regulatory
provisions and why the requirement may or may not be applicable. At a
minimum, the SB should provide sufficient information for the reader to
understand OEPA's conclusion about the applicability of the source to a
specific rule. Similarly, the SB should discuss the purpose of any limits on
potential to emit that are created in the Title V permit and the basis for
exemptions from requirements, such as exemptions from the opacity standard
granted to emissions units under QAC rule 3745-17-07 (A) . If the permit shield
is granted for such an exemption or non-applicability determination, the
permit shield must also provide the determination or summary of the
determination. See CAA Section 504(f) (2) and 70.6(f) (1) (ii) .

Explanation of any conditions frcm previously issued permits that are not
being transferred to the Title V permit

In the course of developing a Title V permit, OEPA may decide that an
applicable requirement no longer applies to a facility or otherwise not
federally enforceable and, therefore, not necessary in the Title V permit in
accordance with USEPA's "White Paper for Streamlined Development of the Part
70 Permit Applications" (July 10, 1995). The SB should include the rationale
for such a determination and reference any supporting materials relied upon in
the determination.

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- 3 -

I will also note that for situations that not addressed in the July 10, 1995,
White Paper, applicable New Source Review requirements can not be dropped from
the Title V permit without first revising the permit to install.

Discussion of Streamlining Requiranents

The SB should include a discussion of streamlining determinations. When
applicable requirements overlap or conflict, the permitting authority may
choose to include in the permit the requirement that is determined to be most
stringent or protective as detailed in USEPA's "White Paper Number 2 for
Improved Implementation of the Part 70 Operating Permits Program" (March 5,
1996) . The SB should explain why OEPA concluded that compliance with the
streamlined permit condition assures compliance with all the overlapping
requirements.

Other factual information

The SB should also include factual information that is important for the
public to be aware of. Examples include:

1.	A listing of any Title V permits issued to the same applicant at
the plant site, if any. In some cases it may be important to
include the rationale for determining that sources are support
facilities.

2.	Attainment status.

3.	Construction and permitting history of the source.

4.	Compliance history including inspections, any violations noted, a
listing of consent decrees into which the permittee has entered
and corrective action(s) taken to address noncompliance.

I do understand the burden that the increased attention to the SB will cause
especially during this time when OEPA has been working so hard to complete the
first round of Title V permit issuance. I do hope that you will agree with me
that including the information listed above in OEPA's SB will only improve the
Title V process. If you would like examples of other permitting authorities'
SB, please contact us. We would be happy to provide you with some. I would
also mention here that this additional information should easily fit in the
format OEPA currently uses for its SB. We look forward to continued
cooperation between our offices on this issue. If you have any questions,
please contact Genevieve Damico, of my staff, at (312) 353-4761.

Sincerely yours,

/s/

Stephen Rothblatt, Chief
Air Programs Branch

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BEFORE THE ADMINISTRATOR
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

IN THE MATTER OF
LOS MEDANOS ENERGY
CENTER

PETITION NO.

ORDER RESPONDING TO
PETITIONERS REQUEST THAT THE
ADMINISTRATOR OBJECT TO
ISSUANCE OF A STATE OPERATING
PERMIT

MAJOR FACILITY REVIEW
PERMIT No. B1866,

Issued by the Bay Area Air

Quality Management District

ORDER DENYING IN PART AND GRANTING IN PART PETITION FOR OBJECTION

TO PERMIT

On September 6, 2001, the Bay Area Air Quality Management District, ("BAAQMD" or
"District") issued a Major Facility Review Permit to Los Medanos Energy Center, Pittsburg,
California ("Los Medanos Permit" or "Permit"), pursuant to title V of the Clean Air Act ("CAA"
or "the Act"), 42 U.S.C. §§ 7661-766If, CAA §§ 501-507. On October 12, 2001, the
Environmental Protection Agency ("EPA") received a petition from Our Children's Earth
Foundation ("OCE") and Californians for Renewable Energy, Inc., ("CARE") (collectively, the
"Petitioners") requesting that the EPA Administrator object to the issuance of the Los Medanos
Permit pursuant to Section 505(b)(2) of the Act, the federal implementing regulations found at 40
CFR Part 70.8, and the District's Regulation 2-6-411.3 ("Petition").

The Petitioners allege that the Los Medanos Permit (1) improperly includes an emergency
breakdown exemption condition that incorporates a broader definition of "emergency" than
allowed by 40 CFR § 70.6(g); (2) improperly includes a variance relief condition which is not
federally enforceable; (3) fails to include a statement of basis as required by 40 CFR § 70.7(a)(5);
(4) contains permit conditions that are inadequate under 40 CFR Part 70, namely that certain
provisions are unenforceable; and (5) fails to incorporate certain changes OCE requested during
the public comment period and agreed to by BAAQMD.

EPA has now fully reviewed the Petitioners' allegations. In considering the allegations,
EPA performed an independent and in-depth review of the Los Medanos Permit; the supporting
documentation for the Los Medanos Permit; information provided by the Petitioners in the
Petition and in a letter dated November 21, 2001; information gathered from the Petitioners in a
November 8, 2001 meeting; and information gathered from the District in meetings held on
October 31, 2001, December 5, 2001, and February 7, 2002. Based on this review, I grant in part
and deny in part the Petitioners' request that I "object to the issuance of the Title V Operating
Permit for the Los Medanos Energy Center," and hereby order the District to reopen the Permit

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for the reasons described below.

I. STATUTORY AND REGULATORY FRAMEWORK

Section 502(d)(1) of the Act calls upon each State to develop and submit to EPA an
operating permit program to meet the requirements of title V. In 1995, EPA granted interim
approval to the title V operating permit program submitted by BAAQMD. 60 Fed. Reg. 32606
(June 23, 1995); 40 CFR Part 70, Appendix A. Effective November 30, 2001, EPA granted full
approval to BAAQMD's title V operating permit program. 66 Fed. Reg. 63503 (December 7,
2001).

Major stationary sources of air pollution and other sources covered by title V are required
to apply for an operating permit that includes applicable emission limitations and such other
conditions as are necessary to assure compliance with applicable requirements of the Act. See
CAA §§ 502(a) and 504(a). The title V operating permit program does not generally impose new
substantive air quality control requirements (which are referred to as "applicable requirements"),
but does require permits to contain monitoring, recordkeeping, reporting, and other conditions to
assure compliance by sources with existing applicable requirements. 57 Fed. Reg. 32250, 32251
(July 21, 1992). One purpose of the title V program is to enable the source, EPA, permitting
authorities, and 1he public to better understand the applicable requirements to which the source is
subject and whether the source is meeting those requirements. Thus, the title V operating
permits program is a vehicle for ensuring that existing air quality control requirements are
appropriately applied to facility emission units and that compliance with these requirements is
assured.

Under § 505(a) of the Act and 40 CFR § 70.8(a), permitting authorities are required to
submit all operating permits proposed pursuant to title V to EPA for review. If EPA determines
that a permit is not in compliance with applicable requirements or the requirements of 40 CFR
Part 70, EPA will object to the permit. If EPA does not object to a permit on its own initiative,
section 505(b)(2) of the Act and 40 CFR § 70.8(d) provide that any person may petition the
Administrator, within 60 days of the expiration of EPA's 45-day review period, to object to the
permit. To justify the exercise of an objection by EPA to a title V permit pursuant to section
505(b)(2), a petitioner must demonstrate that the permit is not in compliance with the
requirements of the Act, including the requirements of Part 70. Part 70 requires that a petition
must be "based only on obj ections to the permit that were raised with reasonable specificity
during the public comment period. . ., unless the petitioner demonstrates that it was impracticable
to raise such objections within such period, or unless the grounds for such objection arose after
such period." 40 CFR § 70.8(d). A petition for administrative review does not stay the
effectiveness of the permit or its requirements if the permit was issued after the expiration of
EPA's 45-day review period and before receipt of the objection. If EPA objects to a permit in
response to a petition and the permit has been issued, the permitting authority or EPA will
modify, terminate, or revoke and reissue such a permit using the procedures in 40 CFR §§
70.7(g)(4) or (5)(i) and (ii) for reopening a permit for cause.

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II. BACKGROUND

The Los Medanos Energy Center facility ("Facility"), formerly owned by Enron
Corporation under the name Pittsburg District Energy Facility, is a natural gas-fired power plant
presently owned and operated by Calpine Corporation. The plant, with a nominal electrical
capacity of 555-megawatts ("MW"), is located in Pittsburg, California. The Facility received its
final determination of compliance ("FDOC")1 from the District in June, 1999, and its license to
construct and operate from the California Energy Commission ("CEC")2 on August 17, 1999.
The Facility operates two large natural gas combustion turbines with associated heat recovery
steam generators ("HRSG"), and one auxiliary boiler. The Facility obtained a revised authority
to construct ("ATC")3 permit from the District in March, 2001 to increase heat input ratings of
the two HRSGs and the auxiliary boiler,4 and to add a fire pump diesel engine and a natural gas-
fired emergency generator. The Facility began commercial operation in July, 2001. The Facility
emits nitrogen oxide ("NOx"), carbon monoxide ("CO"), and particulate matter ("PM"), all of
which are regulated under the District's federally approved or delegated nonattainment new
source review ("NSR") and prevention of significant deterioration ("PSD") programs5 or other
District Clean Air Act programs.

On June 28, 2001, the District completed its evaluation of the title V application for the
Facility and issued the draft title V Permit. Under the District's rules, this action started a
simultaneous 30-day public comment period and a 45-day EPA review period. On August 1,
2001, Mr. Kenneth Kloc of the Environmental Law and Justice Clinic submitted comments to the

'An FDOC describes how a proposed facility will comply with applicable federal, state, and BAAQMD
regulations, including control technology and emission offset requirements of New Source Review. Permit
conditions necessary to insure compliance with applicable regulations are also included.

The FDOC served as an evaluation report for both the CEC 's certificate and the District's authority to
construct ("ATC") permit. The initial ATC was issued by the District shortly after the FDOC under District
application #18595.

ATC permits are federally enforceable pre-construction permits tiat reflect the requirements of the
attainment area prevention of significant deterioration and nonattainment area new source review ("NSR") programs.
The District's NSR requirements are described in Regulation 2, Rule 2. New power plants locating in California
subject to the CEC certification requirements must also comply with Regulation 2, Rule 3, titled Power Plants.
Regulation 2-3-405 requires the District to issue an ATC for a subject facility only after the CEC issues its certificate
for the facility.

4The increased heat input allowed the facility to increase its electrical generating capacity from 520 MW to
555 MW.

5The District was implementing the federal PSD program under a delegation agreement with EPA dated
October 28, 1997. The non-attainment NSR program was most recently SIP-approved by EPA on January 26, 1999.
64 Fed. Re£. 3850.

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District on the draft Los Medanos Permit on behalf of OCE ("OCE's Comment Letter").6 The
District responded to OCE's Comment Letter by a letter dated September 4, 2001, from William
de Boisblanc ("Response to Comments"). EPA Region IX did not object to the proposed permit
during its 45-day review period. The Petition to Object to the Permit, filed by OCE and CARE
and dated October 9, 2001, was received by Region IX on October 12, 2001. EPA calculates the
period for the public to petition the Administrator to object to a permit as if the 30-day public
comment and 45-day EPA review periods run sequentially, accordingly petitioners have 135 days
after the issuance of a draft permit to submit a petition.7 Given that the Petition was filed with
EPA on October 12,2001,1 find that it was timely filed. I also find that the Petition is
appropriately based on objections that were raised with reasonable specificity during the
comment period or that arose after the public comment period expired.8

III. ISSUES RAISED BY I II I PETITIONERS

A. District Breakdown Relief Under Permit Condition I.H. 1

Petitioners' first allegation challenges the inclusion in the Los Medanos Permit of
Condition I.H.I, a provision which incorporates SIP rules allowing a permitted facility to seek
relief from enforcement by the District in the event of a breakdown. Petition at 3. Petitioners
assert that the definition of "breakdown" at Regulation 1-208 would allow relief in situations
beyond those allowed under the Clean Air Act. Specifically, Petitioners allege that the
"definition of 'breakdown' in Regulation 1-208 is much broader than the federal definition of
breakdown, which is provided in 40 CFR Part 70," or more precisely, at 40 CFR § 70.6(g).

Condition I.H.I incorporates District Regulations 1-208, 1-431, 1-432, and 1-433
(collectively the "Breakdown Relief Regulations") into the Permit. Regulation 1-208 defines
breakdown, and Regulations 1-431 through 1-433 describe how an applicant is to notify the
District of a breakdown, how the District is to determine whether the circumstances meet the
definition of a breakdown, and what sort of relief to grant the permittee. To start our analysis, it

6We note that OCE submitted its comments to the District days after the close of the public comment period
established pursuant to the District's Regulation 2-6-412 and 40 CFR § 70.7(h)(4). Though we are responding to the
Petition despite this possible procedural flaw, we reserve our right to raise this issue in any future proceeding.

This 135-day period to petition the Administrator is based on a 30-day District public notice and comment
period, a 45-day EPA review period and the 60-day period for a person to file apetition to objectwithEPA.

8In its Comment Letter, OCE generally raised concerns with the draft Major Facility Review Permit that are
the basis for the Petition. In regard to whether all issues were raised with 'reasonable specificity,'I find that claims
one through four of the Petition were raised adequately in OCE's Comment Letter. The fifth claim, that the District
did not live up to its commitment to make changes to the Permit, can be raised in the Petition since tie grounds for
the claim arose after the public comment period ended. See 40 CFR § 70.8(d). Finally, CARE's non-participation in
the District's notice-and-comment process does not prevent the organization from filing a title V petition because the
regulations allow "any person" to file a petition based on earlier objections raised during the public comment period
regardless of who had filed those earlier comments. See CAA § 505(b)(2); 40 CFR § 70.8(d)

4

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is important to understand the impact of granting relief under the Breakdown Relief Regulations.
Neither Condition I.H.I, nor the SIP provisions it incorporates into the Permit, would allow for
an exemption from an applicable requirement for periods of excess emissions. An "exemption
from an applicable requirement" would mean that the permittee would be deemed not to be in
violation of the requirement during the period of excess emissions. Rather, these Breakdown
Relief Regulations allow an applicant to enter into a proceeding in front of the District that could
ultimately lead to the District employing its enforcement discretion not to seek penalties for
violations of an applicable requirement that occurred during breakdown periods.

Significantly, the Breakdown Relief Regulations have been approved by EPA as part of
the District's federally enforceable SP. 64 Fed. Reg. 34558 (June 28, 1999) (this is the most
recent approval of the District's Regulation 1). Part 70 requires all SIP provisions that apply to a
source to be included in title V permits as "applicable requirements." See In re Pacificorp's Jim
Bridger and Naughton Electric Utility Steam Generating Plants. Petition No. VIII-00-1, at 23-24
("Pacificorp"). On this basis alone, the inclusion of the Breakdown Relief Regulations in the
permit is not objectionable.9

Moreover, Petitioners' allegation that Condition 1.H.1 is inconsistent with 40 CFR §
70.6(g) does not provide a basis for an objection. 40 CFR § 70.6(g) allows a permitting authority
to incorporate into its title V permit program an affirmative defense provision for "emergency"
situations as long as the provision is consistent with the 40 CFR § 70.6(g)(3) elements. Such an
emergency defense then maybe incorporated into permits issued pursuant to that program. As
explained above, these regulations provide relief based on the District's enforcement discretion
and do not provide an affirmative defense to enforcement. Moreover, to the extent the
emergency defense is incorporated into a permit, 40 CFR § 70.6(g)(5) makes clear that the Part
70 affirmative defense type of relief for emergency situations "is in addition to any emergency or
upset provision contained in any applicable requirement." This language clarifies that the Part 70
regulations do not bar the inclusion of applicable SF requirements in title V permits, even if
those applicable requirements contain "emergency" or "upset" provisions such as Condition
l.H.l that may overlap with the emergency defense provision authorized by 40 CFR § 70.6(g).

Also, a review of the Breakdown Relief Regulations themselves demonstrates that they
are not inconsistent with the Clean Air Act, and therefore, not contrary to the Act. A September
28, 1982, EPA policy memorandum from Kathleen Bennet, titled Policy on Excess Emissions
During Startup. Shutdown. Maintenance, and Malfunctions ("1982 Excess Emission Policy"),
explains that "all periods of excess emissions [are] violations of the applicable standard."
Accordingly, the 1982 Excess Emission Policy provides that EPA will not approve automatic
exemptions in operating permits or SFs. However, the 1982 Excess Emission Policy also

9This holds true even if the Petitioner could support an allegation thatEPA had erroneously incorporated
the provisio ns into the SIP. See Pacificorp at 23 ("even if the provision were found not to satisfy the Ac t, EPA co uld
not properly objectto a permit term that is derived from a provision of the federally approved SIP"). However, as
explained below, EPA believes that these provisions were appropriately approved as part of the District's SIP.

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explains that EPA can approve, as part of a SIP, provisions that codify an "enforcement
discretion approach." The Agency further refined its position on this topic in a September 20,
1999 policy memorandum from Steven A. Herman and Robert Perciasepe, titled State
Implementation Plans: Policy Regarding Excess Emissions During Malfunctions. Startup, and
Shutdown ("1999 Excess Emission Policy").10 The 1999 Excess Emission Policy explained that
a permitting authority may express its enforcement discretion through appropriate affirmative
defense provisions approved into the SIP as long as the affirmative defense applies only to civil
penalties (and not injunctive relief) and meets certain criteria. As previously explained, the
Breakdown Relief Regulations approved into the District's SIP provide neither an affirmative
defense to an enforcement action nor an automatic exemption from applicable requirements, but
rather serve as a mechanism for the District to use its enforcement discretion. Therefore, I find
that the provision is not inconsistent with the Act.

Finally, Petitioners allege that the inclusion of Condition I.H.I "creates unnecessary
confusion and unwarranted potential defense to federal civil enforcement." Inclusion of
Condition I.H.3 in the Los Medanos Permit clarifies Condition I.H. 1 by stating that "[t]he
granting by the District of breakdown relief. . . will not provide relief from federal enforcement."
Contrary to Petitioners' allegation, we find that addition of this language successfully dispels any
ambiguity as to the impact of the provision, especially as it relates to federal enforceability, and
therefore clears up "confusion" and limits "unwarranted defenses." Forthe reasons stated above,
I deny the Petition as it relates to Condition I.H. 1 and the incorporation of the Breakdown Relief
Regulations into the Permit.

B. Hearing Board Variance Relief Under Permit Condition I.H.2

The Petitioners' second allegation challenges the inclusion in the Los Medanos Permit of
Condition I.H.2, which states that a "permit holder may seek relief from enforcement action for a
violation of any of the terms and conditions of this permit by applying to the District's Hearing
Board for a variance pursuant to Health and Safety Code Section 42350. . . ." Petition at 3.
Petitioners make a number of arguments in support of their claim that the reference to
California's Variance Law in the Los Medanos Permit serves as a basis for an objection; none of
these allegations, however, serves as an adequate basis for EPA to object to the Permit.

Health and Safety Code ("HSC") sections 42350 et seq. ("California's Variance Law")
allow a permittee to request an air district hearing board to issue a variance to allow the permittee
to operate in violation of an applicable district rule, or State rule or regulation for a limited time.
Section 42352(a) prohibits the issuance of a variance unless the hearing board makes specific

10 On December 5 , 2001, EPA issued a brief clarification of this policy. Re-Issuance of Clarification - State
Implementation Plans (SIPs); Policy Regarding Excess Emissions During Malfunction, Startup, and Shutdown.

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findings.11 Section 42352(a)(2) limits the availability of variances to situations involving non-
compliance with "any rule, regulation, or order of the district." As part of the variance process,
the hearing board may set a "schedule of increments of progress," to establish milestones and
final deadlines for achieving compliance. See, e.g.. HSC § 42358. EPA has not approved
California's Variance Law into the SIP or Title V program of any air district. See, e.g.. 59 Fed.
Reg. 60939 (Nov. 29, 1994) (proposing to approve BAAQMD's title V program without
California's Variance Law); 60 Fed. Reg. 32606 (June 23, 1995) (granting final interim approval
to BAAQMD's title V program).

Petitioners argue that the "variance relief issued by BAAQMD under state law does not
qualify as emergency breakdown relief authorized by the Title V provisions . . . ." Petition at 4.
As with the Breakdown Relief Regulations, Petitioners' true concern appears to be that Condition
I.H.2 and California's Variance Law are inconsistent with 40 CFR § 70.6(g), which allows for
the incorporation of an affirmative defense provision into a federally approved title V program,
and thus into title V permits. Condition I.H.2 and California's Variance Law, however, do not
need to be consistent with 40 CFR § 70.6(g) because these provisions merely express an aspect
of the District's discretionary enforcement authority under State law rather than incorporate a
Part 70 affirmative defense provision into the Permit.12 As described above, the discretionary

11	HSC section 423 52(a) provides as follows:

No variance shall be granted unless the hearing board makes all of the following findings:

(1)	That the petitioner for a variance is, or will be, inviolation of Section 41701 or of any rule,
regulation, or order of the district.

(2)	That, due to conditions beyond the reasonable control of the petitioner, requiring compliance
would result in either (A) an arbitrary or unreasonable taking of property, or (B) the practical
closing and elimination of a lawful business. In making tho se findings where the petitioner is a
public agency, the hearing board shall consider whether or not requiring immediate compliance
would impose an unreasonable burden upon an essential public service. For purposes of this
paragraph, "essential public service" means a prison, detention facility, police or firefighting
facility, school, health care facility, landfill gas control or processing facility, sewage treatment
works, or water delivery operation, if owned and operated by a public agency.

(3)	That the closing or taking would be without a corresponding benefit in reducing air
contaminants.

(4)	That the applicant for the variance has given consideration to curtailing operations of the
source in lieu of obtaining a variance.

(5)	During the period the variance is in effect, that the applicant will reduce excess emissions to the
maximum extent feasible.

(6)	During the period the variance is in effect, that the applicant will monitor or otherwise quantify
emission levels from the source, if requested to do so by the district, and report these

emission levels to the district pursuant to a schedule established by the district.

12

Government agencies have discretion to not seek penalties or injunctive relief against a noncomplying
source. California's Variance Law recognizes this inherent discretion by codifying the process by which a source
may seek relief through the issuance of a variance. The ultimate decision to grant a variance, however, is still wholly
discretionary, as evidenced by the findings the hearing board must make in order to issue a variance. See HSC
section 42352(a)(l)-(6).

7

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nature of California's Variance Law is evidenced by the findings set forth in HSC §42538(a) that
a hearing board must make before it can issue a variance.13 Inherent within the process of
making these findings is the hearing board's ability to exercise its discretion to evaluate and
consider the evidence and circumstances underlying the variance application and to reject or
grant, as appropriate, that application. Moreover, the District clearly states in Condition I.H.3.
that the granting by the District of a variance does not "provide relief from federal enforcement,"
which includes enforcement by both EPA and citizens.14 As Condition I.H.2. refers to a
discretionary authority under state law that does not affect the federal enforceability of any
applicable requirement, I do not find its inclusion in the Los Medanos Permit objectionable.

Petitioners also argue that the "variance program is a creature of state law," and therefore
should not be included in the Los Medanos Permit. Petitioners' complaint is obviously without
merit since Part 70 clearly allows for inclusion of state- and local-only requirements in title V
permits as long as they are adequately identified as having only state- or local-only significance.
40 CFR § 70.6(b)(2). For this reason, I find that Petitioners' allegation does not provide a basis
to object to the Los Medanos Permit.

Petitioners further argue that California's Variance Law allows a revision to the approved
SIP in violation of the Act. Petitioners misunderstand the provision. The SIP is comprised of the
State or di strict rules and regulations approved by EPA as meeting CAA requirements. SIP
requirements cannot be modified by an action of the State or District granting a temporary
variance. EPA has long held the view that a variance does not change the underlying SIP
requirements unless and until it is submitted to and approved by EPA for incorporation into the
SIP. For example, since 1976, EPA's regulations have specifically stated: "In order for a
variance to be considered for approval as a revision to the State implementation plan, the State
must submit it in accordance with the requirements of this section." 40 CFR §51.104(d); 41 Fed.
Reg. 18510, 18511 (May 5, 1976).

The fact that the California Variance Law does not allow a revision to the approved SIP is
further evidenced by the law itself. By its very terms, California's Variance Law is limited in
application to "any rule, regulation, or order of the district." HSC § 42352(a)(2) (emphasis
supplied); therefore, the law clearly does not purport to modify the federally approved SIP. In
addition, California's view of the law's effect is consistent with EPA's. For instance, guidance

Because of its discretionary nature, California's Variance Law does not impose a legal impediment to the
District's ability to enforce its SIP or title V program. EPA cannot prohibit the District's use of the variance process
as a means for sources to avoid enforcement of permit conditions by tie District unless the misuse of the variance
process results in the District's failure to adequately implement or enforce its title V program, or its other federally
delegated or approved CAA programs. Petitioners have made no such allegation.

14Other BAAQMD information resources on variances also clearly set forth the legal significance of
variances. For example, the application for a variance on BAAQMD's website stales that EPA "does not recognize
California's variance process" and that "EPA can independently pursue legal action based on federal law against the
facility continuing to be in violation."

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issued in 1989 by the California Air Resources Board ("CARB"), the State agency responsible
for preparation of California's SIP, titled Variances and Other Hearing Board Orders as SIP
Revisions or Delayed Compliance Orders Under Federal Law, demonstrates that the State's
position with respect to the federal enforceability and legal consequences of variances is
consistent with EPA's. For example, the guidance states:

State law authorizes hearing boards of air pollution control districts to issue
variances from district rules in appropriate instances. These variances insulate
sources from the imposed state law. However, where the rule in question is part
of the State Implementation Plan (SIP) as approved by the U.S. Environmental
Protection Agency (EPA), the variance does not by itself insulate the source from
penalties in actions brought by EPA to enforce the rule as part of the SIP. While
EPA can use enforcement discretion to informally insulate sources from federal
action, formal relief can only come through EPA approval of the local variance.

In 1993, the California Attorney General affirmed this position in a formal legal opinion
submitted to EPA as part of the title V program approval process, stating that "any variance
obtained by the source does not effect [sic] or modify permit terms or conditions . . . nor does it
preclude federal enforcement of permanent terms and conditions." In sum, both the federal and
State governments have long held the view that the issuance of a variance by a district hearing
board does not modify the SIP in any way. For this reason, I find that Petitioners' allegation does
not provide a basis to object to the Los Medanos Permit.

Finally, Petitioners raise concerns that the issuance of variances could "jeopardize
attainment and maintenance of ambient air quality standards" and that inclusion of the variance
provision in the Permit is highly confusing to the regulated community and public. As to the first
concern, Petitioners' allegation is too speculative to provide a basis for an objection to a title V
permit. Moreover, as previously stated, permittees that receive a variance remain subject to all
SIP and federal requirements, as well as federal enforcement for violation of those requirements.
As to Petitioners' final point, I find that including California's Variance Law in title V permits
may actually help clarify the regulatory scheme to the regulated community and the public.
California's Variance Law can be utilized by permittees seeking relief from District or State rules
regardless of whether the Variance Law is referenced in title V permits; therefore, reference to
the Variance Law with appropriate explanatory language as to its limited impact on federal
enforceability helps clarify the actual nature of the law to the regulated community. In short,
since title V permits are meant to contain all applicable federal, State, and local requirements,
with appropriate clarifying language explaining the function and applicability of each
requirement, the District may incorporate California's Variance Law into the Los Medanos
Permit and other title V permits. For reasons stated in this Section, I do not find grounds to
object to the Los Medanos Permit on this issue.

C. Statement of Basis

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Petitioners' third claim is that the Los Medanos Permit lacks a statement of basis, as
required by 40 CFR § 70.7(a)(5). Petition at 5. Petitioners assert that without a statement of
basis it is virtually impossible for the public to evaluate the periodic monitoring requirements (or
lack thereof). Id. They specifically identify the District's failure to include an explanation for its
deci sion not to require certain monitoring, including the lack of any monitoring for opacity,
filterable particulate, or PM limits. Petition at 6-7, n.2. Additionally, Petitioners contend that
BAAQMD fails to include any S02 monitoring for source S-2 (Heat Recovery Steam Generator).
Id.

Section 70.7(a)(5) of EPA's permit regulations states that "the permitting authority shall
provide a statement that sets forth the legal and factual basis for the draft permit conditions
(including references to the applicable statutory or regulatory provisions)." The statement of
basis is not part of the permit itself. It is a separate document which is to be sent to EPA and to
interested persons upon request.15 Id.

A statement of basis ought to contain a brief description of the origin or basis for each
permit condition or exemption. However, it is more than just a short form of the permit. It should
highlight elements that EPA and the public would find important to review. Rather than restating
the permit, it should list anything that deviates from a straight recitation of requirements. The
statement of basis should highlight items such as the permit shield, streamlined conditions, or
any monitoring that is required under 40 C.F.R. 70.6(a)(3)(i)(B) or District Regulation 2-6-503.
Thus, it should include a discussion of the decision-making that went into the development of the
title V permit and provide the permitting authority, the public, and EPA a record of the
applicability and technical issues surrounding the issuance of the permit.16 See e.g.. In Re Port

15Unlike permits, statements of basis are not enforceable, do not set limits and do not create obligations.

16EPA has provided guidance on the content of an adequate statement ofbasis in a letter dated December
20, 200 1, from Region V to the State of Ohio and in a N otice of Deficiency ("NOD") issued to the State of T exas.
(Region V letter to Ohio); 67 Fed.
Reg. 732 (January 7, 2002) (EPA NOD issued to Texas). These documents describe the following five key elements
of a statement ofbasis: (1) a description ofthe facility; (2) adiscussion of any operational flexibility that will be
utilized at the facility; (3) the basis for applying the permit shield; (4) any federal regulatory applicability
determinations; and (5 ) the rationale for the monitoring methods selected. Id. at 735. In addition, the Region V
letter further recommends the inclusion of the following topical discussions in a statement ofbasis: (1) monitoring
and operational restrictions requirements; (2) applicability and exemptions; (3) explanation of any conditions from
previously issued permits that are not being transferred to the title V permit; (4) streamlining requirements; and (5)
certain other factual information as necessary. In a letter dated February 19, 1999 to Mr. David Dixon, Chair of the
CAPCOA Title V Subcommittee, the EPA Region IX Air Division provided guidance to California permitting
authorities that should be considered when developing a statement ofbasis for purposes of EPA Region IX's review.
This guidance is consistent with the other guidance cited above. Each of the various guidance documents, including
the Texas NOD and the Region V and IX letters, provide generalized recommendations for developing an adequate
statement ofbasis rather than "hard and fast" rules on what to include in any given statement ofbasis. Taken as a
whole, these recommendations provide a good road map as to what should be included in a statement ofbasis
considering, for example, the technical complexity of the permit, the history of the facility, and any new provisions,
such as periodic monitoring conditions, that the permitting authority has drafted in conjunction with issuing the title

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Hudson Operation Georgia Pacific. Petition No. 6-03-01, at pages 37-40 (May 9, 2003)

("Georgia Pacific"); In Re Doe Run Company Buick Mill and Mine. Petition No. VII-1999-001,
at pages 24-25 (July 31, 2002) ("Doe Run"). Finally, in responding to a petition filed in regard to
the Fort James Camas Mill title V permit, EPA interpreted 40 CFR § 70.7(a)(5) to require that
the rationale for selected monitoring method be documented in the permit record. See In Re
Fort James Camas Mill. Petition No. X-1999-1, at page 8 (December 22, 2000) ("Ft. James"!

EPA's regulations state that the permitting authority must provide EPA with a statement
of basis. 40 CFR § 70.7(a)(5). The failure of a permitting authority to meet this procedural
requirement, however, does not necessarily demonstrate that 1he title V permit is substantively
flawed. In reviewing a petition to object to a title V permit because of an alleged failure of the
permitting authority to meet all procedural requirements in issuing the permit, EPA considers
whether the petitioner has demonstrated that the permitting authority's failure resulted in, or may
have resulted in, a deficiency in the content of the permit. See CAA § 505(b)(2) (objection
required "if the petitioner demonstrates . . . that the permit is not in compliance with the
requirements of this Act, including the requirements of the applicable [SIP]"); see also. 40 CFR §
70.8(c)(1). Thus, where the record as a whole supports the terms and conditions of the permit,
flaws in the statement of basis generally will not result in an objection. See e.g.. Doe Run at 24-
25. In contrast, where flaws in the statement of basis resulted in, or may have resulted in,
deficiencies in the title V permit, EPA will object to the issuance of the permit. See e.g.. Ft.
James at 8; Georgia Pacific at 37-40.

In this case, as discussed below, the permitting authority's failure to adequately explain
its permitting decisions either in the statement of basis or elsewhere in the permit record is such a
serious flaw that the adequacy of the permit itself is in question. By reopening the permit, the
permitting authority is ensuring compliance with the fundamental title V procedural requirements
of adequate public notice and comment required by sections 502(b)(6) and 503(e) of the Clean
Air Act and 40 CFR § 70.7(h), as well as ensuring that the rationale for the selected monitoring
method, or lack of monitoring, is clearly explained and documented in the permit record. See 40
CFR §§ 70.7(a)(5) and 70.8(c); Ft. James at 8.

For the proposed Los Medanos Permit, the District did not provide EPA with a separate
statement of basis document. In a meeting with EPA representatives held on October 31, 2001,
at the Region 9 offices, the District claimed that it complied with the statement of basis
requirements for the Los Medanos Permit because it incorporated all of the necessary explanatory
information either directly into the Permit or it included such information in other supporting
documentation.17 As such, the District argues, at a minimum, it complied with the substantive
requirements of a statement of basis.

V permit.

This meeting along with the others held with the District were for fact-gathering purposes only. In a
November 8, 2001 meeting at the Region 9 offices, the Petitioners were likewise provided the opportunity to present
facts pertaining to the Petition to EPA representatives.

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In responding to the Petition, we reviewed the final Los Medanos Permit and all
supporting documentation, which included the proposed Permit, the FDOC drafted by the
District for purposes of licensing the power plant with the CEC, and the "Permit Evaluation and
Emission Calculations" ("Permit Evaluation") which was developed in March 2001 as part of the
modification to the previously issued ATC permit. Although the District provided some
explanation in this supporting documentation as to the factual and legal basis for certain terms
and conditions of the Permit, this documentation did not sufficiently set forth the basis or
rationale for many other terms and conditions. Generally speaking, the District's record for the
Permit does not adequately support: (1) the factual basis for certain standard title V conditions;
(2) applicability determinations for source-specific applicable requirements, such as the Acid
Rain requirements and New Source Performance Standards ("NSPS"); (3) exclusion of certain
NSR and PSD conditions contained in underlying ATC permits; (4) recordkeeping decisions and
periodic monitoring decisions under 70.6(a)(3)(i)(B) and District Regulation 2-6-503; and (5)
streamlining analyses, including a discussion of permit shields.

EPA Region 9 identified numerous specific deficiencies falling under each of these broad
categories.18 For example, the District's permit record does not adequately support the basis for
certain source-specific applicable requirements identified in Section IV of the Permit, especially
those regarding the applicability or non-applicability of subsections rules that apply to particular
types of units such the as NSPS for combustion turbines or SIP-approved District Regulations.
For instance, in table IV-B and D of the Permit, the District indicates that subsection 303 of
District Regulation 9-3, which sets forth NOx emission limitations, applies to certain emission
units. However, the permit record fails to describe why subsection 601 of the same District
Regulation, an otherwise seemingly applicable provision, is not included in the tables as an
applicable requirement. Subsection 601 establishes how exhaust gases should be sampled and
analyzed to determine NOx concentrations for purposes of compliance with subsection 303.
Similarly, in the same tables, the District lists certain applicable NSPS subsections, such as those
in 40 CFR Part 60 Subparts Da and GG, but does not explain why these subsections apply to
those specific emission units nor why other seemingly applicable subsections of the sameNSPS
regulations do not apply to those units.19

The permit recoid also fails to explain the District's streamlining decisions of certain

18	EPA Region 9 Permits Office described these areas of concern in greater detail in a memorandum dated
March 29, 2002, "Region 9 Review of Statement of Basis for Los Medanos title V Permit in Response to Petition to
Object." This memorandum is part of the administrative record for this Order and was reviewed in responding to
this Petition.

19	The tables in Section IV pertaining to certain gas turbines located at the Facility cite to 40 CFR
60.332(a)(1) as an applicable requirement. However, these same tables fail to cite to subsections 40 CFR
60.332(a)(2) through 60.332(1) of the same NSPS program even though these provisions also apply to gas turbines.
The District's feilure to provide any sort of discussion or explanation as to the applicability or non-applicability of
the subsections of 40 CFR 60.3 32 makes it impossible to review the District's applicability determinations for this
NSPS.

12

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underlying ATC permit conditions as set forth in Section VI of the Permit. The District
apparently modified or streamlined the ATC conditions in the context of the title V permitting
process but failed to provide an explanation in the permit record as to the basis for the change to
the conditions. For instance, Condition 53 of Section VI states that the condition was "[djeleted
[on] August, 2001," but the District fails to discuss or explain anywhere in the permit record the
basis for this deletion or the nature of the original condition that was deleted.

As a final example of the District's failure to provide a basis or rationale for permit terms,
in accordance with Petitioner's claim, the permit record is devoid of discussion pertaining to how
or why the selected monitoring is sufficient to assure compliance with the applicable
requirements. See 69 Fed. Reg. 3202, 3207 (Jan. 22, 2004). Most importantly, for those
applicable requirements which do not otherwise have monitoring requirements, the Permit fails
to require monitoring pursuant to 40 C.F.R. 70.6(a)(3)(i)(B), and the permit record fails to
discuss or explain why no monitoring should be required under this provision. As evidenced by
these specific examples, I find the District did not provide an adequate analysis or discussion of
the terms and conditions of the proposed Los Medanos Permit.

To conclude, by failing to draft a separate statement of basis document and by failing to
include appropriate discussion in the Permit or other supporting documentation, the District has
failed to provide an adequate explanation or rationale for many significant elements of the
Permit. As such, I find that the Petitioners' claim in regard to this issue is well founded, and by
this Order, I am requiring the District to reopen the Los Medanos Permit, and make available to
the public an adequate statement of basis that provides the public and EPA an opportunity to
comment on the title V permit and its terms and conditions as to the issues identified above.

D. Inadequate Permit Conditions

Petitioners' fourth claim is that Condition 22 in the Los Medanos Permit is
unenforceable. The Petitioners claim that this condition "appears to defer the development of a
number of permit conditions related to transient, non-steady state conditions to a time after
approval of the Title V permit." Petition at 7. The Petitioners recommend that "a reasonable set
of conditions should be defined" and amended through the permit modification process to
conform to new data in the future. I disagree with the Petitioners on this issue.

As Petitioners correctly note, Part 70 and the Act require that "conditions in a Title V
permit. . . be enforceable." However, they argue that "Condition 22 is presently unenforceable
and must be deleted from the permit." I find that the condition challenged by the Petitioners is
enforceable.

Conditions 21 and 22 establish NOx emissions levels for units P-l and P-2, including
limits for transient, non-steady state conditions. Condition 22(f) requires the permittee to gather
data and draft and submit an operation and maintenance plan to control transient, non-steady

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state emissions for units P-l and P-220 within 15 months of issuance of the permit. Condition
22(g) creates a process for the District, after consideration of continuous monitoring and source
test data, to fine-tune on a semi-annual basis the NOx emission limit for units P-l and P-2 during
transient, non-steady state conditions and to modify data collection and recordkeeping
requirements for the permittee.

These requirements are enforceable. EPA and the District can enforce both Condition
22(f)'s requirement to draft and submit an operation and maintenance plan for agency approval
and the control measures adopted under the plan after approval. Fcr Condition 22(g), the process
for the District to modify emission limits and/or data collection and recordkeeping requirements
is clearly set forth in the Permit and the modified terms will be federally enforceable. Moreover,
the circumstances that trigger application of Condition 22 are specifically defined since
Condition 22(c) precisely defines "transient, non-steady state condition" as when "one or more
equipment design features is unable to support rapid changes in operation and respond to and
adjust all operating parameters required to maintain the steady-state NOx emission limit
specified in Condition 21(b)." As such, I find that Condition 22 is federally and practically
enforceable. Therefore, Petitioners' claim on this count is not supported by the plain language of
the Permit itself.

Moreover, to the extent that Petitioners are concerned that Lowest Achievable Emission
Rate ("LAER")21 emission standards are being set Ihrough a process that does not incorporate
appropriate NSR, PSD, and title V public notice and comment processes, such concerns are not
well-founded. By its very terms, the Permit prohibits relaxation of the LAER emissions
standards set in the permitting process. Condition 21(b) of the Permit sets a LAER-level
emission standard of 2.5 ppmv NOx, averaged over any 1-hour period, forunits P-l and P-2 for
all operational conditions other than transient, non-steady state conditions. Condition 22(a) sets
the limit for transient, non-steady state conditions of 2.5 ppmv NOx, averaged over any rolling 3-
hour period.22 Implementation of Condition 22 cannot relax the LAER-level emission limits.
Condition 22(f) merely requires further data-collecting, planning, and implementation of control

Unit P-l is defined as "the combined exhaust point for the S-l Gas Turbine and the S-2 HRSG after
control by the A-l SCR System and A-2 Oxidation Catalyst" and unit P-2 is defined as "tie combined exhaust point
for the S-3 Gas Turbine and the S-4 HRSG after control by the A-3 SCR System and A-4 Oxidation Catalyst."
Permit, Condition 21 (a).

LAER is the level of emission control required for all new and modified major sources subject to tie NSR
requirements ofSection 173, Part D, ofthe CAA for non-attainment areas. 42 U.S.C. § 7501-15. Since the Bay
Area is non-attainment for ozone, the Facility must meet LAER-level emission controls for NOx emission since NOx
is a pre-cursor of ozone. California uses different terminology than the CAA when applying LAER, however. In
California, best available control technology ("BACT") is consistent with LAER-level controls, and California and
its local permitting authorities use this terminology when issuing permits.

The District determined this limit to be LAER for transient, non-steady state conditions because, as the
District stated in its Response to Comments, "the NOx emission limit (2.5 ppmv averaged over one hour) during load
changes .... ha[s] not yet been achieved in practice by any utility-scale power plant."

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measures for transient, non-steady state emissions that go beyond those already established to
comply with LAER requirements. While Condition 22(g) does allow the District to modify the
emission limit during transient, non-steady state conditions,23 this new limit cannot exceed the
"backstop" LAER-level limit set by Condition 22(a). As such, Condition 22(g) serves to only
make overall emission limits more stringent. The District itself recognized the "no backsliding"
nature of Conditions 22(f) and (g) on page 3 of its Response to Comments where it stated that the
Facility "must comply with 'backstop' NOx emission limit of 2.5 ppmv, averaged over 3 hours,
under all circumstances and comply with all hourly, daily and annual mass NOx emission
limits."24

Finally, for any control measures; further data collection, recordkeeping or monitoring
requirements; new definitions; or emission limits established pursuant to Conditions 22(f) or (g)
that are to be incorporated into the permit, the District must utilize the appropriate title V permit
modification procedures set forth in 40 CFR § 70.7(d) and the District's Regulation 2-6-415 to
modify the Permit. The District itself recognizes this in Condition 22(g) by stating that "the Title
V operating permit shall be amended as necessary to reflect the data collection and recordkeeping
requirements established under 22(g)(ii)." For the reasons described above, we do not find
Conditions 22(f) and (g) unenforceable or otherwise objectionable for inclusion in the Los
Medanos Permit.

E. Failure to Incorporate Agreed-to Changes

The final claim by the Petitioners is that the District agreed to incorporate certain changes
into the final Los Medanos Permit but failed to do so. Namely, Petitioners claim that the District
failed to keep its commitments to OCE to add language requiring recordkeeping for stipulated
abatement strategies under SIP-approved Regulation 4 and to add clarifying language about NOx
monitoring requirements. The District appeared to make these commitments in its Response to
Comment Letter. These allegations do not provide a basis for objecting to the Permit because
neither change is necessary to ensure that the District is properly including all applicable
requirements in the permit nor are they necessary to assure compliance with the underlying
applicable requirements. CAA § 504(a); 40 CFR § 70.6(a)(3).

The first change sought by OCE during the comment period was a requirement that the

23

The District may modify the emission limit during transient, non-steady state conditions every 6 months
for the first 24 months after the start of the Commissioning period. The Commissioning period commences "when
all mechanical, electrical, and control systems are installed and individual system start-up has been completed, or
when a gas turbine is first fired, whichever comes first. . . The Commissioning period terminates "when tie plant
has completed performance testing, is available for commercial operation, and has initiated sales to the power
exchange." Permit, at page 34.

24

The purpose of Condition 22, as stated by the District, is to allow for limited "excursions above the
emission limit that could potentially occur under unforeseen circumstances beyond [the Facility's] control." This is
the rationale for the three hour averaging period for transient, non-steady state conditions rather than the one hour
averaging period of Condition 21(b) for all other periods.

15

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Facility document response actions taken during periods of heightened air pollution. The
District's Regulation 4 establishes control and advisory procedures for large air emission sources
when specified levels of ambient air contamination have been reached and prescribes certain
abatement actions to be implemented by each air source when action alert levels of air pollution
are reached. OCE recommended that the District require recordkeeping in the title V permit to
"insure that the stipulated abatement strategies [of Regulation 4] are implemented during air
pollution events," and the District appeared to agree to such a recommendation in its Response to
Comments. Although the recordkeeping suggested by Petitioners would be helpful, Petitioners
have not shown that it is required by title V, the SIP, or any federal regulation, and therefore, this
failure to include it is not a basis for objecting to the permit.

The Part 70 regulations set the minimum standard for inclusion of monitoring and
recordkeeping requirements in title V permits. See 40 CFR § 70.6(a)(3). These provisions
require that each permit contain "periodic monitoring sufficient to yield reliable data from the
relevant time period that are representative of the source's compliance with the permit" where
the applicable requirement does not require periodic testing or instrumental or noninstrumental
monitoring (which may consist of recordkeeping designed to serve as monitoring). 40 CFR §
70.6(a)(3)(i)(B). There may be limited cases in which the establishment of a regular program of
monitoring and/or recordkeeping would not significantly enhance the ability of the permit to
reasonably assure compliance with the applicable requirement and where the status quo (i.e., no
monitoring or recordkeeping) could meet the requirements of 40 CFR § 70.6(a)(3). Such is the
case here.

Air pollution alert events occur infrequently, and therefore, compliance with Regulation 4
is a minimal part of the source's overall compliance with SIP requirements. More importantly,
Regulation 4-303 abatement requirements mostly impose a ban on direct burning or incineration
during air pollution alert events, activities which are unlikely to occur at a gas-fired power plant
such as the Facility and in any case are easy to monitor by District inspectors. The other
Regulation 4-303 requirements are mostly voluntary actions to be taken by the sources, such as
reduction in use of motor vehicles, and therefore do not require compliance monitoring or
recordkeeping to assure compliance. Since the activities regulated by Regulation 4 are unlikely
to occur at the Facility, and compliance is easily verified by District inspectors, recordkeeping is
not necessary to assure compliance with Regulation 4. Therefore, further recordkeeping
requirements sought by the Petitioners are not required by 40 CFR § 70.6(a)(3).

The second change sought by the Petitioners is to add language to Condition 36
clarifying why certain pollutants, such as NOx emissions, are exempt from mass emission
calculations. On page 3 of the District's Response to Comments, the District explained that the
NOx emissions are exempt from the mass emission calculations because they are measured
directly through CEMS monitoring, whereas the other pollutant emissions subject to the
calculations do not have equivalent CEMS monitoring. Though this clarification is helpful, it
does not need to be incorporated into the title V permit itself. Therefore, its non-inclusion in the
Permit does not provide a basis for an EPA objection to the Permit. To the extent that such

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clarifying language is important, it should be included in the statement of basis, however. Since
the District will be drafting a statement of basis for the Los Medanos Permit due to the partial
granting of the Petition, we recommend that the clarifying language for Condition 36 be included
in the newly drafted statement of basis.

Though we hope that permitting authorities would generally fulfill commitments made to
the public, we find that the Petitioners' fifth claim does not provide a basis for an objection to the
Los Medanos Permit for the reasons described above. The mere fact that the District committed
to make certain changes, yet did not follow through on those commitments, does not provide a
basis for an objection to a title V permit. Petitioners have provided no other reason why the
agreed upon changes must be made to the permit beyond the District's commitments. I
accordingly deny Petitioners' request to veto the permit on these grounds.

IV. CONCLUSION

For the reasons set forth above and pursuant to Section 505(b)(2) of the Clean Air Act, I
am granting the Petitioners' request that the Administrator object to the issuance of the Los
Medanos Permit with respect to the statement of basis issue and am denying the Petition with
respect to the other allegations.

Mav 24. 2004		/S/	

Date	Michael O. Leavitt

Administrator

17

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BEFORE THE ADMINISTRATOR
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

En the Matter of Valero Refining Co
Benicia, California facility

Petition No- IX-2004-07

Major Facility Review Permit
Facility No, B2G26
Issued by the Bay Area Air Quality
Management District

ORDER RESPONDING TO
PETITIONER'S REQUEST THAT THE
ADMINISTRATOR OBJECT TO
ISSUANCE OF A STATE OPERATING
PERMIT

ORDER DENYING IN PART AND GRANTING IN PART
A PETITION FOR OBJECTION TO PERMIT

On December 7, 2004, the Environmental Protection Agency ("EPA") received a petition
("Petition") from Our Children's Earth Foundation ("OCE" or "Petitioner") requesting that the
EPA Administrator object to the issuance of a state operating permit from the Bay Area Air
Quality Management District ("BAAQMD" or "District") to Valero Refining Co. to operate its
petroleum refinery located in Benieia, California ("Permit"), pursuant to title V of the Clean Air
Act ("CAA" or "the Act"), 42 US-C §§ 7661-7661 f, CAA §§ 501-507, EPA's implementing
regulations in 40 C.F.R, Part 70 ("Part 70"), and the District's approved Pan 70 program- See 66
Fed, Reg. 63503 (Dec. 7, 2G01).

Petitioner requested EPA object to the Permit on several grounds. In particular,
Petitioner alleged that the Permit failed to properly require compliance with applicable
requirements pertaining to, inter alia, flares, cooling towers, process units, electrostatic
precipitators, and other waste streams and units- Petitioner identified several alleged flaws ill the
Permit application and issuance, including a deficient Statement of Basis. Finally, Petitioners
alleged that the permit impermissibly lacked a compliance schedule and failed to include
monitoring for several applicable requirements,

EPA has now fully reviewed the Petitioner's allegations pursuant to the standard sd forth
in section 505(b)(2) of the Act, which places the burden on the petitioner to "demonstrate^ lo the
Administrator that the permit is not in compliance" with the applicable requirements of the Act
or the requirements of part 70, see also 40 C.F.R, § 70.8(c)(1), and 1 hereby respond to them by
this Order. In considering the allegations, EPA reviewed the Hermit and related materials and
information provided by the Petitioner in the Petition-1 Based on this review, I partially deny and

'On March 7. 2005 EPA received a lengthy (over 250 pages, including appendices), detailed submission
from Valero Refining Company regarding this Petition- Hue lo the fact itwl Valero fta fining Company made its
submission very shortly before RPA's set! It me nt agreement deadline for res ponding ro the Petition and (he size of the

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partially grant the Petitioner's request that I object to issuance of the Permit for the reasons
described below.

I. STATUTORY AND REGULATORY FRAMEWORK.

Section 502(d)( I) of the Acl calls upon each State tq develop and submit to EPA an
operating permit program to meet the requirements of title V. [n 1995, EPA granted interim
approval to the title V operating permit program submitted by BAAQMD. 60 Fed. Reg. 32606
(June 23, 1995); 40 CF.R. Part 70, Appendix A. Effective November 30, 2001, EPA granted
full approval to BAAQMD's title V operating permit program. 66 Fed. Reg. 63503 (Dec, 7,
2001.).

Major stationary sources of air pollution and other sources covered by title V arc required
to apply for an operating permit lhat includes applicable emission limitations and such other
conditions as are necessary to assure compliance with applicable requirements of the Act. See
CAA §§ 502(a) and 504(a). The title V operating permit program does not generally impose new
substantive air quality control requirements (which are referred to as ''applicable requirements"),
but does require permits to contain monitoring, recordkeeping, reporting, and other compliance
requirements when not adequately required by existing applicable requirements to assure
compliance by sources with existing applicable emission control requirements. 57 Fed. Reg,
32250, 32251 (July 21, 1992). One purpose of the title V program is to enable the source, EPA,
permitting authorities, and the public to better understand the applicable requirements to which
the source is subject and whether the source is meeting those requirements, Thus> the title V
operating permits program is a vehicle for ensuring that existing air quality control requirements
are appropriately applied to facility emission units and that compliance with these requirements
is assured.

Under section 505(a) of the Act and 40 C.F.R. § 70.8(a), permitting authorities are
required to submit all operating permits proposed pursuant to title V to EPA for review. If EPA
determines that a permit is not in compliance with applicable requirements or the requirements of
40 CF.R. Part 70, EPA will object to the permit. If EPA does not object to a permit on its own
initiative, section 505(b)(2) of the Act and 40 C F.R. § 70.8(d) provide that any person may
petition the Administrator, within 60 days of the expiration of EPA's 45-day review period, to
object to the permit. Section 505(b)(2) of the Act requires the Administrator to issue a permit
objection if a petitioner demonstrates lhat a permit is not in compliance with the requirements of
the Act, including the requirements of Part 70 and the applicable implementation plan. See, 40
C.F.R. § 70.8(c)(1); New York Public Interest Research Group, Inc. v. Whitman, 321 F.3d 316,
333 n. 11 (2d Cir. 2003). Pari 70 requires that a petition must be "based only on objections to the

submission, LP A was not able to icview the Submission itself, nor was it able to provide the Peiitjoner an opjjortunity
to respond to the submission, Although the Agency previously has tonsidcrcd submissions from permittees in some
instances where CPA was able lo Fully review the submission and provide ihe petitioners with a chance lo review and
tespond lo the submissions, time did not allow for either condition here. 'Hierefort, EPA did not consider Valero
Refining Company's submission when responding to the Petition via this Order.

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permit that were raised with reasonable specificity during the public comment period. .unless
the petitioner demonstrates that it was impracticable to Taise such objections within sucli period,
or unless the grounds for such objection arose after such period." 40 C,F.R. § 70.8(d). A
petition for objection does not stay the effectiveness of the permit or its requirements if the
permit was issued after the expiration of EPA's 45-day review period and before receipt of an
objection, If EPA objects to a permit in response to a petition and the permit has been issued, the
permitting authority or EPA will modify, terminate, or revoke and reissue such a permit using the
procedures in 40 C-FJR. §§ 70.7(g)(4) or (5)(i) and (ii) for reopening a permit for cause.

IL PROCEDURAL BACKGROUND

A Permitting Chronology

BAAQMD held its first public comment period for the Valero permit, as well as
BAAQMD's other title V refinery permits from June through September 2002.1 BAAQMD held
a public hearing regarding the refinery permits on July 29, 2002. From August 5 to September
22, 2003, BAAQMD held a second public comment period for the permits. EPA's 45-day
review of BAAQMD *s initial proposed permits ran concurrently with this second public
comment period, from August 13 to September 26, 2003. EPA did not object to any of the
proposed permits under CAA section 505(b)(1). The deadline for submitting CAA section
505(b)(2) petitions was November 25, 2003. EPA received petitions regarding the Valero Permit
from Valero Refining Company and from Our Children's Earth Foundation. EPA also received
section 505(b)(2) petitions regarding three of DAAQMD's other refinery permits.

On December I, 2003, BAAQMD issued its initial title V permits for the Bay Area
refineries, including the Valero facility On December 12, 2003, EPA informed the District of
EPA's finding that cause existed to reopen the refinery permits because the District had net
submitted proposed permits to EPA as required by title V, Part 70 and B AAQMD's approved
title V program. See Letter from Deborah Jordan, Director, Air Division, EPA Region 9 to Jack
Broadbent, Air Pollution Control Oflicer, Bay Area Air Quality Management District, dated
December i 2, 2003. EPA's finding was based on the fact that the District had substantially
revised the permits in response to public comments without re-submitting proposed permits to
EPA for another 4 5-day review. As a result of the reopening, EPA required BAAQMD to submit
to EPA new proposed permits allowing EPA an additional 45-day review period and an
opportunity to object to a permit if it failed to meet the standards set forth in section 505(b)(1).

On December 19, 2003, ERA dismissed all of the section 505(b)(2) petitions seeking
objections to the refinery permits as unripe because of the just-initiated reopening process. See
e.g., Letters from Deborah Jordan, Director, Air Division, EPA Region 9, to John T, Hansen,

'There arc a iotat of live petroleum refineries in the Bay Area: Chevron Producls Company's Richmond
refinery, ConocoPhillips Company's San Francisco Refinery in Rodeo, Shell Oil Company's Martinez Refinery,
Tesoro Rifining and Marketing Company's Martinez refinery, and Valero Refining Company's Ucnicia facility.

3

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Pillsbury Winthrop, LLP (representing Valero) and to Marcel in E, Keevcr, Environmental Law
and Justice Clinic, Golden Gate University School of Law (representing Our Children's Earth
Foundation and other groups) dated December 19, 2003. EPA also stated that the reopening
process would allow the public an opportunity Lo submit new section 505(b)(2) petitions alter the
reopening was completed. In February 2004, three groups filed challenges in the United States
Court of Appeals for the Ninth Circuit regarding EPA's dismissal of their section 505(b)(2)
petitions. The parties resolved this litigation by a settlement agreement under which EPA agreed
to respond to new petitions (i.e., those submitted after EPA's receipt of BAAQMD's re-proposed
permits, such as this Petition) from the litigants by March 15, 2005, See 69 Fed, Reg^ 46536
(Aug. 3, 2004).

13AAQMD submitted a new proposed permit for Valero to EPA on August 26, 2004;
EPA's 45-day review period ended on OctobeT 10, 2004. EPA objected to the Valero Permit
under CAA section 505(b)(1) on one issue: the District's failure to require adequate monitoring,
or a design review, of thermal oxidizers subject lo EPA's New Source Performance Standards
and National Emission Standards for Hazardous Air Pollutants.

B Timeliness of Petition

The deadline for filing section 505(bX^} petitions expired on December 9, 2004. EPA
finds that the Petition was submitted on December 7, 2004, which is within the 60-day time
frame established by the Act and Part 70, EPA therefore finds that the Petition is timely.

m ISSUES RAISED BY PETITIONER

A Compliance with Applicable Requirements

Petitioner alleges that EPA must object to the Permit on the basis of alleged deficiencies
Petitioner claims EPA identified in correspondence with the District dated July 28, August 2, and
October 8, 2004. Petitioner alleges that EPA and BAAQMD engaged in a procedure that
allowed issuance of a deficient Permit, Petition at 6-10. EPA disagrees with Petitioner that it
was required to object to the Permit under section 505(b)(1) or that it followed an inappropriate
procedure during its 45-day review period.

As a threshold matter, EPA notes that Petitioner's claims addressed in this section are
limited to a mere paraphrasing of comments EPA provided to the District in the above-referenced
correspondence. Petitioner did not include in the Petition any additional facts or legal analysis to
support its claims that EPA should object to the Permit. Section 505(b)(2) of the Act places the
burden on the petitioner to "demonstrate[] to the Administrator that the permit is not in
compliance" with the applicable requirements of the Act or the requirements of part 70. See afso
40C.F.R. § 70.8(c)(1)', NYP1RG, 321 F.3d at 333 n.ll. Furthermore, in reviewing a petition to
object to a title V permit because of an alleged failure of the permitting authority to meet all
procedural requirements in issuing the permit, EPA considers whether the petitioner has

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demonstrated that, the permitting authority's failure resulted in, or may have resulted in, a
deficiency in the content of the permit. See CAA § 505(bX2); see also 40 CF-R- § 70,8(e)(1); hi
the Matter of Los Medanos Energy Center, at 11 (May 24, 2004) ("Los Medanos fn the Ma tier
of Doe Run Company Buick Mi!! and Mine7 Petition No. VU-1999-001, at 24-25 (July 31,2002)
("Doe Run"). Petitioner bears the burden of demonstrating a deficiency in the permit whdher the
alleged flaw was first identified by Petitioner or by EPA. See 42 IJ.S.C. § 7G6ld(b}(2). Because
f his section of the Petition is little more than a summary of EPA's comments on the Permit, with
no additional information or analysis, it does not demonstrate that there is a deficiency in the
Permit.

1. EPA's July 28 and August 2, 2004 Correspondence

Petitioner overstates the legal significance of EPA's correspondence to the District dated
July 28 and August 2, 2004. This correspondence, which took piace between EPA and the
District during the permitting process but before BAAQMD submitted the proposed Permit to
EPA for review, was clearly identified as "issues for discussion" and did not have any formal or
legal effect, Nonetheless, EPA is addressing the substantive aspects of Petitioner's allegation
regarding the applicability and enforceability of provisions relating to 40 C,F,R, § 60.I04{a){l} in
Section ID G, L

2 Attachment 2 of EPA's October 8, 2tX)4 Letter

EPA's letter to the District dated October 8, 2004 contained the Agency's formal position
with respect to the proposed Permit, See Letter from Deborah Jordan, Director, Air Division,
EPA Region 9 to Jack Broadbent, Air Pollution Control Officer, BAAQMD, dated October 8,
2004 ("EPA October 8, 2004 Letter"). Attachment 2 of the letter requested the District to review
whether the following regulations and requirements were appropriately handled in the Permit:

Applicability of 40 C,F.R. Part 63, Subpart CC to flares
Applicability of Regulation 8-2 to cooling towers

* Applicability of NSPS Subpart QQQ to new process units

Applicability of NESHAP Subpart FF to benzene waste streams according to annual
average water content

Compliance with NESHAP Subpart FF for benzene waste streams

• Parametric monitoring for electrostatic precipitators

EPA and the Districl agreed that this review would be completed by February 15, 2005
and that the District would solicit public comment for any necessary changes by April 15,2005.
Contrary to Petitioner's allegation, EPA's approach to addressing these uncertainties was
appropriate. The Agency pressed the District to re-analyze these issues and obtained the
District's agreement to follow a schedule to bring these issues to closure. EPA notes again that
the Petition itself provides no additional factual or legal analysis that would resolve these
applicability issues and demonstrate that the Permit is indeed lacking an applicable requirement

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Progress in resolving these issues is attributable solely to (he mechanism set in place by EPA and
the District.

EPA has received the results of BAAQMD's review, see. Letter from Jack Broadbenl, Air
Pollution Control Officer, BAAQMD, to Deborah Jordan, Director, Air Division, EPA Region y,
dated February 15, 2005 C'BAAQMD February 15, 2005 Letter"), and is making the following
findings-

a. Applicability of 40 C.F.R. Part 63, Subpart CC to Flares

This issue is addressed in Section ELH

b Cooling Tower Monitoring

This issue is addressed at Section TTT G 1

Applicability of NSPS Subpart QQQ lo New Process Units

Petitioner claims EPA determined that the Statement of Basis failed to discuss the
applicability of NSPS Subpart QQQ for two new process units at the facility.

In an applicability determination for Valero's sewer collection system {S-161), the
District made a general reference to two new process units that had been constructed since 1987,
the date after which constructed, modified, or reconstructed sources became subject to New
Source Performance Standard ("NSPS") Subpart QQQ- The District further indicated that
process wastewater from these units is hand-piped to an enclosed system. However, the District
did not discuss the applicability of Subpart QQQ for these units or the associated piping. As a
result, it was not clear whether applicable requirements were omitted from the proposed Permit.

In response to EPA's request for more information on this matter, the District stated in a
letter dated February 15,2005' that the process units are each served by separate storm water and
sewer systems. The District has concluded that the storm water system is exempt from Subpart
QQQ pursuant to 40 C.F.R. 60.692-1(d)(1). However, with regard to Ihc sewer system, the
District stated the following:

The second sewer system is the process drain system that contains oily water waste
streams. This system is "hard-piped" to the slop oil system where Ihe wastewater is
separated and sent to the sour water stripper. From the sour water stripper, the
wastewater {is] sent directly to secondary treatment in the WWTP where it is processed in
the Bio* units.

Letter froirt Jack Broadbenl, Executive Office/APCO, Bay Area Air Quality Management District to
Deborah Jordan, Director, Air Division, EPA Region 9.

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The Cfeiria wiif review Hie d«a»is of the new process *Jram wymtm mi determine the
applicable ni-adai-ifo. A preiimin&ty review iodficatesi iai, dr%£ Chis- sysierti ss baM*fsiped
with £B ertiissiotks, Ihe tic* process drain system may !ws beta included in the slep oil
system., Specifically S-&1 ami/or SUM, If this is ||k C4S#, Tp} was ignored by the
District in ita applpeabilily dstermiii^lipn & eondfi^ed i>r the facility.

The Statement of Bask far the ppsposed P-ercnsl included ati applicability defeiininaiCicMi
for Valero-'s Sewer Pipelitte aad Process Oraias, *hith slated the following:

Valero cosipiies with FF through 61.342(e)(2)(j), which allows the facility 6
Mf/y? of yticaiilreiJcd b#i££t*& w»stt Tikis, facilities arc .altowM to eStcKw
tshrlber tie bensccac waste steams arc cstiiroll&d of aiseomroiisd as foag as lite
uncontrolled stream quantifies, ratal les> thati 6 Mg/y*... Because the sewer and
wmzmz drains are uncontrolled, they are not subject io ftl 346, the sta&dank for
individual drain svsteraf.

La its October §, 2U(M letter. HP A raised concerns over ihis applicability det-sfmiitaifort
du" to the District's failure to discuss the control requirements in 40 C.F.R, f 6L142{<;XJ)-
Under th« choswn cooiplian<8>oplioii» mly wastes, thai have m average wtier «OTftesfc of Id% cm1
grealer may gs uncontrolled is-ee 40 C-F.R. § 61342(e)(2)) and it was not dear ftom th$
applicability delennifialieri ihst the. smissi&fi fGurffiSi met this re£jutrsme-Rl. In	f#EPA*$

r*q««st for mom mfeimrtkm  add Section

7

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61.342(e)(1) to the source-specific tables for all sources that handle non-aqueous benzene waste
streams or explain in the Statement of Basis why Section 61.342(c)(1) does not apply.

e. 40 C.F.R. Part 61, Subpart FF - 6BQ Compliance Option

Referencing EPA's October 8, 2004 letter, petitioner claims that EPA identified an
incorrect applicability determination regarding the 6BQ compliance option for benzene waste
streams under 40 C,F,R. § 61.342(e), Petitioner claims that this should have resulted in an
objection by EPA.

The EPA comment referenced by Petitioner is issue #12 in Attacliment 2 or the Agency's
October 8, 2004 letter to the B AAQMD, Ln that portion of its letter, EPA identified incorrect
statements regarding the wastes that are subject to the 6 Mg/yr limit under 40 C.F,R. §
6L342(e)(2)(i). Specifically, the District stated that facilities are allowed to choose whether the
benzene waste streams are controlled or uncontrolled as long as the uncontrolled stream
quantities total Jess than 6 Mg/yr. In actuality, the 6 Mg/yr limit applies to all aqueous benzene
wastes (both controlled and uncontrolled).

The fundamental issues raised by the EPA October 8, 2004 letter were 1) whether or not
the refineries are in compliance with the requirements of the benzene waste operations NESHAP,
and 2) the need to remove the incorrect language from the Statement of Basis. The first issue is a
matter of enforcement and does not necessarily reflect a flaw in the Permit. Absent information
indicating that the refinery is actually out of compliance with the NESHAP, there is no basis for
an objection by EPA. The second issue has already been corrected by the District. In response to
EPA's comment, the District revised the Statement ofBasis to state that the 6 Mg/yr limit applies
Jo the benzene quantity in the total aqueous waste stream. See December 16, 2004 Statement of
Basis at 26. Therefore, EPA is denying Petitioner's request to object to the Permit. However, in
responding to this Petition, EPA identified additional incorrect language in the Permit,
Specifically, Table VII- Refinery states, "Uncontrolled benzene c6 megagrams/year." See Permit
at 476. As discussed above, this is clearly inconsistent with 40 C.F.R. § 61.342(eH2). In
addition, Table IV-Refinery contains a similar entry that states, "Standards: General;
[Uncontrolled] 61.342(e)(2) Waste shall not contain more than 6.0 Mg/yr benzene." See Permit
at 51. As a result, under a separaie process, EPA is reopening the Permit pursuant to its authority
undergo C.F.R, § 70.7(g) to require that the District fix this incorrect language.

f. Parametric Monitoring for Electrostatic Precipitators

Petitioner claims EPA found that the Permit contains deficient particulate monitoring for
sources that are abated by electrostatic precipitators (ESPs) and that are subject to limits under
SIP-approved District Regulations 6-310 and 6-311, Petitioner requests that EPA object to the
Permit to require appropriate monitoring,

BAAQMD Regulation 6-310 limits paniculate matter emissions to 0.15 grains per dry

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standard cubic Foot, and Regulation 6-311 contains a variable limit based on a source's process
weight rate. Because Regulation 6 does not contain monitoring provisions, the District relied on
its periodic monitoring authority to impose monitoring requirements on sources S-5, S-6, and S-
10 to ensure compliance with these standards. See 40 CF.R. § 70,6(a)(3)(i)(B); BAAQMD Reg.
6-503; BAAQMD Manual of Procedures, Vol HI, Section 4.6. For sources S-5 and S-6, the
Permit requires annual source tests for both emission limits. For S-10, the Permit requires an
annual source test to demonstrate compliance with Regulation 6-310 but no monitoring is
required for Regulation 6-311.

With regard to monitoring for Regulation 6-311 for source S-10, the Permit is
inconsistent with the Statement of Basis. The final Statement of Basis indicates that Condition
19466, Part 9 should read, "The Permit Holder shall perform an annual source test on Sources
S-5, S-6, S-8, S-10„ S-l 1, S-12, S-176, S-232, S-233 and S-237 to demonstrate compliance with
Regulation 6-311 (PM mass emissions rate not to exceed 4.10P0.67 lb/hr)," See December 16,
2004 Statement of Basis at 84. However, Pari 9 of Condition 19466 in the Permit states that the
monitoring requirement only applies to S-5 and S-6. December 16, 2004 Permit at 464. In
addition, Table VH-B1 states that monitoring is not required. Therefore, EPA is granting
Petitioner's request to object to the Permit as it pertains lo monitoring S-!0 for compliance with
Regulation 6-311. The District must reopen the Permit to add monitoring requirements adequate
to assure compliance with the emission limit or explain in the Statement of Basis why it is not
needed.

Regarding the annual source tests for sources S-5, S-6, and S-10, EPA believes that an
annual testing requirement is inadequate in the absence of additional parametric monitoring
because proper operation and maintenance of the ESPs is necessary in order to achieve
compliance with the emission limits. In the BAAQMD February 15, 2005 Letter, the Dislrict
stated that it intends to "propose a permit condition requiring the operator to conduct an initial
compliance demonstration that will establish a correlation between opacity and particulate
emissions." Thus, EPA concludes the Permit docs not meet the Pari 70 standard that it contain
periodic monitoring sufficient to yield reliable data from the relevant time period that are
representative of the source's compliance. See 40 C.F.R. § 70,6(aX3XiXR)- Therefore, EPA is
granting Petitioner's request to object to the Permit. At a minimum, the Permit must contain
monitoring which yields data that are representative of Ihe source's compliance with its permit
terms and conditions.

3. Attachment 3 of EPA's October 8, 2004 Letter

Attachment 3 of EPA's October 8, 2004 Letter memorialized the District's agreement to
address two issues related to the Valero Permit. One issue pertains to applicability
determinations for support facilities. EPA does not have adequate information demonstrating
that the Valero facility has support facilities, nor has Petitioner provided any such information,
EPA therefore finds no basis to object to Ihe Permit and denies ihe Petition as to this issue.

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The second issue perlairis to the Gcmoval of a penult shield Rom BAAQMB Regiiaion
S-2. EPA has reviewed the most recent version of As Permit and dcfcusined thai t&c siield was
removed - ITierefofe, EPA is denying Petitioner's request to object to tbe permit as itiis issae is
moot.

B Permit Application

Applicable Requirements

Petitioner alleges that EPA must object to the Permit because it contains unresolved
applicability determ mat ions due (a "deficiencies in the application and permit process" as
identified in Attachment 2 to EPA's October 8, 2QG4 letter to the District,

EKiritigEPA's review of flic Penrrifl, BAAQMD asserted thai, notwitlistandipg soy alleged
deficiencies m the application and permit process, the Peonit sufficiently addressed these items
or {fie requirements were net applicable. EPA requested fhat the District review some c«f the
Jelermiiiatifms of adequacy a&d rion-applicaMiiy that it had already made- EPA believes ftmt
this process has resulted m improved appffcabifity detenrmiadons, PstWooefE have Med io
demonstrate iiisl such a gsaialiied allegation €>f"deficieBciei in (lie application and, pefirr4
process^ actually resulted in or may have resulted in a flaw m the PenniL Therefore, EPA denies
die Petition on Ibis bams-

2. klsDtific2fk>ri of Insignificant Sou reps.

Petitioner comers that the peanut appiicaiion fa led to list mdgriiUcanf sources, resulting
in a "lack -of information fjhatl inhibits meaningful public review of the Title V permit."
Petitioner further contends ihat, coaifafy So District permit regulations, the applicaikjo Tailed to
included Its! of all emission ynlts, including exempt and insignificant sources and activities, and
failed fe include emissions cJctti aliens for each significant source m activity. Petitioner lastly
alleges thai the application lacked an emissions inventory for sources rot in operation Ajririg
1993,

Under Part 70, applications may not omit information needed to determine the
applicability of, or to impose, any applicable requirement, or to evaluate a required fee amount.
40 C.F.R. § 70.5(c). Emission calculations in support of the above information are required. 40
C.F.R. § 70.5(c)(3)(v!ii). An application must also include a list of insignificant activities that
are exempted because of size or production rate. 40 C.F.R. § 70.5(c).

District Regulation 2-6-405.4 requires applications for title V permits to identify and describe
"each permitted source at the facility" and "each source or olher activity that is exempt from the
requirement to obtain a permit„.EPA's Part 70 regulations, which prescribe the minimum
elements for approvable state title V programs, require that applications include a list of
insignificant sources that arc exempted on the basis of size or production rate, 40 C.F.R.

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§ 70.5(c). EPA's regulations have no specific requirement for the submission of emission
calculations to demonstrate why an insignificant source was included in the list.

Petitioner makes no claim that the Permit inappropriately exempts insignificant sources
from any applicable requirements or that the Permit omits any applicable requirements.
Similarly, Petitioner makes no claim that the inclusion of emission calculations in ihe application
would have resulted in a different permit. Because Petitioner failed to demonstrate thai the
alleged flaw in the permitting process resulted in, or may have resulted in, a deficiency in Ihe
permit, EPA is denying the Petition on this ground.

EPA also denies Petitioner's claim because Petitioner fails to substantiate its generalized
contention that the Permit is flawed. The Statement of Basis unambiguously explains that
Section III of the Permit, Generally Applicable Requirements, applies to all sources at the
facility, including insignificant sources:

This section of the permit lists requirements that generally apply to all sources at a facility
including insignificant sources and portable equipment that may not require a District
permit....[Standards that apply to insignificant or unpermitted sources at a facility (e.g.,
refrigeration urrits that use more than 50 pounds of an ozone-depleting compound), are
placed in this section.

Thus, all insignificant sources subject to applicable requirements are properly covered by Ihe
Permit.

Petitioner also fails to explain how meaningful public review of the Peimit was
"inhibited" by the alleged lack of a list of insignificant sources from the permit application/ We
find no permit deficiency otherwise related to missing insignificant source information in the
Permit application.

In addition, Petitioner fails to point to any defect in the Permit as a consequence of any
missing significant emissions calculations in the permit application. The Statement of Basis for
Section IV of tire Permit states, "This section of the Permit lists the applicable requirements that
apply to permitted or significant sources." Therefore, all significant sources and activities are
properly covered by the Permit,

With respect to a missing emissions inventory for sources not in operation during 1993,
Petitioner again fails to point to any resultant Haw in the Permit. These sources are appropriately
addressed in the Permit.

For the foregoing reasons, EPA is denying the Petition on these issues

* tn anotlwr part of (lie Petition, addressed below. Petitioner argues that the District's delay in providing
requested information violated ihe District's public participation procedures approved to meet 40 C.F.R. § 70.7,

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3. Identification of Non-Compliance

Petitioner argues that the District should have compelled the refinery to identify non-
compliance in the application and provide supplemental information regarding non-compliance
during the application process prior to issuance of rhe final permit on December 1, 2003. In
support, Petitioner cites the section of its Petition (IILD.) alleging that the refinery failed to
properly update its compliance certification.

Title V regulations do not require an applicant to supplement its application with
information regarding non-oompliance,5 unless the applicant has knowledge of an incorrect
application or of information missing from an application. Pursuant lo 40 C.F.R. § 70-5(cXS)(i)
and (iii)(C), a standard application form for a title V permit must contain, inter alia, a
compliance plan that describes the compliance status of each source with respect to all applicable
requirements and a schedule of compliance for sources that are not in compliance with all
applicable requirements at the time the permit issues. Section 70.5(b), Duty to supplement or
correct application t provides that any applicant who fails to submit any relevant facts, or who
has submitted incorrect information, in a permit application, shall, upon becoming aware of such
failure or incorrect submission, promptly submit such supplemental or corrected information. In
addition, Section 70.5(c)(5) requires the application to include "[o]ther specific information that
may be necessary lo implement and enforce other applicable requirements ... or to determine the
applicability of such requirements."

Petitioner docs not show that the refinery had failed to submit any relevant facts, or had
submitted incorrect information, in its 1996 initial permit application. Consequently, the duty to
supplement or correct the permit application described at 40 C.F.R. § 70.5(b) has not been
triggered in this case.

Moreover, EPA. disagrees that the requirement of 40 C.F.R. § 70.5(c)(5) requires the
refinery to update compliance information in this case. The District is apprised of all new
information arising after submittal of the initial application - such as NOVs, episodes and
complaints — that may bear on the implementation, enforcement and/or applicability of applicable
requirements. In fact, the District has an inspector assigned to the plant to assess compliance at
least on a weekly basis. Therefore, it is not necessary to update the application with such
information, as it is already in the possession of the District. Petitioner has failed to demonstrate
that the alleged failure to update compliance information in the application resulted in, or may
have resulted in. a deficiency in the Permit. For the foregoing reasons, EPA denies the Petition
on this issue.

C. Assurance of Compliance with All Applicable Requirements Pursuant to the Act,
Part 70 and BAAQMD Regulations

5 As discussed infra, title V regulations also tlo not require permit applicants to update rheir compliance
certifications pending permit i^uance.

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I Cornp I iaincft &hed u l«

fe essence, Peiiliooer claims thai the Distaffs consideration of the feiJftys compliance
history during the I Life V permitting pxwress was flashed because *he District decided not to
inciijde a compliance schedule in the Pcneit despite a number of MOVs and other mdicatioii% m
Petitioner's msw, of compliance pKsti%fris, and the District did not explain why a eumpliaree
scbetitife ts sot necessary Specifically, Petitioner si feges that £?A axis I object fa Che Permit
because the "District ignored evidescs of recurring or ongoing compliance problems at lfae
facility, jusJead relying en limited review of ostdaisi records. to conclude that a eocupliance
schedule is lamecessaiy," Petition at 11-!9. Petitioner further alleges that a compliance schedule
is necessafy to address HOVs issued io the plant (including many fiist are still pending)6, one-
time episodes7reported by the plar.f, recurring violations and episodes at certain eiaifision utiiis,
comptaists filed with die District, and lite lack ofevfdejsce thai fhe isolations have been resolved.
Thc ?eh«f sought by Petiikxier is for the- District to include "a compliance schedule in the Fermi!,
or explain why one was not neeessaiy." Id. Petftkfter additionally charges that, dee io the
facilily'spoor eofTipHascc history, adftifioital monitoring, recordkeeping and reporting
requirements arc warranted to assure compliancy wiili all applicable oequireiqeDis;, Id.

S«uon 7§Mp%}) riqutm lillsc V pemnis to include 3 ipchcdub ofcompliafr.ee csom^ttnr.
with Section 7JJ,5C^M®K Section 70.5(c)(8) prescribes the requicoments ^c*^pitanceadK&lll&S
to be subaiitied as p&ti of a pen nit application. Fsr ^mrces that ace not in cotttpliance with
applicable requirement at the time 
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the Petition to require the District to address in the Permit's Statement of Basis the NOVs that
the District has issued to the facility and, in particular, NOVs that have not been resolved
because they may evidence noncompliance at the time of permit issuance, EPA denies the
Petition as io Petitioner's other compliance schedule issues.

a. Notices of Violation.

Tn connection with its claim that the Permit is deficient because it lacks a compliance
schedule, Petitioner states that the Dislrict issued 85 NOVs to Valero between 2001 and 2004
and 51 NOVs in 2003 and 2004. Petitioner highlights that, as of October 22, 2004, all 51 NOVs
issued in 2003 and 2004 were unresolved and still "pending." Petition at 14-15. To support its
claims. Petitioner attached to the Petition various District compliance reports and summaries,
including a list of NOVs issued between January 1, 2003 and October I, 2004. Thus, Petitioner
essentially claims that the District's consideration of these NOVs during the title V permitting
process was {lawed, because the District did not include a compliance schedule in the Permit and
did not explain why a compliance schedule is not necessary.

As noted above, EPA's Part 70 regulations require a compliance schedule for "applicable
requirements for sources that are not in compliance with those requirements at the time of permit
issuance," 40 C.F.R, §§ 70.6{cX3}, 7Q.5(c)(S)(iii)(C), Consistent with these requirements, EPA
has stated that a compliance schedule is not necessary if a violation is intermittent, not on-going,
and has been corrected before the permit is issued. See In ike Ma tier of New York Organic
Fertilizer Company, Petition Number 11-2002-12 at 47-49 (May 24, 2004). EPA has also stated
that the permitting authority has discretion not to include in the permit a compliance schedule
where there is a pending enforcement action that is expected to result in a compliance schedule
{I.e., thirmgji a consent order or court adjudication) for which the permit will be eventually
reopened. See in the Matter of Ifunlley Generating Station, Petition Number 11-2002-01, at 4-5
(July 31, 2003); see also in the Matter of Dunkirk Power, LLCt Petition Number [1-2002-02, at 4-
5 (July 31, 2003).®

Using the District's own enforcement records, Petitioner has demonstrated that
approximately 50 NOVs were pending before the District at the time it proposed the revised
Permit. The District's most recent statements, as of January 2005, do not dispute this fact.9 The

Vhese orders considered whether a compliance schedule was necessary to address (i) opacity violations for
which the source had included a compliance schedule with its application; and (ii) PSD violations that the source
contested and was litigating in federal district court. As to ihc uncontested opacity violations, EPA required the.
permitting authority lr> reopen the permit; to either incorporate a compliance schedule or explain that a compliance
schedule was not necessary because the facility was in compliance. As to the contested PSD violations, EPA found
is entirely appropriate for the [stale] en force meat process 10 late iti course" and for a compliance schedule
to be included only after the adjudication has been resolved.

yAs stated in a letter from Adati Schwartz, Senior Assistant Counsel, BAAQMD, loGerarda Rios, Air
Division, U.S, EPA Region 9, dated January Jl, 2005, "The District is following upon each S'OV to achieve an
appropriate resolution, which will likely etitai! payment of a civil penalty." EPA provided a copy of this lelier to

14

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permitting record shows that the District issued the initial Permit on December I, 2003 and the
revised Permit on December 16,2004r According to the District, the facility did not have
noncompliance issues at the time it issued the initial and revised permits. The permitting record

contains the following statements:

* July 2003 Statement of flasis,"Comp!iance Schedule" section: "The B AA.QMD
Compliance and Enforcement Division has conducted a review of compliance over
the past year and has no records of compliance problems at this facility." July 2003
Statement of Basis at 12.

July ,21MB Statement	"Compliant^ Sata*" section? "The Com|ptt»fK« *nd

Enforcement Division has prepared an Annual Compliance Report for 2<30L.. "Hie
inlpqftalioa contained in the compliance report has been ev&lusted during the
ptepatmi^o of ih«s Slatemcw! oi Bfsis for lbs proposed majof Facility Review pnml
The main purpose of tins evaluation is to identify dssgotai or ri^mrtg proteicsKt that
should he subject I© a schedule compliant M© such pebkfins have been
identified," July 2003 Statement m Basis at 35- This section also noted that the
PLsizk* issued eight NQVs lt» tip# mtimry in 2051, hut did not discuss my RiWa
issued tu ihe refinery in 2002 or first half M 2WJ< EPA ooicsis that theretppsar to
tavc b««it appradmsieSy 36 NOVs issued dniing. ihai time, £«& of which'is
M©ptifi«l i» pending m the ddciijisettettoti provided by Petkmmef.

December 16,2004 Statement of Basis: 'The facility is not currently in violation of
arty requirement- Moreover, the District has updated its review of recent violations
mod has not found a pattern of violations that would warrant imposition of a
compliance schedule " December 2004 Statement of Basis at 34.

2003 Response to Corufiifsis CRTC) {from GoUfafi Gate University): "The
District's review of recent NOV's failed la reveal any evidence af current ongoing «r
rectinircg jkjiicompliance that would wairant a compliance schedate."" 2003 RTC
(GCU) at I.

EPA finds that the District's statements at the time U tstued the initial and revised
Permits -do nor provide a meaningful explanation for the lack of a compliance schedule in ihe
Pefinlt. Using the District's own enforcemefU records, Petitioner has demaistrated thm Ihere
we-re approxiitiaiely 50 unresolved NOVs at the time tte i-evised Penult was issued irs Beciiubcr
2004. The District'sstaterrieats m the peniiitting record, however, create the impression that no
NQVs were pending at thai time- Although Ihe Dislnei acknowledges that there have Weil
"fcceni violations," the District fails to addjess ihe fact lhai it had issued a significant number of
HGVs to the fedtity and that many of the issued HOVs were still pending- Moreover, the
District provides Duly a cGfJcI^sery statement thai there are no ongoing of recurring problems that

PehtioRef ob February 23, 2.005

IS

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could be addressed with a compliance schedule and offers no explanation for this determination.
The District's statements give no indication that it actually reviewed the circumstances
underlying recently issued NOVs to determine whether a compliance schedule was necessary.
The District's mostly generic statements as to the refinery's compliance status are not adequate to
support the District's decision that no compliance schedule was necessary in light of the NOVs.10

Because the District failed to include an adequate discussion in the permitting record
regarding NOVs issued to the refinery, and, in particular, those that were pending at the time the
Permit was issued, and an explanation as to why a compliance schedule is not required, EPA
finds that Petitioner has demonstrated that the District's consideration of the NOVs during the
title V permitting process may have resulted in a deficiency in the Permit. Therefore, EPA is
granting the Petition to require the District to either incorporate a compliance schedule in the
Permit or to provide a more complete explanation for its decision not to do so.

When the District reopens the Permit, it may consider EPA's previous orders in Lhe
Huntley, Dunkirk, and New York Organic Fertilizer matters to make a reasonable determination
that no compliance schedule is necessary because (i) the facility has returned to compliance; (ii)
the violations were intermittent, did not evidence on-going non-compliance, and the source was
in compliance at the time of permit issuance; or (ill) the District has opted to pursue the matter
through an enforcement mechanism and will reopen the permit tipon a consent agreement or
court adjudication of the noncompliance issues. Consistent with previous EPA orders, the
District must also ensure that the permit shield will not serve as a bar or defense to any pending
enforcement action.11 See Ilurttky and Dunkirk Orders at 5.

b Episodes

Petitioner also cites the number of "episodes" at the plant in the years 2003 and 2G04 as a
basis for requiring a compliance schedule. Episodes are events reported by the refinery of
equipment breakdown, emission excesses, inoperative monitors, pressure relief valve venting, or
other facility failures. Petition at 15, n, 21. According to the District, "[ejpisodes are reportable
events, but arc not necessarily violations. The District reviews each reported episode. For those
that represent 3 violation, an NOV is issued,1* Letter from Adan Schwab, Senior Assistant
Counsel, BAAQMD to Gerardo Rios, EPA Region DC, dated January 31, 2005. The summary
chart entitled +1BAAQMD Episodes" attached to the Petition shows that the District specifically

l0Jn contrast, EPA notes (hat the slate permitting authority in the Huntley and Dunkirk Orders provided a
thorough record as to the existence and circumstances regarding lhe pending NOVs by describing them in detail in
the permits and acknowledging (he enforcemenl issues in th£ public notices for the pemiiu. Huntley a 16, Dunkirk at
6. In addition, EPA found that the permits container! "sufficient safeguards" io ensure thai ihf permit shields would
not preclude appropriate enforcement actions, hi.

11 After reviewing the permit shield in (lie Permit, EPA finds nothing in it [hat could serve as a defense io
finforcemcnl of the pending NOVs. The District, tmvever, should still independently perform [his review when it
reopens lhe Permit.

16

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records for each episode, under the heading "Status " its determination for each episode; (i) no
action; (ii) NOV issued; (iii) pending; and (iv) void. This document supports the District's
statement that it reviews each episode to see whether it warrants an NOV. Because not every
episode is evidence of noncompliance, the number of episodes is not a compelling basis for
determining whether a compliance schedule is necessary. Moreover, Petitioner did not provide
additional facts, other than the summary chart, to demonstrate that any reported episode? are
violations. EPA therefore finds that Petitioner has not demonstrated that the District's
consideration of the various episodes may have resulted in a deficiency in the Permit, and EPA
denies the Petition 35 to this issue.

c.	Repeal Violations and Episodes sf Particular Untls

Petitioner claims that ceifaifi units at the plan! are responsible for multiple episodes and
violations, "possibly revealing serious ongoing or recurring compliance issues."" Petition si 16.
The Petition then ciics* as evidence, the existence of] 6 episodes and 8 NOVs for the PCCll
Caialvlic Regenerator [5-5^ 9 episodes and. 4 NGYs for a hot furnace (5-22€*}„ 9 episodes and 1
NOVs for the Heat Recovery Siearn Generator (S 103 I}, and 3 episodes and 2 NOVs for flic
Souih Flare (S-ISJ.

A close examination of the BAAQMD Episodes chart roll ed upon by Petit!oner, however,
reveals that the failures identified for these episodes and NOVs are actually quite distinct from
one another, often covering different components and regulatory requirements. This fact makes
sense as emission and process units at refineries tend 
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e. AI legat ion t hat Prob tems are not Reso I vcd

Petitioner proposes three "potential solutions to ensure compliance:" (1) the District
should address recurring compliance at specific emission units, namely S-5, S-220 and S-103Q,
(2) [he District should impose additional maintenance or installation of monitoring equipment, or
new monitoring methods to address the 30 episodes involving inoperative monitors; and (3) the
District should impose additional operational and maintenance requirements to address recurring
problems since the source is not operating in compliance with the NSPS requirement to maintain
and operate the facility in a manner consistent with good air pollution control practice for
minimizing emissions. Petition at 18- i 9,

In regard to Petitioner's first claim for relief, EPA has already explained that Petitioner
has not demonstrated that the District's consideration of the various 'recurring' violations for
particular emission units may have resulted in a deficient permit or justifies the imposition of a
compliance schedule. In regard to the second claim for relief, the 30 episodes cited by Petitioner
are for different monitors, and spread over a multi-year period. As long as the District seeks
prompt corrective action upon becoming aware of inoperative monitors, EPA does not sec this as
a basis for additional maintenance and monitoring requirements for the monitors. Moreover,
EPA could only require additional monitoring requirements to the extent that the underlying SIP
or some other applicable requirement does not already require monitoring. See 40 CFR.
§ 70.6(a)(3)(i)(B), Lastly, in response to Petitioner's third claim for relief seeking imposition of
additional operation and maintenance requirements due to an alleged violation of the "good air
pollution control practice" requirements of the NSPS, EPA believes that such an allegation of
noncompliance is too speculative to warrant a compliance schedule without further investigation.
As such, EPA finds thai Petitioner has not demonstrated that the District's failure to include any
of the permit requirements Petitioner requests here resulted in, or may have resulted in, a
deficient permit, and EPA denies the Petilion on this ground.

2, Non-Compliance Issues Raised by Public Comments

Petitioner claims that since the District failed to resolve New Source Review ("NSR")^
compliance issues, EPA should object to the issuance of the Permit and require either a
compliance schedule or an explanation that one is not necessary. Petition at 21. Petitioner
claims to have identified four potential NSR violations at the refinery, as follows: (i) an apparent
Substantial rebuild of the fluid catalytic cracking unit ("FCCU1') regeneralor (S-5) without NSR
review,13 based on information that large, heavy components of the FCCU were recently

11 "NSR" is used in this section to include both tlw nonattainmentarea New Source Review pcrniit
program and the attainment area Prevention of Significant Deterioration ("PSD") permit program.

^ Petitioner also alleges thai S-5 went through a rebuild without imposition of emission
Limitations and other requirements of 40 C.F.R. § 63 Subpart UUU. EPa notes [hat the requirements of Subpart
UUU are included in the Permit with a future eiTcctivc date of April 11,2005. Permit at SO.

IS

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replaced; (ii) apparent emissions increases at two boiler units (S-3 and S^l) beyond the NSR
significance level for modified sources of NQx, based on the District's emissions inventory
indicating dramatic increases in NOx emissions between 1993 and 2001; and (iii) an apparent
significant increase in S02 emissions at a coker burner (S-6), based on the District's emissions
inventory indicating a dramatic increase in S02 emissions in 2001 over the highest emission rate
during 1993 to 2000,14 Petition at 20.

All sources subject to title V must have a permit to operate that assures compliance by the
source with all applicable requirements. See 40 C,F,R. § 70.1(b); CAA §§ 502(a), 504(a). Such
applicable requirements include the requirement to obtain NSR penults that comply with
applicable NSR. requirements under the Act, EPA regulations, and state implementation plans.
See generally CAA §§ U0(a)(2)(C), 160-69, 172(c)(5), and 173; 40CF.R. §§ 51.160-66 and
52.21. NSR requirements include the application of the best available control technology
{"BACT") to a new or modified source that results in emissions of a regulated pollutant above
certain legally-specified amounts.13

Based on the information provided by Petitioner, Petitioner has failed to demonstrate that
NSR permitting and BACT requirements have been triggered at the FCCU catalytic regenerator
S-5, boilers S-3 or S-4, or coke burner S-6. With regard to the FCCU catalytic regenerator,
Petilioner's only evidence in support of its claim is (i) an April Sf 1999, Energy Information
Administration press release that states that the refinery announced the shutdown of its FCCU on
March 19, 1999, and announced the restarting of the FCCU on April I, 1999;16 and
(ii) information posted at the Web site of Surface Consultants, [nc., staling that "several large,
heavy components on [the FCCU] needed replacement " See Petition, Exhibit A. Petitioner
offers no evidence regarding the nature of these activities, whether the activities constitute a new
or modified source under the NSR rules, or whether refinery emissions were in any way affected

14 Petitioner also lakes issue with the District's position lhat "the [NSR] p reconstruct ion review rules
themselves arc not appticable requirements, for purposes of Title V." (Petition, at 21; Decembtr 2003 Consolidated
Response to Comments ("CRTC") at 6-7}. Applicable requirements are defined in the District's Regulation 2-6-202
as"£a]ir quality requirements with which a facility must eon^ily pursuant to the District's regulations, codes of
California statutory law, and the federal Ciean Air Act, including all applicable requirements as defined in 40 C.K.R.
§ 70,2." Applicable requirements are defined in 40 C,F,R. § 70.2 to include "any standard or other requirement
provided for in the applicable implementslion plan approved or promulgated by EPA through rulemaking under title
I of the Act lhat implements the relevant requirements of ihc Act...." Since the District's NSR rules are pari of its
iinplemenlalion plan, (lie NSR rules ihemselves arc applicable requirements for purposes of title V. Since this point
ha* little relevance to the matter a( hand (i.e., whether in this case the NKR rules apply to a particular new or
modified source at (he refinery), CPA views ihe District's position as ahiier dictum.

The Act distinguishes between the requirement to apply UACT, tvbidi is part of the PSD permit program
for attainment areas, and the requirement to apply Ac lowest achievable emission rate ("LAER"), which is pait of the
NSR permit program for nonatlainment areas, In this case, however, the District's NSR rules use the term "BACT"
to signify "LAER."

14 This press release is available on the fntemct al h
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by these activities

With regard to the two boilers and the coke burner, Petitioner's only evidence in support
of its claims are apparent "dramatic" increases in each oF these unit's emissions inventory.
However, as the District correctly notes:

" ,.the principal purpose of the inventory js planning; the precision needed for this
purpose is fairly coarse. The inventory emissions are based, in almost all cases,
on assumed emission factors, and reported throughputs. An increase in emissions
from one year to the next as reflected in the inventory may be an indication that
reported throughput has increased, however it does not automatically follow that
the source has been modified. Unless the throughput exceeds permit limits, the
increase usually represents use of previously unused, but authorized, capacity. An
increase in reported throughput amount could be taken as an indication that
further investigation is appropriate to determine whether a modification has
occurred. However, the District would not conclude that a modification has
occurred simply because reported throughput has increased,"

December 1, 2003 Consolidated Response to Comments ("2003 CRTC), at 22. Moreover,
Petitioner does not claim to have sufficient evidence to establish that these units are subject to
NSR permitting and the application of BACT. The essence of Petitioner's objection is the need
for the District to "determine whether the sources underwent a physical change or change in the
method of operation that increased emissions* which would trigger NSR," Petition at 20. Not
only is Petitioner unable to establish that these units triggered NSR requirements, Petitioner is
not even alleging that NSR requirements have in fact been triggered. Petitioner is merely
requesting that the District make an NSR applicability determination based on Petitioner's "well-
documented concerns regard'mgpotential non-compliance." Petition at 20 (emphasis added).

During the title V permitting process, EPA has also been pursuing similar types of claims
in another forum. As part of its National Petroleum Refinery Initiative, EPA identified four of
the Act's programs where non-compliance appeared widespread among petroleum refiners,
including apparent major modifications to FCCUs and refinery heaters and boilers that resulted
in significant increases in NOx and SOj emissions without complying with NSR rcquirements-
However, based on the information provided by Petitioner, EPA is not prepared to conclude at
this time that these units at the Valero refinery are out of compliance with NSR requirements. Tf
EPA later determines that these units are in violation of NSR requirements, EPA may object to or
reopen the title V permit to incorporate the applicable NSR requirements.'7

Since Petitioner has failed to show that NSR requirements apply to these units, EPA finds

17 EPA notes tliat with respect 
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that Petitiofi«r has not met iis burden of demonsirating a deficiency in ike Permit. Therefore;, fee
Petition is denied on this issue.

3, Mcmullen! and Continuous Compliance

Petjckwr ctmmnAs ih»t KM must 6bject to the Permi! because the District has
tr.*«rpp?!m &anctb»in.g intOTn»ifeiit cwrsp?faj|«, m Fctftionsr
suggests, see P^Uion et 22, s. M, Ihe Disirki appears coni«iUtcd fa addi^ss it diresigb
€fitorcemet>i of the Permit, when &pproprate: "whefi non-compliasce o«i:rs, tte Titls ¥ perrryt
will «ahanc# tfee abflily to d«tecl arwl enfoit« ag»ir«t those oc«M.rt'««ees>w M, Although file
District may ireslisUcally c-xpcci instances #f psoa-eorapliaficis, it *1-^ not necessarily mmm

21

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them. Non-compliance may still constitute a violation and may be subject to enforcement action

For the reasons slated above, EPA denies the Petition on this ground
4. Compliance Certifications

Initial compliance certifications must be made by all sources that apply for a title V
permit at the time of the permit application. See 40 CRR. § 70.5(c)(9). The Part 70 regulations
do not require applicants to update their compliance certification pending issuance of the permit.
Petitioner correctly points out that the District's Regulation 2-6-426 requires annual compliance
certifications on "every anniversary of the application date" until the permit is issued. Petitioner
claims that, other than a truncated update in 2003, the plant has failed to provide annua]
certifications between the initial permit application submittal in L996 and issuance of the permit
in December 2004. Petitioner believes that "defects in the compliance certification procedure
have resulted in deficiencies in the Permit." Petition at 2A,

In determining whether an objection is warranted for alleged Haws in the procedures
leading up to permit issuance, including compliance certification^ EPA considers whether the
petitioner has demonstrated that the alleged flaws resulted in> or may have resulted in, a
deficiency in the permit's content. See CAA Section 505(b)(2) (objection required "if the
petitioner demonstrates ... that the permit is not incompliance with the requirements of this Act,
including the requirements of the applicable [SEP]"); 40 C.F.R. § 70.8(c)(1); See also In the
Matter of New York Organic Fertilizer Company, Petition No. 11-2002-12 (May 24, 2004), at 9.
Petitioner assumes, m making its argument, that the District needs these compliance
certifications to adequately review compliance for the facility. This is not necessarily true.
Sources often certify compliance based upon information that has already been presented to a
permitting authority or based upon NOVs or other compliance documents received from a
permitting authority. The requirement for the plant to submit episode and other reports means
that the District should be privy to all of the information available to the source pertaining lo
compliance, regardless of whether compliance certifications have been submitted annually.
Finally, the District has a dedicated employee assigned as an inspector to the plant who visits the
plant weekly and sometimes daily. In this particular instance, the compliance certification would
likely not add much to the District's knowledge about the compliance status ofthe plant. EPA
believes that in this case, Petitioner has failed lo demonstrate that the lack of a proper initial
compliance certification, or the alleged failure (o properly update that initial compliance
certification, resulted in, or may have resulted in, a deficiency in the permit,

D. Statement of Basis

Petitioner alleges that the Statements of Basis for the Permit issued in December 2003
and for the revised Permit, as proposed in August 2004, are inadequate. Specifically, Petitioner
alleges the following deficiencies:

22

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Neither Statement of Basis contains detailed facility dcKriptioiw, including
comprehensive process flow information;

•	Neither Sdtemso' of Basis contains suffice information to deteimme applicabi lity
of "certain requirements to sgteeilk smjpces," Petitioner specifically identifies
exemptions fmm jpermitiing psquiTerrLents ifcai BAAQMP allowed fof teaks.
Petitioner also references Attachments 2 and 3 to EPA "s October 8.2(304 fetter as
support for Its allegation- that the Statements of Basis were deficient because they did
sot address applicability of 40 C.F.R, Fsri 63, Subpart €€ Co flares and BAAQMJ?
Regulation -8-2 to hydrogen plant vents.

•	N either Statement of B asis addresses B AAQMD' s corap I lance determin at ions

•	The 2003 Statement of Basis was not RMWle available or the District's Web site during
ih& April 2004 public comsieaf period- «irf 4#CS not iociwfe information about permit
r&vist&ris ir. Msufdi and August 2004

The 2004 Statement of Basis does not discuss changes B AAQMD made !o the Permit
between the public comment period in August 2003- and the final version issued in
December 28D3, despite the District's request for public comment cm sacb changes.

EPA's Part 70 regulations require permitting authorities, in connection with initiating a
public comment period prior to issuance of a title V permit, to "provide a statement that seLs
forth the legal and factual basis for the dratl permit conditions " 10 C.F.R. § 70.7(a)(5), EPA's
regulations do not require that a statement of basis contain any specific elements; rather,
permitting authorities have discretion regarding the contents of a statement of basis. EPA has
recommended that statements of basis contain the following elements: (I) a description of the
facility; (2) a discussion of any operational flexibility that will be utilized at the facility; (3 ) the
basis for applying the permit shield; (4) any federal regulatory applicability determinations; and
(5 ) the rationale for the monitoring methods selected, EPA Region V has also recommended the
inclusion of the following; (1) monitoring and operational restrictions requirements; (2)
applicability and exemptions; (3) explanation or any conditions from previously issued permits
that arc not being transferred to the title V permit; (4) streamlining requirements; and (5) certain
Other factual information as necessary. Sec, Los Medanas, at 10, n.16.

There is no legal requirement that a permitting authority include information such as a
specific facility description and process flow diagrams in the Statement of Basis, and Petitioner
has not shown how the lack of this information resulted in, or m?»y have resulted in, a deficiency
in the Permit, Thus, while a facility description and process flow diagrams might provide useful
information, their absence from the Statement of Basis does not constitute grounds for objecting
to the Permit.

EPA agrees, in part, that Petitioner has demonstrated the Permit is deficient because the

23

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Statement of Basis does not explain exemptions for certain tanks. This issue is addressed more
specifically in Section IH.I-L3.

EPA agrees with Petitioner's allegation thai the Statement of Basis should have included
a discussion regarding applicability of 40 C.F.R. Part 63T Subpart CC to flares and BAAQMD
Regulation 8-2 to hydrogen plant vents. Applicability determinations are precisely the type of
information thai should be included in a Statement of Basis. This issue is addressed more
specifically in Section JII.H,!,

EPA addressed Petitioner's allegations relating to the sufficiency of the discussion in (he
Statement of Basis on the necessity of a compliance schedule in Section in.C.

EPA does not agree with Petitioner's allegations that the 2003 Statement of Basis was
deficient because U was not available on the District's Web site during the 2004 public comment
period or because it did net provide information about the 2004 reopening. First, EPA notes that
the 2003 Statement of Basis has been available to the public on its own Web site since the initial
permit was issued in December, 2003.18 [n addition, Petitioner has not established a legal basis
to support its claim that this information is a required element for a Statement of Basis.

Petitioner also concedes that the District provided a different Statement of Basis in connection
with the 2004 reopening. Petitioner does not claim that the Permit is deficient as a result of any
of these alleged issues regarding the Statement of Basis, therefore, EPA denies the Petition on
this ground..

EPA does not agree with Petitioner's allegations that the 2004 Statement of Basis was
deficient because it did not discuss any changes made between the draft permit available in
August 20133 and the final Permit issued ill December 2003. Petitioner has not established a legal
basis to support its claim that this information is a required element Tor a Statement of Basis.
Petitioner has not demonstrated that the Permit is deficient because the District did not provide
this discussion in the 2004 Statement of Basis. Moreover, Petitioner could have obtained much
of this information by reviewing the District's response to comments received during the 2003
public comment period, which was dated December 1, 2003, Therefore, tPA denies the Petition
on this ground.

E Permit Shields

The District rules allow two types of permit shields. The permit shield types are defined
as follows; (1) A provision in a title V permit expJainiiig that specific federally enforceable
regulations and standards do not apply lo a source or group of sources, or (2) A provision in a
title V permit explaining that specific federally enforceable applicable requirements for
monitoring, recordkeeping and/or reporting are subsumed because other applicable requirements

1STilte V pcrmili and related docuironts arc available ihrough Region IX's Electronic Pcraiit Submittal
System at httnV/www.epa.gov/re^ioii09/aLr,'ncnm^i ndgx.html.

24

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for monitoring, recordkeeping, and reporting in Lh and (d)

PMttiwir alleges thai the permit shield In Tabic DC B of the Permit (j»669«67Q)
improperly subsumes 40 C.ER §f 60 J(c) ant! (d) under SEP approved BAAQMD Regulation
1-522.8, and that the Statement of Basis does not sufficiently explain the basis for the shield.
Petition at 28,

BAMJMD R-egidatkM t-S2£<& rwspires that

MsiiiioriiTg data, shall be submitted on a monthly basis in a format ^peciftri by tkt
APCQ. Reports shall he submitted within 30 4a.ys of the cl^je of the month

teptelti cm,

Sections 60.7(c) and (d) require very specific reporting requirements that are not required
by BAAQMD Regulation t-522,8. For instance, § 60.7(c)(1) requires that ejteess emissions
reports include the magnitude of excess emissions computed in accordance with § 60.13(h) and
any conversion factors, used. Section 60.7(d)(1) requires, that the report form contain, among
other things, the duration of excess emissions due to startup/shutdown, ecmttol equipment
problems, process problems, other known causes, and unknown causes and lota! duration of
excess emissions.

The Statement of Basis for Valero contains the following justification for the shield

40 C.F.R. Part, 60 Subpart A CMS reporting requirements are satisfied by
BAAQMD 1-522,8 CHMS reporting requirements. See December 2003 Statement
of Basts at 31.

agl^s with Petitioner thai the requirement? pf 40 C-F-R- §§ 60 7(c) acid (d) aie apt

stlMMl'by B-AAQMP Regulation i *522.8, and Chat il$« Sigieai&Al of Basb iliws rwt provide
aviatejmsltficaiiofi lor substimlug §| <50,'¦?<*:) and {A), An adespale justishould addi^s

lie requitemeitHji ftfa su^atttMd rcgtihtbti are satisfied by SKSthef rcgu&xloiL mot sloipiy
ihal the requirements satisfied hf another replatkm.

For Ike reasons set Ibrth sbove, EPA is granting the Petition on ifcese grounds. The
District must reopen the Permit to include I tie reporting requirements of f§ 60.7(c) ar«j |<11 <3r
adequately explain how they are appropriately subsumed.

25

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2. BAAQMD Regulation 1-7

Petitioner also alleges that the District incorrectly attempted to subsume the State-only
requirements of BAAQMD Regulation I i-7 for valves under the requirements of SIP approved
BAAQMD Regulation 8-18-404, and states that only a federal requirement may be subsumed in
the permit pursuant to BAAQMD Regulation 2-6-233.2. Petition at 29.

Including a permit shield for a subsumed non-federally enforceable regulation has no
regulatory significance From a federal perspective because it is not related to whether the permit
assures compliance with all Clean Air Act requirements. See 40 C.F.R. 70.2 (defining
"applicable requirement"); 70.1(b) (requiring that title V sources have operating permits that
assure compliance with all applicable requirements). Stale only requirements are not subject to
the requirements of title V and, therefore, are not evaluated by EPA unless their terms may either
impair the effectiveness of the title V permit or hinder a permitting authority's ability to
implement or enforce the title V permit. In the Matter of Eastman Kodak Company, Petition
No.: 11-2003-02, at 37 (Feb, 18, 2005). Therefore, EPA is denying the Petition on this issue.

3 AO C.F-R. § 60.482-7(g)

Petitioner alleges that a permit shield should not be allowed for federal regulation NSPS
Subpart W, § 60.482-7(g) based upon its being subsumed by SIP-approved BAAQMD
Regulation 8-1 8-404 because the NSPS defines monitoring protocols for valves that are
demonstrated to be unsafe to monitor, whereas Regulation 8-18-404 refers to an alternative
inspection scheme for leak-free valves. Petitioner Slates "Because the BAAQMD regulation does
not address the same issue as 40 C.K.R. § 60.482-7(g), it cannot subsume the federal
requirement." Petition at 29,

EPA disagrees with Petitioner that the two regulations address different issues. Both
regulations address alternative inspection time lines for valves. Regulation 8-18-404 specifically
states:

Alternative Inspection Schedule: The inspection frequency for valves may change
from quarterly to annually provided all of the conditions in Subsection 404,1 and
404.2 are satisfied.

404.1	The valve has been operated leak free for five consecutive quarters;

404.2	Records are submitted and approval from the APCO is obtained.

404.3	The valve remains leak free. If a leak is discovered, the inspection
frequency will revert back to quarterly.

NSPS Subpart VV requires valves to be monitored monthly except, pursuant to § 60.482-7(g),
any valve that is designated as unsafe to monitor must only be monitored as frequently as
practicable during safe-to-monitor times. In explaining the basis for the shield, the Permit states:

26

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[60.482-7(g)] Allows relief from monthly monitoring if designated as
unsafe-to-monitor. OAAQMD Regulation 8-18-404 does not allow this relief.
Permit at 644.

BAAQMD is correct that the Regulation S-18-404 is more stringent than 40 C.F.R
§ 60.482-7(g). Therefore, EPA is denying the Petition on this issue.

F. Throughput Limits for Grandfathered Sources

Petitioner alleges that EPA should object to the Permit to the extent that throughput limits
for grandfathered sources set thresholds below which sources are not required to submit all
information necessary to determine whether "new or modified construction may have occurred."
Petitioner also alleges that the thresholds are not "legally correct1' and therefore are not
reasonably accurate surrogates for a proper NSR baseline determination. Petitioner also argues
that EPA should object to the Permit because the existence of the throughput limits, even as
reporting thresholds, may create "an improper presumption of the correctness of the threshold"
and discourage the District from investigating events that do not trigger the threshold or reduce
penalties for NSR violations. Finally, Petitioner also requests that EPA object to the Permit
because the District's reliance on non-SIP Regulation 2-1-234.1 "in deriving these throughput
limits" is improper.

The District has established throughput limits on sources that have never gone through
new source review ("grandfathered sources"). The Clean Air Act does not require permitting
authorities to impose such requirements. Therefore^ to understand the purpose of these limits,
EPA is relying on the District's statements characterizing the reasons for, and legal implications
of, these throughput limits. The District's December 2003 CRTC makes the following points
regarding throughput limits:

• The throughput limits being established for grandfathered sources will be a useful tool
that enhances compliance with NSR- - . .Requiring facilities to report when
throughput limits are exceeded should alert the District in a timely way to the
possibility of a modification occurring.

The limits now function merely as reporting thresholds rather than as presumptive
NSR triggers.

They do not create a baseline against which future increases might be measured
("NSR baseline1'). Instead, they act as a presumptive indicator that the equipment has
undergone an operational change (even in the absence of a physical change), because
the equipment has been operated beyond designed or as-built capacity.

The throughput limits do not establish baselines; furthermore, they do not contravene
NSR requirements. The baseline For a modification is determined at the time of

27

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permit review. The proposed limits do not preclude review of a physical modification
for NSR implications.

•	Throughput limits on grandfathered sources art not Federally enforceable.

•	The [permits] have been modi (led to clearly distinguish between limits imposed
through NSR and limits imposed on grandfathered sources.

December 1,2003 RTC at 31-33.

EPA believes the public comments and the District's responses have done much lo
describe and explain, in the public recoid, the purpose and legal significance of the District's
throughput limits for grandfathered sources. Baied on these interactions, EPA has the following
responses lo Petitioner's allegations.

First, EPA denies the Petition as to the allegation that the thresholds set levels below
which ihe facility need not apply for NSR permits. As the District states, the thresholds do not
preclude the imposition of federal NSR requirements. EPA does not see that the tliroughput
limits would shield the source from any requirements to provide a timely and complete
application if a construction project will trigger federal NSR requirements.

Second , the Permit itself makes clear that the throughput limits are not to be used for the
purpose of establishing an NSR baseline; "Exceedance of this limit does not establish a
presumption that a modification has occurred, nor does compliance with the limit establish a
presumption that a modification has not occurred." Permit at 4, Therefore, EPA finds no basis to
object to the Permit on the ground that the thresholds are not "reasonably accurate surrogates" for
an actual NSR baseline, as they clearly and expressly have no legal significance for that purpose.

Third, while EPA shares Petitioner's interest in compliance with NSR requirement.
Petitioner's concern that the thresholds might discourage reliance on appropriate NSR baselines
to investigate and enforce possible NSR violations is speculative and cannot be the basis of an
objection to the Permit.

Fourth, EPA finds that the District's reliance on BAAQMD Regulation 2-1-234.1, which
is not S[P-approved„ to impose these limits is appropriate. EP A's review of the Permit, however,
found a statement suggesting that the District will rely on this non-StP approved rule to
determine whether an NSR modification has occurred. EPA takes this opportunity to remind the
District that its NSR- permits must meet the requirements of the federally-applicable SIP. See
CAA 172, 173; 40 C,F.R, §51. EPA finds no basis, however, to conclude that the Permit is
deficient.

G. Monitoring

28

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The lack of monitoring raises an issue as to consistency with the requirement that each
permit contain monitoring sufficient to yield reliable data from the relevant time period that are
representative of the source's compliance with the permit where the applicable requirement does
not require periodic monitoring or testing. See 40 C.F.R. § 70-(j(a)(3Xi)(B). EPA has
recognized, however, that there may be limited cases in which the establishment of a regular
program of monitoring or recordkeeping would not significantly enhance the ability of the permit
to assure compliance with an applicable requirement and where the status quo (i,e,„ no
monitoring or recordkeeping) could meet the requirements of 40 C.F.R. § 70.6(a)(3). See,Los
Medanos. at 16. EPA's consideration of these issues and determinations as to the adequacy of
monitoring follow.

I 40 C,F,R. Pan 60, Subpart J {NSPS for Petroleum Refineries)

Petitioner makes the following allegations with regard to the treatment of flares under
NSPS Subpart J: (i) BAAQMD has not made a determination as to the applicability of NSPS
Subpart J to three of the four Hares at Valero; (ii) there is no way to tell whether flares qualify for
the exemption in NSPS Subpart J because there are no requirements in the Permit to ensure tliat
the flares are operated only in "emergencies;" (iii) the Permit must contain a federally
enforceable reporting requirement to verify that each flaring event would qualify for an
exemption from the H2S limit; (iv) the Permit fails to ensure that all other NSPS Subpart J
requirements arc practically enforceable; and (v) federally enforceable monitoring must be
imposed pursuant to 40 C.F.R. §§ 70.6(a)(3)(i)(B) and 70.6(c) and Section 504(c) of the Act to
verify compliance with all applicable requirements of Subpart J. Petition at 33.

The New Source Performance Standard (NSPS) for Petroleum Refineries, 40 C.F.R, Pan
60, Subpart J, prohibits the combustion of fuel gas containing H2S in excess of 0.10 gr/dscf at
any flare built or modified after June II, 1973. This prohibition is codi fied in 40 C.F.R.
§ 60.104(a)( 1). Additionally, 40 C.F.R. § § 60.105(a){3-4) requires the use of continuous
monitors for flares subject to § 60,104(a)(1). However, the combustion of gases released as a
result of emergency malfunctions, process upsets, and relief valve leakage is exempt from the
HjS limit. The draft refinery permits proposed by BAAQMD in February 2004 applied a blanket
exemption from the E^S standard and associated monitoring for about half of the Bay Area
refinery flares on the basis that the flares are "not designed" to combust routine releases. The
statements of basis for the refinery permits state, however, that at least some of these flares arc
"physically capable" of combusting routine releases. To help assure that this subset of flares
would not trigger the H2S standard, BAAQMD included a condition in the permits prohibiting
the combustion of routine releases at these flares.

Following EPA comments submitted to BAAQMD in April of 2004, BAAQMD revised
its approach to the NSPS Subpart J exemption. The permits proposed to EPA in August of2004
indicate that all flares that are affected units under 60,100 are subject to the H2S standard, except
when they are used to combust process upset gases, and gases released to the flares as a result of
relief valve leakages or other malfunctions. However, the permits were not revised to include the

29

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asotiTUiOPS iRoaitora repaired tinder §§ 6£UGS(a)P) and (4) as the basis liial the tiaics will
always, be used to ecratast non-routine feleases and thus ml] mws acliaUy trigger the iOS
standard or the lequireiaeul to racial i monitors.

Wilh respect fi> Pelttirmer's. ftfsi allegation, BAAQMO has dearlycmsidered
applicability qf JNSPS Stikpail J to flares, arid has indicated flat NSPS Sp&pict J applies te one,
S-19, Page 16 of the Pceemfcec 20G4 Statement of Bails mu&x

The Btsicia Reinery km three aep&rM« Dice tatackr systems; f) Ik? «i»b Urns g&
recovery header with Jlares S-l 8 and S-i9„ Tj the acid gas flai€ healer with flare 5-J 6,
arid 1) i}m btitanis (lase header with Pare 17. Flares S~ 16 end S -1.1 were placed is
serrodiirlini the original ftfmery starivp in IV(®. Bate S~i7 was pbcetf m scrvs* wife
the butane cank TKL-1126 in 1972. Flsn; S-59 was added to the main gas recovery leader
in 19?4 to €«stu« adequate relief	for the refinery, S~Wh wbjeet to KSFS

Subpart J, because it w«& t l%cl gas €£?rtb4isiksri device installed alter hm® II. tf tJt the
effective dale of 60,100(b),

The iabte on page 18 of ihe Statement of Basis siso directly slaws thai fiarss 5-14 5-1?
i3md 8 ire tw! to NSPS S«bpait J. While Ibe- Punmif w^ld be^Icaiw if BAAQM l>
kiekided a ifate-raetit thai ite U&zv& have sot been modified so as to trigger the reqijiremems. of
NSPS Subpart J, sacli a statement is riol required by title V. Therefore, UFA. is denymg Ihe
m litis issis#,

However, >gr<^ with Felitiocef feat ihe Pemiit is fliw«d wrtli respect to (ii)
and (i») above, First* Ihe continuous manUanng of§§ 6C% 105(a)(3) and (4) is not ipeju^cd id the
Permit feso&yse, BAAQMD cSms, lfer« S--19 is never usod m a miiuwr thai would itiggtT the
H2S standard End the, requirement to install a. contiguous mtmilOi. While the F&nui do® contain
District - cnfoieeabUi only iriofiicori^g to stow sempltsfice witli a, Merally «fii3K«Wu condition
prahinittTig t^eccmhyaHoH&f routiiicjy-relcased gsises in a Oarc	U7% flwrc h cunraBliy no

federally cnrcrceafcle fpotiifiKiii^ re^nirenwul in flic Permit !o dem^istrais; ecmplbnce vdih chif
TOfidiiikiit or wisTi JISES Sub^rt h both federally ^fetxiKaWe applkable («8^r C.F.R. | 70.6(aX3)(i}(8) aoi fl^AQND	 20800»
BAAQMO must reup^n Ihu i^rmii 10 titha ixwliiife: the imjii^ormg under sectoia 6n.!fl5(a)P)
ftr (4% or, fof exampfc, !a include Mfsqua'fe federally ertfoicsiblt km®tewing io show CK«plianiie
with condition 208'>S, #7.

With respect la issues (iv) a:id (v)T jj is unclesr what ather requirements Petitioner is
lefeoing io, or whM mo Glaring Petitioiser s requesting. For iJicsc reasons, OP A is denying the

30

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Petition on these grounds.

2 Flare Opacity Monitoring

Petitioner notes that flares arc subject to SIF-approved BAAQMD Regulation 6-301,
which prohibits visible emissions from exceeding defined! opacity limits for a period or periods
aggregating more than three minutes ill any hour. Petitioner alleges that the opacity limit set
forth in Regulation 6-301 is not practically enforceable during short-duration flaring events
because no monitoring is required for flaring events that last less than fifteen minutes and only
limited monitoring is required for events lasting less than thirty minutes. Petitioner alleges that
repeated violations of BAAQMD Regulation 6-301 due fo short-term flaring could be an ongoing
problem that evades detection.

The opacity limit in Regulation 6-301 -dees net contain periodic monitoring. Because tftfi
underlying applicable jsifmremeiit imposes no moni taring of a periodic nature, the Fenriit must
contain "periodic monitoring sufficient to yield reliable data from lie relevant time period that
are representative of the source's compliance witli ihepeiniit,49 C.F.Et. § 7®.6/aX3)(iX£|j-
Thus, tha issue before EPA is whether the motikormg imposed in ihe Permit will result ie
reliable and representative csta from, the relevant time §»iad such tliM ccjniplisncc wiift the
Perm! t can be determined.

(it this cm%> tha District has imposed certain monitoring conditions to determine
compliance with the opacity standard during flaring events. Tht Permit defines a "flaring event"

a flow rate of vent gas flared in any consecutive 15 minute period that Continuously exceeds
330 standard cubic feet per minute (scftn). Within 15 minutes of detecting a flaring event, the
facility must conduct a visible emissions check. The visible emissions check may be done by
video monitoring- If the operator cam determine there are no visiWta emissions using video
monitoring, no further monitoring is required until another 10 minvtes has expired, If the
operator cannot detettttine there are no visible emissions using video monitoring, the facility
must conduct either an EPA Reference Method 9 test or survey the flare according to specified
criteria. If the operator conducts Method 9 testing, the facility must monitor the flare for at leal*
3 minute, or until there am no visible emissions. Ff the operator conducts flic non-Method 9
survey* the facility must cease operation of the flare if vteibte emissions continue for three
consecutive minutes.

Although EPA agrees with Petitioner that the Permit does not require morn tori rig during
sliotl-duration flaring events, EPA does not believe Petitioner has demonstrated that the periodic
monitoring is inadequate, For instance, Petitioner hu not shown that short-duration flaring
events arc likely to be in violation of the opacity standard, nor has Petitioner made a showing that
short-duration (kririg wonts occur frequently or at all Thus, Petitioner has not demoralised
that the periodic monitoring in ihe Permit is insufficient to detect violations of the opacify
standard.



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Additionally, in June 1999, a workgroup comprised of EPA, CAPCOA and CAJUJ staff
completed a set of periodic monitoring recommendations for generally applicable SIP
requirements such as Regulation 6-301, The workgroup's relevant recommendation for refinery
flares was a visible emissions check soon as an intentional or unintentional release of vent
gas to a gas flare but no later than one hour from the flaring event," See CAPCOA/CARB/EP A
Region IX Periodic Monitoring Memo, June 24, 1999, at 2. In comparison, the periodic
monitoring contained in the Permit would appear to be both less stringent, by not requiring
monitoring for up to thirty minutes of a release of gas to a flare, and more stringent, by requiring
monitoring within 30 minutes rather than one hour. Therefore, EPA encourages the Dislrict to
amend the Permit to require monitoring upon the release to the flare, rather than delaying
monitoring as currently set forth in the Permit.

Finally, EPA notes that the Permit does not prevent the use of credible evidence to
demonstrate violations of permit terms and conditions. Even if the Permit does not require
visible emissions checks for short-duration flaring events, EPA, the District, and the public may
use any credible evidence to bring an enforcement case against the source. 62 Fed. Reg. &3M
(Feb. 24, 1997).

For the reasuns cited above, EPA is denying the Petition on this issue.

3 Cooling Tower Monitoring

Petitioner claims that the Permit lacks monitoring conditions adequate to assure that the
cooling tower complies with SIP-approved District Regulations 8-2 and 6. Petitioner further
alleges that the District's decisions to not require monitoring for the cooling towers is flawed due
to its use of AP-42 emission factors, which may not be representative of the actual cooling tower
emissions.

a. Regulation £-2

District Regulation 8-2-301 prohibits miscellaneous operations from discharging into the
atmosphere any emission that contains 15 lb per day and a concentration of more than 300 ppiri
total carbon. Although the underlying applicable requirement does not contain periodic
monitoring requirements, the District declined to impose monitoring on source S-29 to assure
compliance with the emission limit.

The December I, 2003 Statement of Basis sets forth the grounds Tor the District's
decision that monitoring is not necessary to assure compliance with this applicable requirement.
First, the District stated that its monitoring decisions were made by balancing a variety of factors
including I) the likelihood of a violation given the characteristics of normal operation, 2) the
degree of variability in the operation and in the control device, if there is one, 3) the potential

Permit, Tabic Vlf - C5 Cooling Tower, pp. 541

32

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seventy of impact of an undetected violation, 4} the technical feasibility and probative value of
indicator monitoring, 5) the economic feasibility of indicator monitoring, and 6) whether there is
some other factor, such as a different regulatory restriction applicable to the same operation, that
also provides some assurance of compliance with the limit in question. In addition, the District
provided calcnlafions that purported to quantify the emissions £h)m the facility's cooling tower.
The calculations relied upon water circulation and exhaust airflow rates supplied by the refinery
in addition to two AP-42 emission factors. The District found that the calculated emissions were
much lower than the regulatory limit and concluded thai monitoring was not necessary.

Although it is true that the results suggest there may he a large margin of compliance, the nature
of the emissions and the unreliability of the data used in the calculations renders them inadequate
to support a decision that no monitoring is needed over the entire life of the permit.

An AP-42 emission factor is a value that roughly correlates the quantity of a pollutant
released to the atmosphere with an activity associated with the release of that pollutant. The use
of these emission factors may be appropriate in some permitting applications, such as
establishing operating permit fees. However, EPA has stated that AP-42 factors do not yield
accurate emissions estimates for individual sources. See In the Matter ofCargill, /nc., Petition
IV-2003-7 (Amended Order) at 7, n.3 (Oct. 19, 2004); in re: Peabody Western Coal Co., CAA
Appeal No. 04-01, at 22-26 {EAB Feb. 18, 2005), Because emission factors essentially represent
an average of a range of facilities and emission rates, they arc not necessarily indicative of the
emissions from a given source at all times, with a few exceptions, use of these factors to develop
source-specific permit limits or to determine compliance with permit requirements is generally
not recommended. The District's reliance on the emission factors in making its monitoring
decision is therefore problematic.

Atmospheric emissions from the cooling towers include fugitive VOCs and gases that are
stripped from the cooling water as the air and water come into contact. In an attempt to develop
a conservative estimate of the emissions, (he District used the emission factor for "uncontrolled
sources." For these sources, AP-42 Table 5-1,2 estimates the release of 6 lb of VOCs per million
gallons of circulated water. This emission factor carries a "D" rating, which means that it was
developed from a small number of facilities, and there may be reason to suspect that the facilities
do not represent a random or representative sample cf the industry. In addition, this rating means
that there may be evidence of variability within the source population. In this case the variability
stems from the fact that 1) contaminants enter the cooling water system from leaks in heat
exchangers and condensers, which are not predictable, and 2) the effectiveness of cooling lower
controls is itself highly variable, depending on refinery configuration and existing maintenance
practices.10 It is this variability that renders the emission factor incapable of assuring continued
compliance with the applicable standard over the lifetime of the permit. For all practical
purposes, a single emission factor that was developed to represent long-term average emissions
can not forecast the occurrence and size of leaks in a collection of heat exchangers and is
therefore not predictive of compliance at any specific time,

^AP 42, Fifth Edition, Volume I, Chapter 5

33

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EPA has previously stated that annual reporting of NQx emissions using an equation that
uses current production information, along with emission factors based on prior source tests, was
insufficient to assure compliance with an emission unit's annual NOx standard. Even when
presented with CEMs data which showed that actual NOx emissions for each oFfive years were
consistently well below the standard, EPA found that a large margin of compliance alone was
insufficient to demonstrate that the NOx emissions would not change over the life of the permit-
See In the Matter of Fort James Camas Mitl, Petition No. X-1999-1, at 17-18, (December 22,
2000).

Consistent with its findings in regard to the Fort James Camas Mill permit, EPA finds in
this instance that the District failed to demonstrate that a one-time calculation is representative of
ongoing compliance with the applicable requirement, especially considering the unpredictable
nature of the emissions and the unreliability of the data used in the calculations. Therefore
under the authority of 40 C.F.R. § 7G,6(a){3X0(D)> EPA is granting Petitioner's,request to object
to the Permit as the request pertains to cooling tower monitoring for District Regulation 8-2-301.

As an alternative to meeting the emission limitation cited in Section 8-2-301, facilities
may operate in accordance with an exemption under Section 8-2-114, which states, "emissions
from cooling towers.,.are exempt from this Rule, provided best modem practices are used." As a
result, in lieu of adding periodic monitoring requirements adequate to assure compliance with the
emission limit in Section 8-2-301, the District may require the Statement of Basis lo include an
applicability determination with respect to Section 8-2-114 and revise the Permit to reflect the
use of best modem practices.

b. Regulation 6

BAAQMD SIP-approved Regulation 6 contains four particulate matter emissions
standards for which Petitioner objects to the absence of monitoring. The District's decision for
each standard is discussed separately below.

(I) Regulation 6-310

BAAQMD Regulation 6-310 limits the emissions from the cooling tower to 0.15 grains
per dry standard cubic foot. Appendix G of the December 1, 2003 Statement of Basis sets forth
the grounds for the District's decision that monitoring is not necessary to assure compliance with
this requirement- Specifically, Appendix G provides calculations For the particulate matter
emissions from the cooling tower and compares the expected emission rate to the regulatory
limit. In calculating the emissions, the District used the PM-10 emission factor of 0.019 lb per
i 000 gal circulating water from Table 13.4-1 of AP-42. The calculations show that the
emissions are expected to be approximately ISO times lower than the emission limit. As a result,
the District concluded that periodic monitoring is not necessary to assure compliance with the
standard.

34

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Petitioner alleges that these calculations do riot adequately justify the District's decision
because the AJM2 emission factor used carries an E rating, which means that it is of poor
quality. As a result, Petitioner claims it is unlikely that the calculated emissions based on this
factor are representative of the actual cooling tower emissions.

Petitioner is correct that the emission factor used by the District has an B rating.
However, EPA disagrees that this rating alone is sufficient to conclude that the emission factor is
not representative of the emissions from the cooling towers at the refinery. PM-10 emissions
from cooling towers are generated when drift droplets evaporate and leave fine particulate matter
formed by crystallization of dissolved solids. Particulate matter emission estimates can be
obtained by multiplying the total liquid drift factor by the total dissolved solids (TDS) fraction in
the circulating water. The AP-42 emission factor used by the District is based on a drift rate of
0.02% of the circulating water flow and a TDS content of approximately 12,000 ppm. With
regard to both parameters, the District indicated in the December I, 2003 Statement of Basis that
the emission factor yielded a higher estimate of the emissions than the actual drift and TDS data
that was supplied by the refineries. Therefore, EPA believes thai the District's reliance on this
emission factor does not demonstrate a deficiency in the Perm it.21

EPA notes that the emission factor's poor rating is due in part to the variability associated
with cooling tower drift and TDS data. As discussed in the Statement of Basis, the degree to
which the emissions may vary was taken into account when considering the ability of the
emission factor to demonstrate compliance with the emission limit, With respect to the drift,
EPA believes that the emission factor is conservatively high compared to the 0.0005% drill rate
that cooling towers are capable of achieving. Where TDS arc concerned, AP-42 indicates that
the dissolved solids content may range from 380 ppm to 91,000 ppm. While the emission factor
represents a TDS concentration at the lower end of this spectrum, increases in the TDS content
do not significantly increase the grain loading due to the large exhaust air flow rates exiting the
cooling towers. Even assuming that the TDS concentration reached 91,000 ppm, the calculated
emissions arc still approximately 22 times lower than the regulatory limit.21

The District has provided sufficient evidence to demonstrate that the emissions will not
vary by a degree that would cause an exceedance of the standard. Given the representative air
flow and water circulation rates supplied by the refinery, compliance with the applicable
requirement is expected under conditions (i.e., maximum TDS content) that represent a
reasonable upper bound of the emissions. Therefore, EPA is denying Petitioner's request lo
object to the Permit as it pertains to periodic monitoring for Regulation 6-310.

21 Although EPA stated above in tlie discussion For Regulation 8-2 [hat AP-42 emission factors arc generally
not recommended For use in determining compliance wiih emission limits, there are exceptions. Data supplied by [lie
refineries indicates (hat the AP^lZ emission factor fur PM-10 conservatively estimates the actual cooling lower
emissions; as discussed furiher below, compliance with the limit is expcclcd under conditions that represent*
reasonable upper boirnd on the emissions.

''Again, this i* subliming n drift r:ite of 0.02%.

35

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(2) Regulation 6-3 ]

BAAQMD Regulation 6-311 states that no person shall discharge particulate matter into
the atmosphere at a rate in excess of that specified m Tabic 1 of the Rule for the corresponding
process weight rate- Assuming the process weight rate Tor the cooling tower remains at or above
the maximum level specified in Table I, the rule establishes a maximum emission rate of40
Ib/hr. Unlike for Regulation 6-310, die District provided no justification for its decision to not
require monitoring to assure compliance with this limit.

Using the PM-10 emission factor cited by the District in its calculations for Regulation 6-
310, EPA estimates the emissions from S-29 to be in excess of 40 lb/hr. While the District stated
that the emission factor represents a more conservative estimate of the emissions than the actual
data provided by the refineries, it did not say how conservative the factor is. As a result, the
Districts monitoring decision is unsupported by the record and EPA finds that the Permit fails to
meet the Part 70 standard that it contain periodic monitoring sufficient to yield reliable data that
aie representative of the source's compliance with Us terras. See 40 C.F.R. § 70.6(a)(3)(iXB),
Therefore, EPA is granting Petitioner's request to object to the Permit The Permit must include
periodic monitoring adequate to assure compliance with BAAQMD Regulation 6-31 L See 40
C.F.R. § 70.6(a)(3)(i){B).

(3)	Regulation 6-305

BAAQMD Regulation 6-305 states that, "a person shall not emit particles from any
operation in sufficient number to cause annoyance to any other person.. .This Section 6-305 shall
only apply if such particles fall on real property other than that of the person responsible for the
emission." Nuisance requirements such as this may be enforced by EPA and Lhe District at any
time and there is no practical monitoring program that would enhance the ability of the permit to
assure compliance with the applicable requirement. Therefore, EPA is denying Petitioner's
request to object to the Permit as it pertains to monitoring for BAAQMD Regulation 6-305,

(4)	Regulation 6-301

BAAQMD Regulation 6-301 slates that a person shall not emit from any source for a
period or periods aggregating more than three minutes in any liour> a visible emission which is as
dark or darker than No. I on the Ringelmann Chart. While the Statement of Basis docs not
contain a justification for the District's decision that monitoring is not required for this standard,
the District stated the following in response to public comments: 'The District has prepared an
analysis based on the AP-42 factors for particulate, which are very conservative, and has indeed
determined that 'it is virtually impossible for cooling towers to exceed visible or grain loading
limitations.' The calculations show that the particulate grain loading is a hundredth or less than
the 0- i.5 gr/dscf standard due to the large airflows. When the grain loading is so low, visible
emissions are not expected," 2003 CRTC at 59. EPA finds the District's assessment of the
visible emissions to be reasonable and that Petitioner has not demonstrated otherwise. Therefore,

36

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EPk is denying Petitioner's request lo object te the Permit as II pertains to monitoring for
BAAQMD ReguiatioB 6-30L

4,	Monircn^g^fPrcss'afs Relief Valves

Petitioner ^leg« ftwl the Percnft f&«t indudc additions*! m-amrnwing to nfiuiw ibaUtl
pressure relief valves at ihe faciliiy are m eompsiiafiee wilhlhe rs^dtettienfe efStP-apptwccJ
Disiocf Regulator 8-28	Relets from Pnssswre Relief Vaiv^sJ,	at 36,

Rsgylatbfi 8-21 requires ihat wtlliiit VM days oflihe firs! ""release at a faritfcy* ihe
fadliy AMI fiqiiip each fmassuas relief device of iJiai source with a lampserpfwif' ieli-iai« tsrfksiof
th&c wiH sliow thst a release has ectufttd since itis last inspccikwi, Rfegplatisn 8-28 also requires
thai a rdtea&e«ve«t loin a pressure relief deviw be r«fsocted to the AFCO on Che next worklsg
day fbliowuig the venting, PetifiCHier siaiss thai neither ihc regulation nw ihe Fermi i iticliKfes
atif monitoring reqmretnerHs to ensure thai the ilrst release event -of a relief valve would ever be
ami tfcat available cdl-CaJe indicators m another objective nmmtortng melted should be
r«*|!sar«d for all pr&sfcurfc tulieif t'st^s ai !te refinery, ragaudlm of a 'vsl're'K release *rv»nl slates.

First, 1FA fediiuvss that t'li# requirement that a fiedky 'eepotl all rc1e<«^ events 10 tie
District is adequate to ensure (hat the first release event would be recorded. EPA also notes that
th^tdfirjesy k $»hj«ci (t> die title ¥ rffqair«m«ni: to certify esropliarioe wife all applicable
te^teractrfs, kdMrig* RepMoii 8-18, Sefis stated abewe, BPA is iteming tfm Petition or> ifus issue

5,	Additional Monitoring Problems Identified by Petitiorter

Petitioner cis-ims thai several sour^&s with, federaly scnforeemblc- limits tmder BAAQMD
Regulation 6  impede nioftiioringoa ths source.

The December 1 r 21103 Slatcmeiil of Basis provides tte Dlstricfs justification fiw not

37

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requiring monitoring. Specifically, the District stated, "Source is capable of exceeding visible
emissions or grain loading standard only during process upset. Under such circumstances, other
indicators will alert the operator that something is wrong." See December I, 2003 Statement of
Basis, n. 4, at 23. [f the source ts not capable of exceeding tbe emission standards at times other
than process upsets, it is reasonable that the District would not require regularly scheduled
monitoring during normal operations. However, if, as stated by the District, S-157 is capable of
exceeding the emission standards during process upsets, monitoring during those periods may be
necessary. While the District stated that indicator? would alert the operator that something is
wrong in the event of a process upset, the District failed to demonstrate bow the indicators or the
operator's response would assure compliance with Lhc applicable limits.

EPA finds in this case that the District's decision to not require monitoring is not
adequately supported by the record. Therefore, EPA is granting Petitioner's request to object to
the Permit as it pertains to monitoring for S-157. The District must re-open the Permit to include
periodic monitoring that yields reliable data that are representative of the source's compliance
with the permit or further explain in the Statement of Basis why monitoring is not needed.

b. Lime Slurry Tanks (S-174 and S-175) / B AAQMD Regulations 6
301,6-310, and 6-311

BAAQMD Regulation 6 contains three standards for which Petitioner objects to the
absence of monitoring. Regulation 6-311 sets a variable emission limit depending on the process
weight rate and the requirements of 6-301 and 6-310 are described above. Regulation 6 does not
contain periodic monitoring requirements for any of the standards and the District did not impose
monitoring on these sources.

As in the previous case for source S-157, the Statement of Basis states that the District
did not require monitoring to assure compliance with Regulations 6-301 and 6-310 because the
"source is capable of exceeding visible emissions or grain loading standard only during process
upset. Under such circumstances, other indicators will alert the operator that something is
wrong," See December 1, 2003 Statement of Basis, n. 4, at 23. The Statement of Basis is silent
on the District's monitoring decision for Regulation 6-311. Therefore, for the reasoiis staled
above, EPA is granting Petitioner's request to object to the Permit as it pertains to monitoring for
sources S-174 and S-175 to assure compliance with Regulations 6-301, 6-310, and 6-311, The
District must reopen the Permit to include periodic monitoring or further explain in the Statement
of Basis why monitoring is not needed.

c Diesel Backup Generators (S-240, S-24I, and S-242) / BAAQMD
Regulations 6-303,1 and 6-310

13AAQMD Regulation 6 contains two particulate matter emissions standards for which
Petitioner objects to the absence of monitoring. The requirement of Regulation 6-310 is
described above and Regulation 6-303.1 limits visible emissions to Ringelmann No. 2.

38

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Rsgplaiioit f» does not contain periodic. monitoring rixjuksiiictits for any of I lie 5 laud aids and ths
District did not impose moniloririg on these sources,

#%s a preliiwiriaiy mallei, Ef*A i»tes thai opacity momtsering is gdneraily not sceesary for
Cmlifsnia sources firing on feci m«l, teed m Hie eQH5i€«?rtbn Phil «ow«» lit California
lasu&Iiy cmnlfiist low*s« I fur fUel,** Therefore, EPA is deriving 1^*1 ft fetter's ss^uest to tfbfec£ io the
Permit as it psriate fo itiomfsrnig tor Regulation 6-303. L

With regard to Regulation 6-310, tte tkcemfesr 1, 2003 Statement of Daafe sets iMh the-
sis fortfa« District's decision that piwfiitonjtg is riot accessary. 5p§cin«Hy, the Pis1.ria slates,

mn^iiOTitf fis] reqainad h®mm ilus sswum will be ttsed fer	att«! rdiaN%

testing only." While tk b tfu« IMt C^raMorc 1S74S stales these engiaes may only be operated tei
**u?iga$e- stnsrgcficy coixtilions^f for reliability-related fccti^flcs to exesaad 10© hours;per

year per sngiiw}, thtecooditiaa is no! federally enforceable. AN«ni federally a^iKewftfefe

r^jsiiictioBs on ilis horns of operation* rlieDiitlfic!^ decision isS to require rii&mtofi?ig is ual

adequately supported. Tjierefoit, EPA is pmting P«itti
-------
BAAQMD Regulation 6 contains one particulate matter emission standard for which
Petitioner objects to the absence of monitoring. Specifically, BAAQMD Regulation 6-311 sets a
variable emission limit depending on the process weight rate. Regulation 6 does not contain
periodic monitoring requirements for any of the standards and the District did not impose
monitoring on these sources.

For ali four emission sources, the Permit requires monitoring with respect to Regulations
6-301 and 6-310 but not 6-311. Given this apparent conflict and the failure of the Statement of
Basis to discuss the absence of monitoring, EPA finds that the District's decision in this case is
not adequately supported by the record. Therefore, EPA is granting Petitioner's request as it
pertains to monitoring for sources S-S, S-10, S-l 1, and S-12. The District must reopen the
Permit to include periodic monitoring for Regulation 6-311 that yields reliable data that are
representative of the source's compliance with the permit or explain in the Statement of Basis
why monitoring is not needed.

H. Miscellaneous Permit Deficiencies

1 Missing Federal Requirements for Flares (Subpart CC)

Petitioner states that the District incorrectly determined that Valero Hares are
categorically exempt from 40 C.F.R, § 63 Subpart CC (NESHAP for Petroleum Refineries),
Petitioner further states that "EPA disagreed with the District's claim that the flaxes qualify for a
categorical exemption from Subpart CC when used as an alternative to the fuel gas system," and
that the Valero Permit and Statement of Basis contain incorrect applicability determinations for
flares S-l8 and S-E9, and that there is not enough information to determine applicability for
flares S-16 and S-l7. Petitioner stales that for all flares subject to Subpart CC, the Permit must
include all applicable requirements, including 40 CF.R. § 63 Subpart A, by reference from 40
CF.R. § 63 Subpart CC. Petitioner goes on to note that Petitioner has requested in past
comments that the District determine the potential applicability of a number of federal
regulations to the Valero flares, including 40 C.F.R, § 63 Subpart A, 40 C.F.R, § 63 Subpart CC,
and 40 C.F.R, § 60 Subpart A, but that the Dislrict did not do so. Petitioner notes that given a
Jack of relevant information, Petitioner was unable to make an independent evaluation of
applicability. Petitioner also alleges that EPA agreed with Petitioner that the District failed to
provide sufficient information for the applicability determinations for flares S-16 and S-70 via
Attachment 2 of EPA's October 8 comment letter. Finally, Petitioner states that EPA must
object to the Permit until the Dislrict provides a sufficient analysis regarding the applicability of
these federal rules to the Valero flares, and until the Permit contains all applicable requirements.

a. 40 C.F.R. Part 60, Subpart A

EPA finds that the applicability of 40 C.F.R. § 60 Subpart A is adequately addressed in
the December 16, 2004 Statement of Basis for Valero. See Statement of Basis at 18 (Dec, 16,
2004). The District has included a table on page 18 of the December 16, 2004 Statement of Basis

40

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ifidiealing applicability of NSPS Sebpan A i« each ofValcxo's flares. Therefore-,, EPA is denying
tins Petition on tfais issue.

b, 40 C.F R. Part 63, Subparts A and CC

40 C. F.R, Pail 63, Subpart OC contains the Maximum. Achievable Cotiftoi Technology
("MACF1 leqmitmmUs for petroleum nsfitieries. Under Subpart CC, the owner w operator of a
Group I siiscellaneotis process vest,. as defined sei § 63 Ml, must leiiuce emis&oc® of Hazaxdous
Atr Pollutants cither by using a flare iftat meets the requirements of section 61. i 1 or by using
anotlier control device to reduce emissions by 9S% a? & a concentration of 20 pprav. 40 CF.R,
§ 63.643(«K I )¦ ^ * flare is used, a device capable of detecting the presence of* pilot flame is
required, 40 C FR. § 67..644(a)(2)

ItoawlraftUty promtom m Subpart CC «naaet forth tit scsiiea 63.640, "AppJiubiiEty
mii design^ kw of affected source.* Ssatofc 63,649(fc) provides ifcai Subpart. CC tppiies to
petroleum refinkg prxjeegg write and elated missions points, Tlie Applicability :^ion further

provides tliist affected £©«««. gubjeel to Siiijpart CC lacUute emteskm points tint m-
^BsedNeeww ptwxa* vaals." 40 C.FR. § $3.640{cKO. The Applicability scaler* atso
provider ih*t affected miK« do not En&fasit: stuissic® points thai Mm seated fa a feel gas. system,
40 C.F.R. f 63.640(d)(5). Gaseous streaa&s routed la a fuel gas sclent are sjxfst&Cidly eraliided
Iront the defitiltion of "imscellioeoiis pieces® vent/1 as *e ^episodic or norwvfirw? leases sitcii
as thos« associalol with startup, shutdown,,	itiaintenaacKs, depressuocig, &nd catalys!

If^for opoaSionsr 40 CJF.ft | 63MI.

The District's Statement of Basis indicates that flares S-IS and S-19 are not subject to
MACT Subpart CC pursuant to the exemption set forth in 40 C.F.R, § (53,6 40(d)(5). See
December 16, 2004 Statement of Basis at IS. In the BAAQMD February 15, 2005 Letter,
BAAQMD again asserted section 63.640(d)(5) as a basis for finding thai the refinery's flares are
not required to meet the standards in Subpart CC- EPA continues to believe that a detailed
analysis of the configuration of the flare and compressor is required to exempt a flare on tlie basis
that it is part of the fuel gas system.

BAAQMD*s February tS, 2005 letter also provides a« alternative rationale (hat gases
vcasted to the refinery's flares r^t within chs dsilniriea or"miacefl^s«o«£ process ^saz."'
Sp«ific?,Hyt BAAQMD assciu that the tre not museeUarwoiw p*xc» v^nist ixscsiise ihoy
are. used only In emtrol "episedie md tKmrntisf'-releaaes, Ai 8 AAQMD states;

.At Mil nf tlw aOfeded refurcriftSj prowss §as collected by the gai- recovery system are
routed to flat«s only ur>dur two drciimftoticw: (I) situations in which, due to process
upset or equipment malfunctions, the gas pressure in the flare header rises to a level that
breaks the water seal leading to the flares; or (2) situations in which, during process
startups, shutdown malfunction, maintenance, depreinsuring (sicJ, and catalyst transfer
operations aw> by defbitior'u not miscellaneous! process vents, and arc not subject to

itt

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Subpart CC

EPA agrees ikat a li&re used only iitider ibe two ctrc^mslsnces described fay the Pistrici
would not be subject to Suhpwi CC becauffc swell ftaes ar^ itoi used to cciMrol ijiiKxIlaficcKis
pi-mma vents as te mm is ddlBerf in 161S4L Acconifig to lilt BAAQMD February 15, 2005
Letter BAAQMI? infeods to revise the Statement of Basis to further explain its xaiiooateihaf
Sul^Mt OC which specifics tte f^jHiiernefits for Authorises to Construct und
FeimiUs lo Operwte, Rute I of tie reguiafi&n cocftaina ttonerfiJv mtisl provide fh? Agency with a
r^aiernenf of ba?k ihat mis forth lie legal «d &claal teis for the perntii  to the State ofTexaj^ 1'heae docaHWJsi? describe sevctaS km
elements- e?f a staleaient of hasis, speciftcifly iielietjg iLm! a Statement Gf basis shoxjid address any

~4fhtt i?«er b	&¦¦ Iftlp:?/wvv^cps-i^/ri^iinj^rogwa^airtU/str't

"07 F«3. 731 (Szmwty 7.3^2)

42

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federal regulatory applicability determinations. The Region V letter also recommends the
inclusion of topical discussions on issues including but not limited to the basis for exemptions.
Further, in response to a petition Hied in regard to the title V permit for the Los Medanos Energy
Center, EPA concluded that a statement of basis should document the decision-making that went
into the development of the litle V permit and provide the permitting authority, the public, and
EPA with a record of the applicability and technical issues surrounding the issuance of the
permit. Such a record ought to contain a description of the origin or basis for each permit
condition or exemption. See, Los Medanos1 at 10,

As stated in Los Medanos, the failure of a permitting authority to meet the procedural
requirement to provide a statement of basis docs not necessarily demonstrate that the title V
permit is substantively flawed. In reviewing a petition to object to a title V permit because of an
alleged failure of the permitting authority to meet all procedural requirements in issuing the
permit, EPA considers whether the petitioner has demonstrated that the permitting authority's
failure resulted in, or may have resulted in, a deficiency in the content of the permit. See C AA
§ 505(b)(2) (objection required "if the petitioner demonstrates .,, that the permit is not in
compliance with the requirements of this Act, including the requirements of the applicable
[SIP]"); see aiso 40 C.F.R. § 70.8(c)(1). Thus, where the record as a whole supports the terms
and conditions of the permit, flaws in the statement of basis generally will not result in an
objection. See e.g.. Doe Run, at 24-25. In contrast, where flaws in the statement of basis resulted
in, or may have resulted in, deficiencies in the title V permit, EPA will object to the issuance of
the permit.

With regard to the Valero Permit, the majority of the sources listed in Table 1IB are
identified in the December !, 2003 Statement of Basis along with a citation from Regulation 2
describing the basis of the exemption. For the sources that fall within this category, EPA finds
that the permit record supports the District's determination for the exempt status of the
equipment. However, in reviewing the December 16,2004 Statement of Basts, EPA noted that
three of the sources listed in Table HB of the Permit are nut included in the statement of basis
with the corresponding citations for the exemptions.24 For these sources, the failure of the record
to support the terms of the Permit is adequate grounds for objecting to the Permit. Thcrcforc,
EPA is granting Petitioner's request to object to the Permit with respect to the listing of exempt
sources in Table IEB but only as the request pertains to the three sources identified herein.
Although EPA is not aware of other errors, the District should review the circumstances Tor all of
the sources in Tabic IlB and the corresponding table in the statement of basis to further ensure
(hut the Permit is accurate and that the record adequately supports the Permit, EPA also
encourages the District to add the citation for each exemption to Tabic [IB as was done for the
Conoco Phillips, Chevron, and Shell permits.

3 Public Participation

^Compare Table HB oflhc Pcrmil with the December I, 2003 statement of basis for the LPG Truck
Loading Rack, ihc TK.-27IO Fresh Acid Tank, and Ihe Cogencration Plant Cooling Tower

41

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Petitioner argues that the District did not, in a timely fashion, make readily available to
the public, compliance information that is relevant to evaluating whether a schedule of
compliance is necessary. Specifically, Petitioner asserts that it had to make several requests
under the California Public Records Act to obtain "relevant information concerning NOVs issued
to the facility between 2001 and 2004" and the "2003 Annual Report and other compliance
information, which is not readily available." Petitioner states that it took three weeks for the
District to produce the information requested in Petitioner's "2003 PRA request." Petitioner
contends that it expended significant resources to obtain the data and received the data so late in
the process that they could not be sufficiently analyzed.

[n determining whether an objection is warranted for alleged flaws in the procedures
leading up to permit issuance, such as Petitioner's claims here that the District failed to comply
with public participation requirements, EPA considers whether the petitioner has demonstrated
that the alleged flaws resulted in, or may have resulted in, a deficiency in the permit's content.
See CAA, Section 505{b)(2)(objection required "if the petitioner demonstrates ... that the permit
is not in compliance with the requirements of [the Act], including the requirements of the
applicable [SIP].") EPA's title V regulations specifically identify the failure of a permitting
authority to process a permit in accordance with procedures approved to meet the public
participation provisions of 40 CF.R. § 70,7(h) as grounds for an objection, 40 C.F.R.
§ 70.8(c)(3)(iii), District Regulations 2-6-4*2 and 2-6-419 implement the public participation
requirements of 40 C.F.R. § 70.7(h). District Regulation 2-6-412, Public Participation, Major
Facility Review Permit Issuance, approved by EPA as meeting the public participation provisions
of 40 C.F.R, § 70.7(h), provides for notice and comment procedures that the District must follow
when proposing to issue any major facility review permit. The public notice, which shall be
published in a major newspaper in the area where the facility is located, shall identify, inter alia,
information regarding the operation to be permitted, any proposed change in emissions, and a
District source for further information. District Regulation 2-6-419, Availability of Information,
requires the contents of the permit applications, compliance plans, emissions or compliance
monitoring reports, and compliance certification reports to he available to the public, except for
information entitled to confidential treatment.

Petitioner fails to demonstrate that the District did not process the permit in accordance
with public participation requirements. The District duly published a notice regarding the
proposed initial issuance of the permit. The notice, inter alia, referenced a contact for further
information. The permit application, compliance pJan, emissions or compliance monitoring
reports, and compliance certification reports are available to th« public through the District's
Web site or in the District's files, which are open to the public during business hours. Petitioner
admits that it ultimately obtained the compliance information it sought, albeit later than it
wished. Petitioner fails to show that the perceived delay in receiving requested documents
resulted in, or may have resulted in, a deficiency in the Permit. Therefore, EPA denies the
Petition on this issue.

44

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IV TREATMENT, IN THE ALTERNATIVE, AS A PETITION TO REOPEN

As explained in the Procedural Background section of this Order, EPA received and
dismissed a prior petition ("2003 OCE Petition") from this Petitioner on a previous version of the
Permit al issue in this Petition. EPA's response in this Order to issues raised in this Petition that
were also included in the 2003 OCE Petition also constitutes the Agency's response to the 2003
Petition. Furthermore, EPA considers the Petition validly submitted under CAA section
505(b)(2), However, if the Petition should be deemed to be invalid under that provision, EPA
also considers, in the alternative, the Petition and Order lo be a Petition to Reopen the Permit and
a response to a Petition to Reopen the Permit, respectively.

V CONCLUSION

For Lhe reasons set forth above, and pursuant to section 505(b)(2) of the Clean Air Art, I
deny in part and grant in part OCE's Petition requesting that the Administrator object to the
Valero Permit. This decision is based on a thorough review of the draft permit, the final Permit
issued December 16,2004, and other docur	1 "

Date

MAR 1 5 2005

Steph
Act in;

AS

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Bib FOR L H!h ADMINIS i H A ! OR
i iMI UD STAITb HNVIRONMI-'NTAL PRO E K" I h \%J\ Si"V

|\ i HI- MA M i'K 01-

UNVX KNVIRONMhNTAI Sk'KVK. I.S I

?KLSHOMJjN'tj U)

}PhnriOM RS* !Krn-p AMKxni.M.. pnh;»h <)Kni-k paiu iai ia nt-NYiNG anij

PAR [ lALLY (">RA\ i l\Q I'l-'fi'l U )\ HAU )B*lt t' HON TO PI-RMi Y

l-l'A ha*, become mvaic of.» iacni.il vnur m ilw K-bn.aiy E, 2006 Order Responding u.
IViilivu.uis"	that fhe AilrmiiKtr.tiur « >bt«i fn Issuance M a proposed Stale Opetaisug

Pcni.it for Onyv l:n\ nonmcnial Kcmcc 'IA cancel fiiai eimi, I ;tm amcntlinii the; February 1
f Jrd»T hv .sinking tun :hc mtuoji ^nuilai "VI Munittmng" ami icplaciuj: it with ihc

I.y^vfir.ij'y rippeisnru; Helow As u rcsul! of the unm ;»m 1 ;iiii iierchv |»j ;*ni1 irti1, the. petition on
titoi is^uc-

1 he amended liii)"u,*iMC lor srr!iit;i \ 1 ,¦> as fulluv,^

S 1. Muiutoring

Hit,' |\-IitiMi!crs rqeue that lb- Administrator insist nhpzci to die proposed

Onvv pcniiit hccitu^t." il liuls Hi mduik conditions that meet the legal requirement1;
for ituniFlonJU',. Hit IVuhi'srxis tilt condi'.u»ti " I RTui on pdge Sft ol the
psypoijed Onyx permit, which pro* utes thuf t Jn> v mi st mssall cahlnate, mumumi.
.iiiti npetute PaHttilL'ifc Matter ( nnfir.unu1; rmiSMon Momtnjx (PM (1 Mf) to
'S'.:iRtaU. ealibiate, mainUm.
;«iJ	titt I'M CFMs until uu h tmv fh.vr r S i PA promulgates all

pe; fijrn.ancL spccilk-atiuiii usiJ a|v,taU.3iial iequnaii<;n[s tor I'M C'fc'Ms"
PrlHsuncis ai'j-Mtc ihat liiere arc iu- PM ini'iiituriiii: KyuuciiK'Uls established stt the
jv.'inut Hithout the ybligafi'in !a (iHial! utld opti.ifc She PM t 'FAR which is
coiuininrtf oil futms. I'.S. hFA	PctitM»n at IK

I' S HJA pHiniiilyatol fhc (it,-lurni.tnti- MHVitlcatioii for PM (TMs

i Pc It iruwnre Ktandunl 1 I / Jis!Vw»«y 11? i! f I £ 14 Hmvevot I, S l-l'A has tiol )fi
pmmiilp/itcfS liitv optratn^mil rcvjiur^nKnls f^.r PM tTMx. Acconhn.uly, the
E\H)uit\;mi'rU to install am! opf.r.ilc PM	ds«es no! i-iurcnlly ;tpply to Onyx,

alilwuttli 0u' pettntt pfupei K iniUHi-s I'M ( TAt > iv>r.. ! S f-HA ptiuimlf.atv.s
Mj.-li r.pctjiional requirement 1 U-u cvet, sishp;ir! i• f.I• c«,)nt;iHiS other

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Fvmmafients uii.fiik-i !<• help ,s„u,c ih the I'M KmU, nriuduiE -
rwi'^rcwciu tui ba..- leak ifctaimn m.wit.nmv ' 1 :iC 1	*^uPPld

w>ili h.o'lious.es, «n«l iheielWc t »nv\ n n ^wiitd :o opt utt ami mnir.Uun ,1 syaar.

nnkiat leak? hum the bai'jlu^rs the perm: c«na«!> lacks |«,fy»wn>
u-uumr.u ;t k.ik dciecliuii sy.slciu. Ac* cr.itnyly. tlichrk »H j cmrtnliv apphcitbii

tt.viuHcni.nl lo opcr.uc ami simio'mh I'M ( f'Ms tloc*.lwC t,ui"C {'lc P?"'*2*
i'r»lac!i! uiiufi .M>r J* R ^.MaK'ToHH). toa I'cwumct* jic correct mat the
nc!-r I.iLkv 'lumiHwttj; rem»twi '.hkUt nth«r pu.Msi.os of 40 C 1 -\R «7<»A .wtd
IhcrcUvc 1 am niujmrv. tin- Fnh«>n ,m ^mu- and acting IH»A rt-vixi-

i.« inCi«TKMal« *11 PM iv• •'rt".'uwiu'red :»» 'He Unl«y umUn subpart

I.t* 1,, na-Sudiiiti a k.ih	v^irm

I a:v. nnf ?e\ issng thi Older issued 1-iHnurv < ;ii
than inm \ I, senum uuh^ i'iiotvi.

Olhcl

ershen I. inimson

SrnPh,,,« «r'.-

t!*€ H'A't' \1 V ! SlatuUiniv \ lu"\ *W>">

Somji H"!\ Inv, k*it ;mviu>.-U ..u.t -!k	no : ^op.rtcl hv il;f',\.	ihc

r,qu,:a^ n, to :«* *lcctMi mU^ h. !*«*«*	':,m "f, ^ was	l"

poprntHK '.he pcraul. IH>\ 4*y.M «Ntfr I»w1 to' pnnif i-r«|HTh fci.lMs all u, tl,e utfiim MA

I r:! IfiC,

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* A

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RESEARCH TRIANGLE PARK, NC 27711

APR 3 0 2014	AIR QUALITY PLANNIMO

mO STANDARDS

MEMORANDUM

SUBJECT: Implementation Guidance on Annual Ctyjipiiance Certification Reporting and Statement
of Basis Requirements for Title V Qpmting/crmits

FROM: Stephen D. Pi
Director

TO:	Regional Air Division Directors, Regions 1-10

I his memorandum and attachments provide guidance on satisfying the Clean Air Act title V annual
compliance certification reporting and statement of basis requirements. It addresses two outstanding
recommendations made by the Office of Inspector General (OIG) in the report titled, "'Substantial
Changes Needed in Implementation and Oversight of Title V Permits if Program Goals are to be Fully
Realized," (OIG Report No. 2005-P-00G1G);

Recommendation 2-1: Develop and issue guidance or rulemaking on annual compliance
certification content, which requires responsible officials to certify compliance with ull
applicable terms and conditions of the permit, as appropriate.

Recommendation 2-3: Develop nationwide guidance on the contents of the statement of basis
which includes discussions of monitoring, operational requirements, regulatory applicability
determinations, explanation of any conditions from previously issued permits that are not being
transferred to the title V permit, discussion of streamlining requirements, and other factual
information, where advisable, including a list of prior title Vpermits issued to the same
applicant at the plant, attainment status, and construction, permitting, and compliance history of
the plant.

In a February 8,2013, memorandum to the OIG, the EPA stated its intent to address these two
recommendations., as well as similar recommendations from the Clean Air Act Advisory Committee's
Title V Task Force 0
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also provide guidance on title V requirements; the I:PA encourages sources to consul! with their state
and local permitting uuthorilics to obtain additional inlbrmation or to obtain specific guidance,

I!" you have am tjuvsfitms, please contact Juan Ktuiliajfu, Associate Director, Air Quality Folic)1
llrvisiorv'OAQPS. at 541-10K4, smtiaga.jimn'Mypa.jinv.

Attachments

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Disclaimer

Tik'M' ilwimaii.\ c.spls/m thr ivtfwn'm'uk oi (he EPA r*%utuUtw> tk.u riin-'y thi' H'A jmheivy otu!
wtrnmiemh /WHViwh mrhumy wrmnmh^v such as "must"
ami "n'lptiraf" fv wtv titled io A'scribe twwW/w*» n'tjuirewctm wider (he terms of the i 'kan Jk.-U-t
umi tftv EPA rt'auhithm. but (he dtteuHtvab do not establish legidl} hbutiny txtfuircmmh in and oj

thi"IH Vt '/V('A

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AlfSlt'lifllMlt 1

Implementation (.uidani-e on Annual C omplianec Certification Requirement I elder the
Clean Air Act Title V Operating Permits Pribram

1. Overview of Title \ and Annual Compliance Certification Hequircmeiits

'I itfe V m the ("lean Air Act (CAA or Aepi establishes an operating permits program for nv.tor
•wirres of air pollutant*, a> well as nther ¦wsuuvs C \ \ sections 501-5"?; 4' I .S.C Sections
''{»<> !~"7%6] t. \ detailed history and desenptiusi uf title V of the CAA available in the pieamble
discussions of both the proposed and final original regulations implementing tick' V the first
promulgation oi 40CI-K Fart 70. See $'! I-K (July 21, I w>2) fFinai Rule); 56 IK 21712
(May 1 <>, ) < Proposed Rule). I he I:PA recently pnmded further information reeardine
compliance certification history in a proposed rulemaking titled. "Aiiicmimciiis to Compli.-uiee
Cetiifkritmn Consent Requirements lor State and Federal < >peiatm$> Permits Programs!,"
published on March 2lK 2ndes title V, stales are required to develop and
implement title V permitting programs in conformance with program rc<)uirements prj upply for ami operate pursuant lo an operating permit. CAA seetiun 5<>2 and
503. The operating pert nit must contain conditions that assure compliance with all of the
sources" appli cable requirements under (he C AA C "AA section 504(a), fitle V also stares, among
other requirements, (tuit sources certify compliance with the applicable requirements of their
permits no [ess frequently than annual h fC \A section 503th)(2)}, provides authority to she CPA
to prescribe procedures for determining compliance and tor monitoring and analy-us of nuJhiuuUs
regulated under the t" \A (CAA section Ni, and requires each permit to "set Ibrih
inspection, entry, monitoring. compliance certification, and reporting requirement to assure
compliance with the permit term,1: and conditions,'" (CAA section

f his pjiidamce document focuses on the annual compliance ceriitieaiion which applies, to the
terms and conditions of i»ued operating permits CAA section 5I]5(>h2! ,sUf>e> that the KPA's
regulations implementing title V '"shun further require the permittee to periodical!) fh.il no less
frequently than annually) certify that the facility is in compliance with any applicable
retjuiicments t>l the permit, and u> promptly report un> Uevialk>ii5> from permit requirements to
ihe permitting aiilliorh} ( A A section 504ui stages that each title V pennil issued :'shail .set
torth inspection. entry, monitoring, compliance certification. and reporting rcqiiitetnents. to
assure compliance wkh tire permit leritiM and eondihoiii-, , , Any report required !o he submitted
by a permit issued lo a corporation under tlii.s subchapter shall be signet! by a responsible
corporate official, who shall certify its accuracy "" Additional requirements of compliance
eeruheatmn ate deserd>ed in section 314(uHe> uf the CAA a.s follows:

The Administrator shall in the ease of any person which is the metier or opciaioi

of h major stationary source, and ma\, in the ease of any olher person, require
enhanced monitoring arni submission of compliance certifications. Compliance
cemtieuuorss shall include i \ ] ideuhuearion of the applicable leqnircmeiu thai is
ihe hasi.s ol'th.e eertilication. i B) the method nscil lor detenninm^ Ihe compliance

1

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status of the source, tO the compliance status, (!)} whether compliance is
continuous or intermittent, \f,\ such other facts as ihe Administrator may require.
Compliance eetliJiCitliiMLs and monitoring data shall lie subject to subsection (c) ol
this section (availability of information to the public |.

( A A section 1	42 t [,S,C, section 74MtaH3), 1 he 111'A promulgated regulations

implementing these piovisions far litle V operating penniis purposes, Key regutaiory provisions
regarding compliance ccilifieutions are found in 40 i'FR section ?0Jnch "Compliance

requirements."

II. ( h ir\ lew of Annual ( iniipliancc i erf illctlMm Requirements

1 he f.l'A's regulations at 40 C'l-R section 70.6(e) describe the required elements of annual1
compliance certifications. Specifically, 40 CTR section 7().6(c )i*j(iii)-(iv> provides thai all
permit's must include the following -innml compliance certification requirements

(iii I A requirement that the compliance certification include ail of the following

{provided that ike identification of applicable information may cross-reference die
permit or previous reports, us applicable):

(A) 1 he identification of each term or condition of the permit thai is the basis of
the certification;

< M) ['he identification of the method(st or other means used bs the owner or
operator for determining the compliance status with each lenrs and condition
durinp the certification period Such methods and oilier means shall include, at a
minimum, die methods and means required under paragraph laM.yl o!' this section1,

(C) The status of compliance with the terms and conditions of the permit for t he-
period covered by the certification, including whether compliance during the
period was continuous or intermittent The certification shall be based on the
method or means designated in paragraph t c H 5 >{ i i i >( H > of this section. 1 he
certification shall identify each deviation and take it into account in the
compliance rerriJlcatknt, The certification shall also identity as possible
exceptions to compliance any periods during which compliance is required and in
which an excursion or exceedance as defined under part 64 of this chapter
occurred: mid

(Dt Such other facts as the permitting authority may require lo determine the
compliance .ifuius of the source

Civ) A requirement thai all compliance certifications he .submitted to the
Administrator as well as to the permitting iuithoiity.

(6) Such other provisions as the permitting authority may require.

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hjriher information 'sinrcnuidui.n compliance certification is described in the reyuLt'ory provision

iiitvtrcswng llic criteria for a permit application. 10 CTR section 70,5tUl, There have been
revisions to Part 70 since its original promulgation in t

One rulemaking action relevant to compliance eerhiici.i5ions w;is in response to an October 2\).
l4W. renmnJ from lite I "niiaS Slates Court of Appals for the District of Columbia Circuit in

SitUtmi Hcwunx-ft />rA'?fU'1 'wi/h'ti t\'RiJC> \. i:P,L 194 F.,'U J,10 <1).(\ Ctr, 1WW). In that ease,
I he Court upheld a portion of the h.PATs compliance assurance monitoring rule, mil remanded
kick the Fl»<\ the need to ensure 4(1 C, FR .sections 70.6(e)(5 ;f u:| and 71 .ftfvK 5'Xtii} were
consistent mill hmgvuige in t A A section JE4tuH 3 i which ,slates that compliance certifications
shall include, ;tmon£ other requirement. " "whether compliance is continuous or intermittent/ "
XHtK' ai I *5 (internal citations omitted}. AccouUn«I>. the Fp.\ proposed to ;idd uppropiiaie
liiiiguugt* to paragraph (c H> j< itsJi't' > of both 40 I 'H< sections M.6 and • I ft i hnvevcr. the Una}
rule on Jinie 27, 200,* jf>8 FR *8518) inadvertently Ueklcd an existing sentence from the
regulations (which was not re hi ted to the addition which resulted from the DC, Circuit decision)
The Oil i Report referenced Ihis issue und in response to (he OKi. us agreed. 1 he FI'A has
proposed to restore the inadwiiemh deleted sentence hack inso the rule .Ve e (e. 7S I R 19104
(March 24), 2(M I '[ Ins proposed rule would reinstate the inadvertently removed sentence -
which. consistent with {Ik C 'rcdible Fvidcnce rule, requires owners and operators of sources to
"identify am other material information that must he included in the certification to comph with
.section 1 UlvK-> of the Act, which piolnbits kr«ov\in>i',> making a certification or omitting
material information" in its original place hctoic the semicolon at She end of 10 CFR sections
70 iN'c.H5){»iMltl and: 71 Cii;c}|i5,)(iii't(Bt The FPA is still reviewing, comments received on this
proposal however, today's uutdanee document is bused on stututojv and Km$-ttutuhiu:
regulatory requirements reyardiny compliance eertiliealion.s, obligations for "'reasonable inquiry"
and constiieration of credible evidence, niaity of which were also relied upon in the H* A's
proposal.

HI. JmpieMH TH.itiuM of ihv Aiiuu:ii < ornplcitur ( tr titi. :ilnm keqtni cmt itts

llic statutory and regulatory provisions regarding compliance certification provide direction to
\ouices and jvnniiiinj' authorities rcgnrdinj' impfcmenution of these prm isions. Nonetheless,
ifucslions arise periodical!) and. us a general mallei, resporidinii to Utuee ^notions l\ piculh
occurs on a euse-by-c;ise basis, consistent with the statutory and rcjmhstory reijjiiiremen'.s. a< well

npplieabk slate or u>c;tl regulations. Questions may he posed u> ;iuthori/ed permiftiiu?
amhorities. M'A Reyionn) Ot'Hecs. or I*HA llc;»d^u;irters offices. >\s a general matter, where
formal responses are provided by 1;PA. such respotKCK m;i>' be searched and \iewed on various
websites ibese include, among other*:

•	hap: leii'M, cpa ^t>v tin tHirptf 'tSpgm him/

*	lutvironmenml .Appeals Rourd i]'AB» decisions on PSD pemninni:

httpy i	govtHt- i\4H tt'cfr i)
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•	The MPA's online searchable database of many PSD ami title V guidance documents
issued by I-PA headquarters offices and J-PA Regions (operated by Region ?>

hup. ti'wii.t'fkt guv )rt:io) As a "best
practice." sources may include additional informattoti uhere there ate unique or complex permit
conditions such that "compliance" with a particular term and condition is predicated on several
elements. In that ease, additional information in the annual compliance certification may he
ad\ isable to explain how compliance with a particular condition was determined and, thus, the
basis tor the certification of compliance,

Consistent with the PPA's legislations, the annual compliance certification must include "fi|he
identification of the methods s) or other means used by the owner or operator tor determining the
compliance status with each term and condition dining the certification period,'" 441 O R section
70 6(en5)(iiil< B) For example, there ma} he situations where certification is based on electronic

t lie t iPA\ pr.tvlicc in 1u publish a nt«u:e in lite I \  R%w>hr imnvutKHi,! tkn a prtttftw ««krr wjn signed Once

-i^ricd, ilw I-PAS pr.iLlFc: iu pi.itv «i cup) nf ;hul ih-af order i»r tbc ntlc V pdifiuit arikv dJltkiMr. which L\

scarelt.ihk

I Ik . ieg.i: require that .i "responsible «|":kial" m.uii the cantpl write cc:lUkali«Ki fhc term "ropoiuihk-
oitlcial" ,>• deluxe hi 4is t FR lion "(i ,t

4

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data irom continuous emissions monitoring deueex nliscii m;\> result in a fairly stiaigj«tinsvar4
aiutuiii compliance uttificatnin. A?icmati\cl>. there sua) be situations nhere compliance during
She reporting period w.i^ determined through paratneit ie monhonng. which requires rhc source to
consider various data and pcrknir. u mathematical calculation, to deiermire the compliance

stalu.s In fhat Uitiei situation when \niio»s thtu from parametric moniiorme nre combined via
calculation. the annual compliance certification may cuJitain mere detail reuaiditu! that term «r
condition which relies on pausmetne monitoring in the pemm.

Regardlessof the !e\e! ol specificity pro\ :ded for she particular terms and conclii-ons in she
annua' certification itself die minimum regulatory 'cqiiirements inehide "|t;lhe identillvation cd
each teim or condition of the peimit that is the basis of the certification " 40 CI R Section
7tU» use tor their annual compliance eertilk'utktn.v Annual Compliance
Certification i,A-Ct)MPk 1PA 1'omt 5IJ'Hi-ti4» at page 4, ;i\ailahic a):

ht{p w'i.' ir f/w jL'fn: turyiHilitx •/«. rmtf.s /«//.< ti-cuwp piif I his limn is no! express!) required for
non-MlA perraitiinu authorities. huwevei, this lorm and the instructions provide feedback
jeyardinp what lo inehide in an annual compliance certification.

Importantly, penmttmy authorises have iidddiona; compliance eertsfteatton requirements and'or

recommendations thai sources should consult before finalizing a compliance certification in
order to ensure compliance wish the applicable teouirerneuts. Ate, op.. 40 ("1 R section
70.ofc

II. Form of the Certification

<\< a general matter, there is no requirement in the Act or hi Part 7ft that a source use a spceilk
Jorni for the compliance certification ialthough swme Mates have adopted specific forms unci
insm:ctioi5Kj f he nuts! relevant consideration in certifications is no: die forni. bin the eonteii!
and ehirity of the terms and conditions with which the compliance status is Kirn' certified Some
stale permitting andiorifes have developed template t'ornu and insiruelions to ussisl source,!, in
ensurinj: compliance with appiieable remtiremenls. 1 Ik* M'A has not provided such templates,
e.xeep! i\s ri. il ni.iv S'v rdpfi i nr »	to rclriuiKu .s'laft't* o.MHfif.tni-c

fi*|'«.»ri hi ri-c ,!nm.,il >i.i'vc \;n"t!v.a«;(i». a- .i;*|ir,ipiCilC

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considered in light of the regulator) requirement Us certify compliance with the specific terms,
and conditions of the permit, 40 C !• K section 7il6i;cH5«ii:NCf Additionally. as, was noted
eailter, because approved state urn! local areas may require additional elements in the annual
compliance certilications, sources shoukl cortllrm that their form is const stem with applicable
slate arid local permitting rvcjitirements.

€, Certification Language

1 lie 1 PA's regulation-; at 40 Cf'R section ?'l,5(dS require lhat the annua! compliance certification
include the following language' "Based ml infortnaiion and belief formed ark^jeasonable
inquire, 1 certify that the statement and intojrnutiini in this eertilkation are true. accurate. and
complete," ff.'tnphasis added, j While the 1 • PA appreciates that each permit includes specific
monitoring require met Us, additional data may be available that indicate compliance ten'
noncompliance! I he L;PA reecnih proposed to put vide additional clarin tm this issue hy
proposing to rvsiore a scnieiKe lo -10 CMt seclum TO/ne'ii ^Hhtji H> that had been inadvertenth
deleted. as disomcd ahi»ve.

IV. Discussion of Compliance Certification Content in ( lean Air Act -Vilvjsnry
Committee Final He-port on the "Title V Implementation Experience

In it it,- HV\\ hchruaf) 8. 201.1, memorandum to the OKi, staled its intern to address the ORfs
recommendation concerning the annual compliance certification, as well as similar
recommendations from the Clean Mr Act Advisory Committee's "1 itle V 1'ask force.4 While this
guidance document responds to the 2005 OKi Report, informaiitm provided above overlaps with
recommendations from the I itle Task force. Tint* ynidance document does not adopt the I ask
force recommendations: however, To she extent thai the\ overlap wish the discussion above, the
f,!}A provides some observations regarding those recommendations.

Section 4 7 of (he 1 ask. force Report discusses compliance certilieation forms. I Itis section
intitules, among other items, eommenis from stakeholders, a summary of the 'I ask force
discussions, and I'ask I tsree recommendations, Of the five recommendations included in ihis
section of the Report, three were unanimously supported hy the I ask force members
t Recommendations 3, -h and 5). Task force f ir.a] Report at M'M 20, KJfVs discussion abm e
regarding the level of specificity and the ibrm of the annual compliance certification generally
addresses the two recommendations lor which there was not consensus within she Task Force
tRecommendations 1 and 2f

1 he five recommendations, directly quoted fn»m the 1 ask force Report, are as ltd lows:

in '\prii' 2fKl£>, Utc i';t»c I ual* 1 oree thiu.iA-d u dikuroent titled," I-tiutf Report u> (he L'lejii Ai: Act A«Jum»i>
t'oiiMi'iuec: Title V lrrip;c;nv"!Uuik>!i 1 \peneTKe ' l'tv.% line ai neat h.k the umu ot'ttv I ,i (cview
liie implementation ,«i*j j.vranmaiicc* fit the ojvs.»t!R£ petmu phniium truier ink- V »»f'ibe I'WO Clean Air Ac;
Arreruiinentv !t;c! ,uk\i in I he icpors ;irc a munber of recomnicnilutiuns, incaxlir.u «mt specife recpmiiicmJiKu.Hi'i
realtime i osnpiuntt cvrr>thai ,t:c consilient wii'lt vmnm; itY.dahrei^ jM mtarrsv.iam pr^vwlui m rr.is
ciikhna"

6

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Reeommendu'don -1, Most a!' the 1'usk force endorsed an approach akm lu ihc "slim
form" certification, hciic\intz thai a Hnedw line ii>tinu perm«1 requirements is no!
retpthed and impose* burdens without additional compliance benefit, I inter this
approach, the compliance certification lutm would include a statement thai the sotttee

was in continuous compliance with permit terms and conditions with the exception of
noted delations and peiiods of intenmllent ecnnpManeo Alihouph th<- permittee
wiuiki cross-reference the permit for fnelh
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Recommendation 4, \\ here a permit term docs inn impose an allirffiauvij nblieation
on the souicc, ihc form should no) require a compliance ceniikatum; e.g., where the
permit stales thai tl docs not convey property rigltis or that the jvnniitittg authority is
tn undertake some aetiv it\ such as provide public nottee uf a revision.

Recommendation 5. All iorms should provide space for the permittee to provide
additional explanation regarding sis compliance vastus ami any deviations identified

during the reporting period.

(ask horce Final He pan a I 31 S-l 20,s With regard to the>c recommendations. the LP A oilers
several observations. First. iherc is nothing m the C A A or Pan 7u that prohibits
Recommendation 3, 4, and 5. which had unanimous support truro ihc I usk Force. &v 40 tl R
see! ion 7!').6tHiviui;iUon, Hi!-* M'A nsk^rvj-. :b.rt tb« vxampk' |vvn uied :a fhc t ,s-»k I nrve Report
uvnario m uhith	ii;itr,i!;u* on tt«e «.i>:nph:iik-c ccn«JiC8tu*»i Mini twaU K* tistrtul te

I'Xf.Liia (lie dctornmrjliur. thin 0,c •source. «.(*> >,m vav> noil m vomplnnH-*" milt ,i p-uiii'it ut;ii nr wihIuiou.

X

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\tt«cimic«t 2

Implementation Ctuidancr 011 Statement of IJasiv Requirements I tula tin Clean Air Act

Title V Operating Permits Program

I.	Ovm iew of i.t'j»al Requirement:* fur Statement of Ba\i*

^eciton 502 ».t the CA \ utkiresses title V permn pmymms pcnerally. \monu oilier required
element of'fhe i;PA\ rukN i«ipicmcntiri|i title V, < \ ingic* stulcd ili.it ihe regulations

i n rl Tide:

Adequate, strettmiined, dikl reasonable procedure* lor expeditiously detenuminu
when applications arc complete. for processing such applications., tot public
notice, including oltcnnp an opportunity for public comment and a heaim*:. iukI
for expeditious res ion of" permit actions, including applications, renewals, or
ie \ isiotJa	

i"AA section 5(12ihl((>i. I he hl'A's regulations implenietiimt: title V a\pj«re that a permsHine
;iuthorii) provide "a statement that set* 'otth the le^al and facUm! has:* for the draft permit
t'omliiiiHis;'ineliKittisi relerences 10 the applicable swtuti»r> or regulatory pro\ isionsj. 'I he
permitting authority shall send [his statement lo the LP A and u< my other person who requests
il." 40 ITR scctin^	A>> win be discussed K*i«nv. :in"toitu othei pui poses, the statement

ol'basis is intended to support (he requirements o'VAA section 502i btfM K pnis idim>
information to aHow for "expeditious" evaluation of (lie permit terms and vondiHous. ;md b\
pixnidiuu information lhal supports public participation 1:1 "die permitting p;oce,s>, considering
other inibrauiiou ks the record,,.

Smee the t-.PA promulgated its Pittt 70 regulations, the hi'A has puutded additional putdanee
;«h3 iulotmaiiort .Mirtoutuime: the statement ol'basK I his informal ion is available on f\P Vs
searchable cwluic database of f ittc V gtridxtnee

ijiHp-":n\w, .i.pa.ittn ¦n'^iunU'r-e>t>'-po!!i'\ itcurfkhtm A search of that database rc% euls
numerous ducumcmis dating hack lo !*>w» thai provide leeUhtek. tenanting !he content of the

statement ollxisis, Because the specific content o!" the statement ot'Kisis depends ?n par* on the
terms and conditions of the individual permit at issue, the I PA's lobulations t»te intended lo
pun ide (lexihtliiy lo the n o! the I'art TO regulations, life hi* A hu^ provided guidance o» recommended
content* of ihc tuiiemcnt nt'hiMs. I aken as a whale, variou.s tiite V pecticfit oTders, and other
documents. partsc-alanA ihove et!cd ;n those oiJei.s, pto\:de a eood roadiriap as to what should he

.&«, f.g:„ iiegwti 1 y	ik Amiwm No, 2: Title Vs Fennit f>eveki.|.nt«iB (Mar.;h l*>. '?96) (avalsR* .viu«.

mMtp;M¥mr,epti4oWrggism?Mii-mik3fiSmi»tm/rJ§tfalpif},

J

-------
ilk lmlcd in a siuieirwm of basis on a permd-by-permit basis, considering, amonp oiher factors,
she technical complexity uf a permit, histor\ of the- lacilily, mid the number of new ptos ssions

being added at ihe lillc V permitting stage. This guidance document identifies a lew such
documents mi example purposes and provides references for tueutiji|,». such materials on the
Internet.

The r PA provided an o\eme\v of this guidance in a title V petition order, hi iiw Mailer of

(hiyx Pnvmrnmcnttd ServH.-eh, Order on Petition No. \ -2UU5-I i bebruar) h if >nyx <>n/i:r)
at 13-14, In the (.hiyx (Jnicr, in Ihe context of a general overview statement on the statement of
basts, the F.PA explained.

A statement ot basis must describe the origin or basis of each permit condition or
exemption, However, it is more than just a short lorm of the permit, it should
highlight elements thai I '.S ! PA and the public would fmd important to review
Rathei than restating the permit, n should list anything that de\ i;ucs from simply a
straight recitation of applicable requirements, The statement of basis should
hiL'hHp.ht items such as ihe permit shield, streamlined conditions, or any
monitoring that is required under 40 C.F.R, •*; 7h.6ta'H3Ki)i B). I hus. it should
include a discussion of the decision-making that went into the development of the
tife V permit and pfovide the pecmininji authoriiy. ihe public, ami I) S, hPA a
reeord of the applicability and technical issue* surrounding the issuance of the
permit. (Footnotes omitted.) Svc, e In Re Port Hudson Opcrntimti; in:nryia
Pacific, IVuuun No, fi-03-Ul, at pages 37-40 (May f), ?00*) r'	Pacific"},

in Mr iktt Run ( 'otvpany Huivk Mill ttmi Mine. Petition No.	at

pages (July	("!k>e Run' >: /« He Port .fame* ('umas AM, Petition

N»». X-l^W-!. at page S {December 22, 2U00) i Ft Juma"}

Onyx Order at 13-U. In the. (h;yx Order, there is a reference io a February IT low. lener that
identified elements which, «t applicable, should be included in the statement of ba>is. lit that
letter to Mr, David Dixon. Chair of the California Air Pollution Control Officers Association
R'APO )A) I'ulc V Subcommittee, the FPA Region *•) Air Division provided a list of air quality

factors to >erve as guidance to California permitting authorities that should be considered when
developi ni! a statement of basis for purpose?* of FPA Region lJ\s review. Specifically. this letter
identified the follow iny: elements which, if applicable, should be included in the statement of

basis;

•	additions of permitted equipment which v.vre not included in the application,

•	identification of any applicable requirements for insignificant activities or Ssate-
reyistored portable equipment (hat have not previously been identified at the I ihe
V facility,

•	outdated SIP requirement .streamlining demonstrations,

•	multiple applicable requirement streamhmru' demonstrations,

•	permit shields,

•	alternative operating scenarios.

•	compliance schedules,

•	CAM requirements.

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•	plaw wide allowable emission limits \ FA I J or other vdtmury limits

•	u operate cir authority to construct permits,

•	periodic monitoring decision?, where ihe decisions »U-vijt<* l'r«»m alrettdy agreed-
upon levels, I iicsc decisions could he pari of the permit package or could reside
in a public i\ available document. (Parenthetical omitted >

hnclusure to f ebutan l^, 1W, icttci fro to Region l> to Mr. David Dixon.

In 21501, in a letter Iron1 the h!\\ to the Ohn> [-siviromik-nta! Protection \p,eney. which is also
cited lu in the Onyx (ink), the I PA explained that.

I lie ! statement of bases.) should aho include factual mtormatiots that is important

for the public to he aware of, I'!,samples include;

f. A listing of ynv I'jtle \* permits issued to the same applicant ;il the
plant site, if any, In some ease;: il may be important lu include the
rationale tor determining (hat .sources are .support facilities,

?, .Attainment slat us.

Construction and permrttinij history of the source.

4, Compliance history rnehuiim'. inspections, any violations noticed, a
listing o!" consent decrees into which the permittee lias entered and
corrective aet)on(s) taken to address noncompliance.

Letter from Stephen Rtfibbluil. FI'A Region u> Robert I imtetihost. Ohio M'A. December 20.
20(11 {available online at hup-' a ww.epa gwregimH7 nw titles	In 2002,

in the context of fsndinp deficiencies with the Stjte of IVxas operating permits prop/arm the I PA
explained thai, ""a statement of hasi*. should me lade, but i< not limited lo. d desc >iption of the
facility, a discussion of any operational flexibility that will he utilized at ihe facility. ihe basis lor
applying (he permit shield, any lederat regulatory applicability determinations and the rationale
sin flic monitoring methods .selected 2" 6*? i R 732, 7i?

(January 7.20021.

The h.PA lias also addressed statement of ha,si,s conical* in additional title V jvUtion orders
(available in an online seaahahle database at

http "www i'jkt.xov rc,>s "'„ title V petition
iirdci h provide information evet: where u >ntlctncm of basis t,s not dirccllv al i,>si;e. for example,
the J'PA has interpreted 40 CH< section 70,7(a'H5> to require thai the rationale lor selected
monitoring nielliods he cleai and documented in she perniit record ta tlw Mniier *>t < 7 A
Rt'fhwif! and C 'hemicuh' f 'ompany LP fi 'flXri//, (Jrder «n Petition No. Vl-2007-01 (Xkiy 28,
2(109} at 7: sa' (tlst> in tiw Stuitvr of Part James ('mius Mill I Ftm Jaawa). Order on Petition \o,
X-100')-1 (December 22. 2000) at page 8 1 his type of hfoinution eon Id he included in ihe
statement of basis. I he b PA, unserves that where such information is included in the statement t»i
basis, this can ficiiitaie a belter understandim*. of ihe rationale for monitoring. Such information
could also be included m osher paib of the permit lecord In addition, it is paiticuknly helpful
when tlie statement nI' busts identifies ke} issues thai the permitting authority anticipates would
be a priority for 1:PA or public review 0or example, if .such is.aies represent i»v conditions or

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mterpietuiions of applicable requirement.-. lha: arc not explicit mi their face >. See v ,t* /'•' t>ic

Sfuth'r (»f ( tmsoitikth-ti iu/Mf/w (V» (if AT. hw K*tw>hvs umi Smm Phm:. < irdcr 011I'ethion No.
11-2001-08 . 21)03} at puyes 37-4(1; /'? lih S fatter af ihw Hun ('umfunn
Bitifk Miil twii liitw {ihw Ru»\. Order on Petition No. VII-PW-UOI (Jul) 3 1, 2002) at pupes
24-26, In ih%' Shift*'* of /(»> Sfcth/no,\ iuwrxy c \>nkr < Order on Petition) iMaj .-4, 2h a vdu»U\ tii-cv provide a yood roadntap as to what should be irtehidcd in a statement oi
basis on a permit-by-permit basis, considering, among other J actors, ihc technical complexity <»i*
the permit, history of the laality, and the number of new provision.-, heinjj added at the title V
permuting staee.;

lit. Discussion nf Statement of Basis Content in Clean Air Act Advisory Committee

Final Report tin the Title V Implementation KvptTience

In the id' Vs 1 ebruiiry S, 2(113. tiiemoraiiduiVi to the OIG. the kPA stated its intent to addte» the
OUTs ~eeoinmendation concerning the statement <•( basis, as well as similar recommendations
from the I lean Air Act Advisory Committee's Title V I ask Force.' While this guidance
doe lament responds to the 2005 (H(i Report, information provided aN >\ e overlaps wish
recommendations from lite Title V Task l\>ree. litis guidance document doe.s not adopt the Iask
I'uice reeonunenduuons: however, to the extent that they overlap with the discussion above, the
IT'A pro\ itie.s some observations regarding those recommendations.

Section 5.5 of the bask 1 oree final Repot t addresses the statement of basis 'litis section includes
a regulator) background piece, comments from stakeholders, a summary olThe 'Task force
discussion*. and I ask force reeommendations. flte recommendations section includes a list of
items considered appropriate for inclusion into a statement of basis, Final Report at 231.

Members of die i ask Force unanimously supported the reoomrnor.daiions regarding the
statement oi'hasts. Because these recommendations overlaps substantially, if not wholly, with
t'uidance previous!;. pro\ ided by I PA, it is appropriate to include these recommendations within
this guidance document as ;m additional guideline lor developing an adequate statement oi'basis

I lie 1 ask force recommended that the following items are appropriate for inclusion in a
statement of basis document:

' Willi rcivird to t'iw title V pi-rueumi; st.-ige. .< K--.1 pr.niicc include ^iakine, pre\ nms i.UtttiitwiO »tj iums aecc.sihtc

to 5,'ive fajckf'i'itur.J mi:	tf.it .tlteaiy exist in the permit; ar.d iiw> tt\: tKinai

stage..

' In April :Mlis the 1 ilk* \ I'tiui1	.s .JiK.tnKiU "I nul H«tn>{i Hi aie tlvM'i Ait Ail Ai stu- f sn'l 1 tree's	to review

t,:ic jn>p;cinfi»tal er, nt*rt aiv a nuiiihei u« arKmiiU'tyatHuiv. ttu .iiUSriji Npet>Jk .vtawnxtHlM^its

i\;4.irdi:!U >.".,itctr,en'. ut Ki-i- eanU'iitN th.it overlap w;th .ire mSurmjine hi tin--	Jvcujr.cu

4

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I A dexei ipliun and explanation of;»ny federally enforceable conditions Iron;
previously issued permits lhat arc not being incorporated into the J'itlc V

pennii.

2. A description and exphsnuituij ouun streitmliiiing of applicable requirements

pursuant to I;.PA While Paper No. 2.
i A description and explanation o-f any complex non-applicability deicrmimwion
(including any request lot a pent)it .shield utsdet section	jhiV) or any

determination that ed to make these
determinations (e.g., source tests, slate guidance documents).

4.	A description and explanation of ;mv dilltrciicc in form of permit terms, and
conditions, as compared to the applicable requirement upon which the
condition was based.

5.	A discussion of tonus and condilions included to provide operiuronal
flexibility under section 70,4{b)s 12).

ft. The rationale, including: the identification of authority, lor any Title V
monitoring decision

Tank Force Final Report at 23!. With reprtl to these recommendations, the I-PA offers several
observations. I"irst. there is nothint* in the CAA or I'.:ri 70 that precludes;; pcrmiftsrsji authority
from including tise items Iisled above in ;t statement of basis. Not sill of those items will apply tn
every permit action (as is the ease with the lists provided by the hl'A in the previously-cited
jnikhmee documents] Second, concerning item tfl. we note that there arc very limited
circumstances in which a condition Irons u previously issued. pennii would not need to be
incorporated into She title V permit Third, concerning item "T 'he "White Paper" refers to
"White Paper Number 2 for Improved Implementation of the Karl 70 Opi*miit\u Permits
Ihoyrum", dated March 5, 1996 (available online at
hujf'-'www.spu gov n'gionO?.\ur^iti'e5 'tUmemm-wtppt-J pti/i

In dew loping the statement of basis, us was discussed ear her, the KPA recommends (hat
permit!!!!!! authorities consider the individual circumstances of the permit action in li<»ht of the
regulatory requitements for the petmit iceoid in oidet to determine whether mloi mutton along
the lines of* the items identified hv the Task Force warrants inclusion mto the statement ol"basis.
In making this determination,, the permitting authority is encouraged to consider whether the
inclusion of such information would prov ide important explanatory information lor the public
and the Ki'A. and bolster (he defensibility otThe pennit Uhus improving the efficiency of the
permit process and reducing the likelihood of rtcei\ine an adverse comment or an appeal), \\hi'e
also c»isuiing that the statutoiy and icguUtU»y leiitnteineiifs ate being met.

s

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Appendix D. Map of Linguistically Isolated Households in the SDAPCD

Page 52 of 59

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0	5

1	i i

N

10	30 Miles

J	I	—I	I	I

I i i [ | i r
0 5 to	20 KiMnMert

PERCENTAGE OF LINGUISTICALLY ISOLATED HOUSEHOLDS AND PERMITTED TITLE V

FACILITIES IN SAN DIEGO COUNTY, CALIFORNIA

I I San Dwgtt Cititriv
A T*k V" (Vittiirttti jW-tlm

Lujfunh	M TQlZi

vwv- liwOh,t IW—did fpgAfc* iia*U flm ttj aifkMuks rrk« J« u»l rn&e* um A*-*'* *M*»' •*»%» p»«*n.r fcuatmirjia tfec <** Am*.* lh

- 4l (WWd	WiVrMM j|l *J» -HffcuM** urn	HfW Am §tmm i*umUa^A« I.* lNiHM» t mtrf+V tU EMlrttiftflliWw iM«# J*»Hw ¦«-»	M-O* *r-,*

m>* «**> !# *« Ujunft, flttf ^ trr	Wt»«4> *»«f* *'•*!« «i *•«*—» ^	«# *»	- J- 
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Appendix E. Fee Guidances

Page 53 of 59

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i€ L

UNIT!	! ENVIRONMENTAL PROTECTION AGENCY

RESEARCH TRIANGLE PARK, NC 27711



AIR

•JING

IS

fMAR 2 7 2010

MEMORANDUM

SI BJKO : Pro^i'Lim anJ l-\.v l.\:ilmnion SlialcLiVjiitd (iiikLince lor -in t11'R Pan 70

Director	/ /

mjf

TO:

Regional Air Division Directors, Regions 1-10

The attached guidance is being issued in response to the Environmental Protection Agency Office
of Inspector General's (OIG) 2014 report regarding the importance of enhanced EPA oversight of state,
local, and tribal1 fee practices under title V of the Clean Air Act (CAA).2 Specifically, this guidance
reflects the EPA's August 22, 2014, commitment to the OIG in response to the OlG's Recommendations
2 through 8 to "issue a guidance document that sets forth a fee oversight strategy" (we refer to the attached
guidance as the "title V evaluation guidance"). The EPA's response to the OIG's other recommendation
is being issued concurrently in a separate memorandum and guidance concerning the EPA's review of fee
schedules for title V programs ("updated fee schedule guidance").3

The title V evaluation guidance is consistent with EPA principles and best practices for efficient
and effective oversight of state permitting programs4 and applies those principles and best practices to the
specific context of title V program and fee evaluations under part 70 of the CAA. As a result, this guidance
highlights opportunities for communication and collaboration between the EPA and air agencies
throughout the evaluation process. Principles and best practices are discussed in Section 1 of the attached
title V evaluation guidance.

1	As used herein, the term ' air agency" refers to state, local, and tribal agencies.

2	Enhanced EPA Oversight Needed to Address Risks from Declining Clean Air Act Title V Revenues; U.S. EPA Office of the
Inspector General. Report No. I5-P-0006, October 20,2014 ("OIG Report").

•' Updated Guidance on EPA Review of Fee Schedules for Operating Permit Programs Under Title V. Peter Tsirigotis,
Director, Office of Air Quality Planning and Standards (OAQPS), U.S. EPA. to Regional Air Division Directors, Regions 1 -
10, March 27, 2018 ("updated fee schedule guidance"). See the EPA's title V guidance website at https://www.epa.gov/iitle-
v-operating-permits/title-v-operating-permit-poUcy-and-guidance-document-index.

4 See Promoting Environmental Program Health and Integrity: Principles and Best Practices for Oversight of St ate
Permitting Programs (August 30, 2016).

Internet Address (URL) « http://www.epa.gov
HoEjeiecl/BnEjciibie « Printed with Vegetable Oil Based Inks oh Recycled Paper {Minimum 2S% Postconsumer)

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Example best practices for conducting part 70 fee or program evaluations described in the
guidance, as well as other existing guidance documents relevant to title V evaluations, include:

Example Best Practices:

•iii The frequency and timing of program and fee evaluations are defined in the Office of Air andiii
Radiation's National Program Manager Guidance (NPM guidance), which is issued for a 2-yeariii

period.3 See Section III of the title V evaluation guidance.iii
•iii The EPA willipost final evaluation reports on publicly accessible websites established for thisiii

purpose. See Section III.D of the title V evaluation guidance.iii

•iii A best practice for resolving concerns that arise during or after an evaluation is to use collaborativeiii

approaches, such as face-to-face meetings between the air agency and the EPAiwhen possible, andiii

preferably prior to taking formal approaches provided for in the part 70 regulations. See Sectioniii

III.Eiofithe title V evaluation guidance.

Other Available Guidance:

•iii EPA guidance on the sufficiency of fees and other fee requirements of pail 70 for permittingiii
programs, including guidance on certain requirements related to fee demonstrations. See Sectioniii
IV of the title V evaluation guidance.iii
•iii EPA guidance on governmental accounting standards tailored to the part 70 program, including aniii
example method for calculating annual fees, costs, and the "presumptive minimum" fee amount;iii
types of revenue that may be counted as "fees"; clarification on the definition of "direct costs,"iii
"other direct costs." and "indirect costs"; and a review of methods for determining indirect costs.iii
See list of EPA guidance on part 70 fee requirements in Attachment B of the title V evaluationiii
guidance.iii

Finally, the title V evaluation guidance contains several attachments:iii

•iii Attachment A is a checklist that may be used by the EPA to help plan for a particular program oriii
fee evaluation using a step-by-step approach with suggested timeframes for completing each step,iii
including a timeframe for the issuance of the final evaluation report.iii
•iii Attachment B is a list of reference documents and other resources that may be useful as backgroundiii

information for reviewing issues that may arise during a program or fee evaluation.iii
•iii Attachment C provides an example annual financial data reporting form. It may be used as a tooliii
to collect information to track an air agency's compliance with certain part 70 fee requirements.iii
The form may be used to track information on fee revenue, program costs, and the presumptiveiii
minimum fee amount for a particular air agency. The example form also includes helpfuliii
explanations of common accounting terms referenced in part 70.iii

The EPA is also working to increase and improve internal collaboration, communication,iii
expertise, and the sharing of infonnation between the EPA staff working on title V evaluations. Foriii
example, as a best practice, the EPA plans to establish an internal system to facilitate staff input on and
sharing of evaluation tools and evaluation reports.

5 See Final FY2017 OAR National Program Manager Guidance Addendum, U.S. EPA, Publication Number 440B16001
(May 6, 2016) (NPM guidance) located at https://wmv.epa.gov/siles/produclion/files/20l6-05/doamients/fyl7-oar-npm-
gttidance-addenditm.pdf

2

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The development of this guidance included outreach and discussions with stakeholders, including
the EPA Regions, the National Association of Clean Air Agencies, and the Association of Air Pollution
Control Agencies.

1 f you have any questions concerning the title V evaluation guidance, please contact Juan Santiago,
Associate Director, Air Quality Policy Division, Office of Air Quality Planning and Standards, at (919)
541-1084 or Santiago, juan@epa.gor.

Attachments

1.	Program and Fee Evaluation Strategy Guidance for 40 CFR Part 70 ("title V evaluation guidance")

2.	Attachment A - Evaluation Checklist for 40 CFR Part 70

3.	Attachment B - Resources

4.	Attachment C - Example Annua! Financial Data Form for 40 CFR Part 70

3

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DISCLAIMER

These documents explain the requirements of the EPA's regulations, describe the EPA's policies, and
recommend procedures for sources and permitting authorities to use to ensure that program evaluations
and fee evaluations are consistent with applicable regulations. These documents are not a rule or
regulation, and the guidance they contain may not apply to a particular situation based upon the
individual facts and circumstances. The guidance does not change or substitute for any law, regulation,
or any other legally binding requirement and is not legally enforceable. The use of non-mandatory
language such as "guidance, " "recommend, " "may, " "should, " and "can, " is intended to describe the
EPA's policies and recommendations. Mandatory terminology such as "must" and "required" is
intended to describe controlling requirements under the terms of the Clean Air Act and the EPA's
regulations, but the documents do not establish legally binding requirements in and of themselves.

4

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Program and Fee Evaluation Strategy Guidance for 40 CFR Part 70

I. Principles and Best Practices for EPA Oversight of Permitting Programs

As part of the EPA's ongoing efforts to strengthen partnerships with state, local, and tribal
agencies (referred to here as, "air agencies'"), in 2016, the EPA established common principles
and best practices for oversight of state permitting programs for air, water, and solid waste. See
Promoting Environmental Program Health and Integrity: Principles and Best Practices for
Oversight of State Permitting Programs, August 30, 2016.' The principles and best practices are
intended to promote efficient and effective oversight that optimizes both collaboration and
accountability in support of program health and integrity.

The title V evaluation guidance aligns with these principles and best practices and will consider
them in title V evaluations of local and tribal air permitting programs as well as state programs.
For example, this guidance provides for air agency evaluations that will be accomplished through
clear, accurate, and up-to-date guidance, including guidance on evaluations and fee requirements
for air agencies; routine review of air agency programs to identify and implement program
improvements; requirements for yearly program evaluations on timeframes established in the
Office of Air and Radiation's National Program Manager Guidance (NPM guidance);2 the use of
tools, including checklists, for planning and tracking the timely completion of evaluations;
opportunities for collaboration between the EPA and air agencies throughout the evaluation
process; and electronic posting of final evaluation reports.

II. Summary of Title V Requirements for Air Agencies
A. Ceneral Program Requirements

Title V of the Clean Air Act (CAA or Act) of 1990 establishes an operating permit program for
major sources of air pollutants, as well as some other sources.3 The EPA promulgated regulations
under 40 CFR part 70 (part 70), consistent with title V of the Act, to establish the minimum
elements for operating permit programs to be administered by permitting authorities.

Air agencies with approved permit programs under part 70 must comply with minimum permit
program requirements, such as reviewing application forms, adhering to certain permit
processing procedures (including timeframes), ensuring certain permit content, collecting fees
sufficient to fund the program, providing for public participation and EPA review of individual

1	The report is located at https://yvww.epa.gov/sites/productiort/files/2016-
IO/documents/principles_and_best_practices Jbr_oversight of state perm itting_programs. pi!)¦

2	The latest NPM guidance is for FY 2018 and FY 2019: Final FY2018 - 2019 OAR National Program Manager
Guidance, U.S. EPA, Publication Number 440P17002 (September 29.2017) (NPM guidance) located at
https://Mnnv.epa.gov/sites/production/files/20/ 7-09/documentsffy / 8- / 9-oar-npm-guidance.pdf. The most recent
NPM guidance should be consulted for specific program requirements and timeframes.

3	See CAA §§ 501-507; 42 U.S.C. §§ 7661-766If.

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permits, and supplementing permits with compliance provisions (when needed), among other
requirements.4

B. Summary of Title V Fee Requirements

The EPA is issuing a separate memorandum and updated fee schedule guidance on the activities
that constitute title V permit program costs and must, therefore, be funded by permit fees. The
requirements for air agency fee programs are further discussed in Section 1 of the updated fee
schedule guidance.3 This title V evaluation guidance identifies best practices and guidance on
EPA oversight of air agency fee programs, particularly through program and fee evaluations.
Attachment B of the title V evaluation guidance provides a list of all previously issued EPA
guidance on part 70 fee requirements. The following is a summary of the fee requirements that
will guide the EPA reviews of air agency programs:6

•	Permit fees must be paid by "part 70 sources,"7 and the permit fees must cover all
"reasonable (direct and indirect) costs" of the permit program.8 If the permit fees at least
cover the total permit program costs, the fees are deemed to be sufficient.

•	Permit fees paid by "part 70 sources" are "exchange revenue" or "earned revenue" in
governmental accounting terminology because a good or service (e.g., a permit) is
exchanged by a governmental entity for a price (e.g., a permit fee).9 Only revenue
classified as "exchange revenue" should be compared to costs to determine the overall
financial results of operations for a period.i° This means that no legislative
appropriations, taxes, grants," fines and penalties, which are generally characterized as

4	See 40 CFR §§ 70.1(a) and 70.4.

5	Updated Guidance on EPA Rex'iew of Fee Schedules for Operating Permit Programs Under Title V, Peter
Tsirigotis, Director. OAQPS, to Regional Air Division Directors, Regions 1-10, March 27, 2018 (updated fee
schedule guidance).

h See the updated fee schedule guidance at Section I. General Principles for Review of Title V Fee Schedules.

7	The term "part 70 sources" is defined in 40 CFR §t70.2 to mean "any source subject to the permitting requirements
of this part, as provided in 40 CFR §§ 70.3(a) and 70.3(b) of this part."

8	See CAA section 502(b)(3)(A); 40 CFR § 70.9(a).

9	See Statement of Recommended Accounting Standards Number 7, Accounting for Revenue and Other Financing
Sources and Concepts for Reconciling Budgetary and Financial Accounting, issued by the Federal Accounting
Standards Advisory Board (FASAB) ("FASAB No. 7") at page 2 and see Statement No. 33, Accounting and
Financial Reportingfar Nonexchange Transactions (December 1998), issued by the Governmental Accounting
Standards Board (GASB) at pages 1-4.

10	See FASAB No. 7 at page 8. For example, see Governmental Accounting Standards Series, Statement No. 33,

Accounting and Financial Reporting for Nonexchange Transactions (December 1998), issued by GASB, and
Statement of Recommended Accounting Standards Number 7, Accounting for Revenue and Other Financing
Sources and Concepts for Reconciling Budgetary and Financial Accounting, issued by FASAB.

" Since part 70 fees are "program income" under 40 CFR § 31.25(a), part 70 fees cannot be used as match for
section 105 grants, and no state may count the same activity for both grant and part 70 fee purposes. See an
October 22, 1993, memo (and several other memos) on this subject, listed in Attachment B of this document.

2

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"non-exchange revenue,"!2 should be compared to program costs to determine if permit
fees are sufficient to cover costs.

•iii Any fee required by part 70 must "be used solely for permit program costs"—in otheriii
words, required permit fees may not be diverted for non-part 70 purposes.1314 Nothing iniii
part 70 restricts air agencies from collecting additional fees beyond the minimum amountiii
needed to cover part 70 program cost; however, all fees (including surplus) must be usediii
for part 70 purposes.iii

•iii During permit program implementation, the EPA may require "periodic updates" of theiii
"initial accounting" portion of the "fee demonstration" to show whether fee revenueiii
required by part 70 is used solely to cover the costs of the permit program.15

•iii During program implementation, theiEFA may also require a "detailed accounting" toiii
show that the fee schedule is adequate to cover costs when an air agency changes its feeiii
schedule to collect less than the "presumptive minimum"16 or if the EPA determines,iii
based on comments rebutting a presumption of fee sufficiency or on the EPA'siowniii
initiative, that there are serious questions regarding whether the fee schedule is sufficientiii
to cover the permit program costs.17

12	"Nonexchange revenue" arises primarily from the exercise of governmental power to demand payment from the
public (e.g., income tax, sales tax, property taxes, fines, and penalties) and when a government gives value directly
without directly receiving equal value in return (e.g., legislative appropriations and intergovernmental grants).

13	Part 70 purposes are all activities in a permit program that must be funded by part 70 fees. As the EPA has
previously explained in the EPA's November 1993 memo, Title V Fee Demonstration and Additional Fee
Demonstration Guidance ("fee demonstration guidance"), the types of activities included in a permit program to be
funded by permit fees, and the costs of those activities will differ depending on many factors associated with the
particular permitting authority. These include the number and complexity of sources within the area covered by the
program; how often the permitting authority reviews permits (e.g., some permitting authorities may renew permits
every year instead of every 5 years); the universe of sources covered (i.e., some permitting authorities may not opt to
def er permitting for non-major sources); the experience of the permitting authority with permitting (e.g., agencies
with permitting experience may not need as extensive training programs as those with no operating permit
experience); and many other factors. Each permitting authority will have to determine its own permitting effort and
what activities are directly or indirectly concerned with operating permits.

14	See 40 CFR § 70.9(a).

15	See fee demonstration requirements at 40 CFR §§ 70.9(c) and 70.9(d) and see the EPA's November 1993 memo,
Title V Fee Demonstration and Additional Fee Demonstration Guidance ("fee demonstration guidance'"}, on
preparing fee demonstrations for the initial part 70 program submittal.

16	A fee schedule that would result in fees above the "presumptive minimum" is considered to be "presumptively
adequate." The "presumptive minimum" is generally defined to be "an amount not less than $25 per year [adjusted
for increases in the Consumer Price Index] times the total tons of the actual emissions of each "regulated air
pollutant (for presumptive fee calculation)" emitted from part 70 sources." Note that the calculation of the
"presumptive minimum" also excludes certain emissions and adds a "GHG cost adjustment." See 40 CFR
70.9(b)(2)(i) through (v).

17	See 40 CFR § 70.9(b)(5) and Section 2.0 of the fee demonstration guidance for an example "detailed accounting."
The scope and content o fa "detailed accounting" may vary but will generally involve information on program fees
and costs and accounting procedures and practices that will show how the air agency's fee schedule will be
sufficient to cover ail program costs.

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Ill.iii Best Practices for EPA Evaluation of Part 70 Programsiii

This section includes an overview of title V program and fee evaluations and describes the
EPA's recommended best practices for conducting program and fee evaluations. This includes a
general process and recommended steps for conducting such evaluations, including a timeframe
for completion of final evaluation reports. This section also includes recommendations for
activities that may occur after a final evaluation report is issued, including for resolution of
concerns raised during an evaluation process, and for public posting of final evaluation reports.

A.iii Overview of Part 70 Program and Fee Evaluationsiii

In its oversight capacity, the EPA periodically evaluates part 70 programs to ensure that they are
being implemented and enforced in accordance with the requirements of title V and part 70.
Program and fee evaluations help the EPA pinpoint areas for program improvement, determine if
previously suggested areas of improvement have been addressed by the air agency, and identify
best practices that can be shared with other air agencies and the EPA Regions to promote
program health and integrity.

The frequency and timeframes for conducting part 70 evaluations are documented in the NPM

18

guidance.aTherftequency and timeframe for a specific evaluation should be consistent with the
NPM guidance for the period in which the evaluation occurs.19 The current NPM guidance
requires each EPA Region to complete one part 70 evaluation each year. This means that final

evaluation reports should be issued within a 1 -year timeframe.20 It may be possible for the EPA
to complete some evaluations on a shorter timeframe than specified by the NPM guidance when
the scope of an air agency evaluation is tailored to some element of the program, based on
previous performance, as evidenced by previous evaluations. Looking for these opportunities and
completing evaluation reports in less than a year is encouraged as a best practice.

Program evaluations can be conducted on any particular element or elements of the part 70
program, including the complete program, or the air agency's implementation (including fee
reviews), enforcement, and legal authority for the program.

As a best practice, the EPA Regions should reviewqprevious evaluation results that may help
inform and tailor the appropriate scope of an upcoming evaluation and may give particular focus
to issues that have previously been identified as problematic. In addition, the EPA Regions
should be aware of any recent statutory or regulatory changes (including to federal or state rules)
and may want to focus part of the evaluation on these newer implementation areas.

18	The final FY 2018 - 2019 NPM guidance includes a goal for the EPA Regions to perforin an evaluation for at
least one permitting authority for each EPA Region per year. The Regional goals in the guidance are reviewed
periodically and may change in the future.

19	The NPM guidance is currently revised on a 2-year cycle. The current guidance is effective for fiscal years 2018
and 2019.

20	The EPA notes that program or fee evaluations are not currently required to begin on the first day of the fiscal
year; thus, an evaluation may start during one fiscal year and end during the next fiscal year.

4

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To ensure that permitting authorities have adequate resources to implement their part 70
programs, another best practice is to conduct a fee evaluation as part of the overall program
evaluation. The content and scope of a fee evaluation may be specific to the air agency being
evaluated, but frequent topics include those identified in Sections 11.B and IV of this title V
evaluation guidance.

B.	Preparing for Title V Evaluations

Developing an evaluation checklist and an evaluation questionnaire can help expedite the
program review process and is considered a best practice for the EPA Regions in preparing for a
part 70 program evaluation. An example evaluation checklist, to plan for and track the progress
of a particular evaluation, is provided in Attachment A. An evaluation checklist provides a
framework of specific topics to be evaluated and recommended steps leading to issuance of a
final evaluation report, including a timeline based on the 1-year timeframe of the current NPM
guidance. Note that the timeframes for the individual steps in the example checklist are flexible,
provided the I-year overall timeframe is met. Another recommended best practice is to share the
checklist with the air agency prior to the actual evaluation to assist them in preparing for the
evaluation.

An evaluation questionnaire is another tool that the EPA Regions may prepare in advance of an
evaluation. Typically, an evaluation questionnaire is a compilation of specific questions intended
to gather information and data from an air agency to assist the EPA in its evaluation of a
particular part 70 program. As a best practice, the EPA Regions should share draft questionnaires
with other EPA Regions or Headquarters offices to seek input and share "lessons learned" prior
to transmitting to the air agency. Collaboration can enhance national consistency and help the
Regional office learn from the experiences of other Headquarters offices.

C.	Information and Data Gathering Phase

An important initial step of any program or fee evaluation is gathering information about current
program implementation. Typically, an evaluation formally begins when the EPA Region sends a
letter to the air agency informing the agency of the EPA's intent to conduct an evaluation, with a
request for specific information and data needed to conduct the evaluation. Usually such a letter
will be preceded by an informal call or email to provide the air agency with notice of the
evaluation. The letter should specify the scope of the evaluation and a timeline for when a
response from the air agency is expected. As a best practice, if the EPA Region intends to use an
evaluation questionnaire, that questionnaire should be included with the letter.

The next recommended step is for the air agency to respond in writing to the EPA's questions
and provide the information or data that was requested. The length of time to complete this step
is dependent on the scope of the evaluation and the air agency's data collection systems. If the air
agency foresees an issue with providing the information requested in a timely manner, it should
reach out to the EPA Region to discuss steps to address the issue and reach consensus on a
revised timeline.

If resources allow, the EPA Region should, as a best practice, conduct an in-person meeting with
the air agency shortly after sending the letter (and questionnaire if one is to be used) to answer

5

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preliminary questions on timing and scope. In addition, the EPA Region and the air agency could
hold a follow-up meeting to discuss the air agency's draft response. In preparing for these
meetings, the EPA staff should make every effort to gather as much relevant information as
possible before meeting with the air agency in order to make the best use of time.

In addition to the evaluation questionnaire, another method for collecting information or data for
an evaluation includes file and permit reviews. File reviews may also be used by the EPA to
evaluate the effective implementation of certain program responsibilities (e.g., to quality assure
fee collection procedures). The EPA may use a permit review (reviewing a sample of issued
permits) to evaluate whether the air agency is satisfying permit-content requirements and permit-
issuance procedures in practice.21

D. Evaluation Report Phase

The EPA staff should document each title V evaluation in an evaluation report. The report may
describe concerns identified during the evaluation and, if any concerns are identified, may
include recommended corrective actions with intended timeframes for resolution. The EPA may
also ask the air agency to provide an explanation of how it will resolve these concerns and an
estimate of the timeframe needed for the air agency to complete its work.

The EPA staff drafting the evaluation report should consult with Regional management or
Headquarters offices as needed, particularly if the report addresses nationally significant issues.
Once completed, the draft evaluation report's findings and recommendations, including those
addressing novel or controversial issues, should be shared with EPA management and other
offices.

As a best practice, the EPA should provide the draft report to the air agency with an option to
provide comments back to the EPA. During this time, the EPA and the air agency may also
choose to have further discussions of the draft report findings. If further discussion occurs,
additional time may be necessary to complete the final report and corrective action plan.

After attaching any air agency comments to the report and revising the report to incorporate
input from EPA management and the air agency being evaluated, the final report should be
signed by the relevant EPA air program manager or other designated EPA official. The final
report should then be transmitted to the air agency and an electronic copy should be posted on a
publicly accessible website maintained by the EPA (the Regional websites are linked to the
national webpage for the part 70 program).22 As a best practice, any supporting information
related to the evaluation should be posted on the EPA website with the final report, including the
air agency's response to the questionnaire, relevant communications, and other supporting data.
Approaches used to address novel or controversial issues should be summarized and shared for
potential use in future reviews.

21	See 40 CFR §§ 70.6 and 70.7.

22	See hitps:/fwww.epagov/title-v~operating-permits/epa-oversight-operating-permits-program.

6

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The EPA may provide an opportunity for the air agency to respond in writing to the final
evaluation report, particularly in cases where the EPA identified concerns but a corrective action
plan was not agreed upon during the preparation of the final report. This step is not necessarily
part of the evaluation process and may proceed on a separate track. The EPA would not expect
such responses to necessarily be part of the final report, particularly in cases where the responses
occur after the final report has been transmitted to the air agency. However, these post-report
responses may be included as supporting information on the website, along with the final report.

The EPA encourages its staff to, where possible, conduct in-person meetings with their air
agency counterparts in order to best facilitate resolution of any issues identified in the report.
Depending on the complexity of the issue, such face-to-face meetings may be facilitated by the
involvement of a third-party negotiator or other EPA offices (e.g., the Office of the Chief
Financial Officer) as appropriate. Such meetings may prove useful to resolve straight forward
issues that can be expeditiously resolved (e.g., permit administration or implementation issues
that do not require regulator}' changes), as well as to discuss long-term plans for resolving more
complex issues (e.g., where resolution may involve changes to statutory authority, regulatory
changes, or a multi-step process that may take multiple years to complete). In cases where initial
discussions between the EPA and air agency staff do not result in a plan to resolve issues, a best
practice is to elevate the issue to the management level (e.g., EPA and air agency management).

Finally, if the issue resolution process described above fails to resolve the issues identified
during a program or fee evaluation, the EPA has the authority to consider whether an official
EPA finding of a program deficiency is warranted.23 The decision to make such a finding should
be coordinated with EPA management at the Regional and Headquarter level. Section 502(i) of
the Act provides that whenever the EPA Administrator determines that an air agency is not
adequately administering or enforcing a title V program, or any portion of a title V program, the
EPA shall provide notice to the air agency and may take certain measures intended to incentivize
compliance. In practice, the EPA refers to the determination as a "finding," the inadequate
administration or implementation as a "deficiency," and the notice as a "Notice of Deficiency"
(NOD).24 The EPA will use its bestjudgment to decide when a finding of a program deficiency
is warranted; whenever such a finding is made, the EPA will issue an NOD and follow the
requirements that flow from that finding.

25 See 40 CFR §§ 70.! 0(b) and 70.4(i)( 1).
24 NODs are published in the Federal Register.

1

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IV. Assessment of Fee Sufficiency and Other Fee Requirements

This section discusses the requirement for part 70 permit fees to be sufficient to cover program
costs, including requirements for updates to certain elements of part 70 fee demonstrations,
including for "periodic updates" to the "initial accounting" and for a "detailed accounting" in
certain circumstances. This section also discusses Attachment C, which is an example annual
financial data reporting form that may be used to report fee revenue, program costs, and to
calculate the "presumptive minimum" for an air agency for a particular year.

Fee sufficiencv.aThe part 70 rule uses the term "sufficient" in relation to fees and costs.23 Since
the question of whether fees are sufficient is a key concern that may be considered by the EPA as
part of a program or fee evaluation, further explanation may be helpful:

•	Section 502(b)(3)(A) of the Act requires permit programs to fund all "reasonable (direct
and indirect) costs" of the permit programs through permit fees collected from sources.
Similarly, part 70 requires the fees to be paid by "part 70 sources."26 requires the fees to
be sufficient to cover all reasonable permit program costs, and requires the fees to be
used "solely" for permit program costs.27

•	The costs against which fees are compared must include, at a minimum, certain activities
required by the part 70 rules28 and all "reasonable (direct and indirect) costs."29
Additional discussion on the revenue and costs that should be used in this comparison is
provided in the separate updated fee schedule guidance as well as Section II.B of this title
V evaluation guidance.

•	If concerns regarding fee sufficiency are raised by the EPA, the EPA will typically follow
the issue resolution procedures discussed in Section lll.E of this title V evaluation
guidance.

Initial fee demonstration. As part of the initial part 70 program submittal to the EPA, air agencies
are required to provide a "fee demonstration" to show that the fee schedules selected by the air
agencies would result in the collection and retention of fees in an amount sufficient to meet the
fee requirements of part 70.30 The contents of the "fee demonstration" vary depending on the
status of the air agency with respect to the "presumptive minimum":

25	See 40 CFR §§ 70.9(a), (b) and (c).

26	The term "part 70 sources" is defined in 40 CFR § 70.2 to mean "any source subject to the permitting
requirements of this part, as provided in 40 CFR §§ 70.3(a) and 70.3(b) of this part." Thus, a source is a part 70
source prior to obtaining a part 70 permit if the source is subject to permitting under the applicability provisions of
40 CFR § 70.3.

27	See 40 CFR § 70.9(a).

28	See 40 CFR § 70.9(b)(1).

29	CAA section 502(b)(3)(A).

50 See the fee demonstration requirements at 40 CFR §§ 70.9(c) and 70.9(d) and the EPA's November 1993 memo,
Title V Fee Demonstration and Additional Fee Demonstration Guidance ("fee demonstration guidance"), on
preparing fee demonstrations for the initial part 70 program submittal. See 40 CFR § 70.9(c), (d).

8

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•	Air agencies with fee schedules that would result in fees abovedhe "presumptive
minimum" are required to submit a "presumptive minimum program cost" demonstration
showing that the expected fee revenue would in fact be above the "presumptive
minimum"31 and also provide an "initial accounting"32 to show that fees would be used
solely to cover part 70 program costs.

•	Air agencies with fee schedules that would result in fees below the "presumptive
minimum" are required to submit a "detailed accounting"33 showing that the expected fee
revenue would still be sufficient to cover part 70 program costs and an "initial
accounting"34 to show that the required fees would be used solely to cover part 70
program costs.

Also, as part of the initial program submittal, part 70 requires the submittal of several additional
elements with respect to program costs.33

Detailed accounting. After program approval, a "detailed accounting" that permit fees are
collected and retained in an amount sufficient to cover all reasonable direct and indirect costs is
required in the following two circumstances:56

•	When an air agency sets a fee schedule that would result in an amount less than the
"presumptive minimum,"37 or

•	When the EPA determines—based on comments rebutting the presumption or its own
initiative—that there are serious questions regarding whether the fee schedule is
sufficient to cover costs.

A "detailed accounting" for an approved part 70 program would be based on data on fee revenue
and program costs. The level of detail required in the "detailed accounting" remains at the
discretion of the EPA and will depend on circumstance-specific factors related to the air agency
being evaluated.38

Periodic updates.aAf'ter program approval, the EPA may require "periodic updates"39 to the
"initial accounting" element of the fee demonstration to confirm that required fees are being used
solely to cover part 70 costs. A "periodic update" for an approved part 70 program is based on

31

This fee demonstration is referred to as the "presumptive minimum program cost" demonstration in Sections 1.1

and 3.2 of the EPA's November 1, 1993, memo. Title V Fee Demonstration and Additional Fee Demonstration
Guidance ("fee demonstration guidance'),

31 See 40 CFR § 70.9(d).

33

§ff §PK | ?§:§fffl(5) and an example "detailed accounting" in Section 2.0 of the fee demonstration guidance.
M See, e.g., 40 CFR § 70.4(b)(8)(v).

36	See the "detailed accounting" requirements at 40 CFR § 70.9(b)(5)(l).

37	The calculation of the "presumptive minimum" is provided in 40 CFR §§ 70.9(b)(2)(i) through (v).

31 See the fee demonstration guidance. Section 2.0, for an example ''detailed accounting."

39 See the "periodic update" provision at 40 CFR § 70.9(d).

9

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records showing that required fee revenue is actually being retained and used to cover the
reasonable direct and indirect costs of the part 70 program.

Example annual financial reporting form.a\ttachment C of this title V evaluation guidance is an
example annual financial reporting form for part 70. This tool may be used to help track the
collection of fee revenue, program costs, and the presumptive minimum fee amount for a
particular air agency. Attachment C also includes helpful explanations of common accounting
terms used for part 70 purposes. This example annual financial reporting form represents one
way to collect the information previously described and is not required by part 70 for any
particular oversight activity.

V.iii Identification of Financial and Accounting Expertise for Fee Reviewsiii

TheaOIG Report requested thatathe EPA explain how to leverage financial or accounting
expertise toaassist with fee evaluations. Historically, the EPA staff with scientific, engineering, or
similar technical degrees or experience are tasked with air agency program and fee evaluations.

A recommended best practice is to seek the assistance of existing EPA staff with governmental
accounting, financial, or economics expertise, who work outside of the part 70 program (e.g.,
staff involved in grants administration or in determining the economic penalty of noncompliance
for civil penalty assessment) to assist with fee evaluations as needed. One way for the EPA to
seek internal assistance for fee evaluations would be to offer a formal detail opportunity
(a temporary reassignment for a set period of time) for a financial or accounting professional to
work on part 70 evaluations. Another way to seek internal EPA assistance would be to use the
EPA's Skills Marketplace.40

EPA staff without financial or accounting expertise who want to become familiar with state,
local, or tribal financial and accounting standards and practices may consider reviewing
governmental accounting guidance issued by the national accounting standards board (e.g., the
Governmental Accounting Standards Board (GASB)) and financial or audit reports generated by
the air agency. Financial oraaccounting audit reports generated by the air agency may also
provide useful data, address emerging issues with the part 70 program, or confirm that known fee
issues are being addressed.

Financial or accounting guidance.aThe primary focus of part 70 fee evaluations is to review
whether the air agency's fee program is being implemented consistent with part 70 requirements
(see Section II of this guidance. Summary of Title V Requirements for Air Agencies). The focus
of fee evaluations under part 70 is different from the focus of typical financial or accounting
"audits" (as that term is used in the accounting profession).41 Attachment B of this guidance

40	The Skills Marketplace is a component of the EPA's recently launched Talent Hub Portal SharePoint site located
at: https://usepa.sharepoint.com/sites-/OA_Applicalions/TalentHnb/smp/SitePages/Home.aspx.

41	In the accounting profession, the primary purpose of an audit is to verify that financial statements of governmental
or private entities are consistent with specific accounting criteria.

10

-------
includes several examples of governmental accounting or financial guidance and other resources
that may be useful for technical staff to build expertise in these areas.

Financial or accounting audit reports generated bv air agencies. Audit reports or financial reports
prepared by air agencies for their own accounting, budgeting, or oversight purposes may include
useful background information for fee evaluations, including caseload statistics, historical
funding patterns, funding sources, and identification of program performance issues. The GASB
requires air agencies to prepare annual financial reports to determine compliance with their
budgetary requirements or finance-related requirements. Most air agencies follow these
requirements through review of financial reports by an auditor, with preparation of the reports by
the air agency budget office, legislature, or by the department itself. Most air agencies also
require local programs to be audited for submittal to the state auditor. These financial audits are
typically conducted at the departmental level, but part 70 data may be available upon request.
Such reports are not required by the EPA, but, if available and timely, they may provide useful
information for program or fee evaluations.

11

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ATTACHMENT A

Evaluation Checklist for 40 CFR Part 70

Regardless of the type of evaluation being conducted (program, fee, or combination of the two),
the EPA describes the evaluation process as consisting of two phases: 1) Information and Data
Gathering Phase and 2) Evaluation Report Phase, each of which is composed of several
recommended steps. The requirement of the EPA's national program manager guidance ("NPM
guidance) for fiscal years 2018 and 2019 is for part 70 evaluations to be completed within 1
year.1 The checklists in Tables 1 and 2 describe the phases, recommended steps, and timeframesaaa
for each phase and step, leading to completion of the evaluation process within the I -year
timeframe.

The EPA Regions may revise this checklist to meet their needs. For example, the column for
recommended duration could be replaced with expected dates for completion of each step for
planning purposes, and steps that do not apply for a specific evaluation could be deleted. The
column for comments could be used to document reasons why expected timeframes were not met
or other relevant information concerning implementation of a step.

Information and Data Gathering Phase

An EPA letter requesting certain information from the air agency, and the air agency's response
is the first phase of the evaluation process. The recommended best practice for this phase is that
it takes no longer than 160 days. Recommended steps and durations for the steps are listed in
Table 1.

Evaluation Report Phase

Drafting and finalization of the evaluation report is the second phase of the evaluation process.
The recommended timeframe for this phase is 205 days. Specific steps and a recommended
duration for each step are listed in Table 2.

1 Final FY 2018 - 2019 OAR National Program Manager Guidance, U.S. EPA. Publication Number 440PI7002
(September 29. 2017) (NPM guidance) located at https;//www.epa.gov/sites/produtiion/fties/'20}7-
09 fd ocuments/Jy 18-!9-oar-npm-g«i dance.pdf-

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Table 1: Information and Data Gathering Phase Checklist
(It is recommended that this phase take no more than 160 days.)

Description

The Region drafts
a checklist and
sends an
information
request letter to the
state, local or tribal
agency ("air
agency").

Air agency
responds to
questions in

writing.

Recommended
Duration

No longer than
40 days.

Checklist

~aStart drafting letter

and checklist:aaa
/ /

riaLetter transmitted:aaa

/ /

Comments

~»\ir agency response
received:aaa

/ /

No longer than
120 days.+

This phase
should be
completed
within 80 days
of project
initiation.

+ The scope of the evaluation and sophistication of the data collection systems employed by the
air agency will inform the time needed for this step.

2

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Table 2: Program and/tor Fee Evaluation Report Phase Checklist
(It is recommended that this phase take no more than 205 days.)

Description

Recommended
Duration

Checklist

Comments

The Region reviews

No longer than

~(Regional review ofiii

the air agency

60 days.

air agency responseiii

response and drafts



~iConsultation withiii

evaluation report.



HQ (as needed)iii

EPA HQ





consultation as



Date step completed:

needed.



/ /

The EPA and the

No longer than

oiEPA & air agencyiii

air agency meet to

30 days after

meeting to discussiii

discuss results

draft report

results:

(optional).

available.

/ /

EPA Regional

No longer than

oiEPA managementiii

management

50 days.tf

briefmg:iii

briefed on draft



/ /

report; copy





provided to air



oiDraft report sent foriii

agency for



commendii

comment (optional).



/ /

Air agency

No more than 30

~iAir agency responseiii

responds to draft

days.

received :iii

report with



/ /

comments





(optional).





The EPA releases

No more than 35

oiFinal evaluationiii

final version of

days/

report released:iii

evaluation report.



/ /

n Iftan air agency will not be providing comments on the report, the EPA Region could issue the final report by the
end of this step or 140 days.

~ Some air agencies may request that the EPA also release the air agency's response with the release of the final
evaluation report. The EPA recommends that Regions include such responses in their final reports, when
practicable.

3

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ATTACHMENT B

Resources

This is a list of resources where users can find additional information related to the requirements
and issues discussed in this document.

Part 70 Monitoring Requirements

•aa;Source Monitoring Guidance:aaa

oaaMonitoring Knowledge Base: http://cfpub.epa.gov/oarweb/mkb/.

oaaCompliance Assurance Monitoring: htlp://mv\v3.epa.gov/tln/ahv/cam/ricam.hlml.iu

oaaEmissions Measurement Center: http://www3.epa.gov/ttn/emc/.

•aasPreconstruction Review:aaa

oaa For EPA resources concerning preconstruction review permitting, seeiii
http:Wwww2.epa.gov/nsr.

oaa For EPA guidance memos on preconstruction review, seem

httpsfJwww.epa.gov/nsr/new-source-rexnew-po!icy-and-guidance-document-index.

EPA Responses to Part 70 Petitions (EPA Orders)

•aaSeeiEPA responses and petitions at

htrps:/Awu>£pa.goWi itle-v-operat ing-permits/J it le-v-pet it ion-database.

Greenhouse Gas Permitting Requirements

•aa October 23, 2015a- Standards of Performance for Greenhouse Gas Emissions From New.aaa
Modified, and Reconstructed Stationary Sources: Electric Utility Generating Units, Finalaaa
Rule: https://www.gpo.gov/fdsys/pkg/FR-2015-IO-23/pdf/2015-22837.pdf.

-------
Guidance oil Government Accounting Standards

•aad-landbook of Federal Accounting Standards and Other Pronouncements, as Amended, asaaa
of June 30, 2015, Federal Accounting Standards Advisory Board (FASAB Handbook):

http://www.fasab.gov/pdffiiles/2015 Jasab Jtandbook.pdf:\\\

oaaStatement of Federal Financial Accounting Standards 4: Managerial Co.s7iii

Accounting Standards and Concepts, page 396 of the FASAB Handbook (Juneaaa

2015) ("SFFAS No. 4").aaa

oaa Statement of Federal Financial Accounting Standards 7: Accounting for Revenueiii
andiOther Financial Sources and Concepts for Reconciling Budgetary andiii
Financial Accounting, page 592 of the FASAB Handbook (June 2015) ("SFFASaaa
No. 7").

•aa£tatements of the Governmental Accounting Standards Board (GASB Statements):aaa
http://www.gasb.org/cs/ContentServer?c=Page&pagename-GASB%2FPage%2FGASBSiii

ectionPage&cid-1176160042391 .iii

o Statement No. 33, Accounting and Financial Reporting for Nonexchangeiii
Transactions (December 1998) ("GASB Statement No. 33"):aaa
http://wwwgasb.org/jsp/GASB/Document _C/GASBDocumeniPage?cid= /176160iii
029148&acceptedDisclaimer=true.iii

c Statement No. 34, Basic Financial Statements - and Management's Discus si oniii
and Analysis - for State and Local Governments (June 1999) ("GASB Statementaaa
No. 34"):

http://www.gasb.org/jsp/GASB/Document C/GASBDocumentPage?cid= 1176l60iii
029121 <&accepted Disclaimer^ true.ii i

•aa Examples of air agency financial or performance audit reports:

•

oaaAccountability, New York State Department of Environmental Conservation^
Report of Title V Operating Permit Program Revenues. Expenses and Changes iniii
Fund Balance for the Two Fiscal Years Ended March 31. 2009, Report Numberaaa
2010-S-61. Accessed January 19, 2017. at:aaa
www ,osc.state.n y.us/audits/allaudits/093011/10s6l .pdf
oaa State of Washington, Department of Ecology, Air Operating Permit Program iii
Report Fiscal Year 2014. Publication Number 15-02-008. Accessed January 19,aaa
2017, at www.fortress.wa.gov/ecy/publications/documents/I502008.pdf.iii
oaaState of North Carolina, Division of Air Quality, Department of Environment and
Natural Resources, Title V Air Quality Permit Program Accountability Report.iii
November 2009. Accessed January 19, 2017, at:

www.ncleg.ne(/documen(si(es/commi((ees/ERC/ERC%20Reports%20 Received/20
09/Dept%20of%20Environment%20and%20Natural%20Resources/2009- Nov%ii i
20-%20Title(X>20V%20Ai r%20Ouali ty%20 Permi t%20 Program .pdf.

2

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List of EPA Guidance on Part 70 Fee Requirements

•aadanuaryal 992a- GuidelinesforilmplementationiofiSection 507bf\theiCleaniAiriActiii

Amendments - FinaliGuide/wes,i U. S. £P A, £) ffi c e ao f AinQualityjPlanningamddStandardsaaa
(OAQPS),dJ.S.aEPA.aSmpagesa5 andal 1 -12aconcerningafee flexibilitysforasmallsbusinessaaa
stationary asources:

httpjAvww.epa.gov/sitefproduction/files/2Ql5-08/documents/smhus.pdfi ii

•aa£Julya7,al993a- QuestionsiandAnswers onlthe Requirement siofOperatingiPermit Programiii
Regulations,i\J .S.3LP A.£eeiSeci\on 9 at page 9-1 :aaa
http://www.epa.gov/sites/prod uction/Jiles/2015-08/documents/bbrd _qa I.pdf. i i i

•aaa\ugustafl,al 993a- ReissuanceiqfiGuidanceioniAgencyiReviewiqfiState Fee Schedulesiforiii
OperatingiPermitiProgramsiUnden Tit lei Vj John.£S.£Seitz,£Director,aOAQPS,dJ.S.dEPAaioaaa
Airi)ivisioni)irectors,dlegionsd-X4"1993afeeascheduleqguidance").dMote£thatahereavasaaa
anaearlieralocumentaDnahisasubjectahatavasasupersededi)yahisadocument:

http:Wwww3.epa.gov/itn/naaqs/aqmguide/collection/i5/fees.pdf.iii

•aaa\ugusteptemben23,al993 - MatrixiofiTitlei V-RelatedandAi riG rant-EligibleiActivities,iii

OAQPS,dJ.S.dZPA,aTheariatrixaiotes;lhatatasao bed'readaindajsedan concert&vithaheaaa
Augusta!, 1993d"eeatschedule]aguidance'X"inatrixqguidance"):
hiipj/www. epa.gov/sites/production/files/20! 5-08/document s/mat rix .pdf

•aa Octobera22, 1993a- Use of Clean Air Act Titlei V Permit Fees as Match for Sectionil05 iii
Grants, Gerald£M.aYamada,aActing£General Council,iJ.S.aEPA toaMichaelaH.aShapiro,
Actinga\dministrator,£DfiIcea)f Airand£Radiation,iJ.8.aEPA:aaa

http://yosemite.epa.gov/oa/eab_web_docket.nsf/fdings%20by%20appeal%20numbei-/95 7aaa

cb8b03e0ccqf0852574b0005aa688/Sf le/addit ional%20filing%20%20no.il %20... 22.pdf. iii

•aa
-------
®aaafulya21, 1994a- TransitionrtorFimdingrPorlionsmfState andrLocal AirrProgramsnvithnnn
PermitrFeesrRathenlhan Federa/^ra/?/.9,«Maryd3.aNichols,aAssistantaAdministratorafbra
Airaand£Radiation.aU.S.£EPAaioaRegionalaAdministrators,aRegionsda- X:aaa
hit p:/7www. epa.gov/sites/production/files/20J5-0S/documents/grantmem.pdf.nnn

•aaa\ugusta28, 1994a-Additional GuidanceronrFundingtSupporl for Stale andrLocal nnn
/3rog?Y/w?.svMary£D.£Nichols,ai\ssistanta1\dministratorafbra1\iraandaRadiation. U.S.dBPAao

RegionalaAdministrators,£Regionsd - X ("additionalqguidanceariemo"):

hup: //www. epa.gov/sites/production/files/2015-08/'documents/'guidl ine.pdfnnn

•aaalanuaryd23,al996a- Letter from Conrad Simon, Director,aAira& WastedVlanagement
Division,dJ.S £EPAdlegiondIaoaMr.£BillyaI.iSexton,aDirector,aIef'ferson£County
DepaitmentaafsPlanningaandaEnvironmentaldVlanagement^irsPollutionsControlaDistrict,
Louisv\Uz,d4633:ahllp:tf\nv\\>.gpo.go\'(ti:kys/pkg/FR-2015-]0-23/pcif/2015-
22S37.pdf.nnn

•aacKlarcha27, 2018- UpdatediGuidance onrEPA Review of FeerSchedules for Operatingnnn
PermitrProgramsiUnderfTitled/,fPeteraTsirigotis.aDircctor, OAQPS,i) S aEPA,£toaaa
RegionalaAiraDivisionaDirectors, Regionsal - 10^"updatedafeeascheduleqguidance"):aaa
httpsMwww. epa.gov/lille-v-operating-permils/lille-v-operaling-permil-policy-and-
guidance-document-index.

4

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ATTACHMENT C
Example Annual Financial Data Form for 40 CFR Part 70
Permitting Authority:

Annual Period: __/	/__ to	/ /	(MM/DD/YYYY)

Annual Program Revenue

A

Total Program Revenue (Fees Paid by Part 70 Sources)

$



Annual Presumptive Minimum Cost Calculation

B

Total Emissions of "Regulated Pollutants (for presumptive fee
calculation)"



tons

C

Presumptive Minimum Fee Rate During Period ($/ton)

$

per ton

D

Total Greenhouse Gas (GHG) Cost Ad justments (as applicable)

$



E = (B*C)+D

Presumptive Minimum Cost for the Program

$



A < E or

A > E

Compare Total Program Revenue to Presumptive Minimum Cost

Enter: "Less Than" or "Greater Than" or "Equal To"





Annual Program Costs





F

Direct Labor Costs1

$



G

Other Direct Costs2

s



H>F+G

Total Direct Costs

$



1

Known Indirect Costs3

$



J = K*L

Calculated Indirect Costs4

$



K

Indirect Rate



%

L

Total Cost Base for the Part 70 Program

$



M = I or J

Total Indirect Costs

$



N = H+M

Total Program Costs

$



() - A - N

Annual Operating Result

(Report deficits in parenthesi's)

s



1	This is the sum of all direct labor costs, including regular payroll, overtime payroll, leave, fringe, and any other
administrative surcharges.

2	This is the sum of all other direct costs, including travel, materials, equipment, contractor, and any other costs directly
allocable to the part 70 program.

Indirect Costs may either be known or calculated. If known, enter on this row; if calculated, skip to the next three rows.
4 If Indirect Costs are calculated, enter the result here, and enter the rate and base below, Accounting or budgeting personnel
may be able to provide additional information on or assistance with calculating Indirect Costs.

I

-------
Program Balance of Accounts (Report deficits in parentheses)

P

Beginning of Year Balance5

$

Q = 0

Annual Operating Result

$

R

Fee Revenue Transferred In (describe in comments)

$

S

Non-Exchange Revenue Transferred In (describe in
comments)a- Informational Only

$

T

Fee Revenues Transferred Out (describe in comments)

$( )

U = O+Q+R-T

End of Year Balance

$

COMMENTS:

Use this section to describe any changes in accounting methods or program elements that
effect the fee program, categories of revenue or expenses that do not fit into any of the listed
categories or apply across multiple categories, transfers in or out, or any unusual activities or
circumstances relevant to fees administration. Attach additional pages if needed

5 This is the prior year's "End of Year Balance.'

9

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BACKGROUND - EXAMPLE ANNUAL FINANCIAL DATA FORM FOR PART 40 CFR 70

The Example Annual Financial Data Form is a tool that may be used to collect information from state,
local, or tribal ("air agencies") part 70 programs concerning their compliance with part 70 requirements
for fees. The use of this form is not required for any specific air agency or time period and it may be
revised as appropriate. Air agencies may find this form useful for collecting programmatic information
for their own internal tracking purposes.

Fee sufficiencv.aThe primary purpose of the revenue, costs, and balance of accounts sections of the
financial data form is to collect information concerning the sufficiency of fees, consistent with Clean Air
Act (Act)a§ 502(b)(3)(A) and 40 CFR § 70.9(a). The fee sufficiency requirements include requirements
for air agencies to collectaannual fees (or the equivalent over some other period) that are sufficient to
cover all reasonable direct and indirect costs ofahe program and to track if required fees are being

6

diverted for non-part 70 purposes.aaaa

Presumptive minimum.aA secondary use for the financial data form is to assess an air agency's status
with respect to the "presumptive minimum" of part 70 7 This assessment may haveabeenamportant when
an air agency was originally approved to collect above the '"presumptive minimum," but changes made
over time have resulted in total annual fees being collected that are less than the "presumptive
minimum."8 This assessment is important because 40 CFR § 70.9(b)(3) requires air agencies that collecta
less than the presumptive minimum to submit a "detailed accounting" to ensure fee sufficiency, and air
agencies that were originally approved to collect at least the presumptive minimum would not have
submitted the detailed accounting with the program submittal. Examples of cases where an air agency's
status in this respect may have changed include where the air agency uses a formula to calculate the
presumptive minimum that is outdated or inconsistent with 40 CFR § 70.9(b)(2) or where the program
was approved to charge fees to individual sources using the methodology for calculating the
presumptive minimum pursuant to 40 CFR § 70.9(b)(2) and the air agency's requirements for fee
payment from individual sources are outdated or inconsistent with the part 70 calculation 9

The EPA may use its discretion to decide when this form should be completed by an air agency and
which sections of the form should be completed. The EPA will evaluate any information submitted and
determine appropriate next steps.

6	The requirements that fees be sufficient to cover all reasonable direct and indirect program costs, and that such fees not be
diverted f or other purposes, applies to all title V permit programs, regardless of whether or not the program was approved to
collect "not less than" or "less than" the presumptive minimum.

7	The presumptive minimum of CAAe§ 502(b)(3)(B) and 40 CFR § 70.9(b)(2) is generally calculated by multiplying a dollar
perton rate (which is adjusted annually for increases in the Consumer Price Index) by the tons ofregulated pollutants (for
presumptive fee calculation)" emitted by all part 70 sources in an air agency for a year (or equivalent period) and adding a
"GHG cost adjustment," which is a set dollar amount to reflect certain increased costs for permitting.

8	Air agencies have flexibility to charge fees to sources on any basis, including to charge emission fees, application fees,
service-based fees, or other types of fees, regardless of whether or not the program was approved to collect "not less than" or
'less than" the presumptive minimum.

9	The presumptive minimum calculation of 40 CFR § 70.9(b)(2) was updated in 2015 to add a GHG cost adjustment; see the
final rule. Standards of Performance for Greenhouse Gas Emissions from New, Modified and Reconstructed Stationary
Sources: Electric Utility Generating Units; Pinal Rule(80 FR 64510, October 23, 2015). See Section Xil.E, "Implications for
Title V Fee Requirements for GHGs" at page 64633:

httpifAvxvw.gpo.govifclsys/pkg/'FR-lQI 5-I0-23/pdf/2015-22837.pdf

3

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Accounting methods: The part 70 rules do not generally require any particular governmental accounting
standards or tracking systems to be used by air agencies. However, part 70 contains certain requirements
for tracking permit fees and program costs and for funding the program costs with permit fees that must
be met by all air agencies, regardless of the accounting standards and tracking systems being used. Due
to variability and changes in accounting standards, systems, and practices, it is important for air agencies
to note changes that may affect part 70 lees, costs, and accounting practices in the comments section of
this form.

The EPA recognizes the following resources may be helpful in understanding governmental accounting
standards as they relate to part 70 programs:

•aa Handbook of Federal Accounting Standards and Other Pronouncements, as Amended, as of Juneaa
30, 2015, Federal Accounting Standards Advisory Board (FASAB).aa

http://www.fmah.gov/pdffiles/2015Jasab handbook.pdf. nn

oaaStatement of Federal Financial Accounting Standards 4: Managerial Cost Accountingnn
Standards and Concepts, page 396 of the FASB Handbook (June 2015) ("SFFAS No.aa

4").aa

oaaStatement of Federal Financial Accounting Standards 7: Accounting for Revenue andnn
Other Financial Sources and Concepts for Reconciling Budgetary and Financialnn
Accounting, page 592 of the FASAB Handbook (June 2015) ("SFFAS No. 7").aa

®aa Statements of the Governmental Accounting Standards Board (GASB):

http://www.gasb. org/jsp/GASB/Page/GA SBSectioniPage&cid- J176160042391 Ugasbs25mi

oaaStatement No. 33, Accounting and Financial Reporting/or Nonexchange Transactionsnn
(December 1998) ("GASB Statement No. 33"):

http://www.gasb. org/jsp/G ASB/Document C/G AS B Document PageHcid= 11 M6160029148nn
&accepted Disclaimer-truenn

oaaStatement No. 34, Basic Financial Statements - and Management's Discussion andnn
Analysis - for State and Local Governments (June 1999) ("GASB Statement No. 34"):aa
http://www.gasb. org:/jsp/GASB/Document _C/GASB Document Page?cid 1176160029121nn
^accepted Disclaimer-truenn

Definition of terms: Several terms (e.g., "Direct Labor" and "Indirect Costs") used in the Example
Annual Financial Data Form are not defined in part 70. Some terms are defined in the EPA's fee
guidance (particularly the EPA's updated fee schedule guidance^0), in the U.S. Office of Management
and Budget's (OMB's) Circular A-87 Revised (Cost Principles for State, Local, and Indian Tribal
Governments), and in the FASB Handbook's chapter on Managerial Cost Accounting Standards and
Concepts (SFFAS No. 4), among other reference documents.

Supporting information: The information reported on this example form should be based on relevant
supporting accounting information or documentation. Air agencies that complete the form for submittal
to the EPA should maintain such supporting information for submittal to the EPA upon request.

10 Updated Guidance on EPA Review of Fee Schedules for Operating Permit Programs Under Title V, Peter T sirigods.
Director, OAQPS, to Regional Air Division Directors. Regions I - 10, March 27.2018. (updated fee schedule guidance).

4

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INSTRUCTIONS - EXAMPLE ANNUAL FINANCIAL DATA FORM FOR PART 70

These instructions are a general explanation of how to complete the attached Example Annual Financial
Data Form for Part 70 ("example financial form"). This form is not required to be submitted on any
frequency by air agencies - it is simply a useful example of how an EPA Region may collect financial
information related to title V fee requirements. The EPA Regions may revise this form to suit a
particular air agency or may opt to only require certain sections be completed.

Annual Program Revenue

•aaTotal Program Revenue (Fees Paid by Part 70 Sources)($):dnclude all title V fees paid directly
by part 70 sources, including emission fees, application fees, and other fees under the air
agency's fee schedule.aa

caa The fees collected under a part 70 program are referred to as "Exchange Revenue" or
"Earned Revenue" in governmental accounting guidance because a good or service isaa
provided by a governmental entity (e.g., a permit) in exchange for a price (e.g., a permitaa

11

fee).aAlso, governmental accounting guidance provides that only revenue classified asaa
"Exchange Revenue" should be compared against costs to determine the overall financialaa

results of operations for a period.12 This means that legislative appropriations, taxes, grants,aa
fines, or penalties, which are generally characterized as "Non-Exchange Revenue," shouldaa
not be compared against costs to determine if fees are sufficient to cover part 70 program
costs.aa

caa Some part 70 programs have direct access to permit fees to cover costs. However, other partaa
70 programs are required by state or local law to deposit permit fees into general accounts,
with operating costs subject to legislative appropriation. In both scenarios, if the funds wereaa
originally paid as permit fees and used for part 70 purposes for the report year, the fees maya
be considered "Total Program Revenue" and entered as such on the example financial form.aa
Permit fees that were retained in a prior year and transferred for use in the report year shouldaa
be reported as "FundsTransferred In.'aa

caa Note that any non-part 70 fee revenue ("Non-Exchange Revenue") should only be identified
for informational purposes in the "Program Balance of Accounts" section of the example

14

financial form, specifically the "Non-Exchange Revenue Transferred In" line.

" See Statement of Recommended Accounting Standards Number 7, Accounting for Revenue and Other Financing Sources
and Concepts fa- Reconciling Budgetary and Financial Accounting, issued by the Federal Accounting Standards Advisory
Board (FASAB) ("FASAB No. 7") at page 2. Also see Statement No. 33, Accounting and Financial Reporting for
Nonexchange Transactions (December 1998), issued by the Governmental Accounting Standards Board (GASB) at pages 1-
4. Conversely, "Non-Exchange Revenue" arises primarily from the exercise of governmental power to demand payment from
the public (e.g., income tax, sales tax, property taxes, fines, and penalties) and when a government gives value directlyee
without directly receiving equal value in return (e.g., legislative appropriations and intergovernmental grants).

12	See FASAB No. 7 at page 8.

13	"Non-Exchange Revenue" arises primarily from the exercise o f governmental power to demand payment from the public
(e.g., income tax, sales tax, property taxes, fines, and penalties) and when a government gives value directly without directly
receiving equal value in return (e.g., legislative appropriations and intergovernmental grants).

14	Since "Non-Exchange Revenue" is not allowed to be counted as part 70 fees, they should not be compared to costs or
carried over to the "Beginning of Year Balance" or "End of Year Balance'' lines.

5

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Annual Presumptive Minimum Calculation

This section helps to determine if an air agency's status is considered to be "presumptively adequate" to
fund program costs for a year.i5 This determination is relevant to part 70 when an air agency's feeaa
schedule was approved to be above the "presumptive minimum," but due to changes overtime, it is now
collecting and retaining fee revenue below the "presumptive minimum." When such a change occurs, 40
CFR § 70.9(b)(5) requires the air agency to submit a "detailed accounting" to show that its fees are
sufficient to cover the part 70 program costs.

•aa Total Emissions of "Regulated Pollutants (Tor presumptive fee calculation)" (tons/year): Report
the actual emissions of "Regulated Pollutants (for presumptive fee calculation)," as the term isaa
defined in 40 CFR § 70.2, for all part 70 sources for the year. Also see 40 CFR § 70.9(b)(2)(ii)aa
and (iii) for additional information on emissions that may be excluded from the total. The EPA
sometimes refers to these emissions as "Fee Pollutants" since they are only used for feeaa
purposes.aa

•aa Presumptive Minimum Fee Rate During Period fS/ton):aThe EPA calculates the "Presumptiveaa
Minimum Fee Rate" ($/ton) for part 70 in September of each year, and the fee rate is effectiveaa
from September 1 through August 31 of the following year. The EPA publishes the fee rate on
the EPA's title V permit websitei6 If a part 70 program uses a different 12-month period, thenaa
the fee rate in effect at the beginning of the reporting period or an average fee rate (prorated by
month) may be used.aa

•aaTotal Greenhouse Gas (GHG) Cost Adjustments, as applicable3"S):aA final rule publishedaa
October 23, 2015, included a "GHG Cost Adjustment," which is part of the calculation of the
"presumptive minimum" for an air agency under part 70.17 The adjustment is intended to reflectaa
the increased costs of permitting GHGs for part 70 programs.aa

•aa Presumptive Minimum Cost for the Program ("$): To determine the total "presumptive minimum"aa
for an air agency, multiply the actual emissions of "Regulated Pollutants (for presumptive fee
calculation)" by the "Presumptive Minimum Fee Rate" and add the "GHG Cost Adjustment" (as
applicable) for the period.aa

•aa Compare Revenue to Presumptive Minimum Cost: Compare the "Total Program Revenue" to the
calculated "Presumptive Minimum Cost for the Program" to determine if the fee revenue has
fallen below the "Presumptive Minimum." If the total program revenue is lower, a "detailedaa
accounting" is required to show that fee revenue is sufficient to cover the program costs.18

15	Seet40 CFR § § 70.9(b)(2)(i) through (v) for more on thefpresumptive minimum."

16	See https:fJmvw.epa.gm/title-v-operalmg-permits/permit-fees.

17	See 80 FRb-1659 and 40tCFR §§ 70.9(b)(2)(i) andt§ 70.9(b)(2)(v) concerning thef'GHG cost adjustment" for part 70.

18	SeetAO CFR § 70.9(b)(5).

6

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Annual Program Costs

The full cost of a part 70 program is described in accounting terms as being comprised of all reasonable
"direct and indirect costs." To assess the full cost, one should assess the total resources used to conduct a
program or complete an activity under a program. Full cost includes all "direct and indirect costs,"
regardless of funding sources. "Indirect costs" exist whether or not the program exists, while "direct
costs" exist only if the program exists. If, by eliminating the program, a particular cost is eliminated,
then the cost is labeled a "direct cost."

Examples of "Direct Labor Costs," "Other Direct Costs," and "Indirect Costs" are provided below. It is
beyond the scope of this example financial form to include a review of whether ail part 70 program
activities described in the separate updated fee schedule guidance^9 are included in the "Direct and
Indirect Costs;" however, such a review may be part of a "detailed accounting" or other EPA oversight
activity.

®aa Direct Labor Costs fS):aSalary and wages for direct work on part 70, including for professional^
administrative, and supervisory staff. These costs should include fringe benefits (compensationan
addition to regular salary and wages). Also, include the portion of "Direct Labor Costs" not
covered by employee contributions, such as those associated with employee contributions to
insurance and retirementaa

•aa Other Direct Costs($):aPirect part 70 expenses, such as materials, equipment, professional

services, official travel (i.e., food and lodging), public notice, public hearings, and contractors.aa

•aa Indirect Costs($):d1ndirect Costs" are funds spent on general administration (sometimesareferred
to asaoverhead). For a part 70 program, this is a share of costs associated with managingahe
organization within whichahe permit program resides, represented through an "IndirectaRate."
For example, to the extent that a program resides within a larger office, the program may£>e
charged a proportionate share of the overhead expense associated withahe larger office. The
budget or accounting office of the environmental division or department may be able to provide
the indirect costs for part 70 or may be able to assist with determining them using one of thea
following methods:aa

oaaKnown Indirect Costs($):aThis is the known value of "Indirect Costs" for a part 70 program,aa
such asanay be provided by an air agency budget or accounting office.aa

oaaCalculated Indirect Costs($):aIf the "Indirect Costs" are not known, then multiply anaa
"Indirect Rate" (e.g., a percentage that represents a fraction of total costs that are indirect
costs) by a known "Total Cost Base" (either "Total Costs" or "Total Labor Costs" for the part
70 program) to calculate "Indirect Costs." If calculated in this manner, the "Indirect Rate"aind
the "Total Cost Base" should be included on the example financial form.aa

•aa Annual Operating Result ($)afhe difference between the "Total Program Revenue" and "Total
Program Costs" reveals the degree to which the program generated a surplus, deficit, or breaksaa
even. If costs exceed fee revenue, then there was a deficit. If fee revenue exceeds costs, thenahere
was a surplus. Deficits should be reported in parentheses to indicate a negative number.

19 See Updated Guidance on EPA Review of Fee Schedules far Operating Permit Programs Under Title V. Peter Tsirigotis,
Director, OAQPS, to Regional Air Division Directors, Regions 1—10, March 27, 2018 (updated fee schedule guidance).

7

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Program Balance of Accounts

This section of the example financial form shows the program's overall fiscal status over time based on
the balance at the beginning of the period, changes in account balances from operations, fund transfers,
and resulting year-end balance.

•aa Beginning of Year Balance (S):aThe net balance (surplus or deficit) at the beginning of the year.aa
If unknown, enter zero. This is the prior year's "End of Year Balance."aa

•aa Annual Operating Result ($):aThe amount of fees minus costs for the year. If negative, include ina
parentheses to indicate a deficit for the year.aa

•aa Fee Revenue Transferred In ($):aPermit fee revenue not already accounted for above that isaa
transferred from other accounts, such as fee revenue that was collected and retained in prior
years used to cover costs for this year. Enter the amount of fee revenue and describe the sourceaof
funds in the comments section (e.g., permit fees retained in prior years) and whether thedransfers
are temporary (e.g., one-time) or permanent (e.g., recurring). If the funds originated asspermit
fees for the year being reported, enter the amount on the "Total Program Revenue" line,rather
thanahis line.aa

•aa Non-Exchange Revenue Transferred In ($): Non-Exchange Revenue (e.g., grants, taxes,
penalties, fines, and similar) transferred in to cover program costs. Enter the amount here and
describe the source of funds in the comments section. This line is for information only and will
not be included in any calculations of permit fee revenue on this form.aa

•aa Fee Revenue Transferred Out (SVaPermit fee revenue transferred out of program accounts duringaa
the report year. In the comments section, describe the intended use of the funds and whether thea
transfer is permanent or temporary. If you intend to use the fees inrfuture years for the part 70aa
program, please indicate so inacomments. Ifanot, please describe the intended use of funds andaa
whether the fees are in excess of the costs for the year. Any such transfers out will be subject toa
close scrutiny by the EPA.aa

•aa End of Year Balances $):aThe net balance (surplus or deficit) at the end of the year. In the

comments section, please describe any steps that will be taken to address a significant deficit, ifaa
known or available.

8

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EXAMPLES OF TYPICAL DIRECT AND INDIRECT COSTS

The following examples are intended to help permitting staff understand how various types of costs
would be categorized for accounting purposes. For a complete list of part 70 program activities that
should be included as part 70 costs, see the EPA's separate updated fee schedule guidance.

Direct Costs:

"Direct Costs" consists of two categories: 1) "Direct Labor Costs" and 2) "Other Direct Costs."

«aa Examples of Direct Labor Costs:

-	Cost of "direct labor';aa

-	Fringe benefits (i.e., retirement, health insurance, and life insurance); andaa

-	Leave, holiday, overtime and premium pay, and other personnel costs.aa

®aa Examples of Other Direct Costs:

-	Equipment purchases; andaa

-	Miscellaneous items, such as supplies and materials, equipment rentals, travel, purchased
services such as printing, and contractual services.aa

Indirect Costs:

"Indirect Costs" can be thought of as the time spent on administrative support and other office expenses,
which are not solely related to the program's operation because they benefit multiple programs or cost
objectives, but are needed to operate a part 70 program.

®aa Examples of Indirect Costs:aa

-	Space rental, utilities, including telephones;aa

-	Administrative support related to an office's overall mission, including such costs as
procurement, contracting, office services, property management, vehicle management,
supply, finance, payroll, voucher processing, personnel services, records management,
and document control;aa

-	Miscellaneous supplies and materials, including postage;aa

-	Data processing, management, and control;aa

-	Equipment rentals and costs;aa

-	Training and developments

-	Budget development, planning, and coordinations

-	Public information and inquiries;aa

-	Safety management, including inspection, training, and promotion;aa

-	Recurring reports, such as accounting or property reports; andaa

-	Unemployment Compensation, Equal Employment Opportunity Office costs and otheraa
affirmative action program costs.aa

9

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DETERMINING THE PROPORTIONAL SHARE OF INDIRECT COSTS

When "Indirect Costs" are not known, they can be calculated though the use of an "Indirect Rate."
Generally, an "Indirect Rate" is calculated by dividing total "Indirect Costs" by total "Direct Costs."
Because air agency accounting methods vary, the indirect and direct costs can be for all environmental
programs, the environmental department or division, or the air program. The resulting "Indirect Cost
Rate" is the percentage of "Total Costs" that are "Indirect Costs." The resulting "Indirect Rate" is then
multiplied by the "Total Cost Base," which may be either "Total Direct Labor Costs" or "Total Costs''
for part 70, as shown below.

Indirect Cost Rateff= Total Indirect Costsaf Total Direct Costs

Calculated Indirect Costs = Indirect Cost Rate * Total Direct Labor Costs for Part 70

or

Calculated Indirect Costsaadndirect Cost Rated'' Total Costs for Part 70

FOR MORE INFORMATION ON DETERMINING AIR AGENCY COSTS

For further information on determining costs for state, local, and tribal governments, see OMB Circular
A-87 Revised, Cost Principles for State, Local and Indian Tribal Government (May 10, 2004) and OMBaa
Circular A-133, Audits of State, Local Governments, and Non-Profit Organizations (last revisedaa
June 26, 2007). These guidance documents are not specific to part 70 but are generally useful for
understanding costs for the purposes of the part 70 program.aa

10

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'A*'	' l'"-,

£% '

UNITED STATES ENV

RESEARCH

CTION AGENCY

27711

,53©

WAR 2 7 2013

OFFICE OF
AIR QUALITY PLANNING
AND STANDARDS

MEMORANDUM

SUBJECT: Updated Guidance on EPA Review of Fee Schedules for Operating Permit Programs

The attached guidance is being issued in response to the Environmental Protection Agency Office
of Inspector General's (OIG) 2014 report regarding the importance of enhanced EPA oversight of state,
local, and tribal1 fee practices under title V of the Clean Air Act (CAA).2 Specifically, this guidance
reflects the EPA's August 22, 2014, commitment to the OIG in response to OlG's Recommendation 1 to
"assess our existing fee guidance and to re-issue, revise, or supplement such guidance as necessary" (we
refer to the attached guidance as the "updated fee schedule guidance"). The EPA's response to the OlG's
other recommendations are being issued concurrently in a separate memorandum and guidance concerning
title V program and fee evaluations ("title V evaluation guidance"). '

Title V of the CAA and 40 CFR part 70 contain the minimum requirements for operating permit
programs developed and administered by air agencies, including requirements that each program issue
operating permits to certain facilities (facilities that are "major sources" of air pollution and certain other
facilities) and that each program charge fees ("permit fees") to these facilities to fund the permit program.
These operating permits are intended to identify all federal air pollution control requirements that apply
to a facility ("'applicable requirements") and to require the facility to track and report compliance pursuant
to a series of recordkeeping and reporting requirements. Section 502(b)(3) of the CAA requires each air
agency to collect fees "sufficient to cover all reasonable (direct and indirect) costs required to develop and
administer" its title V permit program.4 The 40 CFR part 70 regulations establish the minimum program

1 As used herein, the term "air agency" refers to state, local, and tribal agencies.

' Enhanced EPA Oversight Needed to Address Risks from Declining Clean Air Act Title V Revenues; U.S. EPA Office of the
Inspector General. Report No. 15-P-0006, October 20, 2014 ("OIG Report").

3	Program and Fee Evaluation Strategy and Guidance for 40 CFR Part 70, Peter T sirigotis, Director, Office of Air Quality
Planning and Standards (OAQPS), U.S. EPA. to Regional Air Division Directors, Regions 1 - 10, March 27, 2018 ("title V
evaluation guidance"). See the EPA's title V guidance website at https://www.epa.gov/title-v-operating-permits/title-v-
operaling-permit-poiiiy and-guidance-dociimenl-index.

4	42 U.S.C. § 766la(b)(3)(A).

Under Title V

TO:

FROM:

Internet Addmss (URL) • http://www.epa,gc»¥

Recycled/Recyctabte « Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

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requirements for operating permit programs, including requirements for fees to be administered by air
agencies with approved part 70 programs.5

On August 4, 1993, the EPA issued a memorandum, commonly referred to as the "1993 fee
schedule guidance," to provide initial guidance on the Agency's approach to reviewing fee schedules for
part 70 programs.6 Since that time, the EPA has issued a number of memoranda and a final rule7 that have
touched upon, revised, or clarified certain topics contained in the 1993 fee schedule guidance.8 The
attached updated fee schedule guidance provides additional direction on how the EPA interprets the title
V permit issuance and fee collection activities, as well as discussion of other fee requirements for air
agencies. In addition to the memoranda and final rule noted above, the updated fee schedule guidance
includes numerous changes to remove outdated regulatory provisions and focuses on the review of
existing part 70 programs, rather than on initial program submittals.9

The updated fee schedule guidance sets forth updated principles, which will generally guide the
EPA's review of part 70 fee programs. These updates are consistent with the fee requirements of title V
and part 70, as well as prior guidance on fee requirements. Accordingly, these updates do not themselves
provide substantively new fee guidance or create any inconsistencies with fee requirements or prior fee
guidance.

The development of this guidance included outreach and discussions with stakeholders, including
the EPA Regions, the National Association of Clean Air Agencies, and the Association of Air Pollution
Control Agencies.

If you have any questions concerning the updated fee schedule guidance, please contact Juan
Santiago, Associate Director, Air Quality Policy Division, Office of Air Quality Planning and Standards,
at (919) 541-1084 or Santiago, juan@epa.gov.

Attachments:

1.	Updated Guidance on EPA Review of Fee Schedules for Operating Permit Programs under Title V

2.	Attachment A - List of Guidance Relevant to Part 70 Fee Requirements

3.	Attachment B - Example Presumptive Minimum Calculation

5	40 C.F.R. § 70.9.

6	See Reissuance of Guidance on Agency Review of State Fee Schedules for Operating Permits Programs under Title V, John
S. Seitz. Director. OAQPS, U.S. EPA, to AirDivision Directors. Regions 1-X (August 4, 1993} ("1993 fee schedule
guidance") at page 1. Note that there was an earlier document on this subject that was superseded by the 1993 fee schedule
guidance.

7	See the October 23, 2015, final rule, Standards of Performancetfor Greenhouse Gas Emissions from New, Modified and
Reconstructed Stationary Sources: Electric Utility Generating Units. 80 FR 64510, 64633 (Section Xll.E "Implications for
Title V Fee Requirements for GHGs").

8	A list of the relevant title V fee-related guidance memoranda is included as Attachment A.

9	At this time, all air agencies have EPA-approved part 70 programs. It is conceivable that additional part 70 program
submittals will be received in the future for a number of Indian tribes, and, if so, the EPA will work closely with the tribes to
assist them with identifying activities which must be included in costs related to the program submittal and to meet other fee
requirements of part 70.

2

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DISCLAIMER

These documents explain the requirements of the EPA regulations, describe the EPA policies, and
recommend procedures for sources and permitting authorities to use to ensure that title Vfee schedules
and fee evaluations are consistent with applicable regulations. These documents are not a rule or
regulation, and the guidance they contain may not apply to a particular situation based upon the
individual facts and circumstances. The guidance does not change or substitute for any law, regulation,
or any other legally binding requirement and is not legally enforceable. The use of non-mandatory
language such as "guidance, " "recommend, " "may, " "should, " and "can, " is intended to describe the
EPA policies and recommendations. Mandatory terminology, such as "must" and "required, " is
intended to describe controlling requirements under the terms of the Clean Air Act and the EPA 's
regulations, but the documents do not establish legally binding requirements in and of themselves.

3

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Updated Guidance on EPA Review of
Fee Schedules for Operating Permit Programs under Title V

The purpose of this document and the attachments is to provide guidance on the Environmental
Protection Agency's (EPA's) review of fee schedules for operating permit programs under 40 CFR part
70 (part 70), the regulations that set minimum requirements for permit programs administered by state,
local, and tribal air agencies (referred to here as, "air agencies") authorized under title V of the Clean
Air Act (CAA or Act). This document updates and clarifies the previous fee schedule guidance issued
by the EPA on August 4, 1993 (the "1993 fee schedule guidance").1 This updated fee schedule guidance
clarifies which permit program costs must be included in an analysis to demonstrate that adequate fees
are collected to fund all part 70 program costs. The guidance also discusses other fee-related
requirements for air agencies. The updated fee schedule guidance focuses on the costs of program
implementation, rather than on the costs of initial program development (as was the case for the 1993
fee schedule guidance).

I. General Principles for Review of Title V Fee Schedules

Section 502(b)(3)(A) of the Act requires operating permit programs to fund all "reasonable direct and
indirect costs" of the permit programs through fees collected from "part 70 sources"2 and requires the
fees to be sufficient to coverall reasonable permit program costs.3 The terms "fee schedule" and "permit
fees" are sometimes used interchangeably to describe the fees that an air agency charges to part 70
sources to fulfill this requirement.4 Section II of this guidance provides an explanation of the term
"direct and indirect costs" and a detailed explanation of specific permit program activities to be included
in costs for the purpose of analyzing whether the permit fees are sufficient to cover all the permit
program costs.

The fees collected under a part 70 program are classified as "exchange revenue" or "earned revenue" in
governmental accounting guidance because a good or service (e.g., a permit) is provided by a
governmental entity in exchange for a price (e.g., a permit fee).f Also, governmental accounting
guidance provides that only revenue classified as "exchange revenue" should be compared to costs to

1	See Reissuance of Guidance on Agency Review of State Fee Schedules for Operating Permits Programs under Title V, John
S. Seitz, Director, OAQPS, U.S. EPA, to Air Division Directors. Regions 1-X (August 4, 1993) ("1993 fee schedule
guidance").

2	The term "part 70 sources" is defined in 40 CFR § 7.2 to mean "any source subject to the permitting requirements of this
part, as provided in 40 CFR §§ 70.3(a) and 70.3(b) of this part." Thus, a source is a part 70 source prior to obtaining a part 70
permit if the source is subject to permitting under the applicability provisions of 40 CFR § 70.3.

3	See 40 CFR § 70.9(a).

4	The fee schedule is typically included in the regulations that the air agency uses to implement part 70; it is a component of
the part 70 program. The fee schedule (and other elements of an air agency's regulations for part 70) can vary significantly
across air agencies.

s See Statement of Recommended Accounting Standards Number 7, Accounting for Revenue and Other Financing Sources
and Concepts for Reconciling Budgetary and Financial Accounting, issued by the Federal Accounting Standards Advisory-
Board (FASAB) ("FASAB No. 7") at page 2. See also Statement No. 33, Accounting and Financial Reporting for
Nonexchange Transactions (December 1998), issued by the Governmental Accounting Standards Board (GASB) at pages 1-4
("GASB No. 33").

1

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determine the overall financial results of operations for a period.6 This means that legislative
appropriations, taxes, grants,7 fines and penalties, which are generally characterized as "nonexchange

revenue,"8 should not be compared to part 70 program costs to determine if permit fees are sufficient to
cover costs.

Any fee required by part 70 must "be used solely for permit program costs" (in other words, the feesaa
must not beadiverted for non-part 70 purposes).9 Manyaair agencies transfer fees that are inasxcess of
program costs for a particular year into accounts to be used forepart 70 purposes in another year when
there is expected to beai fee shortfall, and this is an acceptable practice. However, if title V fees are
transferred for uses not authorized by part 70 (e.g., highway maintenance or other general obligations of
government), they would be considered improperly diverted.

Each air agency is required, as part of its part 70 program submittal, to submit a "fee demonstration" to
show that its fee schedule would result in the collection and retention of fees sufficient to cover program
costs, including an "initial accounting" to show that "required fee revenues" would be used solely to
cover program costs.10

The EPA will generally presume that a feeaschedule is sufficient to cover program costs if it results in
the collection and retention of fees in an amount above the "presumptive minimum"—i.e., "an amount
noldess than $25 per ton" adjusted annually for increases in the Consumer Price Index" "times the total
tons of the actual emissions of each regulated air pollutant (for presumptive fee calculation) emitted

from part 70 sources," plus any greenhouse gas (GHG) cost adjustments, asaapplicable.12 A fee schedule
that is expected to result in fees above the "presumptive minimum" isa:onsidered to be "presumptively-
adequate." Note that the "presumptive minimum" isainique to each air agency because the total tons of
actual emissions of "regulated air pollutants (for presumptive fee calculation)" are unique to each air
agency.

As part of a fee demonstration, air agencies w ith fee schedules that would not be presumptively-
adequate are required to submit a "detailed accounting" to show that collection and retention of fee

6	See FASAB No. 7 at page 8; GASB No. 33.

7	Concerning grants, an EPA memo, Use of Clean Air Act Title V Permit Fees us Match for Section 105 Grants, Gerald
Yamada, Acting General Counsel, U.S. EPA, to Michael H. Shapiro, Acting Assistant Administrator, Office of Air and
Radiation, U.S. EPA, October 22, 1993, states that part 70 fees are '"program income" under 40 CFR § 31.25(a), and, because
of this, part 70 fees cannot be used as match for section 105 grants and no air agency may count the same activity for bothtt
grant and part 70 fee purposes.tt

* "Nonexchange revenue" arises primarily from the exercise ofgovernmental power to demand payment from the public
(e.g., income tax, sales tax, property taxes, fines, and penalties) and when a government gives value directly without directly
receiving equal value in return (e.g., legislative appropriations and intergovernmental grants).

9	See 40 CFR § 70.9(a).

10	See 40 CFR §§ 70.9(c)-(d) (fee demonstration requirements); 1993 fee schedule guidance (explaining that preparing the fee
demonstrations that is part of the initial part 70 program submittal).

" See CAAt§ 502(b)(3)(B); 40 CFR § 70.9(b). The presumptive minimum fee rate is adjusted for increases in the Consumer
Price Index each year in September. The fee rate for the period of September I, 2016, through August 31, 2017, is $48.88 per
ton. For more information, including a list of historical adjustment to the fee rate, see https://www.epa.gov/title-v-operating-
permits/perm it-fees.

12 See 40 CFR § 70.9(b)(2) (emphasis added). The components of the "presumptive minimum" calculation—including certain
emissions that may be excluded from the calculation, and an upward "GHG cost adjustment" that may apply—are addressed

in 40 CFR §§ 70.9(b)(2)(i)-(v).

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revenue would be sufficient to cover program costs.13 Air agencies are also required to provide an
"initial accounting" to show how ""required fee revenues" will be used solely to cover permitting
program costsi4 Air agencies with fee schedules considered "presumptively adequate" are nevertheless
required to submit fee demonstrations,13 but they may be '"presumptive minimum program cost"
demonstrations^6 showing that expected fee revenues are above the "'presumptive minimum" calculated
for the air agency. In order to receive the EPA's approval, any fee demonstration must provide an
""initial accounting" showing how required fee revenues will be used solely to cover program costs.17

After an air agency fee program is approved by the EPA, there are several fee requirements that may
apply to the permit program as circumstances dictate. One requirement is for an air agency to submit, as
required by the EPA, "periodic updates" of the ""initial accounting" portion of the fee demonstration to
show how "required fee revenues" are used solely to cover the costs of the permit program.18 Further, an
air agency must submit a ""detailed accounting" demonstrating that the fee schedule is adequate to cover
costs ifan air agency changes its fee schedule to collect less than the presumptive minimum or if the
EPA determines—based on the EPA's own initiative, or based on comments rebutting a presumption of
fee sufficiency—that there are serious questions regarding whether the fee schedule is sufficient to cover
the costsi9

In addition, title V and part 70 provide general authority for the EPA to conduct oversight activities to
ensure air agencies adequately administer and enforce the requirements for operating permits programs,
including that the requirements for fees are being met on an ongoing basis.20 One method the EPA uses
to perform such oversight is through periodic program or fee evaluations of part 70 programs. As part of
such an evaluation, the EPA may carefully review how the state has addressed the fee requirements of
part 70 as previously described and work with the air agency to seek improvements or make corrections
and adjustments if any fee concerns are uncovered. Also, as part of such an evaluation, the EPA may
require "periodic updates" to a fee demonstration or a "detailed accounting" that fees are sufficient to
cover permit program costs.21 See the EPA's separate Program an J Fee Evaluation Strategy and
Guidance for 40 CFR Part 70 ("title V evaluation guidance") for more on this subject.22

13	See 40 CFR § 70.9(b).

14	See 40 CFR § 70.9(d).

15	See 40 CFR § 70.9(c).

16	See Sections 1.1 and 3.2 of the fee demonstration guidance.

17	See 40 CFR § 70.9(d).

18	See 40 CFR § 70.9(d).

19	See 40 CFR § 70.9(b)(5); fee demonstration guidance, Section 2.0 (providing an example ofta "detailed accounting"). The
scope and content of a "detailed accounting" may vary but will generally involve information on program fees and costs and
other accounting procedures and practices that will show how the air agency's fee schedule will be sufficient to cover all
program costs.

20	See C AA § 502(i); 40 CFR § 70.10(b).

21	See 40 CFR §§ 70.9(a); 70.9(b)(1), (5)(ii).

22	Program and Fee Evaluation Strategy and Guidance for 40 CFR Part 70, Peter Tsirigotis, Director, Office of Air Quality
Planning and Standards (OAQPS), U.S. EPA, to Regional Air Division Directors, Regions 1 -10. March 27,2018.

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Ilaa Types of Costs and Activities Included in Title V Costsaa

A.aOverviewaa

Activities that count as part 70 costs (direct and indirect costs of part 70).tPart 70 uses the term "permit

program costs" to describe the costs that must count for fee purposes under part 70.23 This term is
defined in 40 CFR § 70.2 as "all reasonable (direct and indirect) costs required to develop and

administer a permit program, as set forth in [40 CFR § 70.9(b)] (whether such costs are incurred by the

permitting authority or other State or local agencies that do not issue permits directly, but that support

permit issuance or administration)." At a minimum, any air program activity performed by an air agency

under title V or part 70 must be included in program costs. Many of the activities required under title V

or part 70 are described in Sections II.B through II. K of this guidance.

As described above, part 70 costs must include all "reasonable direct and indirect costs"24 that are
incurred by air agencies intthe development, implementation, and enforcement of the part 70 program.
"Direct costs" are expenses that can be directly attributed to part 70 program activities or services.
"Direct costs" can generally be subdivided into two categories: "direct labor costs" and "other direct
costs." The term "direct labor costs" refers to salary and wages for direct work on part 70, including
fringe benefits. The term "other direct costs" refers to other direct part 70 expenses, such as materials,
equipment, professional services, official travel (e.g., transportation, food and lodging), public notices,
public hearings, and contracted services, 'indirect costs" are costs for ''general administration" or
"overhead" that are not directly attributable to a part 70 program because they benefit multiple programs
or cost objectives, but they are needed to operate a part 70 program. "Indirect costs" for a part 70
program are typically determined based on an indirect rate or a proportional share of the expenses of a
larger organization. Examples of "indirect costs" include, but are not limited to, costs for utilities, rent,
general administrative support, data processing charges, training and staff development, budget and
accounting support, supplies and postage.

Intaddition, note that air agency accounting practices vary in how they nominally categorize costs as
"direct costs," "indirect costs," or "other direct costs," depending on the specific nature of the activity.
An example would be training costs, which are typically treated as "indirect costs" buttsometimes ast
"direct costs," particularly where the training ist about part 70 (e.g., for permit staff development). While
accounting practices and terminology may vary among air agencies, the important principle to remember
is that all reasonable direct and indirect costs of the program must be represented in the costs reported to
the EPA, regardless of how the costs are categori zed by the air agency.

Part 70 and the 1993 fee schedule guidance describe the part 70 activities of "reviewing and acting on
any application for a part 70 permit"23 and "implementing and enforcing the terms of anytpart 70tt

23	See 40 CFR § 70.9(a).

24	The phrases, "reasonable direct and indirect costs" and "reasonable (direct and indirect) costs" have the same meaning. The
phrase "reasonable direct and indirect costs" was initially used by the EPA in the 1993 fee schedule guidance, page I. The
phrase "reasonable (direct and indirect) costs" is also found in CAA section 502(b)(3)(A), (C)(iii).

25	The response to comments document for the part 70 final rule clarifies that the phrase "acting on permit applications" in
section 503(c) of the Act means the act of issuing or denying a permit, not just beginning review of a permit application. See
Technical Support Document for Title V Operating Permits Programs (May 1992) at page 4-4, EPA Docket No. EPA-HQ-
OAR-2004-02 88; Legacy Docket No. A-90-33.

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permit," and these activities must be included in part 70 costs.26 The following paragraphs use these
phrases to clarify the extent that certain activities performed by the air agency must be included in part
70 costs. The phrase ''reviewing and acting on any application for a part 70 permit" refers to all
activities related to processing the permit application and issuing (or denying) the final part 70 permit,
while the phrase "implementing and enforcing the terms of any part 70 permit" refers to all activities
necessary to administer and enforce final part 70 permits, prior to the filing of an administrative or
judicial complaint or order.27

Also, the following paragraphs clarify the extent to which fees must fund the costs of "permit programs
under provisions of the Act other than title V" (hereafter referred to as "other permits") (e.g.,
preconstruction review permits) and "activities which relate to provisions of the Act in addition to title
V" (hereafter referred to as "other activities") (e.g.. a requirement for an air agency to develop a case-
by-case emissions standard for an existing source).-8

Costs related to "other permits."29 The costs of "implementing and enforcing" the terms of a part 70
permit must be treated as a part 70 cost.30 Thus, part 70 costs must include the cost of implementing and
enforcing any term or condition of a non-part 70 permit required under the Act31 that is incorporated into
a part 70 permit and meets the definition of "applicable requirement''32 in part 70. Similarly, the cost of
implementing and enforcing any term or condition of a consent decree or order that originates in a non-
part 70 permit that has been incorporated into a part 70 permit must be included as a part 70 cost.33

The costs of implementing and enforcing "applicable req uirements" from a non-part 70 permit that will
go into a part 70 permit in the future may be counted as part 70 costs. However, once a source has

26 The phrases "reviewing and actingon any application for a part 70 permit" and "implementing and enforcing the terms of
any part 70 permit" are found at 40 CFR § 70.9(b)(l)(ii) and (iv). Similar phrases are found in the EPA's 1993 fee schedule
guidance at page 3 and the phrases in the guidance have the same meaning as the phrases in part 70. See also, CAA §

502(b)(3)(A).

21 An EPA memo. Matrix of Title V-Related and Air Grant-Eligible Activities, OAQPS, U.S. EPA, September 23, 1993 (the
"matrix guidance"), page 8, which clarifies that enforcement costs are counted lor part 70 purposes prior to the filing ofta
complaint or order. See page 8.

28 The phrases cited here were originally discussed on pages 2 and 3 of the cover memorandum lorthe 1993 fee schedule
guidance.

2' Note that the EPA's 1993 fee schedule guidance contains the statement that "the costs of reviewing and acting on
applications for permits required under Act provisions other than title V need not be recouped by title V fee." This statement
has been interpreted by some to mean that the costs of non-title V permits "are not needed" or "may optionally" be counted
in title V costs.

r,(} See 40 CFR § 70.9(b)(l)(iv).

31	Examples of non-pait 70 permits required under the Act may include "minor new source review" (minor NSR) permits,
"synthetic minor" permits, Prevention ofSignificant Deterioration (PSD) permits, and Nonattainment NSR permits
authorized under title 1 of the Act.

32	"Applicable requirements" are the air quality requirements that must be included in part 70 permits. See the definition of
"applicable requirement" in 40 CFR § 70.2, which includes "any terms and conditions of any preconstruction permits issued
pursuant to any regulations [under title 1]," and certain requirements under titles 1, 111, IV and VI of the Act.

33	The EPA has previously explained that consent decrees and orders reflect the conclusion of a judicial or administrative
process resulting from the enforcement ofCappli cable requirements," and, because of this, all CAA-reiated requirements in
such consent decrees and orders "are appropriately treated as 'applicable requirements' and must be included in title V
permits. . ." See In the Matter ofCitgo Refining and Chemicals Company, LP., Order on Petition Number Vl-2007-01, at 12
(May 28, 2009).

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submitted a timely and complete part 70 application and paid part 70 fees, all costs o{"implementing and
enforcing the non-part 70 permit must be counted as part 70 costs.34

Also, any implementation and enforcement activities related to a requirement that is incorporated into a
part 70 permit that is not ""federally enforceable" and would not meet the definition of an ""applicable
requirement" (e.g., a "state-only" requirement) need not be treated as a part 70 cost.33 The matrixtt
guidance also clarifies that state-only requirements are air grant-eligible activities, rather than title V-
eligible activities.

Costs of performing certain other activities related to applicable requirements.t Certain activities required
by the Act or its implementing regulations are not "applicable requirements" as defined in part 70
because they apply to the permitting authority rather than the source.36 We refer to such activities astt
""other activities." As such, questions often arise asto whether the costs of "other activities" are part 70
costs, costs of the underlying standard, or costs of the preconstruction review permitting process.

Examples of applicable requirements associated with ""other activities" include, but are not limited to,
the following:

®tt Emissions standards or other requirements for new sources under section 111(b) of the Act;tt

®tt Emissions standards or other requirements for existing sources under section 111(d) of the Act;tt

•tt Case-by-case maximum achievable control technology (MACT) standards that may be required
under section 112 of the Act; andtt

•tt Activities required by a state, federal, or tribal implementation plan (SIP, F1P, or TIP), includingtt
section 110 of the Act.tt

The 1993 fee schedule guidance stated that the cost for performing ""other activities" would be part 70
costs only to the extent the activities are ""necessary for part 70 purposes."37 The 1993 fee schedulett
guidance has resulted in numerous questions over the years as to the scope of the term "part 70
purposes." The EPA believes a clearer standard for determining when "other activities" must be
included in part 70 costs would include an evaluation of: the extent to which the air agency is required to
perform the "other activities" pursuant to part 70, title V, or the approved part 70 program; the extent to
which the activity is performed to assure compliance with, or enforce, part 70 permit terms and
conditions; or the extent to which a non-part 70 rule (e.g., a section 111 or 112 standard) requires the air
agency to perform the activity in the part 70 permitting context. If an "other activity" does not meet any

34	See EPA memo, Additional Guidance on Funding Support for State and Local Programs, Mary D Nichols, Assistant
Administrator for Air and Radiation, U.S. EPA, to Regional Administrators, Regions 1- X, August 28, 1994.

35	See 40 CFR § 70.6(b)(2).

36	Although the "other activities" may originate within a federal standard or requirement that we generally refer to as an
"applicable requirement" and the activities may result in an "applicable requirement," the activities themselves do not meet
the definition of "applicable requirement" within 40 CFR § 70.2.

37	See page 2 of the introductoiy memorandum for the 1993 fee schedule guidance.

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of these criteria (e.g., a non-part 70 rule requires an activity in a non-part 70 context), it should not be
included in part 70 costs.

Nonetheless, if any activity is an "applicable requirement" for a source, the applicable requirement must
be included in a part 70 permit and the costs to the air agency of including it in the permit (and
implementing and enforcing) must be treated as part 70 costs.38

For example, the cost of incorporating a standard (e.g., a section 111(b) standard) into a part 70
permit—where the task is merely one of copying the requirements from the regulation unchanged into a
permit—would be a part 70 cost. However, the cost of developing a source-specific emission limitation
outside the permit processing context (e.g.. a standard pursuant to section 111(d) emission guidelines)
would be a section 111 cost (although the cost of subsequently incorporating that standard into the part
70 permit would be a part 70 cost).

The costs of "other activities' related to implementation plans, including section 110 or 111 of the Act,
should not be counted for part 70 purposes if the activities are required as part o f the preconstruction
review process or directly relate to implementation plan development, as required by title I of the Act.39
On the other hand, part 70 costs can include ambient monitoring or emission inventories necessary to
implement the part 70 program (e.g., development and quality assurance of emissions inventory for
potential part 70 sources for the purpose of determining applicability)# If an air agency is unsure where
to draw the line on including such activities in part 70 costs, they should contact the EPA for assistance.

General standard for EPA review of part 70 costs for a particular air agency. In general, the EPA expects
that part 70 permit fees will fund the activities listed in this guidance. However, in evaluating a part 70
program, the EPA will consider the particular design and attributes of that program. Because the nature
of permitting-related activities can vary across air agencies, the EPA evaluates each program
individually. The activities listed in this guidance may not represent the full range of activities to be
covered by permit fees.41 Additionally, some air agencies may have further program needs based on the
particularities o f their own air quality issues and program structure.

Sections II.B through ILK of this guidance provide further information on specific permitting activities
and the extent to w hich the costs of such activities must be treated as part 70 costs.

B. The Costs of Part 70 Program Administration

All part 70 program administration costs must be treated as part 70 costs.42 Examples of program
administration costs include:

38	Seee§ 70.9(b)(l)(ii), (4).

39	Implementation plan development is mandated under title 1 of the Act and costs typically include such activities as
maintaining state-wide emissions inventories and performing ambient monitoring and emissions modeling of air pollutants
for which national ambient air quality standards have been set.

40	See the matrix guidance at page 1.

41	The fee demonstration guidance cites various factors that may affect the types of activities included in a permit program
and influence costs. See fee demonstration guidance at 4-5.

42	This section includes many activities that would be categorized as part 70 costs under 40 CFR §§ 70.9(b){ 1 )(i)-(iii) that are
not covered elsewhere in subsequent sections of this guidance and are necessary to conduct a pait 70 program.

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Program infrastructure costs (e.g., development of part 70 regulations, implementation guidance,
policies, procedures, and forms);

Program integrati on costs (adapting to changes in related programs, such as NSR, secti on 112
programs, and other programs);

Data system implementati on costs (including data systems for submitting permitting informati on
to the EPA. for permit program administration, implementation and tracking and to provide
public access to permits or permit informati on);

Costs to operate local or Regional offices for part 70, the costs of interfacing with other state,
local, or tribal offices (e.g., briefing legislative or executive staff on program issues and
responding to internal audits);

Costs related to interfacing with the EPA (e.g., related to program oversight, including program
evaluations, responding to public petitions, revising implementati on agreements between the air
agency and the EPA); and

•	Activities similar to those above.

In additi on. there are other program implementati on costs, such as the costs of making determinations of
which sources are subject to part 70 permitting requirements that must be treated as part 70 costs.43
Examples of such activities include:

•	Maintaining an inventory of part 70 sources (e.g., for enforcement of the requirement for sources
to obtain a permit or for part 70 fee purposes);

•	Costs of determining if an individual source is a major source (for applicability purposes);

•	Costs of determining if a source qualifies for coverage under a general permit (if the air agency
chooses to issue them); and

•	Costs of determining if a n on-major source is required to obtain a part 70 permit and costs of
implementing any insignificant activity and emission level exemptions under part 70.

C. TheCostsof Part 70 Program Revisions

All costs of revising an approved part 70 program must be treated as part 70 costs, including the costs of
developing new program elements to respond to changes in requirements, whether the revisions are the
air agency's own initiative or required by the EPA.44 Examples of program revision costs include:

•	Costs of revising the program elements that are changing (e.g.. program legal authority,
implementing regulations, data systems, and other program elements);

43	Many of these activities may also be described as related to reviewing and acting on applications for part 70 permits, as
provided in 40 CFR § 70.9(b)(l)(ii).

44	See 40 CFR § 70.4(i).

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•	Costs of documenting the changes; and

•	Costs associated with obtaining the needed approvals, including for submitting program
revisions to the EPA and any necessary follow-up work related to obtaining approval.

D. The Costs of Reviewing Applications and Acting on Part 70 Permits

All costs of reviewing an application for a part 70 permit, developing applicable requirements as part of
the process of a permit, and ultimately acting upon the application must be treated as part 70 costs.t*5
These costs must include the costs of the application completeness determination, the technical review
of the application (including the review of any supplemental monitoring that may be needed, review of
any compliance plans, compliance schedules, and review of initial compliance certifications included in
the application), drafting permit terms and conditions to reflect the applicable requirements that apply to
the source, determining if any permit shields apply, public participation, the EPA and affected air
agency review, and issuing the permit. The cost of these activities must be included for initial permit
processing, permit renewal, permit reopening, and permit modification.

The costs of developing part 70 permit terms and conditions. All costs associated with the development
of permit terms and conditions to reflect the "applicable requirements," including the costs of
incorporating such terms in part 70 permits, must be treated as part 70 costs. The applicable
requirements include the emissions limitations and standards and other requirements as provided for in
the definition of applicable requirements in 40 CFR § 70.2. Such costs may include the costs to
determine the provisions of the applicable requirements that specifically apply to the source, to devel op
operational flexibility provisions, netting/trading conditions, and appropriate compliance conditions
(e.g., inspection and entry, monitoring and reporting). Appropriate compliance provisions may include
periodic monitoring and testing under 40 CFR § 70.6(a)(3) (i)(B) and monitoring sufficient to assure
compliance under 40 CFR § 70.6(c)(1).

Part 70 also requires certain regulatory provisions to be included in permits, such as citation to the origin
and authority of each permit term, a statement of permit duration, requirements related to fee payment,
certain part 70 compliance and reporting requirements, a permit shield (if provided by the air agency),
and similar terms. The costs of developing such terms must be covered by permit fees.46

The costs of developing "state-only" permit terms need not be treated as part 70 costs. Air agencies
should screen or separate ""state-only" requirements from federally-enforceable requirements and—
while the act of separating part 70 terms from state-only terms should be treated as part 70 costs—the
costs of developing state-only permit terms, putting them in the part 70 permit, and implementing and
enforcing them as they appear in the part 70 perm it need not be treated as part 70 costs for fee
purposes^7

45	See CAA section 502(b)(3)(A)(i); 40 CFR § 70.9(b)(lf)(ii).

46	See 40 CFR § 70.6.

47	See the matrix guidance, which notes that state-only requirements in part 70 permits are air-grant-eligible activities, rather
than title V-eligible activities.

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The costs of public participation and review (bv the EPA and the affected air agency)! All costs of
notices (or transmitting information) to the public, affected air agencies and the EPA for part 70 permit
issuance, renewal, significant modifications and (if required by state or local law) for minor
modifications (including staff time and publication costs) must be treated as part 70 costs.48

Any costs associated with hearings for part 70 permit issuance, renewal, significant modifications, and
for minor modifications (if required by state or local law), including preparation, administration,
response, and documentation, must be treated as part 70 costs.

All costs for the air agency to develop and provide a response to public comments received during the
public comment period must be treated as part 70 costs.

Any costs associated with transmitting necessary documentation to the EPA for review and response to
an EPA objection must be treated as part 70 costs.49 Also, the costs associated with an air agency's
response to an EPA order granting objection to a part 70 permit and/or the costs of defending challenges
to part 70 permit terms in state court must be treated as part 70 costs.

E. The Costs of Implementation and Enforcement of Part 70 Permits

With some exceptions related to court costs and enforcement actions, the costs of implementing and
enforcing the terms of any part 70 permit must be treated as part 70 program costs.30 Implementation and
enforcement of permit terms and conditions related to part 70 includes requirements for compliance
plans, schedules of compliance, monitoring reports, deviation reports, and annual certifications.

The costs of any follow-up activities when compliance/enforcement issues are encountered should be
treated as part 70 costs. Part 70 costs include such activities as conducting site visits, stack tests,
inspections, audits, and requests for information either before or after a violation is identified (e.g.,
requests similar to the EPA's CAA section 114 letters).

Part 70 costs should include the costs for any notices, findings, and letters of violation, and the
development of cases and referrals up until the filing of the complaint or order. Excluded from permit
costs are enforcement costs incurred after the filing of an administrative or judicial complaint.31

Part 70 costs must also include the costs of implementing and enforcing any restrictions on potential to
emit (PTE) that are included in a part 70 permit, whether they originate in the part 70 permit or were
transferred from a non-part 70 permit, such as a minor NSR permit for a ''synthetic minor source."

48	See 40 CFR § 70.7(h) concerning public participation and 40 CFR § 70.8 concerning the EPA and affected air agency
review.

49	See 40 CFR § 70.8(a).

50	See 40 CFR §§ 70.4(b), 70.6,70.9(b)(l)(iv), and 70.11.

51	See the matrix guidance at page 8.

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F.	The Costs of Implementing and Enforcing the Requirements of Non-Title V Permits Required

Under the Act

Part 70 fees must cover the costs of implementing and enforcing the terms and conditions of "other
permits" (n on-part 70 permits) required under the Act, such as prec on struct ion review permits under title
1, that have been incorporated in part 70 permits as "applicable requirements."52

Also, the costs of implementing and enforcing the terms and conditions of consent decrees and orders
that originate in a non-part 70 permit that are incorporated into a part 70 permit must be treated as part
70 costs. See Section 11.A of this guidance.

The costs of implementing and enforcing applicable requirements for "prospective part 70 sources" need
not be treated as part 70 costs until such time as the source submits a timely and complete permit
application and pays fees. In addition, the costs of implementing and enforcing "state-only"
requirements need not be treated as part 70 costs.

G.	The Costs of Performing Certain "Other Activities" Related to Applicable Require me nts

Certain activities are required by the Act but are not "applicable requirements" because they apply to the
permitting authority, rather than the source; such activities are referred to as "other activities."53
Examples of applicable requirements that contain these activities include, but are not limited to.
standards for existing sources under section 111(d) of the Act; case-by-case MACT under sections 112
of the Act; and certain activities required by a SIP, FIP, or TIP. including section 110 of the Act. The
costs of other activities must be treated as part 70 costs, if the air agency is required to perform the
activities by part 70, title V, or the air agency's approved part 70 program; if a n on-part 70 rule requires
them to be performed in the part 70 permitting context; or if the activities are needed to assure
compliance with, or to enforce, the terms and conditions of a part 70 permit. The costs of other activities
should not be treated as part 70 costs, if they do not meet any of these criteria (e.g., a n on-part 70 rule
requires an activity that occurs in a non-part 70 context). See Section II.A of this guidance.

H.	The Costs of Revising, Reopening, and Renewing Part 70 Permits

All costs associated with processing permit revisions, including for administrative amendments, minor
modifications (fast-track and group processing^ and significant modifications, must be treated as part 70
costs.34 The part 70 costs must include all the costs of reviewing and acting on the application, as well as
implementing and enforcing the revised permit terms.35 The costs of implementing any "operational
flexibility provisions"56 approved into a program to streamline permit revision procedures must be
treated as permit program costs (this may also generally be considered to be one of the costs of
implementing a permit).

52	Required to be treated as part 70 costs in certain cases by 40 CFR § 70.9(b)(l)(iv).

53	Required to be treated as part 70 costs in certain cases by 40 CFR §§ 70,9(b)(l)(ii) and (iv).

54	Required to be treated as part 70 costs under 40 CFR § 70.9(b)(l)(ii), Also see 40 CFR § 70.7 for more on permit issuance,
renewal, reopening and revision procedures.

55	40 CFR §§ 70.9(b)(l)(ii) and (iv).

56	Section 502(b)( 10) of the Act requires the operating permit regulations to include provisions to allow changes within a
permitted facility without requiring a permit revision under certain circumstances. The EPA refers to these provisions as
'"operational flexibility provisions." See 40 CFR § 70.4(b)(12).

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The cost for the air agency to reopen a part 70 permit for cause must be treated as part 70 costs. The
proceedings to reopen a permit shall follow the same procedures that apply to initial permit issuance,
and include a requirement for the air agency to provide a notice to the source of the agency's intent to
reopen the permit.

When the EPA reopens a part 70 permit for cause, the air agency's costs for the proposed determination
of termination, modification, or revocation and reissuance, and the costs to resolve the objection in
accordance with the EPA's objection, must be treated as part 70 costs.

The cost of renewing permits every 5 years, which involves the same procedural requirements, including
public participation, and the EPA and affected air agency review, must be treated as part 70 costs,57 just
as for initial permit issuance.

I. The Costs of General and Model Permits

All costs for development and implementation of general and model permits under part 70 must be
included in part 70 program costs, including the costs of drafting permits, public participation, the EPA
review and any affected air agency's review, permit issuance, publication, assessing applications for
coverage under the general permit, and other related costs.58 Note that the issuance of general and model
permits is an option for air agencies, but if such permits are issued by an air agency under part 70, the
costs must be included in part 70 costs.

J. The Costs of the Portion of the Small Business Assistance Program (S BAP) Attributable to
Part 70 Sources

The SBAP under title V is authorized to provide counseling to help small business stationary sources to
determine and meet their obligations under the Act.59 The SBAP is authorized to provide assistance to
small business stationary sources, as defined by CAAt§ 507(c)(1), under the preconstruction and
operating permit programs; however, air agencies need only to include costs related to assistance with
part 70 in part 70 costs.60 See 40 CFR § 70.9(b)(l)(viii). Allowable costs for part 70 include the costs to
establish a small business ombudsman program to provide information on the applicability of part 70 to
sources, available assistance for part 70 sources, the rights and obligations of part 70 sources, and
options for sources subject to part 70. Allowable costs also include the costs associated with part 70
applicability determinations.

57	40 CFR § 70.9(b)(lt)(ii).

58	Required to be included in part 70 costs by 40 CFR §§ 70.9(b)(l)(ii) and (iv). Also see40 CFR § 70.6(d) for more on the
administration of general permits.

59	For examples of the types of activities of a SBAP that could be attributable to part 70 sources and funded by part 70 fees,
see Transition to Funding Portions of State and Local Air Programs with Permit Fees Rather than Federal Grants, Mary D.
Nichols, Assistant Administrator for Air and Radiation, U.S. EPA, to Regional Administrators, Regions I - X, July 21, 1994
("transition guidance"); Letter from Conrad Simon, Director, Air & Waste Management Division, EPA Region 11 to Mr.
Billy J. Sexton, Director, Jefferson County Department of Planning and Environmental Management, Air Pollution Control
District, Louisville, Kentucky, January 23, 1996 ("Sexton memo").

60	Note that the preconstruction review permitting costs of assisting non-part 70 sources should generally not be included as
part 70 costs, except for costs related to implementation and enforcement of permit terms from a preconstruction review
permit that have been included in a part 70 permit.

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Part 70 costs for S BAP must include the costs for outreach/publications on the requirements of part 70
and/or the applicable requirements included in part 70 permits, the costs of assisting part 70 sources
through a clearinghouse on compliance methods and technologies, including pollution prevention
approaches, and the costs to assist sources with part 70 permitting, which may include the portion of
costs for a small business compliance advisory panel that are related to part 70.

K. The Costs of Permit Fee Program Administration

All costs associated with the administration of an air agency's part 70 fee program must be included in
part 70 costs, including the costs for revising fee schedules (as needed to cover all required costs),
periodic updates, detailed accounting (if needed), determining the presumptive minimum for the air
agency, participating in EPA evaluations of fee programs or similar EPA oversight activities, assisting
sources with fee issues, auditing fee payment by sources, assessing penalties for fee payment errors,
responding to internal audits and inquiries, and similar activities.61

III. Flexibility in Fee Schedule Design

An air agency may design its fee schedule to collect fees from sources using various methods, provided
the fee structure raises sufficient revenue to cover all required program costs.62 Thus, air agencies may
charge: emissions-based fees based on actual emissions or allowable emissions; fixed fees for certain
permit processes (different fees for initial permit review, renewals, or for various types of permit
revisions); different fee rates (e.g., dollars per ton of emissions) for certain air pollutants; fees reflecting
the actual costs of services for sources (such as charging for time and materials for a review); or other
types of fees, including any combination of such fees. Finally, air agencies may charge annual fees or
fees covering some other period of time.

This flexibility for fee schedule design is available without regard to whether the air agency has set its
fees to collect above or below the presumptive minimum. Many air agencies have designed their fee
schedules to collect fees using an emissions-based approach that mirrors the approach of part 70 for
determining the presumptive minimum program cost for an air agency.63 However, air agencies are not
required to charge fees to sources in that manner, and it is possible that such an approach may not
necessarily result in fees that would be sufficient to cover all part 70 program costs.

51 See 40 CFR § 70.9(b)(l)(ii); Overview of Clean Air Title V Financial Management and Reporting - A Handbook for
Financial Managers, Environment Finance Center, University of Maryland, Maryland Sea Grant College, University of
Maryland. Supported by a grant from the U.S. EPA, January 1997 ("Financial Manager's Handbook") (providing an
overview of air agency application of general government accounting, budgeting, and financial reporting concepts to the part
70 program).

62	See 40 CFR § 70 9(b)(3).

63	See 40 CFR § 70.9(b)(2)(f).

13

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IV. The EPA Review of Existing Air Agency Fee Programs

The initial program submittals involved review of data on expected fee revenue, program costs and
accounting practices that were prospective in nature, since little or no data would have been available on
actual fees or costs at that time.

At this point, the EPA review of air agency fee programs generally focuses on a review ofactual data on
fee revenue, program costs, and review of existing accounting practices. The EPA oversight of existing
fee programs will also likely be conducted as part of a program evaluation, a separate fee evaluation, or
through submittal of any periodic updates or detailed accountings related to fee demonstration
requirements. The EPA has issued a separate memorandum and guidance on part 70 program and fee
evaluations concurrently with this updated fee schedule guidance.^4

Fee evaluations for existing part 70 programs will generally focus on certain key requirements of the Act
and part 70 for fees discussed in Section 1, General Principles for Review of Title V Fee Schedules, of
this guidance. Such reviews may cover certain aspects of air agency accounting practices and procedures
related to fees, particularly fee assessment procedures, tracking of fee collection and revenue uses
(including transfers in and out of part 70 program accounts), whether all part 70 costs are included in the
air agency's accounting of costs, and potentially other accounting aspects.

A fee evaluation may include a review of an air agency's fee program status with respect to the
presumptive minimum defined in 40 CFR § 70.9(b)(2). This may be important in cases where a part 70
program was initially approved to charge above the presumptive minimum, in order to determine if the
air agency is now charging less than the presumptive minimum. This is relevant because 40 CFR §
70.9(b)(5)(i) requires an air agency to submit a detailed accounting to show that its fees would be
adequate to cover the program costs if the air agency charges less than the presumptive minimum. This
requirement is ongoing (not restricted to program submittals).

In addition, the EPA revised the part 70 requirements related to calculating the presumptive minimum to
add a "GHG cost adjustment'' in an October 23, 2015, final rule.65 Although the EPA has announced a
review of this final rule (82 FR 16330, April 4, 2017), the EPA has not proposed any specific changes to
the "GHG cost adjustment." Because air agencies are required to collect sufficient fees to cover the costs
of implementing their operating permit programs, they may still use the "GHG cost adjustment" (as
applicable) in calculating the fees owed to reflect the associated administrative burden of considering
GHGs in the permitting process. The "GHG cost adjustment" is designed to cover the overall added
administrative burden of adding GHGs to the permitting program in a general sense.

6-1 Program and Fee Evaluation Strategy and Guidance for Part 70, Peter Tsirigotis, Director, Office of Air Quality Planning
and Standards (OAQPS), U.S. EPA, to Regional Air Division Directors, Regions 1 — 10, March 27, 2018.

65 The "GHG cost adjustment" was promulgated as part oftan October 23, 2015, final rule titled. Standards of Performance
fir Greenhouse Gas Emissions from New, Modified and Reconstructed Stationary Sources; Electric Utility Generating Units,
80 FR 64510. Specifically, see Section XII.E. 'implications for Title V Fee Requirements for GHGs" at page 64633, See also
40 CFR §§ 70.9(b)(2)(v) and (d)(3)(viii).

14

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"Presumptive Minimum" Calculation

1.	Calculate the "Cost of Emissions." The calculation is based on multiplying the actual
emissions of "fee pollutants"66 (tons) from the air agency's part 70 sources for a preceding 12-
month period by the "presumptive minimum fee rate"67 ($/ton) that is in effect at the time the
calculation is performed.

Air agencies may exclude the following types of fee pollutants from the calculation:

-	Actual emissions of each regulated fee pollutant in excess of 4,000 tons per year on
source-by-source basis.68

-	Actual emissions of any regulated fee pollutant emitted by a part 70 source that was
already included in the presumptive minimum fee calculation (i.e.. double-counting of
the same pollutant is not required).69

-	Insignificant quantities of actual emissions not required in a permit application pursuant
to 40 CFR § 70.5(c).70

2.	Calculate the "GHG Cost Adjustment" (as applicable)71 The ';GHG cost adjustment" is the

cost for the air agency to conduct certain application reviews (activities) to determine i f GHGs
have been properly addressed for an annual period. The adjustment is calculated by multiplying
the total hours to conduct the activities (burden hours) by the average cost of staff time ($/hour)
to conduct the activities.

To calculate the total hours for the air agency to conduct the activities, multiply the number of
activities performed in each category listed in the following table by the corresponding "burden
hours per activity factor," and sum the results.72

Table 1. GHG reviews counted for GHG cost adjustment purposes

Activity

Burden Hours per
Activity' Factor

GHG completeness determination
(for initial permit or updated application)

43

GHG evaluation for a permit modification or
related permit action

7

GHG evaluation at permit renewal

10

66	The term "fee pollutants" used here is shorthand for "regulated pollutants (for presumptive fee calculation)," as defined in
40 CFR § 70.2.

67	The "presumptive minimum fee rate" is calculated by the EPA in September of each year and is effective from September

I	to August 31 of the following year. The fee rate is adjusted annually for changes in the Consumer Price Index (CP1) and is
published on the following Internet site: htrps;//www.epa.gov/title-v-operating-permits/permh-fees.

68	See 40 CFR § 70.9(b)(2)(ii)(B).

69	See 40 CFR § 70.9(b)(2)(ii)(C). For example, a source may emit an air pollutant that is defined as both a hazardous air
pollutant and a pollutant for which a national ambient air quality standard has been established, e.g., a volatile organic
compound. The actual emissions of such a pollutant is not required to be counted twice for fee purposes.

70	See 40 CFR § 70.9(b)(2)(ii)(D),

71	See 40 CFR §§ 70.9(b)(2)(i) and (v).

II	The table shown here is found at 40 CFR § 70.9(b)(2)(v).

15

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To determine the GHG cost adjustment^ $), the total hours to conduct the reviews (calculated
above) is multiplied by the average cost of staff time ($/hour). The average cost of staff time
must include wages, employee benefits, and overhead and will be unique to the air agency. The
average cost may be known for the air program or may be available from the air agency budget
office or accounting staff.

3. Calculate the Total Presumptive Minimum. The total presumptive minimumt($) for the annual
period is determined by adding the "cost of emissions" (determined in Step 1) and the "GHG
cost adjustment," as applicable (determined in Step 2).

See Attachment B, Example Presumptive Minimum Calculation, for an example calculation for a
hypothetical air agency that incorporates the "GHG cost adjustment."

V. Future Adjustments to Fee Schedules

Air agencies must collect part 70 fees that are sufficient to cover the part 70 permit program costs.73
Accordingly, air agencies may need to revise fee schedules periodically to remain in compliance with
the requirement that permit fees cover all part 70 permit program costs. Changes in costs over time may
be due to many factors, including but not limited to: changes in the number of sources required to obtain
part 70 permits; changes in the types of permitting actions being performed; promulgation of new
emission standards; and minor source permitting requirements for CAA sections 111, 112, or 129
standards. Air agencies should keep the EPA Regions apprised of any changes to fee schedules over
time. The EPA will assess the proposed revision and determine whether it must be processed by the EPA
as a substantial or non-substantial revision. As part of this process, the EPA may request additional
information, as appropriate.

73 40 CFR § 70.9(a).

16

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ATTACHMENT A

List of Guidance Relevant to Part 70 Fee Requirements
EPA Guidance on Part 70 Requirements:

•	January 1992 - Guidelines for Implementation of Section 507 of the Clean Air Act Amend me ntsa-
Final Guidelines, Office of Air Quality Planning and Standards (OAQPS), U.S. EPA. See pages 5
and 11-12 concerning fee flexibility for small business stationary- sources:

hlt'p://\vww.e pa. gov/si tes/production/files/2015-08/documents/smbus.pdf.

•	July 7, 1 993 - Questions and Answers on the Requirements of Operating Permits Program
Regulations, U.S. EPA. See Section 9: http://www.epa.gov/sites/production/files/2015-
08/documentsfbhrd_qa I .pdf.

•	August 4, 1993 - Reissuance of Guidance on Agency Review of State Fee Schedules for Operating
Permits Programs under Title V, John S. Seitz, Director, OAQPS, U.S. EPA, to Air Division
Directors, Regions I-X ("1993 fee schedule guidance"). Note that there was an earlier document on
this subject that was superseded by this document:

http:fJwww3.epa.gov/ttn/naaqs/aqmguide/colleclion/i5/fees.pdf

•	August 9, 1993 - Acid RaimTitle V Guidance on Fees and Incorporation by Reference, Brian J.
McLean, Director, Acid Rain Division, U.S. EPA, to Air, Pesticides, and Toxics Division Directors,
Regions I, IV, and VI, Air and Waste Management Division Director, Region II, Air and Toxics
Division Directors, Regions III, Vll, VIII, IX and X and Air and Radiation Division Director,

Region V: hitp://www.epa.gov/sites/production/filesf20l5-0H/documenis/combo809.pdf

•	September 23, 1 993 — Matrix of Title V-Related and Air GrantaEligible Activities, OAQPS. U.S.
EPA ("matrix guidance"). The matrix notes that it is to be '"read and used in concert with the August

4,	1993, fee [schedule] guidance": http://www.epa.gov/sites/productionJfiles/20l5-
08/documents/matrix.pdf.

•	October 22, 1 993 - Use of Clean Air Act Title V Permit Fees as Match for Section 105 Grants,

Gerald M. Yamada, Acting General Counsel, U.S. EPA, to Michael H. Shapiro, Acting
Administrator, Office of Air and Radiation, U.S. EPA:
htrpsfJwww.epa.gov/sites/production/files/20l5-08/documents/usefees.pdf

•	November 01, 1993 — Title V Fee Demonstration and Additional Fee Demonstration Guidance. John

5.	Seitz, Director, OAQPS, U.S. EPA, to Director, Air, Pesticides and Toxics Management Division,
Regions I and IV, Director, Air and Waste Management Division, Region 11, Director, Air, Radiation
and Toxics Division, Region 111, Director, Air and Radiation Division. Region V, Director, Air,
Pesticides and Toxics Division, Region VI and Director, Air and Toxics Division, Regions VII, VI11.
IX and X, U.S. EPA ("fee demonstration guidance"):

http: f/www3.epa.gov/ttn/naaqs/aqmguide/col lection/i5(feedemon.pdf

I

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•	July 21,1 994 - Transition to Funding Portions of State and Local Air Programs with Permit Fees
Rather than Federal Grants, Mary D. Nichols, Assistant Administrator for Air and Radiation, U.S.
EPA, to Regional Administrators, Regions I - X ("transition guidance"):
http://www.epa.gov/sites-/production/files/20I5-08Aiocuments/grantmem.pdf

•	August 28, 1994 - Additional Guidance on Funding Support for State and Local Programs, Mary D.
Nichols, Assistant Administrator for Air and Radiation, U.S. EPA, to Regional Administrators,
Regions 1 - X ("additional guidance memo"): http://www.epa.goV/sites/productioti/files:/2015-
08/documents/guidl ine .pdf.

•	January 25, 1995 - Options for Limiting the Potential to Emit (PTE) of a Stationary Source Under
Section J12 and Title V of the Clean Air Act (Act), John S. Seitz, Director for Office of Air Quality
Planning and Standards, U.S. EPA, to Regional Directors, Regions 1 - X:
https://www.epa.gov/sites/production/files/documents/Hmit-pte-rpt.pdf.

•	January 23,1996 - Letter from Conrad Simon, Director, Air & Waste Management Division, EPA
Region II to Mr. Billy J. Sexton, Director, Jefferson County Department of Planning and
Environmental Management, Air Pollution Control District, Louisville, Kentucky ("Sexton memo"):

hl(ps:/'Jwww.epa.gov/sites/production/files/20l6-04/documents/sexton _l996.pdf

•	January 1997 - Overview of Clean A ir Title V Financial Management and Reporting - A Handbook
for Financial Managers, Environment Finance Center, University of Maryland, Maryland Sea Grant
College, University of Maryland. Supported by a grant from the U.S. EPA ("financial manager's
handbook"): http://www.epa.gov/sites/production/files/20J5-08/docimenis/t5jinance.pdf

•	October 23, 2015 - Standards of Performance for Greenhouse Gas Emissions from New, Modified
and Reconstructed Stationary Sources: Electric Utility Generating Units: Final Rule (80 FR 645tl 0).
See Section XII.E, 'implications for Title V Fee Requirements for GHGs" at page 64633:

http://www.gpo.gov/fdsys/pkg/FR-2015-10-23/pdf/2015-2283 7.pdf

Guidance on Governmental Accounting Standards Relevant to Part 70:

•	Handbook of Federal Accounting Standards and Other Pronouncements, as Amended, as of June 30,
2015, Federal Accounting Standards Advisory Board (FASAB).

http://www.fasab.gov/pdffiles/2015Jasab_handbook.pJf

•	Statement of Federal Financial Accounting Standards 4: Managerial Cost Accounting Standards and
Concepts, page 396 of the FASB Handbook ("SFFAS No. 4").

•	Statement of Federal Financial Accounting Standards 7: Accounting for Revenue and Other
Financial Sources and Concepts for Reconciling Budgetary and Financial Accounting, page 592 of
the FASAB Handbook ("SFFAS No. 7").

Statements of the Governmental Accounting Standards Board (GASB):

•	Statement No. 33, Accounting and Financial Reporting for Nonexchange Transactions (December
1998) ("GASB Statement No. 33"):

http://www.gasb.org/jsp/GASB/Document C. GASBDocumentPage?cid-l 176160029148&accepted
Disclaimer= true.

2

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• Statement No. 34, Basic Financial Statements - and Management's Discussion and Analysis for
State and Local Governments (June 1999) ("GASB Statement No. 34"):

http://www.gasb.org/jsp/GASB/Document_C/GASBDocumentPage?cid= 117616002912l&accepted
Disclaimer=true.

3

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ATTACHMENT B
Example Presumptive Minimum Calculation

This attachment provides an example calculation of the "presumptive minimum" under 40 CFR part

70 for a hypothetical air agency ("Air Agency X").?1

Background:

•tt The "presumptive minimum" is an amount of fee revenue for an air agency that is presumed to
be adequate to cover part 70 costs.2

ott If an air agency's fee schedule would result in fees that would be less than the

presumptive minimum, there is no presumption that its fees would be adequate to cover
part 70 costs and the air agency is required to submit a "detailed accounting" to show that
its fees would be sufficient to cover its part 70 costs.3

ott If an air agency's fee schedule would result in fees that would be at least equal to the
presumptive minimum, there is a presumption that its fees would be adequate to covertt
costs and a "detailed accounting" is not required. However, a "detailed accounting" is
required whenever the EPA determines, based on comments rebutting the presumption oftt
fee adequacy or on the EPA's own initiative, that there are serious questions regarding
whether its fees are sufficient to cover part 70 costs.4

•tt In addition, independent of the air agency's status with respect to the presumptive minimum, at
"detailed accounting" is required whenever the EPA determines on its own initiative that therett
are serious questions regarding whether an air agency's fee schedule is sufficient to cover its parttt
70 costs. This is required because part 70 requires an air agency's fee revenue to be sufficient to
cover part 70 permit program costs.5

•tt The quantity of air pollutants and the "GHG cost adjustment" are unique to each air agency andtt
vary from year-to-year. As a result, the presumptive minimum calculated for an air agency istt
also unique to that particular agency on a year-to-year basis.tt

•tt No source should use the presumptive minimum calculation described in this attachment to
calculate its part 70 fees.6 Sources should instead contact their air agency for more informationtt
on how to calculate fees for a source.tt

1	The example calculation follows the requirements of40 CFR § 70.9(b)(2)(i)-(v).tt

2	See 40 CFR § 70.9(b)(2)(i).

3	See40 CFR § 70.9(b)(5) (concerning the "detailed accounting" requirement).

4	See 40 CFR § 70.9(b)(5)(ii).

5	See 40 CFR §§ 70.9(a) and (b)(1).

6	See40 CFR § 70.9(b)(3) (providingair agencies with flexibility on how they charge fees to individual sources).

I

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• An air agency may calculate the presumptive minimum in several circumstances:

o As part of a fee demonstration submitted to the EPA when an air agency sets its fee
schedule to collect at or above the presumptive minimum.

o As part of a fee evaluation to determine if an air agency with a fee schedule originally-
approved to be at or above the presumptive minimum now results in fees that are below
the current presumptive minimum. When this occurs, the air agency is required to submit
a ''detailed accounting" to show that its fee schedule w ill be sufficient to cover all
required program costs. Such a change in the presunptive minimum for an air agency-
may occur for many reasons overtime.7

o To update the presunptive minimum amount for the air agency to account for changes
that have occurred since the calculation was last performedaA common reason for an air
agency to do this is to recalculate the arnount to add the GHG cost adjustment.8

The presumptive minimum calculation is generally composed of three steps:

1.	Calculation of the "cost of emissions. "aThe "cost of emissions" is proportional to the emissions
of certain air pollutants of part 70 sources.

2.	Calculation of the "GHG cost adjustment" (as applicable). The "GHG cost adjustment,"
promulgated in October 23, 2015, is intended to recover the costs of incorporating GHGs into the
permitting program.

3.	Sum the values calculated in Steps 1 and2.

7 It has been almost two decades since most part 70 programs were approved. Changes may have occurred since then that
would affect the presumptive minimum calculation for an air agency. For example, changes in the emissions inventory for
part 70 sources or changes to air agency fee schedules. The part 70 rules were also revised in 2015 to add a "GHG cost
adjustment" to the calculation of the presumptive minimum fee.

*See 80 FR 64633 (October 23. 2016); 40 CFR § 70.9(b)(2)(v).

2

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Example Scenario and Calculation:

Air Agency X performs its presumptive minimum calculation in November of2016 using data for Fiscal
Year 2016 (FY16 or October 1, 2015, through September 30, 2016).

Step 1 - Calculate the Cost of Emissions:

The "cost of emissions" is determined by multiplying the air agency's inventory of actual emissions of
certain pollutants from part 70 sources ("fee pollutants") by an annual fee rate determined by the EPA.

A.	Determine the Actual Emissions of "Fee Pollutants" for a 12-month Period Prior to the
Calculation.

Note that the term "fee pollutants" used here is shorthand for "regulated pollutants (for
presumptive fee calculation)," a defined term in part 70,9 which includes air pollutants for which
a national ambient air quality standard has been set, hazardous air pollutants, and air pollutants
subject to a standard under section 111 of the Act, excluding carbon monoxide, greenhouse
gases, and certain other pollutants.10 Note that any preceding 12-month period may be used, for
example, a calendar year, a fiscal year, or any other period that is representative of normal source
operation and consistent with the fee schedule used by the air agency.

For example, a review of Air Agency X's emissions inventory records for part 70 sources for the
12-month period (FY16) indicates that the actual emissions of "fee pollutants" were 15,700 tons.

Total "Fee Pollutants"t= 15,700 tons for FY16

B.	Determine the Presumptive Minimum Fee Rate (S/ton) Effective at the Time the
Calculation is Performed.

The presumptive minimum fee rate is updated by the EPA annually and is effective from
September 1 until August 31 of the following year. Historical and current fee rates are available

online: h{tps://www.epa.gov!/title-v-opera!ing-permits/permit-fees._Jhe fee rate used in the
calculation is the one that is effective on the date the calculation is performed, rather than the fee
rate in effect for the annual period of the emissions data.

For example. Air Agency X calculates its "presumptive minimum" for FY! 6 in November 2016.
The air agency first refers to the EPA website (listed above) to find the fee rate effective for
November 2016. This fee rate ($48.88) is used in the next step to calculate the cost of emissions.

Presumptive Minimum Fee Rate ($/ton) = S 48.88 per ton.

9	The definition of "regulated pollutant (for presumptive lee calculation)" is found at 40 CFR § 70.2.

10	Note that 40 CFR §§ 70,9(b)(2)(ii) and (iii) provides exclusions for certain air pollutants and includes a definition of
'"actual emissions."

3

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C.aCalculate the Cost of Emissions.aa

Calculate the cost of emissions by multiplying the total tons of'"fee pollutants" (value found in
A)tby the presumptive minimum fee rate (value found intB).tt

Cost of Emissionst= "Fee Pollutants" (tons) * Presumptive Minimum Fee Rate ($/ton)
= 15,700 tonst* $48.88/ton
= $767,416

Value Calculated in Step 1: Cost of Emissionsa= $767,416
Step 2 - Calculate the GHG Cost Ad iustment (as applicable):

The "GHG cost adjustment" is the cost for the air agency to review applications for certain permitting
actions to determine ifGHGs have been properly addressed.

A.a Determine the Number of GHG Activities for Each Activity Categoryaa

Determine the total number of activities processed during the period for each activity category
listed in the following table [based on table at 40 CfR § 70.9(b)(2)(v)].

Activity

Burden Factor
(hours per activity)

GHG Completeness Determinations
(for initial permit or updated application)

43

GHG Evaluations for Permit Modification or
Related Permit Actions

7

GHG Evaluations at Permit Renewal

10

For example, Air Agency X's records were reviewed to determine the number of activities that
occurred for each activity category during FY 16:

•tt 2 GHG completeness determinations for initial applicationstt
•tt 46 GHG evaluations for permit modifications or related actions

(II significant modifications and 35 minor modifications)

•tt 20 GHG evaluations at permit renewal tt

Note that the activities above are assumed to occur for each initial application, permit
modification, or permit renewal, regardless of whether the source emits GHGs or is subject to
applicable requirements for GHGs. Thus, there were 20 GHG evaluations at permit renewal
because there were 20 permit renewals.

4

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B. Calculate the GHG Burden for Each Activity Category.

The GHG burden for each activity category is calculated by multiplying the number of activities
for each category (identified in A) by the relevant burden factor (hours/activity) listed in the
table above.

GHG Burden = Number of activities * Burden factor (hours/activity)

For example, Air Agency X calculated GHG burden as follows:

•	2 Completeness Determinations * 43 hours/activity = 86 hours

•	46 Evaluations for Mods or Related Actions * 7 hours/activityt= 322 hours

•	20 Evaluations at Permit Renewal * 10 hours/activity = 200 hours

G Calculate the Total GHG Burden (in hours).

The total GHG burden hours are calculated by summing the GHG burden hours for each activity
category determined in B.

For example, Air Agency X calculated total GHG burden hours as follows:

Total GHG Burden Hours = 86 hours + 322 hours + 200 hours

= 608 hours

D. Calculate the GHG Cost Adjustment.

Calculate the GHG cost adjustment for the period by multiplying the total GHG burden hours
(value calculated in C) by the cost of staff time.

GHG Cost Adjustments Total GHG burden hours (hours)t* Cost of staff time ($/hour)

For example, Air Agency X's budget office reported that the average cost of staff time for the
Department of Natural Resources (including wages, benefits, and overhead) for FY16 was
$56/hour.

GHG Cost Ad justmentt= Total GHG burden hourst* Cost of staff time

= 608 hours * $56/hour

= $34,048

Value Calculated in Step 2: GHG Cost Adjustments S34,048

5

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Step 3 - Calculate the Total Presumptive Minimum:

Calculate the total for the period by adding the cost of emissions (value calculated in Step 1) and the
GHG cost adjustment, as applicable (value calculated in Step 2).

Presumptive minimumt= Cost of emission ($) + GHG cost adjust mentt($)

= $767,416 + $34,048

- $801,464
TotalaPresu mptive Minimum= 5801,464
Conclusionzaa

$801,464 is the Air Agency X's presumptive minimum for FY1 6. This value would be compared against
the total part 70 fee revenue for the same period to determine if the total fee revenue is greater than or
less than the presumptive minimum.

6

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Overview of

CLEAN AIR

Title V Financial
Management	and

A Handbook for Financial Officers
and Program Managers

-------
ACK NOW LEDG M KNTS

Tlx- jW4j(lut:tki»i of lhi> IkwUki N m.>de {t{i!r«t finaiu'irtl fi*ruik if Appends,\ A a«r frutit ftnfmwwdi'
Am'mUmy, Audi tiny and }tn>i)u tul Ht-pii>nnx'. repmik\! with	of thf

Otm'rnmciit Finance Ofliccrs A>m-iAtit. of tin*, lunulNok. crtiitaci

Fnvir(»urncnt;>

-------
Overview of

mm «

Title V Financial
Management and Reporting

A Handbook for Financial Officers
and Program Managers

Produced in
Environmental Finance Center
University of Maryland System

Supported by
US. Environmental Protection Agency
Maryland Sea Grant College

January 1997

-------
,> - IVI.' hy M.tijlwia v.. !r«i;i inJlrjv
FnbiuMSiiM NumNf UM Mi-( TH'-Vi-lC

Produced If	liiwiH 11 fun r, I 'urn rsity of MwyJwtd Spiaii it coop-

mtim w»i» tie MbU.iii- i niv t«an:< '.iltp, lloiwisllf of Maty tad, College Pill,

"	^J * |Tj "£ft *f 'ClCTIUC'F	* (•-

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si.iH1 ,«»u lm ti! otlM uls ,yi.l M!i,ill Inivni -.\i\ flT «m ivi «. ,«<	111 .lenu.wi.tit

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coiUM'i., iiviIitmH. .mil pintcrwc.

"11 sr pjiiiinprninfi itn'mitnms .in- i «
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Contents

Introduction	 						v

Overview of Title V Program Management Challenge 	viSi

CHAPTER 1

Time Keeping and Cost Allocation 		 I

Introduction				1

Allocating Title V Costs 					 4

Time Keeping 				7

Lesbos Learned In Air Quality Agencies		 15

Conclusion 							19

CHAPTER2

Accounting Fraincw ork for Title V Programs 		21

Types of Funds 						23

Government Fund Accounting Reports ...........	29

Accounting for the Title V Program 		29

Summary; Pros- and Cons of Title V Accounting

Structure Alternatives 			 . 		38

Criteria for Evaluating the Need to Modify
an Agency:Title V Accounting Structure	„ 40

CHAPTER 3

Management Reporting and Tracking 		.43

Introduction 					 		43

Internal Reporting 			 44

External Reporting . 			49

Conclusion 								55

Appendix A 	 ................. 59

Appendix B 						81

Hi

-------
Introduction

mj

m

Title V of the Clean Air Act Amendments of 1990
(P.L. 10] -549) establishes an operating permit pro-
gram for stationary sources of air pollution. Title V
requires that slate agencies and local air programs col-
lect fees from air permit holders to support operation
of the permit program. Since the passage of the Clean
Air Act states have been working diligently to ad-
dress the many challenges associated with the imple-
mentation of the Title V program. All states and LI S,
territories (6) have submitted operating permit pro-
grams to EPA for approval. Most of these programs
have been approved.

Among the myriad challenges confronting states
in designing and implementing the Title V operating
permit program is the need to address associated fi-
nancial management responsibilities. This document
explores the financial challenges air quality agencies
face when implementing the Title V program. The
goa) of the document» to help state, local, and feder-
al air program personnel—especially those with' limit-
ed financial management experience-—to understand
the fundamentals of financial management and report-
ing, It provides an overview of Title V program fi-
nancial management challenges, discusses generally
how states are addressing these challenges, provides
state-specific examples of Title V management and re-
porting practices, and discusses pros and eons of vari-
ous approaches, to financial management.

Introduction »

-------
1 This overview report was developed to be an
introductory guide to key Title V financial manage-
ment responsibilities •- but should not be considered
lo be formal EPA guidance. The report was devel-
oped through a broadly designed interview-survey
process that explored Ihe slate/local application of gen-
eral government accounting, budgeting, and financial
i reporting concepts to the Title V program. The prima-
ry large! audience for this document includes state and
local air qualify agencies thai arc in the process of de-

i	velopins or refining the financial management and re-
porting aspect of their Title V program,

The remainder of this report is presented in five
section4.. The next section provides a brief description
of the Title V management challenges as were idenli-

ii	lied through the research phase of ihe project.

Sections three, four, and five explore the primary fi-
nancial management challenges. The findings of the
study are summarised in if* conclusion section of this
report.

How Many Air Programs Are There?

There are 56 slate (including the District of
i Columbia and Territories) and 60 local air operating
i permit programs in the United Slates, Most stales in
ihe U.S. have a single program account for all ail* pro-
gram operating procedures, fees,, and permits within

i their slate,

i

1

In eleven stales there are also local air programs,
, Some states allow these local programs to collect and

w Introduction

-------
distribute their own Title V fees. In other slates,
however, a state agency collects all Title V fees and
distributes, them to the local programs. In California, 5
on the other hand, ihere is no stale program at all. and |
all 34 local permitting authorities submit operating
permit programs directly to the KPA,

There are no mulii-state Title V permit program.4.. <
There are, howevei. some multi-state hoards which
discuss certain environmental issues, including air
pollution and Title V permits.	!

Clean Am Act	1

(Mkatinu Permits Pnogkams	[

Number of	Mumber of	Number of	j

Region Stales/Territories Stole Programs local Programs	i

1

6

6

0

II

4

4

0

HI

8

§

0

IV

8

a

10

V

6

6

0

VI

5

5

1

¥1!

4

4

2

VIII

6

8

0

IX

7

7

39

X

4

4

e

Total

58

56

CO

Itrtroduttmn rif

-------
States with Local Priw.kams

ibt of

1 Heg:or

Slate

Programs

IV

Alabama

o

1 iV

Kentucky

i

IV

North Caroiha

w

1 IV

T&noessee

4

i VI

New Mexico

1

! vii

Nobrr.f.k:-;



IX

Areorsa

3

IX

California

34

IX

Nevada

?

X

Oregon

1

X

Washington

8



Overview of Tillt* V Program MaiiageiiMnt
Challenges

Die ininnJueiion of I he Clean Air Aci Title V Fee

Piopram pre seined many challenges to Male stir quali-
ty uerricy personnel. ^eciTiadly in the ureas oi finan-
cial iimiiiigcuiuiil ami reporting. Hisloriealiy. these
agencies have been invoked with (he implementation
;sik1 management of the Seel ton 105 program, funded
by fcdetal grants, Conversely. Title V does not pro-
vide fecieuil gratif.s to state ,iir quality agencies fur
piognim implemeniaiioii, lasicad, (he Tide \' jirr-
jram i>, de.sjpiied to he completely self sufficient, rely-
injk' on lee.1; received from Ink V permittees to nffsel
program expenditutes, In many eases, the Tide V pro-
pram is ihe first niajoi fee-based program implement-
ed by state air qu.tlil) ageneiev

rjj'r initmhicUMt

-------
Learning to finally account for fee-bused program
revenues and expencJilures is the primary challenge
facing air quality agencies that, have historically deall
primarily with grant-based programs Further, these
agencies must now J earn to inaiMigc fee-based and
grant-based program resources simultaneously, The
Title V program requires- Male, air quality agencies to
account for Title V resources iu a fashion that segre-
gates them from other air quality programs, requiring
slate agencies lo review the methods used to account
for program resources.

i

Ifeed on interviews conducted with slate ami lo-
cal air program personnel, the financial management i
and reporting challenges facing Title V program agen-
cies can be broken down into three categories:

•	Time Keeping and Cost Allocation. As a result of
Title V, air quality agencies modified procedures for	1
tracking and distributing labor and non-labor costs	j

among Title V and non-Title V programs, A key	j

challenge these agencies face is addressing the	;

niuoner in which indirect costs are allocated to	|

these programs.	j

•	Accounting Fund Structures and Controls. In es-	!

tablashing the Title V program, air quality agencies	-

had to select an accounting fund structure for the	i'

Title V program. Different fund structure?* are rec-	j
ommended for different types of activity by the

governmental accounting industry. Also, the fund	.

Muictme would need to attire the permit program	i
is managed as a segregated set of accounts to assure 1
compliance with the Clean Air Act,

tmimdueUoB Li

-------
[ • Internal and External Hfportinf*. Finally, those

| agencies implementing the Title V program are de-
1 \cltipmp internal ami exu-nud tepoiunji >>Hta*duie%
' t'oi ihcii stakeholder Assessing the success ol the
j Titk- Y (ii'ogiaDi will rely heavily on the list- al
stHHid icportin^ pi acmes

i These eatCL'Oiies jollmy lite natural -sequence o:
J actual financial management activities. First, lilt,' flow
j of financial inl^imaiioii begins with the initial input
ol' labor cos) ininrmaltnn in (lie linie keeping process,
Next, firtanci.il information is organized the budget
and accaimni!}! .system Finally, the information is
repoi ted in financial ;«i
-------
Chaffer 1: Time Keeping
and Cost Allocation

introduction

Tim* keeping

The ability to accurately track lime spent by em-
ployees is just as important in (he government sector
as it is in ihc private sector. Private sector businesses
need to keep track of what their employees are doing
— as well as when they are doii)£ if — in order to
minimize costs and maximize efficiency, While these
goals are also important for governments, sound lime
keeping procedures also allow government accounting
departments and program staff to monitor the labor
charges from program to program. Government bud-
geting and accounting is characterized by strict segre-
gation of the numerous programs.

This same argument holds true for the Title V pro-
gram. Funds to be used to pay the engineers, man-
agers, and administrative staff for working on Title V
tasks must conx* from the Title V program. The only
way to ensure the proper segregation of these labor
charges is through the use of an appropriately de-
signed time sheet process. Employees record their
time on a daily basil, by using different time codes,
each of which refers to a unique account to which
time is charged. After time sheets are submitted, the

Chapter !• timr Kt€pimgmti Cotl AUomtum I

-------
jj	loin? labor hour* dunged to each project can be alien-

;	kited, cither manually or through it computerized .svs-

!	tem. Most importantly, this information can iheri he

)	used by accounting staff and managers alike lo moni-

;	lot the iiatufc oi'Title V, Secrtw 105. oj any other

! cific aii cjuulitv procram.

I

j Cost Adoration

| A p! mwiry ftHHtion of any government accounting
| system to record accurately revenues ami expendi-
ture* as ihey arc realized 01 incus red. Timely rceot d
i ing or posting of accouni activity is ncce.\ need to record dll
• direct and indirect costs associated wsih piogram im-
plementation in a manner that allows those costs to he
identified oi iccogm/eJ - • as a Title V program e\-
| pen sc. for example, Once the accounting system has
I identified the pio^ramfsl to which the expense is at-
: tribute d, the expense can then he allocated. olTs-etung
! the coo'espcMidinj! revenue .soureeis). Figute 1 paplii-

eaily depicts (he flow ot information associated with
| the itme keeping am! cosi allocation process.

4 ( hapur l: Timr Kfrpiiif; ami Cmt AtiimiUm

-------
Figure 1; Cost Allocation
and Time Keeping Activity

Employee carries

iifUiif

__

i Using aHivsty codes
1 errplovee properly

recoras lifrte
i or t»nw shefe!

i

	f	_	_

IAsmwi approves
time sheet after
reviewing time
charges-

1

lltmgiftftiiiii
PCQCMMI

lnfo,*m«t
-------
! AHiicitliiig Title* V Costs

; Numerous costs are assnciatcd with 'Title V pro-
j gram implememahoti, all of whirls can he allwairil is;
i a vunef) of ways, Dircci kthoi includes those prok^-
Munals who can ,'H tribute all or a portion of Elicit work
| lo the Title V program. Indirect In hoi includes (he ;id-
i!)ii»sitii!iw iiRil managerial personnel who provide
jjenenil support for the entire air quality division or
| department Direct fnon-luboi) costs art- those i-oki.s
s ineut'ied through the direct implementation of the Title
, prog run i, Fiiii'tlly, indirect tmm-hhon costs arc
i those costs incurred by the entire di quality division
j or depamneni that will benefit all air pi op am v Ex-
( ii triples oi'ejch of these t\pes o1 expense are present-
| ed below

I	< atl'U"»l\ }	>

Dinvt hhn

Imliieel luhoi



•	I'lnpluyecs iCNjx^nsible lor Title V permimnp

•	«\ir tjtiulrty <~ii^inccr>. ei^kliieuiig penninee
inspections

•	Manajins t>i ait <|iii;(iiv ,iiier,CR".

•	An quality agency ;idiuinsstuii\e
support M.'dT

•	Twel expriiv." to \ i>it Title V permittee

•	leiephoiir chaises :oi Tiilt- V pinpam t«isks

fmSiieet rnon luhm * Olhee supplies fur air t|i«;iiry agency
• liti'ities Ion at! qtuiJitv .^eik'j

•t l hapti r |; Jimr Kfrpittf: itml Cost A Hutation

-------
Diri-ci ("mr Aikn'Gfiwi Oven-iew

Allncaiinp she appropriate direct cost*. lo the Title !
V pr-n:ram is lv>t accomplished in- usuiy stine sheets, i
eiihcr iiinnUiil of automated. that t;u*. mirn»cl with the
government accounting kvvte»i>. Willi sticu a system in ;

place, ii^igninp Until cosh in vawnt*- ait t|tmliiy pro- j

pjanis s> ;i	process. Ah quality dr< |

paitmciu employees fill ou! time si tech weekly us	|

hi weekly lo reliecf tin- tinmbej of houi s spent on un • ;
iou^ tusks. By ussiL"ui%' ii unique account chaise ctnlc i
tn each task, atcnummg art- able to iiucK. is; dc*
tail, the amount of diiect laho! chaired to each ait
ijmtlify program. This iii1orui.ition allows accounting
department1- re- iccpncilc dirrci labor charses v/ith (lie '
"IIIit.- V pio^ram budget and also provides Tnle V pio-
pram manager-- with inlot inatmn on turn laboi is he- '
lll*r tftsltthulCii aciosS vni toils an ifimhty piopwiis i

such as Title \. Section 105. and others,	i

1

Direct, rsnndaboi ciiaip^ vlmitld he allocated us-

ihe ^urie approach. Air quality employees dial	j

ehai^e direct expen.\t*v Mich as UaveJ. Hi air quality	!

programs c;ti: use the satne ,ta*t Hinting cJjai^r code	•

procedures as lor direct labor,	j.

Indirect ( ost Allocation Overview	I

Otargin;; indirect Jahoi and non-labor costs lo var- j
nuts an quality pfopunts is mtah more challenging '
thjii umier lhe direct com scenario in unlet to mum-

liisis el'licieril mid accurate itmiiitum^ practices. air
quality program accountants and manager*' alike need

(fwpsttl litm Kt tfling Mtii ( <>\t Ailactiiitnt 5

-------
| fi.i Clique thai all indirect costs arc* recovered, and ilial
they at'o iccovered cquitaM).

The most practical method of ailoeatinj! indirect
j labor costs to Tide V ami non-Title V programs in-
! viilvev using direct labor charges a.s an index. Under
this fratrtnuirk, nulncct labor charges art" allocated lc»
Title V and non-Title V programs based on the nuiti-
i ber nf dheei kibur hours charged to the vitriol aii
programs. For example, il 'lit It* V direct labor charges
represent sixty percent of I he Mai direct labor charges
within the air quality division, assigning sixty percent
of the indirect labor costs to [lit- Title V program is
justifiable. It can be assumed that sixty percent ot the
secretarial art J immaterial support tune is being spent
| on Title V related I asks under this scenario Percent-
! ajje allocations for indirect labor costs can be adjusted
| weekly ot monthly, based on (he direct labor charges
' for ihat period;.

j Allocating indirect non-fahot costs among Title V
| and non-Til le V is r,wc complicated As indiiect costs
are to be shared among a variety ot programs, they
should be allocated in a manner where the piogram
receiving the greatest benefit from she source of' the

i

1 cost is responsible for the majority olthe cost recov-
er I'nforumately, this presents a tedious and compli-
cated task for accounting stafl. Instead, common
| practice usually involves the same process as de-
scribed tot indirect labor; as the indirect non-labor
costs are allocated based on the percentage direct
j labor charged to each program, However, some stale
j piourums use (heir own discretion for allocating these

ft < hnj.trr tnm Krepmg anil < i>f! Altttralum

-------
costs, often treating indirect non-labor costs as general	f

overhead and charging to each air quality program	;

equally. State specific approaches to this type of com	j
allocation are described in the next section,

Sfafi Title \ Programs

1

Accounting personnel from stale air quality divi-	"

sions across, the country were contacted in order to	j

determine ihe common practices regarding cost alio-	|

cation for Title V and non-Title V programs. The ma-	i

jority of the state air quality agencies interviewed rely	.

on the methods described and recommended in the	j

previous section of this document when tracking time.	I
and allocating and recording costs.

The table on page 8 contains a sample of ihe states J
contacted ami describes Uietr approach to com allocation, ,

Time Keeping	j

Of the slate air quality divisions contacted, all bm J
one- require the completion of weekly ttniesheets to j
provide accounting and program staff with a detailed !
account of where time is spent during the week. To j
complete the timcsheet, employees must provide ihe !
number of (direct labor) hours worked daily on each j
particular task, each of which identified by its own
unique account/charge code. The level of detail in the j
account/charge code system varies from state to state,
but at Ihe very minimum, the Title V program is rep-
resented by iis own unique identifier. The majority of
the time sheet system;; in the stale air quality agencies. ;

Chapter I; Tfmr Kotping end Cost Allocation ?

-------
Tmj>: V Cosi Ai,lo( ai ion ami Tivr Keeping Pkln. en drill

htvr vlw;p !>'• c.i.pt.i

Ininiuid'*
cii MIS i.Matwi'i-iuent

Nj> \>Li<
i.-.lt':. iIh-h , li.i^'il L'ijj,ii)
w rnt rri friuv* • »vf .si
CM empfewet* ««e tf»

th.'jp tH( ir r w

N'rn lihi.*	alhx'.i'n?

In-	t 'I\, ;«m.

'Irk' V,	rn ibi.i
lilvt klutf-'L" h i pn.

Wsi-LM cu.'is ji<, ,i!1i .

tiij.	( hlh V. l,<<))

1 ,:lf \ !(!'»• ht«,r.S > i,.:di giro

/iii'ii

Win-'sko 1.^-tS >wC ,ts;i«..U;l

?>.wih pnn»;,(«i (istir V. iisifi
"i»hc \, M)5,i uri Jif.-i;

!.>!'j>	t.i 1,1th if.'o

c-.rTf

Irta	arc t-rd 1« ill.i.jv k

>r :<•> n..h iiicourf Tiih V
will	Qk IV'A >, <,<,[(.•!;> wk if

dnvvv it ti.inbc* i'* nhci !ss>.u-
p.'.-is .i« v irtvJin U t iurk!.">
Irut •.hit'. .ail Hrun<,»! icporwi;:
f.wew i't1 km ikndv iiiX'crutai

rjo ^nriii'O fi'T>c	an- Usui mJ

with MIS by	t.>jo

!hrpltn«» .iff prvHTU-i,,' frviis
ilm'j'ifir nminiir-rcla^d .nvnanii.
kite V h on'v Hiuii.ii v>kk
tumw ik't.iil K Avrai }n ;vp„fi
n utt iiimmuy ri'piW* dfslnl'Jkii
H1 rryr ,"i ran  mmihlv

I;;jk *Uvt	b;I1 mK rf.m

wilh rww .KV^iuiitsnj" si'liwiit Tin.e
;i,ivh«l' k-jkiii i-> 'W #t»J
'.Uif! fiiiji- 4 ;(is u^nbt-r "t i'-ih-
go.-.'c. iiKiaijiKf* Tiik V. /uru-ij
rri H"« idfntny -~r>,vi?i;
':-sks	in yridi r tin1 "i uV

i uk'fOfV

Tin niip!."ik-u!fli ffi-br.t i.ui-ur'ii-j;'
s\ Mom KU-'SjCi"- with 'ho eiiifik-vf.
iint. 'Jifii \\ »-A"»h u^uv urj iif-

lit idkvi cru^Ji)^ t.•

In "{"(Iff V

CtMiwhrtttM

.X^il'l.iriii J3i .iihv.ltJ

or frut'hini <-S,iI}< Trie \
A ni" V F'A i\ WiXt ii4'
or.r>n>r-,' c?..«' .•,kn*i,ri,w,

w \\ -lr* t'i'rTf\j,fr.il mi* t»i

h'V k'\ d ta>L> li.r Ihr Tit\ \ [•;»»-

i'Mih >V»i*r.;iiiii i. i'	;nfi

'4IS .i'h! rcpiWi ,ttv j'tfisi,
i.'ij. ci^Cinit'd fun'.i. per
IM i.iik, etc

C hnpirr ITime ht rfiinf! and I 'mf Aiiocatinn

-------
are cnmpulcrim) .mil mUMikr with i!u* e*4ha manage-	\
mens htlornnitinn system*s1i MISi in ptaer if! the
slate. This relationship itrr.onp compute) ¦Astern^ al-

lows titnosbeti hs'ntiriuiioii, ioi example the tot;! if	•

niunix'! t>1 heers chained 10 Title V loi the v. eek. to	1

be jnnitcdiulel) tefkv.ed in the Title V budget	^

1'ipiiK' 2 shows an e>;.iiuple ol a ct arid mT>-ciide-
toed Ui scoretitte tasks coneeil) uic sinm n in the 1 n>i J
two columns under ihr "iJt<>je..T' headm;:, I'lus juntu - !
uhi>, entijue iiccounf codes, [

The fii.sf 1'ii'rc itcitvi'ies »tc "NSR" i"\>w Sumctr |
Review"s stihiasks. Tbc last ilt:ee project (unctions j
listed ure OPP i Opcrathi^ Pc: mil Ingram i activities, |
"The	coiunm hsts fin- ujvraitnj.' permit iMogtidii |

;uiivtiy section tcklej Base*! nr. this it:Uf:matk«i). nv> >
count it it' and program peisormel c;in review the i i me
sheet isnii know exact!) how much time was spent on j
each task and to what in, counts that lniie should he !
ehari'ed, atl wrthomi any gucssuurk. Hguic 2 includes
the actual putt's troin the Mine an quality agent,v 3hat 't
"is! and ilefine she uppiopiiate account sob-code"* !ur
the slate acit\ ities inehttlinj: the Title V Operating 1
IV,) mil Program,

Ijibor Costs: Direct	'•

DsieeJ la hoi, those houi.s dedicated to a specs! te
task. are accounted 1 <>i usim: die link* sheet system }

ilesciihed above. hntplovccs simply eittei the numhei
o| hour', wot led and the account eude h,
-------
POS # 1008 DEPARTMENT OF ENVIRONMENTAL QUALITY - T1W£ RETORT — REPORT 1

mnm

9
¦§

I

!

i

r

I Wl, N \M! •iTrti'i

¦n«	smotem ai»i,»e$

1 l. .< > • i,\ \1 •< 1 i M> • >'. i

BIWW SIGNATURE.-.
CEKItPlEDB-Y	

PROJECT

1

2



4

5

i

7

8

9

10

it

12

13

14

IS



1

FUNG,

SECT. |

-

1

17

11

V;

m

21 '

.m

1 ¦¦¦¦

74

25

»

¦m

26



!

8t

torn 1

M

014 1



£00



4.00









!•¦¦¦



6.00









1.00



21.00

V-,

024









3 00









1 »



ion

s.oo| fT

¦JOO



1P .00

wsq

o:vt



1.00

5«0













5.00

2.00





'..00

... .

1700

OPf

ins



5,00





4.00









?sff



7.00







fROO

rw»p

PAR





n

4.00





-

















aoo

OPP

FIF









1.00

7.00

• ' ""

















fl.oo



































a co



































000



































0.00



































000

vj.t.













.

















0.OT

S,LT.































0.P0

M I L.













•

















0.00 1

AC T













*















		

0.

1 TOTAL HOURS

8,00

aoo

8.00

8.00

8,00

OJJB

§.,o§

1.00

§„«

sm

8L00

B.C

• "« 1

n ro

too



«8.00

com*

i -;i

-------
applicable.) After the time sheets arc submitted and I
approved, the actual hours are charged to appropriate "
Title V or non Title V program.	|

Figure 2 also shows total direct labor charges for	!

an air quality agency employee, The "Total Hours"	(

line displays the total hours charged for the day and	!

period (two weeks in this case), while the far right	i

column "Total" shows the number of hours spent on	|

each particular task,	i

Ai« Quality Division
Timk Sheet Bl'ixift & Activity Cooks

June 21,1994	j

Operating Pcrrr.it Program

Function Code OPP	j

Section Code	i

I Activity)

INS

PAR
Elf
REG

'VMM

VIS

CFM

SKI

Explanation

Facility Inspections and Report	!

Writing/Staff Review
Operating Permit Application Review j
Emissions Inventor)/tee Assessment !
Regulation and SIP Development for '
Stationary Sources	i

Ambient Monitoring — See March 24,

budget Chargeable Work	|

Activities for list of activities.

Visibility Monitoring
C'KMs Certification and Audits
Stack Tests Witness and Review	i

("kaptrf I: Tunc Keeping and CmtAfliKatim 11

-------
cm

Review of Facility Compliance



Reports

SUA

Small Business Technical Assistance



Program

EPA

EFA Reporting

FIL

Filing

AQB

Air Quality Advisor>" Board

BPT

Budget Preparation and Tracking

CMI

Complaint Investigation (Stationary



Source)

ENF

Enforcement prior to Filing in Court

ADM

General Administrative Duties.



(Reserved for Administrator



Secretaries, Program Manager!

j New Source Review (NSR) Function Code NSR
I .Section Code (Project/Activity)

Assigned

Application * A Unique Application number is
!	assigned for each application corre-

sponding to company name and date
of application

ADM	General Administrative Duties

(Reserved for Program Mgr. and
i	Administrator)

12 Chapter i; Timp Ktepimg tusi €mi A Uocetum

-------
Non Fee Program (EPA 105 Grant and Slate General
Fund)

Function Code
(Budget) 105

Section Code (Activity) and Explanation

A MM

ASB
CMI

REG

IB FT
ENP

ADM

RAD

RSI

Ambient Monitoring (See March 24,
1994 Budget Chargeable Work
Activities for full list of activities)
Asbestos and Indoor Air
Complaint Investigation (Not related
to stationary sources.)

Regulation and SIP Development (Not
related to stationary sources).

Budget Preparation and Tracking
Enforcement Activities-including all
enforcement actions for asbestos and
work after filing in court for stationary
sources,

General Administrative Duties
(Reserved for Administrator,
Secretaries, and Program Manager)
Radiological Activities
Railroad Safety Initiative

iMbor Coxts: Indirect

For most ot the air quality agencies interviewed,
the process oi allocating indirect labor cost is based
on the direct labor tracking system described above,
Labor costs for air quality division managers and

C.hapftr 1 .* Tims Ktepmg and Co.it4notation 13

-------
1 administrative support statf that are not directly cm rib-
j unibie to a program activity cade ate allocated based
j or. the percentage of loud labor charged lo each of (ht
' air programs. e.g.. Title V, Section 105, etc. I J?in£
, the employer time sheet *y,siem, the total number of
dirt-it labor howv charged to each air qualm program
is calculated uionjj with She peicentage that program
i represents of total direct labor charges. These percent -
I lift then multiplied by the total number of indi-
rect labor hours chained for the same period, resulting
in flic proper allocation to U- charged to eaih stir quab
; ity program. Most air quality agencies inter\ iewetl
rely on their MIS n» perform these calculations, while
others make the caleuhliom iiiaiituslh,

i

t Xim-iabttr Costs

Direct non-labor casts are allocated and recorded
| differently fioni state to .state. Some agency staff that

" were interviewed rely on the time sheet system to
j track llie.se costs, usually for travel expenditures that
aic to be charged Hi a particular program, e.g., a Title
; \ pcimiiiee inspection, Other agencies use an inde-
j pendent expense authorization system to appio\e. pay.
allocate, am? record ditees costs, Regardless of the
subtle procedural differences, all agency staff inter
viewed ti.se ait accoum,'charge code to ensure that the
| direct (non-labor) costs are charged lo the appropriate
aii quality program, a code thai usually differs from
that used Hi allocate and recoid labor charges within
• the time sheet system. Additionally, all those inter-
viewed relied on their agency's MLS at some level to
charge direct costs to the various air program budgets.

]J ( ftapio 1; hmt kttpittg and I 'ml iihtmtwn

-------
As expected, allocating and recording indirect j
non-Iabot costs to the various air quality program 1
presents 4 greater challenge to the stale agencies eon- ;
t note J. As described previously, indirect mm-labor
costs would best be allocated among various ah pro-
grams by assessing the amount of" benefit or usage ;
each piogram realize* as a result of incurring the mdi- '
reel cost. Again, measuring the relative contribution of
each indirect expenditure to each air program could |
present a unacceptable administrative burden as at- !
tempts ;ire made to calculate, for example, the amount
of air conditioning costs to be charged to the Title V
pro cram. Instead, the majority of the state air inutility I
agencies interviewed relied on the direct labor pes- >
rentage calculation described above in oider to alio-
cute their indirect non-labor costs. The remaining j
states grouped these indirect r.on labor costs into an !
overheinMike category, distributing the costs equally
among ail of the air quality programs. Again, all state j
agencies contacted rely on their MIS at some level to j
allocate, record, anil post these costs to {he proper air i
program budgets.

Lessons I.earned by Air Qualify Agencies	j

Although the Title V program is relatively new	J

and state and local agencies are just now beginning to	j

implement the accounting procedures necessary tn	'

manage the program, a few lessors have been learned	j1

that can provide insight tor local air quality agencies	j

as they develop their own programs.	I

Chapter i: lime AVcptn# and ( »i A ti(H 
-------
| Allocation Methods

Generally speaking, the methods used by various
ait qualify agencies; to allocate costs among Title V
and non-Title V programs have teen in use for many
years. The use of time sheets and the practice of in-
dexing indirect labor and indirect non-labor costs to
| direct labor hours has a long hi stop.1 in both public
and private sectors, However, most of the agencies
, contacted expressed fbe desire for a more exact or de-
tailed approach to indirect cost allocation. While these
j agencies, for the most part, were unable to offer any
| .suggestions toward efficient improvement;-, a few of
' the agencies were in the process of refining their MIS
" to allow for greater control over indirect con! alioca-
| tion, using indices in place of or in addition lo direct

I labor hours,

~

Some air quality agencies also raised concerns
over direct non-labor cost allocation practices. Wile
most charges are easily categorized and recorded as
Title V. Section 105, etc., some direct charges, espe-
cially those shared among programs, are more diffi-
cult to allocate. For example, an air quality engineer
i incurs travel expenses for a trip to visit a Title V per-
mittee. However, on the same trip, that engineer also
performs a site visit under the Section 105 program,
To which program should the engineer charge the (di-
l rect) travel costs? Indirect costs would be allocated
based on direct labor hours, but travel expenses, are
direct costs and roust be charged directly to a specific
; program. In .some states, the answer lies in the enci-
| neer's own judgement regarding the extent to which

16 Cltaptcr I; Ttrne htrpinf and € mi Alk*aTion

-------
lire flip v.:is primarily to conduct one rn'iivst} 01 ai>-
ullict, Most siakw luivi'	policies r«* puictiees

in place thai rests)! m equal sharing ol eosis between i
ait piogram bmifitl centers such as the Title V pro- i
I'nitiJ iind the Section 105 srraiil propmcm, Regardless ;
of the process that states have devised, it K important j
to p!siiit otil that these pniceiiurcs should he formally
d'>M. u mettled and coinrfmmealed to Jr. PA Regional Air
contacts. Dticuniejunlioii of Uk practices will help in |
minimize a:ty iriiMiuderstisiiiisrij,^ reeurdme cost sliai •
mp v vicliev.	,

AccaunlfChargf Ctides	!

Many ,m qu,tlit> utiCLC ii'.s expressed tliifivully in	;

implementing die time sheer s\stern with respect to	i

iiconmU'lKiiyr cone*. Interviews with iseeth.} ;tc-	J
counting pe'sonm-i indicated that some lime .sheet s\ ,s

terns contain too mam codes, sub-codes, mi h-sub-	,

codes. ete. ins clurtrinj! tasks under Title V. «i ijoi;-	j

1'itle V programs. In these cu^es, ;tir tfuaiitv program	I

personnel ;«e sometime* inconsistent v, ith respect to	'

chare itm time to identic;)! tasks. This problem is up-	i

pa\ utect b> the hiei that tew aeetmnfisig start'persons	i

i

are required to understand die subtle diiTererii.es be-
tween these often technicu! tasks and are unable to i
cuttvet the MlS-codinc, sint'lehamEedlv.	|

|

Cotneiseiy, about the same iiumbei of agetkaes
claim the accomt!'chare e codes are not detailed	J

enough, with ^ Jew n» *ju«ihiy aecneics using only j
one aeefHiiit/chiU'ge code fur ,«ll Title-V-related ta^.s. !
This weakness leaves air program mitmipers without j

('{Mtpit'f Jinn hitpmp. tmti Co*! AUitcntitm 17

-------
adequate information concerning the specific tasks
with which their employees are involved.

Several agencies indicated that they have already
modified their activity code lists to facilitate use and
achieve more accurate recording of time arid expense
charges. It should be expected that agencies will con-
tinue to modify their activity codes as they gain more
experience with the Title ¥ program and identify
ways of improving the process.

MISiTime Sheet System

Many of the. individuals interviewed in air quality
agencies are currently working to enhance their man-
agement information systems (MIS) and to expand the
role of MIS in air quality program management.

While all of those interv iewed employ MIS to some
degree, most are moving towards significant system
enhancements that will present budget comparison re-
ports, labor distribution reports, and other financial
comparisons in real time, taking into account the most
up-to-date data in the system. For all of the state air
quality agencies, these enhancements include sophisti-
cated interfaces between the MIS accounting/finance
modules and the agency's time sheet system, allowing
up-to-date information on labor cost allocation among
Title V and other air quality programs.

Report Reconciliation/Re vie w

Filially, most of the air quality agencies expressed
the need for a more thorough review process with

#J Chapttr J; Tint Kttping and Cost Allocation

-------
re>pi\1 to Itv;- uiTir Mu-ei s\ Mem nrul tTcn olk'i'aUnri

proccJuio Spcul kalh, .sir vjualily a|.V}K'y ; utmtifik"*
pci>umiti Kiicw periodic lnJerannm i\ reqimed lx-
tvuvri un minting >Uui am: ah pui-nam .stall to cjimU'.
that dirci'i i.r.ct indited lal'or am; non-Liln<: *'hoi !.v>
;nc bfinj' aliocak'd and jcomh'd ^otivctfy, BecaitM'
ir,os( u*.countitil' pt*i>on:H*! air mat Janiili.n w i)i' 'lie
kvlmical	ii?iiuil;i ptopu'ns am! tasks, 1 Ik re-

view c-i i;ntc and i'D\i JifnH'.r.ii'ii preveduu> idunild in-
dude air pfojiium	to CKMiiC lliiil ffi'^r

aliucatjoit> c!*: til in implement-
ini> prcK.etlniV> to monitor time and track indirect and
iiikvl vVMs iw> Moused ^ sill adminisiciing llic 'hue \
pio^raiH in Mincer! v. ith other [rmiTjUc \ pr«grains.
Mi >.sl agencies aic idyins: uis methods of' i'usI alJona-
tints thai have ivcr. m lis.,- ]'nr mam yeai s aiul vU'lti
acceptable rcNiihs, while otlie; Mate- aic v.aukiiijj lu
impimt' iht' procedures limber. The fiscal mara^'v-
nieni ot the 'Jitic \ prt\crair will continue so he ic-
fmed by Male „it qu.-lih u^rnocs un pfoi'iam and
acciitmlms: Muff ^.on'iiuie in .share Lom\iisi^c and
fxpaiuliiii: riuiiHiLTiHcii! iuU;nr,auon systems lake mi
uieater inlcs.

i huplti !; i)mi	uuJ( i»i %(!<• anion I!'

-------
ClIAI'TKU 2: A( ( Ol'NTINC

Frameworks iok Title V
Pkockams

Gchcjjiiiu'ril atoamiiny jih! financial reporting	;

practices ditk"1 Ctcsiderabh Iron) I hose UujikI in 1 he	i
piivaic, commcH ial sector. Gcneially avccpici! 1,1 -

vuimiini: principles (< fAAPl iuj eoviTttment pmvido	j

strict guidelines cmieci .'imp ihe meihotis it-u'd In man-	j
aje tlii' presided l\\ tu>.p<;>eis. V.'hde

GAAP >!iiiul.ii4^ lur business enleiprntv arc Jivipttetl	j

in pioutk- nitiunMiimi! needed in- irjVt-sior-, .md credi-	j

hits, GAAP Matklards In; I'oyennnenl die intended  diffenT.vVS between govern-	i
:nciil accounting and the pi i\a1c m cjoi i,s the G A AP-

reennunended iv-c of fund :umimi:. According to	|

die CnA'i-'tfiim'tiSai Aceounum: Slandaids Huard	:

rGASHh a !tm;/ i crrrtui; tm pectin activate* or utiainim;
t cuahi tthit ri:vt s in onhfuc wiiti spt cud

( haptn J ¦ Aci muling § nttth x »>k\ tot itih 1 t'ntprums 21

-------
! rf':juhi(it>nn. n stra itens, or limtlatiotis. iScwcc;
| HASH (7<(!ttUri!i(»i ff,' CocrnmeMat 4iVoi/ij/f«e
|	kminh t\tl Rrj'Oi'fiiiy .ShaniarJt, St-ainn ISfKh

I Simply staled, fitmj ;wvountii)C is the- practice of
; separating flic uvord krcpiissj activity of ;m\ number
!. ol individual funds. A fluid can be 1 icwn! as .» fiscal
entity with sr^reuaied neeouiitstit! tec«'d> used to ins-
I>h'i5icii« a Njxvific program or activity. A federal
erarit. fin example. might be accounted Sot ii> a sepu-
raw tujhj Most state ami !>v;i! t'overnmeiUs have re-
,j lied mi lusid based accoiinuiie sy stems lo; man) \eur>
its order to adnunisles ;ukf maim^e a variety ofdtlfe:-

ei»t prom a;tis.

i	~

i

I UudejNt.itidiiiij fund viccunntjiiy is very important
! r«,»the inamuiemeni of Title V penmi programs .ti the
; stale ami local program level. The a.Nsj^iirueul of a
j sj^cifie kind type to the Title V program by a ^tatedu-
i c.il program e«t;iblishe> die expected level n; -eeayj:;)-
; ;ion fi'i nn other suae funds; (he degree to which the
j fund is nveam tn he ;i seH-,sup|x>m»e, hiiMiics>-t> pe
emerpme; uuti (he type.- of reports thai wiH Ik* avail-
| ahk* fin interna) and exsermd rcporfm-e.

I

¦ Tins section ^ JeMened lo f.iimltasi/e slate ano lo-
| ca" program managers wit!; fund acc«luntine u,\ ;l re
| lates to! he operation ol Title V programs, It pi ox ides
[ ati explanation of fund types lli.H aie available 3or use

In states, describes (he accounting approach thai
i state- and loeal prom aim are now usitisj. aiul present,-
I criteria foi evalmHitiii the need to modih a	ac-

counting structure

I

22 i'haplrr *;	Fiiuat »wd'j fm Titlr i" l'rn:;rams

-------
lypes of Funds

In cciiciiJ, L'<.»vcif(tiicni> v;m dicnsc Morn pciicriv
tV|H"* I»l' i'lllkK H> 1||U»»|J!C	1 hcvc tUJKl tVp'C^ \

JHC tVJICKilh divided IJltO it'll! CUli-yoi 11'V CfUUTil	"

ir.eiU Fi'.iftK. Prop)ii'i.M') bmds. FiduciaiA FumK ;trnt
Account Gun;p>, H;;ch l\ [V of imid has ih own diiH-

;,ctcnsiks and :s u^-u k>i udU'sviu ltavintncui ;»ctivi •

iic%> * :• ,n .ipiucal summary of the or- |
giiiiMaiion of government nmas.	i

Government Funds

i
i

The Lti .'uud	. i'tnvinmi'tit lund.- j

iiif iim.\I lo account !ti: all iM'nnal ;'(nerniriiii: t(¦/•-
oration v. Mich ;•;>> ?;rc and pr>!kv prof e-,1 ion. public j|
p;id>. iiiid uvrfatioii. Then- ;irc i3\t- hind ;
i\ no v, trhin this	!

1.	'I he Oenemi I- md is the chief operating
fund uf u vtate or local government and Is
used to account for all program resources
that are noi accounted for in oilier funds.
The govern men uses only one general
fund, containing the majority of its finan-
cial transactions.

2,	Special Revenue funds are used to
account for finances that are legally restric-
ted or earmarked for specific purposes,
such as the suite implementation of an

VittipU'f J, .\t WUHtMitf I	ft As f*a Jill* I	* *

-------
environmental mandate, For example, a
federal gram most likely would reside in a
fund of this type.

GASB stales that special revenue fund
typesrnuyiv used:

to m tvmst far the proceeds of specific rev-
enue sources fbtif arc legally rrsiricScd to
expenditure far specific purposes. {Source;
GASB Codificatirm of Governmental ,-1< -
tVJMWfiiie ami F mane nil Reporting Snm-
dank, Section 1300J 041

It should k* noted ilntt (he definition of a special
revenue lurid is permi.vSive. not prescriptive. A
special revenue fund mux he used under govern-
mem program circumstances described above,
Inif if is not a icquneinem. Many amemtnents
do »oi use special revenue funds, choosing in-
stead to report (restricted'! activities in their gen-
eral fund. However, the heodits uf special
revenue fund accounting over that <>f the genera!
tufxi will be examined later in this document.

3,	Capital Project1* Funds account for finances
used for major capital development. Govern •
metits usually prefer to account for these re-
sources in funds separate from oilier
operations.

4.	Debt Service Funds are used to account for
the repayment of ^overnmeni long-term

debt, such as major bond issuances.

•V Cbaptrr 2; Ammniittf; Ft

-------
Fk.i hi. 3:
I iM) Okcavization Chart

Slate

y

I. Governmental,
Fund Types p'

1, General
Fund

2, Special
Revenue

3, Capital
Projects

! 4. Debt

Service

5, Special |
< Assessment

1.

II, Proprietary
fund Types

_L

L'

Enterprise

r

1 Internal
Service

II
11

III Fiduciary
Fund Typil

i'kapii r 2: Accutmlnif; f-ttum fi-r Tith \	,15

-------
5. Spetiai Assessments funds account for the
fundi tic ubmined through special assess-
ments for public improvements. For exam-
ple. after levying a special assessment lax

for a new sidewalk, [he funds are account-
ed for here,

Proprietary Funds

In general, proprietary funds aire u.>wJ in ac-
count for those giivernnwni acthities anil pro-
gram,s that arc similar to the private commercial
sector, such as;»transput tation system or water
\vstem that receives direct payment for ver\ices,

t Enterprise Funds are used i» account tot

activities that ure operated much like pri-
vate sector business erne sprites. Govern-
ments need tu charge users for 4 vauety 01
public .services 10 recover all ur a portion
of the cost\ associated with a particular
program or activity. Public utilities are ;t
popular example of an entity fiscally man-
aged within thif, type of fund,

According 10 GASH, this type of fund may
be used;

to unrmitfor opertmotis ij'ti that arc fi-
nanced t»uf operated in a manm-i similar
to private bu,tincs,s enterprises — where
the intent of (he governing body is that the
costs i expenses, including depreciation) of

26 Chapter 2; Arpfmnimg Fnmwwurks for Tiiie I' i'mgrnms

-------
fmwiu'wg poods t*r services to the xtnenri |
public on a continuing hasi\ he financed
or wovrm! primarily through mer	\

vhtityrs: or (b) irher'e the gtn'crniny hody j
bis decided (hat periodic deierntinu/ion or j
revenue^ r timed, expenses incurred, tnui'oi
net income i,\ appwprian for aipitai mma-
tc/hiHi c, public pi >/;'i ;v. manaitnnent con - '
twi, (itwtmiiihilisy, or other purposes.
iSource; (JASH CodifiviHior, <>f	>

Ooverwncntaf Accounting tmii l-inimciu!
Reporting Standards, Section I300J04i j

i

1

The benefits oi using enterprise fund>
to account fur she Title V pi og rani will be ,
presaged hi the next section,	j

2, Inter tad Serviee Fund* account for opera-
tions similar us those found in 215 enterprise
fund. bul im enlities thai provide goods j
and services 10 other government depart- i
men is, Government pruning and data prsi*
cessiiit' arc examples t«j activities	,

iiccoimied for in «hest- funds,	i

!

Fiduciary Funds

I

Hdueiaiy I amis art used to account for assets |
held by the government us a third-party mis tee 01 j
ueem. Examples of the Funds accounted tor in-

v	|t

chide government pension plans and willed assets.

( hi)(*
-------
!, Trust atui A^encv funds

•	Ai'e/u v Funds are used to account for
non-government assets, or assets be-
longing to another sjovermnent, such as
a count) that collects taxes rut a coun-
ty-wide basis.

•	Pension Trust funds account lor siov-
eramcm pension plans

•	I:.Kpaidtihie Trust Funds nceoniU for
government assets thai have been pro-
vided to that government via a Uust or
other agreement. Under expendable
trusts, imerest and piineipal ma> he ex-
pended based on (lie provisions of" the
agreement, Assets left to the govern-
ment are often placed in this type ot
fund,

The use of expendable trust funds to account
for Title V program resources will he present-
ed in the next section,

•	iWme.xpendahle JYitsi Funds .ire stmilm
to expendable trusts, except thai only
interest earnings may be expended,
leaving the original principal intact.

2X Chapitr !; .Ifttuuttiripi Framt works fur Titir I1' I'm/trams

-------
Government Fund Accounting Reports

All o| tlx- lmi\eminent "um> ik-.sesibeu above aie
Jt'NHiiiiHl enstise el'lecine .iconiniiSii: lor public
monk"-. In oftici ir- cest ihis ohkvuvf.'..mwrriiiienEs
eel) on J'ltwm'Ki! iL-pons. StukchoUU*^. \vhic>. lncluitc
UA payers. cmeminent u«.c<i»ee}>, levcntti**
expeiulifiiif s!aie;ni')Sfs, htidini v* actual voinpai •

tic. prov uic ;ri)|"iiri;tiii utUtrriwluw. More spe-
cifically. ;eporK can he used lu verily Uias
>jvcit»c pi op i tin i^, Micii as Tuk V. are ix-irit' imple-
mented dS.cienlh and in accuikLiict v. nil pu\ element
accuui i iui m, !»la litki di,

As described in the following sectionthe reports
thai can be generated and subsequently used to account
for the resources of a government program vary slight-

ly h.ivd on (lie specific uovomr.iatf lunU sype used.

Amnnifiiip lor tin Title V Program

Slate .itivl focal aii ijtuililN u^esieio ate cu'eccmcd
v.'ilh lam litJe V s't'M>ii:ces are manaeed. hrst ul ;dl,
apeiK'% muniwvi.s need m know tiic pi^sjrajn is
iiciny nuuiuped (ii micIs a \vu\ thai usei tees jic vo\cr-
mi: proL'iaif} oosiv "Hie> also need tu ktmv, thai Title
\ >ta!V lime and cspciiM*^ ate Ivijit' coveted usiiii:

Fitk" V :cmh3hv« and, i^nveiH'l) , tlun non-Tnte \'
pioeuin"; expenses aye n«n beir:c rvcoveieil t'u
-------
to the air quality agencies admim^iering the Title V
. program, hut also to a mtrnher o| other slakchnfdeis.
! including the Title V permittees Mate and focal gov-
ernment officials, USEPA, and the general public,
j each of which has an inietest in the efficient mid cf-
? fective operation oi the Title V program

j As long us the particular government fund com-
1 pltc> with GAAP uiiii state or local requirements,

!	these arc no restrictions as to which accounting fund

|	encompasses the Tide V program, However, while

'	there are numerous fumi types in governmental ac-

|	counting. only a few can be considered viable for

i	Title V accounting based on the GASB deflation of

1	the fund types. In the governmental lunil type cuiego-

!	ry, possible candidates include (he general fund aiul a

I	special revenue tnud, though it is likeh thai genera]
turn! Liceoiuititi" tot a Title V panijt program would
he considered inappropriate became ot the Sack of

I	earmarked fund segregation (see below*. Capital

Ttii K V Program At rot-mini;:
AmtOJVRIAIF CioVF.RN'MF.NT FtMS TVT'KS

Proprietary Fit#
fiduciary ruiia&

*	< icneral Food

*	Special Revenue Fuad

•	laieiprise Baud

~	Expendable Tmsl

yaiBj iij^pg

M Chapter 2; MrmnHn% t'rmm

-------
internal servraerffintfi Jlniltte fiiticaiiifttiil ¦esiegiiMf, •	J

slate faifliftBidpttiiwfliiiclMjlft tnistifiiiiiitiliit mmlA	|
mcomxbfm

pensIdias't«a«ttl'tlstlile in:isiift»i»	|
We tf«iee€»a§fi»i!ieTOfe^

GenemtfbmAf	'

The ctr.eiuJ iuu-.I <>. compti^vii iff*. l«m»« nimiit*.'*
o; accounts	with ihe t'crinai mm •.*«»:• n ¦

ijisiivif ti) ,ni\ Mci'.c iiumk"ifi;tlst) Thi', Intni iindiii-'ic
accuuntviay {-plicc -aid tire protection, park**.
areuvuiidirnvHtli;-, jnwcnimcr.t pmj'rum i»j .'uKivnv
ilial is uot ticrofsr.te-il toi I'l.W; hcrr in Hh- .Ku.tninnsci;
\vmomi. !! ikr Ink- V proii^m \u-re to Ik- fiHUilh
nv.u^fvii from ilu	lunti, it woti/d hi; ick'«>l usi itidcpnulen; .kvoum, sqiin.ae limn oihi-i t/cn^
;•! |litiif ;icv( irons ilir. IA-Ik i
ixvottnt m or livun.any oihv; micr!1 'if H'!!!Ki}sli\r .'ippioviti

U'l.jle. ii 'V.-mltl !u: i'>r.nvi»Uwi i'to.T-.pUtllln	|

GASB Jo iim' ihu ijfuserai itttid let ai\:oum k;v i!w M <>-
V priij:riiiti. it i- ulewriy utx flic best amitcr fr'irsi »-»f
«\ll. Tilli" V	m m>t ah	* ?««: '

'{''lyi W« <»~	ft m*t *t i if I1 fjhtM" "J*"* •'?*'" I'* ftt. j». -firjj,-1.. ii {

V	#-<¦* •- AMirftWIt k"M *»	A.-1 £	m H1C W w t If^Jc mm fiisS I.,*

-------
j using the general fund. Under this scenario. Title V is
| merely one of a tarpe number of accounts, and while
general information on the program's fiscal activity is
j available through the general fund financial reports,

I the information is not as robust as il would be under

»

another government accounting fund type.

More importantly, most government general funds
, do not restrict the movement of resources among the
j many general fund account groups and accounts,
j Further, if is a common government accounting prac-
tice to reallocate program resources among general
fund accounts. Title V resources must be accounted
for separately, without interaction between any other
1 accounts. This requirement makes the general fund an
unattractive option for Title V accounting,

Of the .state air quality agencies interviewed, none
uses the government's general fund to account for the
Title V program, based on the limitations described
above. Appendix A contains illustrative general fund
statements that .show the types of reports included as
part of the general fund process.

The types of general, fund reports provided as part
of a comprehensive annual financial report include the
] following:

j	Tiie statement of revenues, expenditures, ami

j changes in fund balance. This statement reports

the financial performance of the entity over the
j annual reporting period. It is meant to com tint tsi~
! Late the sources, uses, and balances of current

32 Chapter I. Accounting tram*worts jnr Title I' Programi

-------
fusjiK'ial leMHifwVs used If,' /?."»'/„ This repair is Hom \kn\n!
as a .snapshot in hn.e of ihe cniily'> liiwiiCKil posi-
tion, h preset;Is rhe balance K*l\veeii t'overnmenu!
assets ant! liabilities 4nut fund cquiiy,

1

Stiunlaio ;jcctHir>ii?ij: fomsisSs include presentation ,
of eomhinirsg snilenjOKs ihui. vmoup ail sub-lund.s tutu '
a suciunan report ;\,s well as separate statements on
iompemerit units,	i

Because Title \' is a new protrarn specific < I lustra-
tions of financial suik'niciils are not yet available, In j
order to ilhiMrate the way ihv i sorts to (he
Section Iu5 propam Subsequently, Title V resuinces
have been inaituced through the same tiovernntrnl uc-
counting fund t\pe *- the special jc\enue fund -¦ a>

Chftpttt i.1,4t cvuttiiw," H-'mmtwivk) pit Tith 1' f'ntf-ram^ J3

-------
the Section 105 program. In nearly ;il) state and local
1 air programs contacted. the Tills: V nrocrarri i\ man
J aced within a special revenue ('iiml,

Special tevenue fluids, are flu: lutokbone of govenv
i mom accounting structures, as most Lwernnient.s op-
| erase isumeious .speaaf revenue fund* to implement ;t
{ variety of pm^raim and activities, As Mated previous-
1 1)". special revenue funds account lot financial re-

sources, often in the form of federal grants. that are »i
,! .Mime v.'uv restricted or ear-marked for ;t specific tiov-

i	-	.	. *

j eminent purpose. The permit fees that flow into the
I suite Title V programs ate tesnicteii jiisr as a federal

grant would be. even though these funds orkhwfe
j from private sector permittee* and not the federal go\-
| ernment. Because Title V revenues men not he used
tor any purpose other ilwii the implementation ;;»!
management of the Title V program, a special revenue
; I'uiscI is art appropriate accounting entity. All icvetiues
| and expenditures Hewing in and out of the Tule V
[ .special revenue account are used solely for that pro-
j gnsm and muy no! be co-mingled with any other spe-
cks! icvemie fund without state k'sdsiutive approval.

Governments may also account for Tiiie V re-
,source?* using a Title V account within an existing spe-
cial revenue fund, Uiidcj the scenario described
above, the Title V program i> accounted for through
the management of ii.s (nni special revenue fund.
Conversely, governments may account for Title V
simply as an account within a special revenue fund
possessing similar restrfcikwus, such as a Clean Air
.special revenue fund that accounts for resources for

¦>4 ( lirtph r	Fntme%n»ks fitr Titte 1'

-------
Tide V ,mi,) uon-Titlr V pivp'arns, In this situation,

111 It- \ Mccoimt'i les'nirco arc rolticicd foi use rail)'
\\ it hi 11 Title V pi'in", ruins ijiuS tiiaj. ur»i t >c iramfi'ncd
miiMsie o! tlx liiml v.HfM"Ut Icyisltiuw appjm nt
This \:mvtu:v is oiu-n iKcti 1m: ^vncie- iit wheli 111e
Til If V proi-r.ni: is not larev cin h to uivtifX scl-k^'u-
rioii ml' - ;< sepaiuk' fund

With nnl\ nr»r e?AC|itinn, ull .vtulc an qualiU HL'en
t it'? iiilc! \ k"\u\I um- the *-1*»<.'ci;i] rcn-mie titi.ii ?c uc
lOiiiil l«'i ;lic 'I ilk V jnni.'hr.) Mu>t ul die
anuunl H»i Ttfl< V iv\ idiij/ihi.' j si'jmr.iti*	H'V

iiHK* hiihl t'Title- V m;iyi, while the iV?jW»iim: « i'l" spcviai iL'vciiui' hii.c rrpint> Rc<, ;mse me)
air put of liie penend kind, t>,?\ aiv pitvmteii both ;is
;i * enipoiicnt oi the cunshHiirip Valanesus lot tin- Lien
t'Uil iuiu! am! iiiili^'idmii sjvvi;tl k\c:hk

Enirrpriw / umt

Hiterprise hnuls arc use;! tn account for poxen**-
mer.tul programs arid activities tlmt are Miiiilu; m	|

nature lo priuiie comnuichi! usm«Klit*Rv. Sci-
vicl> iJuit iequme a cash 
-------
! the account ttt.g regulator may. however, chunge Urn
n» the near future.

Tlx* Cknernmerd Accounting Stuwiards Board

UiASB i is in the pieces* of tiiudifvmg the require-
ment for the use uf enterprise funds. Due cut in mid-
I1)5)?, shi- new requirement will encourage a broutJei
; use ot'eiitcipme ftifklj- tor self-supporting activities, If
Hie new requirements ate passed by (JASFi, if is possi-
ble that Title V programs would need to he clarified as
. enterprise funds h\ .stales to be in full compliance with
j GAAP, GASH language us now drafted Is as lolkmv

I fhnitieSA-! ipe (Wfn'iln'i ,\hon'd he repntfe*! (is pf<>-
j prichiry t enterprise} timdx, Tt» provide more r«»<-
! \i.%iriwx la/ion^ ip>vcrn>nr>Hx. die ei/cumsuineei

untier 'd'foii, 'h ftiserpriM" neonuitiax w/n or xiundii
| he Kvct/ arc re\i^ed m foiltnrs:

1	,tyv tfftivnv that	a fee If hmw fvr its

seniitw mux be tvfHtrMi uxin,t,' enterprise fund
nn(init nud fhwnt itd reporting, ,4c? aetnity is
ietf Hired to hf tept.tried Nvm,y enter prite fund
tnr,HMMf! umf «ywrfw«f if «mv otw of the*?
ertieriu t\ met:

ei, The uctMtv ixstuw debt that h strut ed
MH'fiy hy a pledge t>f (he tics revenue from
ft ei and eiuiritr.s afihe activity,
h Stair or load lows or regulations require
that the activity recover the costs of pro-
viding services, smiudinv eapittd live
char#?* or debt twice, with fees and
i ihifk

id Chuftirt 2; Atanttttmg Fnmu'tfitrix for 'itlie V i'rtigr«m\

-------
( . Tin pririni' ptditits of thc aefiritv r Publish ,

fees and charges di signed to recover (he j
costs »f providing services, itichhiini? * apt- i
hi! a\i churvi.» t>r dt-hl \ fniff, iSt-wir:
Prrtmrinim of thv (hnetmutfthii At'-

i

i i'uritthv Suwdttrils lit w d at Mttjni issut-s j
RfiiJtti k'	iwivijhii / iiiom i-	r

tippnMro !«•> p.tytn^ Kn I he ^uvet mr.cnl pi opium via m-	j

come la\t> nr other miuivc!>, ibe pmt'rain act* much	\
like ,i ctunnitTk s;il currpi im\ Ti'uis. ;m enterprise jttnd

tn.i} ulfiniafeh tic the structure iimhS loi Tide V fee	j

program*.	|

EMorprive fund acvmifiitiu: :!\lmsos ihc u>c oj [
iiiiancfii! reports [ha? uic not i'onnd nude: otbes tun ;
ewmeut fund ..eeotinnni" NCOiun "SlislcTiscn! oi Cash Flovis" reports sluil would ,
he UmlIh) in showing the intnemeu] oi resouiet^ hi
and inn of the Tiik' V pin^r
-------
| Expendable Trust

\

'

Expendable frosts are employed by governments
!o account for resources provided to the government
[ under a trust agreement for implementation of a >pe-

I eific objective. These resources are often in the form
j til gifts or donations to the government, but have also
: historically taken the form of federal grant. A* op-
, posed to ft non-expendable trust, both principal and
j interest of expendable trust resources can be expended
" in accordance with the trust agreement.

1 Title V resources can be accounted for under an

expendable trust structure. Wlnle the Title V program
j does not provide any gifts or direct grants to be en-
! (rusted io The st

While the four government fund options discussed
may be used for the Title V program,, some are dearly
j better than others. The table below summarizes the
i strengths and weaknesses of each option for use in the
; Title Y program.

Jfi Otafter 2; Accounting Fnmtmrkx- fiw Tiiif 1* Program*

-------
Fund Ijpc

(iCiKial

f-lfl lit

Kwmir
Fund

| l-.nUrprivf

I Fund

lApiiMiaMr

Trod
FuimJ

StmijjUiv

Vtnaktime

Reports

R.ikK inip.V-

Fun:!', c ;~rs he

Silkhm/u >>!

iiu\',tc.i1 nil

Tl" i fhun

remnntiw kx

•Uto 'cam-

l-ru* iu'u null |r



yeicr;^ tiiia ^

Uii 'thn W'lh

.Hid vH.iiij i s

fii-ci*

CiiN' 1 4 v- Ul

HI fiind lv.-



,~! Ti,'k

ii;wc lwl.ii vc



V i'UiCelmt^

>Vl'l» NdkVl





Vi iUlUI

i hikK urv vy-

1 1*'JitV*¦ i»thltfi'

Staicsiiv'ir! i*i

kp-Ui' G<"l,

cr ft'|X»ni!ij,

ft.'.UIllVX <. \

ri quire

t'n!Uy,

pc.Wuic-

U'>, u«nv< (ir

SUA" l.tivv

,'iu vli.ttHV

p,!vi:i.i!rn,i.

;iunn'!nj spt*

ifi Tumi o..l

,-tjt1W.lV.il 111

t'l.ll H'VtTuii

i



Hcimiw.

tk-ucr.uK no"

M.tlrim'itt i'l

n-UL'h iiXi; a

U^t'ui !l'I Mil JII

ft'Vtiiui;:.. t\

i

^uth

pemhmres



ii'V V

,r-.ki ihaiif-'t1'

entcip^u'



"l; twnd ;-.ii

f mrh,'«i» i-



iruT, KlUik r





•>hlv'i!t, bUd^'Ll

Willi



•¦.'i





11

Uglier liii-



i,.' !li It

plwd level of











Alinw, LU^I.





~ lew TfpTtiii.i'.





f'Uruh ,i"i-

Not t if if hi it;;

Sirimv.i Hi

•¦rf'CKaltii

f»(v'!wkl! tl>I

c\

liwt XiWltll



jtirihlajs.",,

purfvw n .

tTams, hr>lrir •

;mn c,'i;«nj;ev

\ Hit1"', KBK1

t.blv UVd 1 •j

in liiivl KO-

rqvrH 4>. cn-

fcdcr.!1 |'uril>.

jfivt', luLrtcc

kvpr m- t«iM



hi.ufel











•>;atu!ntfrt >,4





ii'.-ll liHV, f

l.sajjc liy
A^rfuio
lltlrnii« fd

Nunr

•Mi n i'-ui
"lit i W i*l' i" i

N< w

One ifeacj

:! ,.i «?.

Cfmptrr 2: Avt-tMmtsg i'mmtwiwks fi»t Jiih V,W

-------
( riJt'ria tor aluafinu the Need to .Mudih an
Agency's Title V Accounting Structure

As moM state and local air programs rue just be-
t ginning to work with accounting procedures far the
| Title V program, few have had the opportunity to a,v
! sc^ whether or nut the selected accounting sirticfore
J {fund type) is acceptable in terms of meeting the re-
j quirements of the program itself ant! providing ae-
i! counting stuff and Title V program managers with
information needed to accurately monitor costs.

' {)] order to assess the adequacy of the Title V ae-
i counting program. air programs should avk the foi-
t |owinp question's:

I • Does the current accounting structure ensure that
! Title V resources are being managed and report-
ed on independently of all cither noil-Title V pto-

t grains'.1,

! * Do accountitig managers within the state or local
i agency foresee atiy possibility that Title V funds
| could he transferred to another account for unau-
¦ thori/cd use? I! so, which fund structure within
the agency provides the highest level of protec-
tion from transfers?

I

| * Does the current accounting structure allow tor
| the creation of reports that arc meaningful to air
! quality agency managers and other stakeholders
j such as permittees and USEPA?

40 C ha filer 2; ,-tfCPHfirtw^ Frcmrwork\ for Title V

-------
• k the cunt-ii! hccuijiiIhi^ smieturc fJcxibte
enough Its allow chanyes in reporting procedures
— for example, tu eorrecl any inadequacies?

Tin* ;iji>wt'j> !o these questions miiy indicate that a
change m uccounlini; Mruclurt> is necessary in order
immayo the Title V program more effectively.

I hapta 2: AtcmatiMg tmmnwf,ijui I I'mgmms 4i

-------
Chaptkk 3: Mana<;kmi«:nt
Rr.roKTiN(i and Tracking

Introduction

Ylaiwciiaf ivjmrtiup is *of the most impoilanf
activities in both Hie pnvate ard public M-dors. The
(>iCHtT4atic«]i ol anient, .lutiKiU' illuOl Mialioti in ilk"
siakcSnikki - e!\i privaie busier.^ oi tincrinin-nf
pinpnim can liteiaily t>mke the dilfeiviKe heiween
baiiktnptcv to: the private busis\ it? pn>erain in
etkvth'encss lo; a ;:o\eminent juxrtv).

M;:rn academic- and bt;s,ness leaders alike agree
dial siit>nnia);uii is the luoei jinpnrt.wt resource in ai»\
niSiiy, private oi public, Fm e.vurnple,.munufnetu?- ;
mi* business need? inl^i'niatiuL or; Isuv. costs arc alio ;
c«tcd tmnmsr diffcsetK products, just ;us Title V	J

p:opnij)i manners ace inkiestetl in tdentif} in,4? hi iu i
prt.\i')ani personnel >pend ihejr turn- anjony Title V
and non-Title V proi'satm. 7hose examples :vllecl ;ht
need Jui "internal" reporting — prov idsne information j
to tluM? « jlhtri the 01 L'am/ation

Similarly. iniimnuiion ts tequiml t>\ those outride j
ilk- isi'L'iniuatioi; that have an interest in the nieces* of I
tlie program. A bank is not euis^: Hi loan a business
millions of de-Dirs whhon! tsisi taking a ImI. at the i»-
iiaiiv'inl position oi the opei.ition Similarly, Makcbohi- \
eis it; llie Title V ptop am including permittees.. the |
siate leiMslanite. ami the knleiul pnvrnment need i

I htipltrt j: Mnnafiriiu hi HrpotlMf mat Trtukiuf: 43

-------
lo know that financial resources are being used as
intended by the ITS Congress in the Clean Air Act.
® These two example^ show the ncccssilv of "exlertwr

reporting — providing information to stakeholders
! outside of the organization,

This section represents the third of the three steps,
in Ihe natural sequence of financial management and
1 report in c activities, Internal and external reporting
i logically follows the activities that occur in the first
j two steps. To recap, the first step mvohes gathering
| ihe accounting information via tools Mich as lime
' sheets and recording the direct and indirect lahoi and
j n on-labor costs as ihey are incurred, The second step
| entails introducing the cost information to the part ten -
1 iar government fund put in place to manage the Title
j V program. Once the information has been gathered
i and posted to the fund, it is time to put that informa-
tion to work in the form of financial reports for inter-
, rut I and external usage.

! Step 1; Gather time keeping/cost allocation
information

1 Step 2: Post information to Title V
accounting fund

Step M Develop internal and external
financial reports

Int'.rnal Reportinsi

Internal reporting procedures allow important pro-
gram and accounting information concerning the Title

44 Chapter ,1: Managrmcni ft {porting end }/at king

-------
V |»rot'inili to be disseminated th,nniaJ)f>ii! the ati pro	j

nam. T3ii,s sharinp o! jnf'oiuiataccomplishes se\	j

era! import.mi ohjivtnes, including. Mi! a I Sown	|

prwum and .k'OMittlifii,1 personnel to i.inde;si;jMS 1 he	i

<.?;iuiv ot she Tific \' pmpram in a usneiv nun.nor, and	|

{2? it heips (ticsitity tho.se areas or the Title V prej-'tatr,	\

in nei't! of mmiiffeaiion or i:npiou'nk'tn. TJu^ second	i
point is MyitisK'iim as the Title V proeiani s> quite ne'.v
and its coiiMiinl rmpu'vcnicni will retpjnc file sbarnii'
oi mlonnalion throughout the cruiagency.

I hi I inanaul Jiii*M'iU!*

the i!iiui nl three main Mops in llie hnanciul mamoje-
it et»r ami repotimt* process, Subsemitfuih. the aciivits
fh;*i occurs m this liuai step is a ftiikiuwi oi what h;sf-
pC!JS II: ihe If! v! two, Mosl flll.ilk'Iitl rCpVliliL*	:

ati mcI up- to pjoviih ,t s!a;htu:d w\ of Uidj'el and in
runeiii! stak-meist sepoi is ioi i menial us* is, hased on
the type oj p».ncuisneilKtl	fund it» usi4, Ft*t |

example, if "he Title Y prngrnm i* accoynte.d lor	i

special icsemie fund. the standard icpoit* ac\essihie
via the ix'cotmlirip .system include balance sheets	.

statements of icvenues. expenditures and vhanpes	J

ns linid balance, and Ina.lpet ver.su > ,umal report;'.,	:

"1 he >cpoit.\. iMia.Sly L'eiieraied month!), aie based on '
i 1 I the inl'oimatioti picn ided thiossf'h rn. ou"btion <«!' |
pemnt »Vc uxvjpts. time .Tied and cost allocation J
pi act ices and < 2 i the type of sjovirniiUMit tunc ir. use ¦
ios Title V acemaifiiir. Htvan.se of ^ovennneiita) ue- i
counting \';»;hi;mK all aii programs have the uhilitv to |
cieatc these reports thrmijili tlwii accoimtinv .svHiems. !
sliowir.p *J«Ic V-specific itil'ormutioji Some hiive the

Clmph) WwwiyiWKf Hipunitif.' uml Triulin^ J~

-------
'	ahilit) to access the information on Jisie. Appendix A

I	shows examples of tin* types? ol .standard reports that

|	cun are generated through the «overi»nesti Fsnartcial

|	reporting system.

I

I Specialized Financial Repurtiit"

\ The reports described tn lite previous section arc
' wry important to the air program stalf, pro\ iding tn-
formation concerning Title \ turnl account balances
and actual expenditures and revenues id date. Inier-
! views conducted with air program stall revealed,
' however, (hat reports emforui/ed to fit various indi-
vidual needs of the u,ser> beyond tho.se ottered by a
' traditional reporting sysiem can also be extreme!)

useful, Fiji scinie agencies, these special)zed reports
| include,

•	Summaries of Title V obligations ami
j encumbrances

; • Lis! of permittees ami fee revenues generated

*	Account balances In object code

| Specialized reports Mich a> these are extremely use-
ful to arr program managers as they implement a new
program .such us Title V for two main reasons. First, the
| nature of a fee-based program involves constant moni-
tuiing of the balance of revenues and expenditures, ne-
cessitating up-to-dare in format ion on permit fee
' revenues anil labor cost allocation, for example, fn ur-
[ tier to recognize whether or not the permit Ices are ade
' quately offsetting program expenditures, a specialised
, level ol reporting is needed. Second, specialised reports

4H I impti r J: ,Managt num Nrportin/; and Tmrkmg

-------
van ke used 1<% nionstoj mlemal pciroMnancc ehai.ieua- ,
jvtio c»t tlx? Tide V pjocraii! iisd:-. The .iiinmin o: iii- |

n\; liil-«or spent |Vt T;ite V permittee. Jru cxasvtjsie. may |
t\- UNchri mlVfnKiuoi: in- Tillr V managers as wnurti i< I
nuixtnwy <»f Title V imliivci cost allocation,

!

Whjir most ul (hi- ugeneirs interviewed desirv
l!H' abilii) eeiieutie etishi:n icpeit^, Sew ;-«rc ;¦ hie to

;icn.'i;"iph>!i lb;* ehjulm- wsih fU-ii eitiieni tnuna'K*-
mritt in1\>rriniti<»ti ,».\"ik'ms *.YUSj. f nt mam \la5ts,
gpiu'raline t t^tuini/ed jvpoiK enlajl.v MihiiiiUinii a r'ni - (
!':Kil rei|ue.si In 'lie atxmuuinj; •• rJ MIS dcpartfiieii! thai ;
describe^ "hr rinaiH'ia! iniornialiitcs K'ifiK'-skat. I>v	"

]hm t>1' fiic icpoit can lake up to tuu week"- in soim- .
cuse^. nUcr. ;onllim: h; iniunnali'Mi ti-ai ts h>o dated j
in he <*! irmeh i»m'. A lew states. however, ha\e s.o	!

phisikafed MLS in place ilia: Jkm a lurjie \:nici> ol
Nfivialimi firkin u:i repotis ie> he ^rr.fiitied nit-lute. j
in n*ul linn*. lu !he.u' ihc financial rcpoii». te- !
fleet I lie ii'tovi np-to-itafe in! «>rn t;a mu possible.

I

The ^l;ue ot' W'ynmirie nsovjdci. ;• cmul example ui j
the ttseUilne.ss ul cnstoim/ed financial reports. 1 Iirt j
different financial iep»ni> an1 jjenuatcd hy Wyoming's

MIS. kacn of lLv icpotts t3isph;y> accounting intoi-
malion jioi contained in the Vi,tmbtd spreiai ieu*iuie i
I'iukJ lejvrb described tr ihe pu'vioes >cctiusi	j

Wyoming's ,s\ stem prt,sdc^ an*>tlset filiei to the dma.
subs<-quentiy ^ivin^: Tide V p:«u;rarn managers de • [
? ruled iii!o:matioii on the status rT then lee-bascd pm- |
«.Trani. The tux paee of the system includes a	jj

Sximmaiy of Obligations representiup the ei^is wish "
ih>i* aiilinijj! expended < 5:	m««f Hiporthif; and /rrifXrn,c h'7

-------
in^ balance. The his! line o' the InM pat'e stunts (.he
Title V lees that are available to etner these costs,
1 This infuriiialinr. is crucial to managers uf a fee-based
program, as ii provides cash i'low int'orinufioii. The
last hvu fmaneial report- present derailed irifurniatioi!
| 01; Title V perm:; program expenditures, aann, mfor-
| ittafion thai is mure detailed ami more useful than the
' standard special revenue fund repoit>.

i
!i

Summary: htltrnni Repurting

I

, In nrder tii effectively manage re.vsnirce.x "Iilk* V
; agencies need access to dif'l event !) [vs of internal re-
j ports: those pejseal purpose statements that are avail-
i able through 'he govenmient fund ivCvtHinttnj? Ntciii<

I and specialized liiumciai reports that can be created
| by Tide V managers to provide detailed information
lacking hi the general purpose reports, Genes atine
ciiMomi/eu li'iaiifial reports is best accomplished
! tluotieh the u.h" n{ a sophisticated MLS that can |>ru-
| vide {lie detailed information othlitie

r

} Interviews of ait pjouimn pel sonne! yielded the
| foltfnvina iietieiai informntion inianiirsg internal re-
; porting;

• Mmi Tide V programs are itvorpoiated mto
siaie etivuonmenut! department-wide general
purpose financial .sluteinerHs thwhince sheetv
statements h}" revenues, usui expenditures, ete.' on
a regular basis, via their government fund ac-
craintinj; systems, Financial reports specific to
the Title V fund can he requested by state or In-
ea! permit piopram nutmivjen

4.K ( kaph-t J: .lliiMnxfwrMl iirpnthmi nnd Trm'kmi;

-------
• Most Title V agencies expressed the need for
more specialized internal financial reports,

« A few agencies have the ability to generate de-
tailed, specialized financial reports by using so-
phisticated MIS; the remaining must submit
formal requests for such customized reports and
sometimes must wait weeks to receive them.

A*> ur pr'i Ivpn to ideimh ;ue:i> lor mv
irjj; (|ie«r niirncriiciituiinn *•>:' Shi- 'litle V piocrani.
the variety and ikjml of mseinisJ reports will hshm
hi:ch mcetix,

K\h-ni;it Reporting

i",\icrr»il rcpo'iint' is J he prutikr - Ilk",' (U he kepi ill-

!

fwnk'it as In lb;- j'm;mekil	ol a puh'n' or pi i\,:lc ,

entity, Hoi il>c "fitIf V pmgKisi:,	llu.l nw\ !

v/Hi in jcn icw the adin?ms1ei ins; u|fciK*\\ t'm.uia;;!
H'pujh irKUntie Title V penviKUvs, \tatv lepskiluio, j
01 L SL1 /\*	I

Title V External Reporting Status

In general, external reporting procedures for the

Title V program have yet to be developed for a couple i
of reasons. First, as the Title V program is relatively
new, stales lave been concentrating on designing and
implementing the program itself, In oilier for external
reporting to be meaningful. Title V program adminis-
trators first need 10 get the program established aid |

C lutph t J. Mfitirtfi im nl Hrpuflitiji ami 1 rucking 4<•'

-------
j	{Jevduji nsc,;siircii»er;t culcri.i ilntr stakeholder, w ill

I	find u.h'Iii' Secondly, title \" kehi'ttk-is ini\e \ci t<>

"	jtKici" oMcroal reporting Ucmaiuls on Stu* ;«n jsmOTtm.

j	.SLikeimSdeis, "1 illc V iieniiikee> in nariiutlar, appieci

i	ate UK |act fhat tlie pioerain K .stilt under dewlop-

!	ment ,niil ^ency per,-.v>jmcl uu» coiwenliuiitit: on

!	uiipleiiiemauo;! l Jvrul umi
, .KXiiim' pswp used by fhe prtvmmeiH. The Naiiunat
| C'cxiih tl i»t: Go\ri:imerual Aceoiuiiiisg ( fS'CXiA) re-
! ii'iirem ar-Mplennti nt a i \FR eae!i yeai so provide \ery
detailed jctmsmiiia inlomv.tjnn to .1 wide audience. In
uddfliort to the information cuiseertiiiig ^ovoimnent :ie-
coarr.in^ activity ior the yvai. the CATR also presents
other eerie ad and ^atKueaS inl'orrnalton. A key churac-
teiistie of (lie CAPR is that i" presents audited Eiiuuicud
statenier.ts lor the state or loea« j,'overn:nen'

1'hroi.ieh the structure of sjovornifienc hind
;ky< DiriliuL' and iniMiaeemetit mfonihiUon .systems, ac-
I eouiUn'iir information on tlie 'i Hie V prou: am is pro

J udett to upper leuds of the uoveitrnental eMity,
j This Jidoinuttnm i.\ ilien summarized at;d becomes
I part oi the CAI"R. In mo>t cumw. the Tide V .speedk
1 ininrnialiem is not readily identihabit? in iho report,
j en though many Title V programs are ;kxoimled tor

S'i Vhitptrt .i: MHitilgt Mriu Kc]mii»ir% unit lunittttf

-------
in iheii iHVii iriI anemic himK Whik' live C'AIK
pre.H'ii;,1. srJonr.aiion or; ;ilt special revenue fuutb,.
musl 'I ii 1e V piogfiiiiis arc fin iuo mtiJI in crtr.^XsrjMni
h> uthcr u> Ix lifted M'p;ini{cl\ Suhseijueniiv,
file 1'iSk- \ i'.cuiuntit^ informal ioij s> burani w ilhiii ,
aiifrthr; ^u-cial revenue fi;rul Minuwiry	I

hxlrnwl Ova sifihf ( 'nmmiHecs	*

\; inenliorifii !yp:e;il external irpmtihf	j

techniques nnv<- \ et in mnkTiuh/e lor lite Title \ pro-	j

etam. Huwevei, many HsztTxitis have ioiined cMcma!	;

ithirvt-p;iriy) i.nrrsirhi tnmmiHee.s !o help monitor tlie	!'

IW'-baved Tilk' V prupuiin Ikjcj h multipie-^akefiuki-	s

ei perspective, Thcst.- co:simi!kY> u ill most jikeh Iv	j
llif itnpeUK lo ihe development of exicrx;,; repor
procedures A iisisiihrt of me ;u;encv peisntinci mtcr-

viewed luve sot up client* committees which art- com-	:

posei! of Title V pctim'k-t-v Mute leji.MuturN. and ollie?	>
I'ciHilatniy reprCM.-flUfiivvv The mission of the over-
¦sight committees is lo help 1 he Tit 1c V admimsleinsi:

apeuc} develop a proirrtiU'i tint! ;tikit esses the m-eds n(	;

all stakeholders, one of those t leech honi: the ;icci*v\	¦

lo inJnrm;t1ioi>.	"

I

'To restate, smkehokk'is have \ei to pin pre-sure j
on Tiiie V agencies lot external reporting. A:1 (lie Title j
\ pn>jr;'.in Uskes shape, stakeholders will become j
more iiiie-'eiieii in I'ecviviijj! up u*< dale pi "gnat:; infoi • .
mation stieh as:	J

•	Cuiieui lee lc\ch	I

*	C twb associated wish piffiitin impJemer.nuioii i

t 'hops* i Mtumx*Hti nt HrfHutmg itttd Trttckim; 51

-------
| * Expenditure and revenue reconciliation
HI « Various performance indicators

t

i

! Simply stated, the stakeholders, especially those

f	thai have mobilised into forming oversight commit-

j	lees, will want to know where their fees are going and

j	how efficient])" they .ire facing used to administer llic

|!	fee-based Title V program,

t

j External Reporting: Measuring Performance

1 A challenge tltiu wilt face Tide V agencies as they
! develop external reporting procedures is idenisfyiiig
j and measuring program performance criteria, Once
, Title V programs are implemented and underway, it is
( safe lu assume stakeholders will soon be demanding
i financial and performance-hased reports. Title V
stakeholders may desire perthrmaiiee-twsed reports
that answer questions such as:

•	How many labor hours does it take to implement
the Title V program for each jvrrniuee'

•	How many days does it lake to review a Title V
j permit?

•	Are Title V-re luted labor and other costs decreas-
ing or increasing over time compared to work-
load?

The air programs must lake great caie when (level-
j oping their external reporting program, as the apphca-
1 bilitv of coke as id performance data may vary widely
( across the Title V program, For example, a report
| showing, the relationship between the total number of

Si Chapter J: Sfanaxumrnt Mefiurting ami Tracking

-------
iuhS the iiimmii msi of Ink- V piopiim m¦ -	;

plerueritiiiiuii n;a_% ptvi nlc ;nt\katlm«: uitttrnKtlsun a^-	!
sin'- K-qtiKeJ ainuutil oi' lahn; nouis (o'H i may \asy

itmout-' "I isle \* pL-rn:!i:«^	:

Iwthr mtr-M part, the htrin.*!"iuf pvthtnnaikc
{lacking cuiwfifh Tie putentiai fis;nlls, desenheu
above, Males	\\tt;k ,lu!!u i<¦ develop external re- j

pon»iip puii't^v.'s (ha! I'icvkJc FJieaiiirijjIul measures o1 j
~pi.ai.ee. uh»U* Mill *:in*lirip the ihvK »*f Tufv

External lie porting: AVtr York us b.xumph	,!

The SmHc of \ev. Yeik'1- Depar.nn'iK of' hm tun:-
mental C'on.Nmauor. tie\eiops an aniuwi reptto; to? t;je
New York, State f JpetUmf.' Permit Proi'taii! f Title X \ j
KrkrkaJ pott it ms ;ue inviinkd in Apperaux 1? Tru '
New Yoik K-pt'ii i,sa u^-e111i e>,ample of cMernul ie-
jxwiifi}.* hi pi»n't!c;\ 1'ieK'iiUal eavli \ear to the Neu j
\eui State 1 epNlaiuic, the Governor and fhr Ufriee '
r the estimated \ersus aesual costs H pioeiani
11 ni *k'jitcsitrit i« mi , I he an'rare ir.iiuhe'' ol penni> issued
aitmi.iSlv. a» we!i as fulutc lin'al \e:tr prot'iVliocv

Summary: ilxtmml Rrpt»iitii>

Mum avenue* aie ;ii iSie pnvm ol' implementing
ami lei'iiHiiL" then Title V prupain> ami have ml \et
addressed external repouini: 1 low cut, ha see > mi ihe i

(!•	tnmt	">«' iwriiNf 5.f

-------
; interviews conducted, the following similarities have
l been identified:

•	Stakeholders such as permittees and regulatory
agencies have not yet demanded external report-

I ing from the Title V agencies as the program
continues to be implemented,

•	Governmental fund accounting systems support
externa] reporting to be u?.ed for the
Comprehensive Annua! Financial Report
(CAfR). However, due to the relatively small
size of the Title V program, it is rarely identified
in the CAFR,

•	Some agencies have organized oversight com-
mittees to provide feedback to Tide V-ad minis-
tering agencies. These committees will be the

driving force in the creation of external reports
for stakeholders in those stales,

» Agencies will need to begin to develop external
reporting to respond to requests from stakehold-
ers.

.W Cfuiptrr J, Management Rtporting ami Tracking

-------
C«NCi,l/SlON

'[ he Clean An Ail lillc \ (.Spcs*»i;nt: Pt'mr.f hut'iain !
jncsen?> tr j
grar:T> sikh as Seitn'nl Ftv-ba\ed psocrair^ need :
n|kvi;iS ci'Uhidt'iaiu>ri^ :.n urni1- of inr»c ktvpinj:, uisi ;d
]us.;ni>.>n. ,n'v-ountii:j; t'umi iyp;* sHu'imu, and ivpoi tun:, <

(

This miuly U'iifnl ib.1" Man- uml im.\il ;tir pion.im-*	|
,:fv maK-im* pvu', simie.s sr. »»iclivs>ni|> she iimm J'rnan

ciu'i u^umeeiiu'rt ckilieitii^ ;>s>oci«iU'tl w ith the Tuir V	j

jXup'anL IIowcut. btv;fj\ns if,c propr.mt in Ivgmr.iry	'

tilt* iiuplriiifHlaticri ph;iH\ it -s like Is ihuf ,si;ite ;>.nd lo-	i

c;i' pnu'r;)!';^ \v;|l need 10 ,;d t'oM AlltvnthMi	|

i

« All (JiUiht) uiUiKiev irai^t icfnie prou'diiu^
for !incL?hns and noiMiihor ;minnjL'
Title V ;md Title \ p:ut»Mrns. Of tho"-*'
intci v irwcii, .;!! hut smh1 ^L'fiic} utilize inn-
nK'cIs to m'cd!\f l;ihc»] o>siv incurred inrltlie j
\' ;ithi linn-TillC1 \ pniriunu* Noisir n] these |
sysiems an- wr\ .M,ipl'ii«ic;4cil aiul tnicm'I !
will, ihi- inajKiyctncii! inf'01mniinji \vsknii
(MIS f lo pt'iicivite detailed ivpoiib	j

I uiit'Sii'.liHi 55

-------
•These agencies miss! aKo address the manner
in which indirect costs arc allocated to these
program,"* All individuals interviewed have
procedure* in place ti) record itnd allocate in-
direct kiboi and non-labor costs to appropri-
ate Title V and non-Title V program
accounts. Stale and local proerants would
benefit from documenting these procedures if
the} have nut done so,

2. Accounting Fund Slimline1* and Control

*	Air quality agencies must review their ac-
counting structure* and asse.vs whether the
current procedures are adequate for nnuwgnis;
the a'MHtree.N of a fee-bawd program or if
new accounting methods are requited for pru
gram elTicierte) and
-------
lepons kn 1 ilk* V that mote eloHdy teiiret
the fuel i!mt the Title V p!ol-uiHi is uht fee
supported	;

liHcniiii and F.\icrtuil Reporting	j

ii

•	Agencies ; are tun her ninny in
implementation, ii seems iliai intenuil lr;ick

nip jniorn latum K tnoje remit!) tivuilablc !

« f;xier».j] reporting is an area liiat to u pieu)
extent has not cje\ri
-------
Appendix A

Excerpted tiosai Governmental Accounting, Auditing ami J-iiUiticial
Reporting (Cmvenirncni Fiuar-cc Officers Association

Appendix A 59

-------
General Fund

The genera! funu is used to account for re,sources, traditionally
associated with government, which are not required legally or bv
sound financial management to be accounted for in another fund.

Namk of Government
General Ft m>

Comparative Statements of Revenues- Expenditures

and Changes in Fund Balances
For the fiscal years ended December 31, 1&X4 and 19X3
(amounts expressed in thousands)

13X4

1513

R«ver>u«*:

Taws:

Property	

Sjes 	

f'snc/.is? ,, ,,
licenses and penwts
ffrtefgawrnrpefrtai ,.,
Charges for sflwiccs , .

F>n#s	

itfetesi	

CCA|p&rft}3 	

Payments .n >"eu of la«s

Ofug fcrfe.Ues	

Totaf revenues

$U,133

37,795

§,842
4,^93.
2.041
5,770
2,300

m

625
145
365
7 5

sta.eae
5.253
4,126
I ill

4.469
2,335

521
4?e

33.20)

Expenditures:

Current;

Ge««a< government
Public safety ......

Highways and sfrwts
Saniiatw ....
C'Jttire arid fecroation
Dsbt service:

Principal

Bora) sssuarce c&ss
Total opsrxJ-lu-es

IS

150
31,195
6.000

4,232
»3.438
3 735
2.?2i

5.89?

29.954
3 246

3,844
13,150
3.389
3 404
6,16?

Excess o* revenues over tupercMiras:

r>0 Appendix A

-------
rat	itxi

Otter financing mums {uses}:

G^rsftr.g transfe* (.velpc'ric furiJ . . . ,	1,576 -
Operaing tw'rs Cut

Oeij* sea'Cf iuns	 ,	tS.32?t ;3 331.1

pjf'f ne ccslrurlion fund		f .210)

Comporwrt wk . . 	 ....	(2J*j — ?

CD Bo ftv lalla!vr< pis",*:" 'uia 		R® — ^

Capita ieaser 		140

Sate? oigewfa f.w: asset1	 . .	5 —

To&l cWf f nai: ng sources (uscsi 		 .	|2,CW)

Eiceti (

Pied tetanias. jaiua^ > ,, . .	185# ",8S£
Pmcm equ-ty fensfe's out--1 eel

 .rtfiprS ml c' Iks mtamer;!.

Appendix A til

-------
N,\MK ok (;vs ended December 3* "9X4 and 19XT?
M maims	1 S/",W

! bs:

;• c 4 •

?!4

I £-j,j

' tl'j

,i1.'

IWJMMj wrM'

!»'







>* 4





.Mi?

* 1,1"
«: kSu



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CcrrtuMr-n

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fV, < .t.|- ir. in. ->f ;j«fr



fff

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ft



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-5

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*.-y> levwutf. , .



37,1^5

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Eiptfrtiiures:













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Getmeil .............

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32

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ftl'jfsOv .

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:•?'

(7)

Jt>

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to

OiSK



?:5

2§

i'4-

n?

K'*

r KSi»r '<•

355

K4

±>:.i

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»<1—m

404

B«i

/Jr

Hi,

m

16

CftV-vJaVia



! Ti7

4^4

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K.U 4f>\l 1

m:

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i

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t.St.i



IS-

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i TjZ

i Pi 5

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^uavjsm S-'fi-ns













fcijj wirj

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7fi:

IS

V.irltr v5

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w

f-'a, k ?•«

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;.,f *



£411

6 I'.'

t!W|

	19X3— 	

V«an«
hwit>
Attu#l (Unttvoufc'e)

ft? Apptniltt .4

-------
Imslpf JtetuJif

-1W4

V?rtinw
fev-'St'f
aiHona

- — - 15X3 -

Wvr'i

ftvcrsblt
Attai! ibi?r,wrsbl!ti

p' ' -

[r*~ 11 ; vt!i
tK

Tf Im c .f r "i; .•«1

"if.tf :;1 '»>< *ki ,

v\.



': • 11 C i f;

0!N"f Itfumcifij, if wits jjM.il

, " .

Cre! • ; -'r. !*'•• ..

,V; I fs-<\ l,i* 3
rp'!r^ r j'-'*\" •
u," Tpcnfrr

CD&ti u'.t'n1 ,'J^i

S tr a Uc:

!;>,= "'!••• hn. v„ * ¦

IBB

USIfl

ICS*

lis

ficcss idthcif-rj'J of revenue' stoetfeM.rvrKrj 'tter f Mpcndtlim ind
ether firicne.'ns urn	 "e; >*	i ',;'t f

V.f.t

: i r;-

; l§ Its Mttfftisitl $ft



•\ppeiufii A <"«»

-------
Nwti: OF (,ll\ KKNMKN!
(il.VKKAl Fl'N'l)

CotrparanvH	Shack,

December 31, 13x4 jr.d 19xJ
(a'TKJunis expressed in fhojsand&>

Assels .	...

Cgfh twict r%w cwi.'e, crib
tiwslw.H

F»e&sivab!e% inet o' aVvAAfiscs !Tp.V5t		

"c»A«t

PlCft-l)	, . , ,., .,

5MP#rtt»- nttw>i a', j lenalics
U.fs.	,	....

Sa«j , .

Acmnft , ,

;nI6'gov«i*tKfWd
f-cjorai1 ...

Ct

Transpa.tat'on *u":1
Water ana S,""i\ri

FSiffiHnAJiipren' f/*j ,	, .

Due lrnm co,T-p(ir^t jfi!

Nertnc rocewac fs.

Reel	funs .	, , ,,

f.Unagemetf	fund

InvOnlo? ilj

Awaores to tm «u"dss:

Fjmi TMgrtwnt V1		

.Usnagertisn*. in'c^ar d>' \ »d , .
Tela! as?*: Is 	

1M4

S3,0tJ7
™ c=ti

<>£

8("

r

25

no

55

fi
I?

0
/*#
ift

dl

4C
« ib'd

11X3

; 55:

1.2?6

48

74
4
IS
300
59

150

127

h

193

37

52

3.382

fW	t 4

-------
		 			 _ _	19X<_	11X3

LaWMtes find fund1 balances
Ujfeoiif'S'

Aceoyi'sPf.yab'f , .. .	bit'	0M

Cf.Tsensalfc atiss'-M'f , , , ,	?.?f	201

CofS:frii pevat't- . ...	fr-	151
Dv k 0"! 6' (inos

Pfesnt coiitfutlic-. im, .....	K'	—

WsierfHtfwvo'Vvc! ... .	3"	II

Fieri managssrifnt fjni , ..... ,	C	—

yfi-spac-ni ffr>rmat,.: fi t-ytte"'!: L-'iCf .... . .	t"	M

Deferred revent*:

llnie'fs! 	 .... ...	-	48

pwf.wv , .... .	?*	n

hlccs! pir«." i -| Tftny h«s .	4U	i

Ti)ki'pr.5 		if.	1?

Fedfa' portff'i'tf! .,. . 		IP	Si

lc't> < dii ! «_ •' ...	' Ba?

Fund batarKes:

Rkpwc neumt>nr:*s , .....	o£P

R^cfryr rt 'r- scr,icr fecrea'!^ prtfraT-		145	—

Resw/edto-WuOfrifriicsmf.T		7i>	—

R?swoc for fidWiWii .... 		71

Offww, info ig laced ,. . ,, .	£ ?U:	' M:

Tela'Ixd balance*		 		-,&tS	1,607

Tctel liat'i !<•{ .mc ta IV (in "»'«	'it1 a p 0" ivl o* s!d>tnnev

Appendix 4 ft5

-------
Name of Government
Sm i.u. Riakm i: Ft m>s

Combining Statement o1 Revenues, Expenditures ana
Changes in Fund Balances
For tr-e !)scal yea/ eided December 31 19x4
(Wtih comparative totals fo< she fiscal year eacted December 19x3;
('amounts expressed in thousanas)

Retinues;

Mew fuel w*; . ,
Acohirfc ftfrv&'aye Id*.

'rte'gowmT.en-ia!	

rniewst		

Dor.a!lons		

Total revenue ... .

Tans-
portrtion

72?

m
w

77
906

»»«rte COBS
ttmn- Bevitolh
alien

m

333

39
K3
58?

—TOW*-—
19*4 1«

533

T2S
651
433
H8
•49
?,D3'

355

28
70
T3S
1,343

Expenditures.

Curte^r

Highways aid $w«te
Ecovrrc ana physical

Oyweicoment	

Cu/tjr# and P.8c.*«s;icn
Total exoeridib'os .

Exrtts (dehcie'cyi ot revenues
o»#r \ufi-Serj expwtMares ,
C1fw 'iranctng souf'»
Oprafmj ferule'

General (untj	

742

164

1,30:

1.001

[141

401
40!

(63J

63

?43

401
1.C01
2 144

2ft
805
S33

;*o

63

Escfsfs	of raverwes aivi other financing sources

cvar lunfier) oxwidtures and

gt>vf few nor g uses	 1f4	p.4)

Fjnd balar:e$, Jarrj»*> l , .. , 744 4S0

r>nd M««, December 31 . ... 308 486

ISC 7r
•222 514

1.373 1,229

The rases to t>4 (mm
-------
Special Revenue Fends

Special revenue IimuK are i.vul if ittvtniiu St* specific revenues
Ihsil arc k-gulh loltklctJ tu cxpcniikuio t<» particular purposes.

lumsivtrnim fnmi "J hi*, fnmt i* us^U to account lor the
powiiHiicni'f- share »1 imhh: fuel fu\ icyckucs and special sine
frani* thai arc legally tolrictccl u» the muinicniuice of stale bigli-
w;ix \ wilhin the iroveiiuiienf * boundaries.

Pink* Matnif<ti v /" Mid— Tl;i^ iuJld f*> U>CiJ to iKOKi.'iil !u!
private dnna(inix,'. and aimbotii hevcraoe lax revenues (apprt>\t !i> 10X3 J thut aic s|vc:ifk'hjh ivarictcd to :1k mainu •
naiH-e of tin.* j'ovrnmiem'.v p.irLv

OWO" Kvi'ihiii'/iSifni Hwjcci Futsd i'h*^ Hi nil ^ tw«l m uc-
count for the fcimnuiiit) dociopmcnt block L'rarjt !hat is iuiHiinf
tlx reumlizaiiua piojccl fur subMainku'd h(m^i33|r in the pivein-
dicih'h jiimdinion

Appintitx , \ (i?

-------
Name of Governmbnt
Special R.f. . ¦ i ¦ ¦

Combining Balance Shtet
December 31, 19x4
{with comparative totais for December 31, 19*3)
(amounts expressed In thousands)



Tmns-
partittan

P«rk*

Main-
iftitftfict

C08G

HwliAil*

utktn

—Tot
1»*4

IW

AimIi











Cash and cash aquivateils

m

14€

_

311

158

Investments 		

. 1,174

m



1,577

1,144

iftta-ca receivable 		

1

I

—

2

12

CasfKiSirisfetf	

	



4

i



l«erpvenw»niii receivable











rtslJlcW		



—

'9

n

5

Tota! assets ,. -

1240

550

?3

1,813

1,3*9

Liabilities arid fund bttovc*<











liabilities:











Acc&ynls paptte 				

, 33?

84

—

416

32

Dua to otw fcxris-jerara; fund

—

_

—

—

35

liatJf'iHas payabi« from











restated ass*-	

—

_

18

!8

—

Total hb him —		

332

14

:e

434

t20

fund balances:











Reservedtorenevntiwtcss ...,

. 355

8

5

368

151

Umeservdd, undesignated	

, S55

45®

_

1013

1JTC

Toia! fund balances	

KB

46S

5

1,379

V229

Tot# .iaoJitifs art











fund balances			, ..

1,240

5S0

23

1.B13

1,349

T7w notes to i'ne kmnmi statements 
-------
Enterpuisf. Fi:m>s

Enteiprise Funds are used to account for operations that arc fi-
nanced and operaied in a manner similar to private business enter-
prises — where the intent of the government's council Is that the
costs of providing goods or services to the general public on a con-
timing Km* K- financed or recovered primarily through user
charges; or where the government's council has decided that peri-
odic determination of net income is appropriate for accountability
purposes.

Wait r titifi Si'nct Authority fuml — This haul i,v used in ac-
count ior llic acJivitio of fhe* Wjltt am! Sewei Auihorily n>. Wcmicif

curopnucnt iimf the N'.Ml U i KVMrN i )

/•'iVk trie f'uutl — 1 hunt i> a-ed l
-------
.ViMh iji" Guvkrn.vjknt

EN I'FMIittSK M M>S

CoHtim'ng Balance Shoe!
i31. 19X«
rirftfj3Pdl»ve totals sor Docflrobef ;§X3i
(amounts exp'est-ei) trt Hiousanas)

WltTf

and Sewcf	Tol.iiis

iUbo'.ty E!k!*c 13X4 ISX}

Assets









Current Assets:









Car< and c;-»s>fi eou ^ntf-

$ Uk;t!

a 4 a;,

$ fi.AT?



Cas-i ft I'l fiscal asjen! , ...

123

—

? 23

-

"nvMlrntrtf , , . ,

. 1 -i (3 1 C

1 -35

'6,405

tf, 3?9

nitres! ns?e.',«''«



">!

W{1

.:;>S

Auoiintj f«:e votAt if?( .j'









a, saaTce to- era fv.lft* •?;«

2,i2*

',37b

i,vWr

3.55'

D« f!On oils-* 'i.'M;; . ...









GwfSi 'umt ... .

,. j /

_

•57

39

Pleal m;napffTi*r! :a luiiw (See! »*fv acorni ,

n-r

_

73?

srn

'iever ue tend re,ie&il jn>" repiaerrrwtf acrj^.t

.. 1MZ

—

!,6a;

!,1tr3

Tora» restr rod ss?cn<.....

.. ;?«54

1 ft.i

«7,^C

:,4h6

Ewred charges ., . ,



—

fi'xH



Fued assets:









..sic

an



1,05?

•/;)»

S'J b-nos ,\m ijo'f-M

30.9^3

:o-3

?r,s?i

19,B1r

i»¦«:i ism cisnQS anc r, >>«"nn .



fiOi.i;

;s.4?r.|

t4,7 ivit'i3£

t £S->



1 i's;j

Uuxl

Ac Junii-aW iiapJe; al









mpro«ncn!s &l"g''"j'bi.'d I'-js .

Hi?)



$>.:,¦

,n-m

am equ ikiww

*if<» 'IVj



r£,br-

j mji*

?# Apprntit.x ,4

-------
inset" vfysrcjeMixrEf
Ctrib'r.^iW*. ^ fc.Fi'cs?

ffcti liifts fnfil rfaaaiiulalif

Tj';i (H^T5,

•BfiCtilfi

Writ-

frit! Serfser	- TU'tL—

Awfronlj £l<-cir»f l§fi 1WJ

-•V
, 1\-
V, trji

"" 4','i	•>*

llACUitifi if,I? 1511'

Ciifftrrt labilities:

; 1	> " T:~

t--t ' » = ; - .ci ¦'

it-, "'iv;-'
l.1 1 .. »i'.i <,/*,l^

.	,	f*"i

F t;* »'*gf r.v * 'j'-il	' ¦

f!{r!„i;< nif'i! "Vr ',i	'

hA-'tr.-.c'vi':'.:r |	—

'.k'.ljrcr ! "i'i'.l sa/.'-hV	. t

V.v,„"w'. Tin*.,- r:> \v.	' '>

/«! . "1.K " 1 I1!-''	.-v 1

C-t-IC'f ''it* Ti' , '< ly,V.l

r >' »V t	j

Cn;" ^ pji« ;v ^t'.:

W ti''I'-

Cur'ent fiabilcties wyable (rem restricted assets:

O.i'CM1 ;i-!¦ i,' .rf •'
r-i-.'u ,'T'fti;1 i,iit.:.

A."tvfi 'r.|r-«-vi i iv if i'

v. *>•u.t V't; ' „ , J' t
ra>-1' -,<

Ncrcjoents Itnbjl4.es;
t f'K"i? j! .i;' :>'i t'j'" f>av.-r
irr-* uf ;'nrn,t,i a:'r

Fu-.M ,i._ K'.U- V.-L f I'.'I	>'

u."s~-:d .j k: ,i"v •	. ?"f

rn~ 's< i( risf5 s";	. \{

Timv t,,f >-:¦!' iv	(",*• fri

"-fc'frf	tit.<4

m;*-,

. !•;*
I s^ii

!E

16

.4l:

* J>, ,U

• Ufa

4'-.'i
I f- 1

* 4 ";•<

i ,r-.-

.¦fj f>if

?t 'v;
/6

tSM*

V'/il-

?(¦

\fipfHih r. i

-------
Eqult y:

Cc-ntrtb'Jfrd capita)-
Gwm^n! . . .

Customers ... 		

D?v»iopcrs	

frtefgovervne'tfal ...
Tola,! csmfi&med capita'


rnJ9m»r

AuShafity

4,033
14,tSs2
3524-
fi.585
S8.92X

El«cir«

3,13S

3,158

19X4

4,033
14.062
39,379
5,535
62.C62

803
13,854

34,293
5,508
54,532

Rilateid earnings;

?£>.* ie«'!«j& lwn;J

cwateeis ana ma n?c*wcn





\29*

1,02a

lot fCWJs SO lit









To") .15 b! *e.*v;»

Sfc)i

¦

891

402

PfSfap'" ano rcDl;^^"T'£:r, . .

, U3?



1,632

:,'85

Jn»tS£'Ki i



a H47

3? U?

35,191

"<>!ai m'.i-'m eam.ngs

XL\0b2

6.64?

4'tS2$

37,781

Tela' «mi a'i'J



$13313

5177,469

J13?,3S7

Tr# Aifes fa the >m'mi s^!enmis sre in ,t.?rf u' *',s s*,?.V/?¥

72 Apptttdu ,4

-------
Name of Government

ENTJ.KI'KI.M I-1XOS

i of Revenues, Expenses and Changes in fietafmt
for the fees! year ended December 31, ttX«t
(With comparative totals for the fiscal par eiweef Dswmber 31,18X3)
(amount* expressed in thousands)

—Tf|*ls

' tiwtjr	Sietfle	19*4	11*1

0p«n4t 11,11?	-	I9JK?	$7,586

Sewer charges 5,671	—	5,671	4,344

Tap lew.....,.,..,,.....,....,.........,. 1.521	-	l,S2t	t.iSS

Electric isles -	tS.2811	IS,?®	IS,ill

Tetar opeiafop rnmmm..................... 15.411	15JS®	31,569	28,197

r,lT^,	 u*	.wa	.7.™	««.

Administration.,.,,.,.,,..,....,............. MS?	1*	4,®	4*

Oepweirtaa............................... 2»«	318	2.754	iMl

lilt cprlfiit open* ..............,..,., IlifO	12*73	25,143	23.ilB

Operating! luces*3,141	1,11?	1,518	4,379

iiispefafiiij rwiiiiis (expenea*):

s . . . i i ffl . 4 , a , « . I s . ! . . !. a li ( i . i. 3%fW	Wwtf	1 .

w*rt$!mmm...............................,	t::•	rs-f	>"

InliftJl expense									..... {3,4

Bond issuance caste........... t»j	—	iSi	flit

toss on safes of fastf assets ....................... fill	—	ft®	-

Total »©BSptJlfB§ fS*(flU#S

{expenses;<1,3"' •	:•» •>	it-'.'.	>_<:(.

Income litof# ooerailna transfers 2,4 v	i	«, .• f ¦;	4

Transfer (tc! otner funds:

, , -	i'r	. i /

. «" 4"*c	• i ;i«	c Vf-	"i.<
h< I' in- I >_*!-, .In ' ,1'i '> , , ¦?,> f'.c.4 t.' !L

Si k- fir i tvf nr-r; jvi ' ?'5 >"L	; t •	S-".l jv	S'"

>?vr f-1 '*n- '



AjJj't thiii

-------
N \NH U* (.dVKKNMhM

F\\ti-:ki»kisf Fimjs

t'omcTinr^i 5*,i!rmr;it f>< f^h • 'cf-.

Ft..' fiv:n yo.ii r.nSftd nwo'nj.w 3\ "«X4
'A'>H) ccmp.araf V"- tot.i,s lei f!\ca< ysat rarity: Dfwrt.fH ,v, 1-»X3)
lamr-uri? oxp:c«ml in thouynntf-,i



«ll

kVaujr









ina Sewtr



—.1**

__



AuthCKtj

t'filiti

m*

tfW5

Cash Hows from spe/flftng activities:









*(> -u,.,j *v-u r

Mo V.'



SH sAi :

^.'4

l',rl !l.Tj lC» "Jppl.fi'A

;s.S!'i

lO.fW!



la 3:Ji

Ccssi* :• fo* a>t^»«*JsrT fv 5 i*'( >

ii X?



11 Jj,?'



r-u ? to fTf.'a.ve^

,3 1i •

1 ?;>)

p»eai

'4.513 b

f,v* rifi led hy cr',-iinca„! v.'-c .<

5.:r.

/.X h"



3. MI

Cash flows /;or noncap !a) financing act vo>«s:









V,'-.-:!--' -o y v.i v.""i



;" ,5 •>!;

n iff?

-

'•a* 0,- hwttt , .



4f



s

ft-: 1 JS'i I'L.'CVJ L'Ak? 1' t,









r>c*',insiw! i.it.i -;q a'.: ,'!t'er

J

J l. !C-

1", 1 



'' c



h'p'sjt e.is.i	

.y.3-1

-

•2 jr..'

tj ^7'

p.,r,-.,nr l.t1, i ] p- ; 1

¦&.

	

5



P. ij ' <1 j





w.

^ £37 r

C?".i !r j:" ^ 'n; •> -if yt;• ¦ .ri}'I'lc-rL-

1 ' 1

	

!!•'

—

t cf uc'icn cas'Tuiff









iff!!,-1;; r.,i«iAi ,



—

in

.

w ''C. ! 1" i h > (

/, 2 i;





»"53 r t

Mfl rati r>roi.ioDi t.w by ' Jf «n









,*ij . . -

?1,37«



21 te«;

?35

Ia«h flows from Investing activities:









Fv^'.fc- '(f 'if ' A ' f ' . M'  i.icfr,.*y

' i s-j-



1 :,K(:

: is

Nk r%sh pfcA>,;aj ,'js>"j' bj













¦«y

i25,5'«' ;



74 •Xfipt'tttfa * .•!

-------
Vl,	ill	'i ui.

j' I	I ; >,K. > ^

C	t	*¦

i - • .rv 'j :iX v n 'rr-'wc ijr.

i>; ¦'!'i. -i ;*! 'f,: v it-', i'f'-'.

i '(•"I n'-pj .T. , ..III" '

fMi-t

Mo Sti cf	- Totals --

Aofhit.iv En: ir.t IBM 15X3

I ,tar

fr, ~ 3* ^ a ,h T(

; tr li'l 5 t *'«*!1

Ul ( <>S( II IMJON  ( );M km IS«, IN* OM| TO Nl I

< \mi PMrtvmrj) is\ ()PM<-vi'iint. Anivi'iii'N

Wstc'

itftd SCM'		—

e cr('-c 1M4 tm

ic -i t->'C	. .. s r ^. t"r !?. M'i ti.™

Adjustments to lecontile operMIng income
1r> n«t c*s'i ptcvldta by operating a-ritalies;

Uar't®-.	-i.H	XSr ."'r.-l ,

ii" f,Vi ' ,. ii. "i.ti !• >	ii'Ti'	"!.c it'.-,	ii'j1

i'< cf:«'"r;" .i"-(• t.rr<,	-	¦

¦In, r „> c *t/

t.'ii-.- e:' 1 if' piwjr:' .. , ..	If? ',13

'I" veii'C"	' 'i .v'.Urii'^ .	1 !\* .'if-, iV" l-'Xn1

rr,u\l?r !¦'	KC£i;e I. ,	.	"t	M

1.cr.ff•: "CMi'i'; .f^-V	i>i~ H	• ><

I-it 'it' 1 • i'njw"!?, rfyrtit1'"

1c!„• p>< v 1	- :3?J'

"~rf i&C iHK.r'Viff ¦ i'>

fonf "nc-n^-j i-.t ¦ rsjni'f	'•	'i	'*'1

I'-rtcAft' ioi»tc-;t?'r .i' I'li-r-pcvfrni-ris

'(,,1.^:6%	...	,,	>i\	-	it*;

pvj'trtM	!"iiw-u Lms ,, ;v£n	- ,•?*i	f

"o'.3,	.	Z ' ii,'	I'M 1	Li'.t./

Not t.1}'1 pv v i-lf-O f'» ff CfJV'.'i rt'l;'.'.;.'; , ,, ; I" ,01'' lil.tS'J 5 b.'&C-r ( |1 s>.:

Noncash Investing, Cf pita anc financing Aridities

ti-itrij,',1	if	.	,	'C<	—

fi-n'fi: ifTi'.: Ii"isrc!i ''O1-.- ¦iii'/e'itrpcfii	3.D3C-

vt f	c

T:>t	,'rr	j;? >?;> ".Itw: i>;-" !*''>•*

Apptnttu ,t 75

-------
Trust and Agency Funds

Tmst funds lire used to account for assets held by l!ie govern-
ment in d tiustev capacity. Agency funds arc u>ed to account for
assets held by ihe government an an agent for individuals, prjvate
organizations, other rovcrnrncnb and/or other funds,

Senior Citizens" Trmisportatkm Fund — This fund is used to
account for donations that are received pursuant to a trust agree-
ment thai resfriris the use of Those donations w providing subsidies
lor senior citizens' fiimsportniion to special pnenimeiu sponsored
events,

Perpetual Caw fund ~ This fund is used to account tor princi-
pal trust iiniouHt-s received and ielated interest income- The interest

portion of the Intel can be used to maintain the community cemetery.

Public Safety Employees Kctimnenrs System Fund — This
fund is used to account for the accumulation of resources for pen-
sion benefit payment,> to qualified public safety employees.

Deferred Ctrntpmstmon Fund -- This fund is used to account
for assets he id for employees it) accordance with the provisions
of Internal Revenue Code Section 457,

7* AftfWidix A

-------
Nam* or Government
Tri'st and Agency Fvnds

GemMnmg Balance Sneet
December 31, 19X^

(With comparadve tolafs few Deceribef 31, 19X3^
('emtwtts expressed ir> thousands*

Mm

bpmtMWt	f»Mteti

Twl >W	ti'l



St",st



M»k

Orif

_





TmmprMm

Cl»

E%fl«VMS

I Has



IK3

As$els

Cas'i v s \* Wi

! v

s rsi

$38

i IB

$n,

15,

mmtimnfs ., . .

4"

! 7ii

K,»f.

i,:«

17,V"

is;«i

~Mwesr 'Kt./dt».

f

V

Mi

—

i-4

ttij

T«at awi;

5 k-

SK»

f nr<

S 1 !'•{

! l&.OEi

f i&.m

iiiiliilSes «ntf iwd tal««













tiibllltlfs;













At •TK*"IS ro>*b»

i :y

i i:

n



1 Sf

ise

Dtifttodc-r-pf-'f-kr,













.VPfK p,-^«hi)!

_

_

—

iytC

?1f

«<

U!ai' sn*' < :



t3

ifi

S.21C





Fund tetencts:













f\>ser«,fl for













«.'£•

—

i,10?

—

_

•

1,'Ui

















_

—

1(5.301

_

>i 532

U.U«

UrotJMvwl













JfidhfUplfltM . , .

51

S5<



—

¦n.iwi

mi-

Tolai Kfid sala'.sm

51



¦* m

_

id,kc

14.T03

Tata' lit-;













l.itfb&lvw

S Sf

5 2.DM

$ 14714

$ T,r-ir-

$ n®

5 16,644



Apptndu. A 77

-------
Namk of Government

Senior Citizens' Transportation
Expendable Trust Fund

Comparative Balance sheets
December 31, 19X4 and 19X3
(amounts expressed' «n thousands)

19X4	19X3

Assets

Ca=h anrj rasf-iiqwv3'e«$ . . 	 			$ H

hvtstmems ... 			4' 53

interest sezmmle		5 2

Tola: assets ,, 		 ,	$ S! 5 51

Ltablllllfs and fund balances
^abilities.

Accounts pa/itfe	 		 $7	$ 2

Fund ba ances.

Urwswwd wu»*g»ti#fl			. , 51	-9

>ta-! abtM'ps b\3 fuM bawws 		 S 58	S 51

Ths nvits to Sir fewcv' t,'iffmei's wji tnlrgrti 0

7H Appendix A

-------
N\MI m < rOI ! KWlf'M

Senior Citizens* Transforation
Expendable Trust Fiji®

Comparative Statements of Revenues, Expenditures
and Changes in fund Balances for fiscal pars ended
December 31,19X4 and 18X3
(amounts expressed In thousands)

Nuveiue*:

.ritorsEf ,	.

Dansltcw .	,

Td«' fWtOf.5 . ...

Expend Huresj

CuiiiBL

iie'tf'j awrmwni	

te» d roWvif s swr exper-rfstj.-f^

Jts.rA*ir) 1 .
~urJ stfari-f'S. CfCCTDf- .. .

f 0

II

Ht

4f»
C f '

1113

S ?

29
2i
W

$4?

it? r,:
-------
\!TVM)!\ H

Excerpted from New York Slate
Operating Permit Program * Annual Report 1*)% «pp. ft-13),

Appendix V ftl

-------
New York State Operating Permit Program

1995 A naval. Report

i'lwsfcnt*	Pii-cc

imrtxSuction							 I

Pli-faCt" 	 I

Hack pot ft! 	.	 .... .. , 3

New York Stau*'» I )p«:5tirijj Prrnsit Prngrani Status	*

New York. Suite s (fferatHtg Pemui lYwaso ImpJerncnUitukn		 -5

Fiscal Report				ti

Operating Permit Pribram Iw , ... 		 	 h

i'lcdn Air Compliance Aci Reporting Requirements							

Ri'finnificiiiJi'tl F« Adjustment							 a

Piojji.tiii Rep*nl	 12

StAic Fiscal Year 94W5 Deiails Projection1!.							 12

Other Imuivuil Afcnck-s				-			-	..................				 ..13

Appcndicrv

fVpjxriidix A: XYS Oep.'iJliriL'i;;«»!'l-.coiiouijc Depurlir.mi Ck\us

Air Act	OnthtiJsriUii, Anutul Report u? the NYS

DEC*-August JAWS

Appendix. 8: NV.S rvpariitwiU >i;' Hi'hIHi Clc m Air Cmrpk-nnv
Acuities-.N'ovemlvr IW

Appendix V: S YS himrmjmental hiscilitk^ C'orporrition-Simll Hikiuc^s
AhSi>;uike J'uijjf-im Annual Report lit [JlX" Amam HW

ligiiifH

Pieutc I	Operatinc Permit actual Costs								 *>

Fi?;mc 2: P5,% Operating Penisii L'sumntcd Com	..............		!0

Pwurc 3: IWW Operating Permit l-viutwted Cw!1-..		II

f i^uro 4: Projected Number •,»!" t\'ntriii<; .Subject to Roxiew

tor 1 itfc V OPP Implementation	 !2



-------
I4 isr \i. Report

Operating Peranit Pwgriuii F«e

Beginning >«• 1'hij Tulc V i%H tlirjvs were required to p| the tciitiige based
< iff I'ft .pursuant lo section V •iti* LCI. OPP j«r. t^lk-uul ,«e «k-
posited in Ike OFP Account ©f the Cletn Air Fbnd established by State Finance
l.j\w Ncui-'t siir v MH»ro t fitiian* ao pay Air Quality Control Ptogran fee ilat
are deposited to the Environmental Regulatory Account established in 1983,

Both lie federal Act and the NYSCACA require fee revenues sufficient 10
cover all reasonable direct and indirect costs required to develop, administer and
enforce the Slate's Title V permit program. Once EPA approves the State's plan
for delegation of ®e Title V program lo Be M;,?i 1 ir|.< V/ORP Sees can «aly be
Olid 10 fond Till© V permit pntgram activities. Rlor to npftre»v»L Tilt? V activities
r»fi be twxted Crib iny sources avillilifc lo lie Sine, for fiscal years (994/95
•iuiicj I vv^/vc)* yjfi s i mm • wcif»iK«i€f skis. occti itiii€ifi.ti ifuu^ £*».-•	* uiMSf

the Utility Regulatory Account, Federal Funds and the OFP Account.

In 1994/95, Title V activities constituted 35% of the DECs air program ef-
fort, however the. OPP Account only paid for 26% of DEC* air program costs. It
is anticipated that as newly authorized positions funded from the OPP Account
are filled during 1995/96, the insulin expended from the OPP Account will ap»
proach MIR of the Title V program cost Many of the employees who will lie
recruited to lie new OPP job® will I*. transferring from existing positions cur-
rently funded by the Section 105 federal grant. Section 105 funds may not be
used for Title V costs Mice federal approval of the OPP is obtained. Those grant
funds ate expected to be reduced accordingly by the federal government.

The Stile legislation requires that commencing January 1,1994 and annual-
ly thereafter, the Department use a formula to calculate the fee per ton of emis-
sions that subject sources are required to pay and that lie, calculation and fee be
established as # role through publication in the Environmental Notice Bulletin.
The fee is calculated by dividing the current Slate fiscal year appropriation for
the OPP by the iota) tons of emissions of regulated air contaminants from
sources subject to tie OPP during the prior calendar year, with consideration
given to any surplus or deficit in the OPP Account of the Clean Air Fund, any
lean repayment from the Mobile Source Account of lite Clean Air Fund and the
rate of collection of Mils issued for the fee. The fee is limited to a maximum fee
of $25 per ton, increased by the percentage, if any, by which the Consumer Price
Index. (CMS) exceeds the CP! for tJie prior yen. Based upon this ceiling, the 1994
fee was 125,69 and the 1995 fee was $26.44.

.Ipfvmhi i< AJ

-------
Cit'itii Air CmjijiJi.incf Ai t Rrprirfiflg Roqiiin inonrv

IV N YS(' >\l \\ -»jVi the, !iif Jimm" jsil'nt iualuir fh,s; (iir- u'jh;if tin.*!
i.'ii;. 11".C; v ai«- .!'¦ li?ii<-i%\v; (Si-; 4cu1.1l iliscv'i ,«io .luhrtsi >uv>J nm-mii" w
..cr.CiJ mi	}c.ir	:ui \incct ,n*>i

I ros*', n Ciit.cs ,n;ii Pi. y.\M ImI.uu ? -f (l\ Lit ;i!1 tr I h;H:"^ OH'
ST') ! O'ifi s>7 pjn-ci u->ns f>!i tini%-> .nut irnltKvi >,«:>. an,'. kwiu.'V ¦>:
I-i'IImI* ill Mr	h < f ,'Pi' I{¦)••: iiiki uimJK. „s u'lO'tinu'tKi.itKvi up ;ii;

in rhr kv>. !'¦	.pJi-tfU.-.U" niinEnii: ikiniu' fitmv \\m'\

1 ,k'it ut hick itn'mcn:* is	.mdei	M-m

Cp.1 Mttnii's p;< i\ »k\! ;ii 1'iiv ii'j'iul ,ur ,,.-En,4 of ['it'li	K'-

.u'on A;hiI 1 .iiiJ Mtit'-.'l" «< ti'i ,i Si,<,L J J yo;>!!•: 'Im\I (II tills U'lUHf '• i(KC	,!Hrt'uk

lii"'!.- ,u s.uia;!' 11, fiiv"[nii «i| a ii:;d	.in u is!'	i.itlusi^ milv icHeU (l»>:

k-,ci ipcikSiii,' lilt- I^'kisialiLv Iiu.\ ;su;ik>:iam m ,1 padiruLir yc.,*' and iir.fki'.-
ii/.-u U»u> niii_v suit hi' il^Nu vJ 111 IhiU j-mi, A 10(.'|nIuUm.- apjisdiautUH, i> ii.'U-

• t!i\ H lsH t"p .ult'i	1! i rl ,'!P,H ¦* I* ,V 'i"l	IIV ('l,' (ip!J l.\"

,'.0: in.1)1 ilu' ipproprMiicii, ilii- Vul iippr.ifrcif.op c,ntKt? K* cpcnt

H\]vn>, 1 >c Hirkli" .:r;nu.>l -i jhi,h \imi \ "¦pjin-.jiu.ili<*11% rmr/isr >. >y-
Pi-'PttaSuwir <•>} a avk-ikMu'^a' .hi uncu Ilk- li.iliiliH w,>*. iijcjp.vd

Stiiti* I'1nc«}1 Yi'iir 1994/95

1 lK> 111 llM.1 ('IS'1.! .Hi,'	I lie ' >|T Hi s)""l h"'-i'vjS VM-'C

Ihl" .MInHIMl «». imVs • \|1r Jliljl'ilt'i % !*J tits* 1 .VlUtii'SU' lltr ot hmruti-
rrtTla! I \mhce .'iilniti, Hr:i l!i, I , i«h. mpi, f l,-v •|upn'..-nc .111." 1 Or I'll*, iniirnrni-;1
!m._ 111.in-?. t*ci;sfi|a";Oii :\ -.ivl'iitnl	i:- incliK'icii hi l-iviiit' I.lln

0I I'.imK kt Pi'' pr-jjinw v» ~« 1 H'P Aix'.mnt ^".4I,<.ccm ""sth tlx- <:w; c».>m
inp I'MVii 1.1,h" Oi'firi.i! 1'iiihi	firi< 1 s, im) ! i.v>5?.,KH P 1 his-; iniwir ifft.vK expc-iJunifp". h\ the C>c|t:n mvns l*tn pen
/tdTtiiil vsitinn.	Jh .'h.Misii Di'Vt-liipnu'isl. .tiul >hi* E-.m irt'i'itu-"its

I-.uiiUiiM L^rpMk'.Ci'iii, A dcr.uUNi >,iiusntus in Hjckhkd h» I t^aiv 2

Ri^eituo .itiucip.;ti"il tu ix- ri.i.cr.'i>J in M"\ J'M.'i	I In-

¦ ts oiim'iI imi i-nilompurr lif!!ii',r t^1* si Wi1 h«i,» tiisn'^ a j^i tin, !'.v.
iit	u-iuii1- .5 iI ink.'Hc'L'Iii'k liKiis1-. 1 n'U*rui>.'	Jt>cs i»rnth\ H

-------
chick- ;ui\	Ura.A tlur r;»\ Iv	tinni j-m: n\.r '<•< v j-riUihu ,v

iin.' inti-n si

I,5f;i' c-uiii.ih"- t|i;i[ tlx K;I,hk'< it'. f(,»- t Jl'l' fwyijri' „»( tlit iriJ iMJY

!¦ 	i

Ais:u		 S 'I??/*?4'

J'Miwti';: <:\-vni,liit;i«,1 , , *I" 53.SS
I mini; iT.I.'uxt,	 .

Slate Fiscal Year MJMG/(>7

The estimated direct ami tnikm costs of fie Off in SPY 1996/96 we
$14,590,658. This iinioniil reflects projected expenditures by the Departments o
Environmental Ceoicrvation, Health, Economic Development awl the Environ*
menial Facilities Corporation, A detailed wiiuoiiry is included in Figure 3,

tinder current legislation, revenues estimated to 'I* received in SPY 1996/9
total f 1 ©,522,5.10, This amount is based on an emission tonnage billing of
430,000 IC'J.- ;n:.* ¦ ,i rat lew fee of $2?.If minus a 10% uncollectible fipiri I!
fee of $2?.19 is lie maximum allowed by tlx- ceiling currently prescribed m itis
NYSC At A.

Rcnmom lukci 1it Adjustment

Tin h** 'C	n-.|iH,'vki! bv DIvT let tin t W rc^nrHi.t m> lui

ihcr	Sin- u'quo! i" nn'H'ly lot the- irl. ;tiimi;il vu'.tu **t the

pn»vu:it lc">iv iinilsoi;n\l , p;.n-\oi has if. «•} m*.	;iihi

pt-b 1H X i.- inal-inr hi uiMitirm-iHfctimr ltr an arfjmtinnit ,T fhi* timr

Afiptftih.iM HS

-------
Figure i:

1994-1995 Opkrvitm; Pkkmff Acti'ai. Costs

CMtgwy

Persons) Fnnp Nonprsornl

$««» Semites Strviee Cipiitl kx

Dlwti Program Coito
sr.*	."."Vfrvft!, f

F.i, 'q-w'j' Far;1 ;

444656

•1 iSi.m

setee-*

T^ce-i;

X

1 T'f-r«
15C

m m

o

k'lsl

i erwss

Tola) Operiftng PmrJi Ptograw Coils

1.1 «? 795

ASSUMPTION;

OEFAflT'.ivfn cr L'iVlP£«!*««. CCfMSEHVATlG'.

Li o : c.\'s 16rtud ji "T,n» jnd.Ad'.'iiv nJi.'tJs <* Liang lOiusi-rvn*!! nr.:* in ¦.& y slat ! A&i
iftVnrro.;iAi' s-'ui" "rte	»!n ">;S *" Sp* 'ftM v5 T.-t

ajr- *«.<> ac-P'^l t-s |hf ;*te! A'f «>eid1ft- in SFf i>A4-?5 In; \<, ^s'« wf'i c«WM*<1¦>'!P-'i r'
jL'ni-j	.fwVc.'Si". .» »ui< '4 -is

Mt kpfttnJir li

-------
Fu.im 2;

I'J95-% OlM KM INC IYkaJII l > I IM VH [1 Costs

PfSCW! fnnac	Nonjuison*

Category	Sfr-ct 6'wrlifr SwMotol Sm.i'c Cajwjl Tola

Diret! Prcg-aw Cosh
r i '-in'

Ll'ftW.	w 'n't,1:1/	b.^r,-	'.fTfc ,"£r "¦ •"!«.	j

Hf>«t>	:v>rr •;;•«	.

b'r\-ir'

lie, e-' if1	-4'..*LLmI-i •' UC

t ' f[	'l	'	I '¦ U>1"„	1

Tola! D(WC1 Cestf	L 1'; Si'	<"	* fiL"',' '*

tr»dift:! Proofm Costs

Fwwr.x'C:i,'^;ri®n 				' IV'if	;i 17*4 **»

Ml.-r-..	. 				..	T.7V, : S-TS-

I*-	•*), itw *-»• ........			-W*

•>'. C.v	.	C	•!

' i.- 		,		is

t*iJOfMnttngC®*., B,t28,S25	C\>L:;	. \r: g , \\f

ISSiliWliiS:

: r rJ S>,v . i'l' -'Iii-I'ii re',.. (i ;>tv'.X.'f. t5'x-i

Menfwrwnal iirvte »«*•	• **'>•.! ; • «ju k jf-ri v.«enB6*wwwiii

¦oifcii IBIS-t ipfufiitltaw <11% of ptannad to 12 •««§! pafaf),

rnf# s-r|i-'firtcl t»5 Cc'pc.'ntie.'!

M< i * j! !«••.".•	.> •«>; .>.'1 > u .J rt Lt • 5 _¦>:•;	r. 5 1 •; r.,*ri,,, rj'ffi >¦ <«

;\.y)!."> r«l ,*>¦'(•!•»" >f "t . <•*>¦" I If 1 ^ ; «.\ il

ffingt iw®!iii.1i.Cl*K?

Fir-'if' *T-1*. .j.i¦> ... ,rtc,',--i i'»

hi,i* vt I' t s ',.s . Hi .V.i *> ",!t «';! i' u.' _« t t'y .'I
V UV. j'l'J 4' 'Ct f'll'.' '| >

I ijf'.'i-it.-!'; 'i E, U'.'T'	- ""i1- .if; •;*¦ 'j s> i',. <

Apprtidi.x I! b "

-------
Figure 3:

l9%-97 Opekatim* Permit Estimated Costs

Pmom

Fring«



M«jpe«»ntl





Ciltflfiff Swiet

Btntflft

SuMrttf

S*fyic«

c^iitf

Total

QiiMt Progr»m Co$SS











Efviwwnn1











Cons*vdliuii 5ESD"W

wsw





tmm



H«.!f , , ., 7H 579

76,043

3F 622

TS,31i:

c

4 re 924

Eww,-











D«VetoCi«ff!! . ... 3s9,3?5

¦24 m?

824,248

S6.M

c

1/582,5*4

ErvirrtJWfle'











f *¦*:»> Cc; , ¦>

0

«

it«o:

0

1,000,000

Total Dtff ct Costs 5 ^5^,653

',6Si 3 S3

7,631,9*6

3,602,WC'

s,000,0:0

n.tmm

IwSftet Prognw Celt*











Envre^T»»l€«nrefw;-£0 , .





2,041,753

0

2,»\m

Hs#h . -	





57 735

0

9',769

Ercr kt - Deia'uprr*-.! . ,





156.4S6

0

'S 4S6

Ewwwta!' %gM« Cci?





ti

0

£•

7o*V f"S rrc< Cj'Si. 	 .





2 £56.062

0



Total Opmiing Com SftS.fS ,635.3'5 r.691,9t6 5,83d,©2 \mm -iweie

ASSUMPTIONS'

Piancwi whwj'* s xr 4> mr-fi •*'*<. Dv»[«toicrii.» lui ill •pencv a»e ta'CuWfd at 3117",- of petscnal '.er.-vs

rj.'ect ws lor i ager.&es see fstru'sfed at a 65\ cl pe-?.:*a wvite sna iv«s h>*f ,s

88 Appendix B

-------
State Fiscal Xi: \k 1994/95

Pi TAILS AND PRO.Il ( HONS

'I h»* N"*iSt Ai \ ;«qair» I)I;C" !n l.v immlvi «,t Upciuiijt;. Penrut ;;j>-

j>lnaui«fl- *M. «;n>. !i '.rwl A'.nni v,;• s titki.it :i. pi<'%t.i'lw.j u.r v.'sfb

„-,n .iwi.ijV	iuik. : pirimi. uumH'i ui pu>.i-ii hp-si- spcvii ptt p.-1111.11 jml

irmnhT .-l uiinpirit i:;.'imir hippEkMUMn Uxd. Smi c f(,-. Sf.itr divl r«>I Ikih
knVKilh ,\ppi,Ht a t »!'•' )l. filrvt sr. S!^ u* i„<\ put tPlH 'Af lr H'
su'wra i'l P--'» ii v.r»st	i't. . ,nplet;KTJ Ihr pi.i-
»-Uif Mu' i:f\i Iim >i'.t"s 'I .tic t« !t^\icil i;i li.sn.ii- ¦«

4;

PKo.H.I II l> \t Mill K ill I'l-11 Ml IS
10 MEVJIW IX (IKOKK TO IWI.I.MI.M I111 f \

Pwttfc 1f. Ix. -tAvniOt Ret «r,

PerwlTypt	owr Irtk ne*i 5	!im»* icbys'prtvt.

t • j rvt,;* '< ¦ :> ">

Ma ml ¥00 Ammmm Ailitwalii tifjwotfifpH

'"."•T t^ACT pfi"n S **,•!' o
\:'i t; iiji'.i-,,i

.t/c11 -r.j.:1•c 1'*•", r.ty
Wir,'?¦ ¦] J.;- "-I "• 0

MV	!1;1 l"„i»•

Kiri>r>,	v ?r* r "V. i

Tfin ! Tt .11'!, >¦it I :	'i .!> « 1 in. [>. ,'i\' A , i; f ; i r, ii) t, sh I •

tf fef r,-'v J |,V'« *,>rsr:f „-.'i v >1 '¦•>>	r~ nf, •> • 1' t '1,1 s- t - -ir ,• •;• iv * !,

!»>•>, 1 I f„ " n<- I,' ' I, J\	,.1 f'. . , P f.'K'"Cu,;i:.-'. A!*J1 to * c 1'"*

Tin t.-'s I-1	•1 ,'r*t'» . . 11, « > j. ¦ . > •»	'> •"

; a :fys I?' V'' * " fV ~ ifrt	i'r ; 1 ¦/. f I, • U ;-c Vt 'J.: . tt Jja'i 0

K'> "7 y J «" 1 1	1 1< It ,-t f." Dm VH:"	ati. if.t u U", !-3

f,' "T '• >. f." t'	>¦ -ur V:. it"' ThR' rf-,i,r. ,-"r|' •( . 11, 1 i,r;, •,
ifViir* l*t;» !¦.¦ ••*'« nt*

T !¦' i")., . • >'• (~ ',rC	V '« Ci'; "!.»•'1 1".' *< . c «•,"*' ,-1 -r. 'r.-j.
1 '1'fp 1, f, 7 [, i(<

tTo

45

20C

ApfH n
-------
Other involved agencies

TJh' N'YSCACA iJol'ji ik)! .viKi-'Hlt'alJy svquirc tlml i!k anivhitf.s of uiliei in-
volved ri|!ciick*s te tepoelctl. Howtvn, Ok- Depuumcnt ol HlmHIi, Dc(>:«rtiiAkiU yi
Economic Devebprneni ami ;he Environmental Paciiuicv Cdrprtfiition v.\v?o
.'i$kcU in report so ffcri ihe direct emu ot the fiscal portion ot ttrn report covM bv
ilclnniiwd. Kxponilitiirrv rfjMiitril m lhi,i\r ngcrjck" h:>u' brfrs	iti (his

report. Their submissions to> DHC" arc included as appendices Io Shis report.

90 Appendix 8

-------
The J3nvir«ii«t.lent.i? n«ui».€ Ccwct pan of fh-1 iwial ."hkI Lnvirauinen**!

P Pvi't'HUW (Cli'l'J ni'J i«- h»rari, > :i tnjn-tU';'r«v "•rrit.iinj* pri
iTMIi >, otrtfV'H'd fif liu' 1 invi'isils nl Maiyitiiu! Hra (i:ant Ptojruan, lur Schiiii!

ct	tin' CoIlt'iH"- o? A^n-aiJuxe. the Sch«*oi ul Law. and ihf

CfNif.i For Environmental ami Jim-inn.- Swifev CUT provide* inioinw
tiorul, educational ami re.vwl; |v?U s ima'ym nful ttvhmrai problcm-soivirp

Ahout Sea Gratii

The National Sea Grant Piogiam €Hcouw|!t'x wist- vlcwHrtlxitip oi tuir iiiarini*
resource* through research, education, outrtMch and technulojj transfer,

Maryland Se,« Grant is me ot wcnty-nine Sea Grain programs across the
country - part of u tialionsl partner,ship Mipp«t«l jointly by slate ni>d federal
fund's, IriHii il.i» NiiUiMiiii < k'Cinsit atiii A?ir.o.sphcnc

About »)n i t ('

With siipfswl tram the I X UitViiOijrictiiiu I'Mwiiui! Amicy ililYu mid ilu-
Maryland Sea Gram Culk^ Pcoj-T^it. tl«» laivirftmnt-ma! Finance Onier

it HA treated to liaiii, ptovufc' avM- nil in uiriiontal ShiIiIK't

"1 lit* 1,'enkr proniutt's ;• tnntprrfit'nsiu' t>«xl inti^nuivc busk at i'livncirimeren1
fiiiaiwr fiooi u Mi.ik'git iiianageiiieiit pmprttive that	that sound

environmental practice.-. encompass a broad spetfram of activities, Activities
Mich as needs jTsscvdrn'Mlv issue pioriti/fllioii, identification of relevant envi-
ronmental regulation* anil compliance ksucs, ilevidopmcnt of capital fat'tliiics
plans, identification of revenue sources, and community paiticipation aic pre-
cursors to securing ftmtliitfi that form part of the EFC's holistic approach.

To fiihl out nwie ahom tin* KmKfitmwml rin.jiue fVtiie; visst «w»i wef>

-------
Title V of the Clean Air Act

One of the most important benefits of the new Title V operating permits program of the Clean Air Act is
(hat ifac program itself will ensure thai adequate resources are available for its administration. By col-
lecting fees from stationary air pollution sources in exchange for permits which regulate levels of emis-
sions. stales and localities can achieve a number of desired goals:

•	Use revenues generated by those regulated to monitor, enforce, and repon oo stationary
air emissions

*	Create incentives for those sources to reduce emissions by forcing permit holders to internalize
the costs of emitting air pollutants	* *	.

¦ Begin to track air pollution control requirements and performance so it becomes easier-to man-
age programs across media, such as air, water, and land

If revenues generated from a program go to support other state efforts, then not only will the program
suffer from lack of resources, but those paying the permit fees will not receive the level of service that
they arc paying for.

This handbook identifies ways a state or local air program agency can collect, segregate, and account for
Title V fees so that they are noi commingled with other efforts.

SEPA JwSnal

Issues in Environmental finance

Environmental finance Center a University of Maryland System
http://www.mdsp.untd.edu/MDSG/EFC/index.hlml

-------
Appendix F. SDAPCD Fee Information

Page 54 of 59

-------
Title V Revenue

Fiscal Year

Revenue

FY1819

$40,658

FY 1920

$23,692

FY2021

$86,154

-------
SITE RECORD ID

TITLE V PROGRAM

APP RECORD ID

OPEN DATE

RECORD STATUS

FACILITY

INVOICE NBR

TRANSACTION DATE

TRANSACTION AMOUNT

FEE SCHEDULE

FEE rTEM CODE

FEE DESCRIPTION

APCD1976-SITE-00145

Yes

APCD2018-APP-005393

04/30/2018

Open

General Dynam

cs NASSCO

3298915

12/09/2020

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3282028

11/12/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3282026

11/12/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3292236

11/24/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3293581

11/30/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3294826

12/02/2020

$239.40

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2019-APP-005991

08/29/2019

Open

General Dynam

cs NASSCO

3298913

12/09/2020

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006212

02/24/2020

Open

General Dynam

cs NASSCO

3350687

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3298910

12/09/2020

$82.80

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3307198

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3308694

12/21/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3309252

12/22/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3309313

12/23/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3309315

12/23/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3311039

12/29/2020

$1,008.90

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3311078

12/29/2020

$615.60

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3312178

01/04/2021

$752.40

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3312179

01/04/2021

$239.40

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3311919

01/04/2021

$820.80

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3312724

01/05/2021

$564.30

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3313164

01/06/2021

$598.50

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3313663

01/07/2021

$684.00

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3323360

01/19/2021

$222.30

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3323420

01/20/2021

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3328974

01/28/2021

$510.00

A PCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00145

Yes

APCD2020-APP-006308

06/01/2020

Open

General Dynam

cs NASSCO

3335972

02/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00145

Yes

APCD2021-APP-006729

04/19/2021

Open

General Dynam

cs NASSCO

3426368

06/07/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-00145

Yes

APCD2021-APP-006729

04/19/2021

Open

General Dynam

cs NASSCO

3435442

06/17/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-011BO

Yes

APCD2020-APP-006524

11/12/2020

Open

Solar Turbines Incorporated

3282927

11/16/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-02083

Yes

APCD2019-APP-006051

10/11/2019

Open

City of San Diego - PUD Point Loma Water Treatment Plant

3437281

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-02083

Yes

APCD2020-APP-006323

06/09/2020

Open

City of San Diego-Metropolitan Wastewater Dept

3435469

06/17/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-02083

Yes

APCD2020-APP-006484

10/13/2020

Open

City of San Diego-Metropolitan Wastewater Dept

3258451

10/15/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-02083

Yes

APCD2020-APP-006484

10/13/2020

Open

City of San Diego-Metropolitan Wastewater Dept

3435463

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1978-SITE-02756

Yes

APCD2017-APP-005185

10/24/2017

Open

Fleet Readiness Center Southwest

3437359

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1978-SITE-02756

Yes

APCD2020-APP-006230

03/16/2020

Open

Fleet Readiness Center Southwest

3294077

12/01/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD1978-SITE-02756

Yes

APCD2020-APP-006230

03/16/2020

Open

Fleet Readiness Center Southwest

3297949

12/07/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD1978-SITE-02756

Yes

APCD2020-APP-006385

07/23/2020

Open

Fleet Readiness Center Southwest

3336531

02/10/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1978-SITE-02756

Yes

APCD2020-APP-006385

07/23/2020

Open

Fleet Readiness Center Southwest

3435464

06/17/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2019-APP-005961

08/07/2019

Open

SFPP, LP

3350650

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2019-APP-005961

08/07/2019

Open

SFPP, LP

3437310

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2020-APP-006542

11/30/2020

Open

SFPP, LP

3295426

12/03/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1979-SITE-00623

Yes

APCD2020-APP-006542

11/30/2020

Open

SFPP, LP

3435459

06/17/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2021-APP-006689

03/24/2021

Open

SFPP, LP

3367612

03/24/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1979-SITE-00623

Yes

APCD2021-APP-006689

03/24/2021

Open

SFPP, LP

3435444

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2021-APP-006741

04/30/2021

Open

SFPPLP

3394653

05/03/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1979-SITE-00623

Yes

APCD2021-APP-006741

04/30/2021

Open

SFPPLP

3395800

05/05/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

Yes

APCD2021-APP-006742

04/30/2021

Open

SFPPLP

3394667

05/03/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1980-SITE-02754

Yes

APCD2019-APP-005964

08/09/2019

Open

USN Air Station NORIS

3350652

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1980-SITE-02754

Yes

APCD2019-APP-005964

08/09/2019

Open

USN Air Station NORIS

3437308

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1980-SITE-02754

Yes

APCD2020-APP-006196

02/07/2020

Open

USN Air Station NORIS

3350502

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1980-SITE-02754

Yes

APCD2020-APP-006196

02/07/2020

Open

USN Air Station NORIS

3437278

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1980-SITE-02754

Yes

APCD2020-APP-006345

10/29/2020

Open

USN Air Station NORIS

3273322

11/02/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1980-SITE-02754

Yes

APCD2020-APP-006345

10/29/2020

Open

USN Air Station NORIS

3435466

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1982-SITE-00195

Yes

APCD2018-APP-005404

05/17/2018

Cancelled

Cabrillo Power 1 LLC

2702934

01/28/2021

$174.87

A PCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1982-SITE-00195

Yes

APCD2018-APP-005404

05/17/2018

Cancelled

Cabrillo Power 1 LLC

2702934

01/28/2021

$389.40

A PCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1982-SITE-00195

Yes

APCD2019-APP-005818

05/02/2019

Open

Carlsbad Energy Center LLC

3295666

12/03/2020

$207.00

A PCD 94

APCD 94D

Senior Engineer

APCD1982-SITE-00195

Yes

APCD2019-APP-005818

05/02/2019

Open

Carlsbad Energy Center LLC

3437313

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1984-SITE-03438

Yes

APCD2019-APP-005733

02/27/2019

Cancelled

Otay Landfill Gas, LLC

3271619

10/28/2020

$207.00

A PCD 94

APCD 94D

Senior Engineer

APCD1989-SITE-03596

Yes

APCD2018-APP-005293

02/02/2018

Open

Sycamore Landfill Inc

3283052

11/16/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07494

Yes

APCD2018-APP-005292

02/02/2018

Open

Otay Landfill Inc

3257808

10/13/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07494

Yes

APCD2018-APP-005292

02/02/2018

Open

Otay Landfill Inc

3258257

10/14/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07494

Yes

APCD2018-APP-005292

02/02/2018

Open

Otay Landfill Inc

3282027

11/12/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07494

Yes

APCD2018-APP-005292

02/02/2018

Open

Otay Landfill Inc

3425388

06/03/2021

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07494

Yes

APCD2018-APP-005292

02/02/2018

Open

Otay Landfill Inc

3426622

06/07/2021

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005736

02/27/2019

Open

City of San Diego/Environ mental Svc Dept/Miramar Landfill

3350619

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005736

02/27/2019

Open

City of San Diego/Environ mental Svc Dept/Miramar Landfill

3437319

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005745

03/04/2019

Open

City of San Diego Environmental Services Dept

3273447

11/02/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005745

03/04/2019

Open

City of San Diego Environmental Services Dept

3289177

11/18/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005745

03/04/2019

Open

City of San Diego Environmental Services Dept

3293582

11/30/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005745

03/04/2019

Open

City of San Diego Environmental Services Dept

3294829

12/02/2020

$68.40

A PCD 94

APCD 94C

Associate Engineer

APCD1989-SITE-07515

Yes

APCD2019-APP-005745

03/04/2019

Open

City of San Diego Environmental Services Dept

3437317

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

-------
APCD1989-SITE-07515

Yes

APCD2020-APP-006545

12/04/2020

Open

City of San Diego/Environ mental Svc Dept/Miramar Landfill

3326499

01/22/2021

$74.00

A PCD MISC

A PCD NBF

New Application Base Fee [FF]

APCD1989-SITE-07515

Yes

APCD2020-APP-006545

12/04/2020

Open

City of San Diego/Environ mental Svc Dept/Miramar Landfill

3435453

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1990-SITE-0BB25

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3258255

10/14/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-0BB25

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3258663

10/15/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3268978

10/20/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3269505

10/21/2020

$684.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3270065

10/22/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3271387

10/27/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3273446

11/02/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3274475

11/04/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3278250

11/09/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3290028

11/19/2020

$769.50

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3291404

11/23/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3424755

06/02/2021

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1990-SITE-03325

Yes

APCD2018-APP-005299

01/22/2018

Open

SD Co of Pub Wks San Marcos Landfill

3425340

06/03/2021

$598.50

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2019-APP-006052

10/11/2019

Open

City of San Diego - PUD, Metro Biosolids Center

3350607

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1994-SITE-07517

Yes

APCD2019-APP-006052

10/11/2019

Open

City of San Diego - PUD, Metro Biosolids Center

3437282

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3294828

12/02/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3294931

12/03/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3297958

12/07/2020

$239.40

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3298544

12/09/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3299468

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3299844

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1994-SITE-07517

Yes

APCD2020-APP-006321

06/09/2020

Open

City of San Diego PUD, Metro Biosolids Center

3435470

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3380955

04/15/2021

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3390058

04/21/2021

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3390054

04/21/2021

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3425876

06/04/2021

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3435352

06/17/2021

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2018-APP-005446

06/26/2018

Open

SDG&E Miramar

3437352

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1995-SITE-09138

Yes

APCD2019-APP-005696

01/17/2019

Open

SDG&E - Miramar Energy Facility

3273445

11/02/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2019-APP-005696

01/17/2019

Open

SDG&E - Miramar Energy Facility

3277895

11/09/2020

$68.40

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2019-APP-005696

01/17/2019

Open

SDG&E - Miramar Energy Facility

3277899

11/09/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD1995-SITE-09138

Yes

APCD2019-APP-005696

01/17/2019

Open

SDG&E - Miramar Energy Facility

3437324

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

Yes

APCD2019-APP-006050

10/11/2019

Open

City of San Diego - PUD NC LGE - South

3437279

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09778

Yes

APCD2018-APP-005425

06/12/2018

Open

Minnesota Methane LLC San Diego Miramar Facility

3437356

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

Yes

APCD2019-APP-005735

02/27/2019

Open

City of San Diego Environmental Services Dept

3437323

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1999-SITE-10882

No

APCD2018-APP-005554

09/24/2018

Open

Otay Mesa Energy Center LLC

3350604

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD1999-SITE-10882

No

APCD2018-APP-005554

09/24/2018

Open

Otay Mesa Energy Center LLC

3437337

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD1999-SITE-10882

No

APCD2018-APP-005651

12/14/2018

Open

Otay Mesa Energy Center LLC

3393471

04/29/2021

$103.50

A PCD 94

APCD 94D

Senior Engineer

APCD1999-SITE-10882

No

APCD2018-APP-005651

12/14/2018

Open

Otay Mesa Energy Center LLC

3437334

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3234222

09/08/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3317085

01/14/2021

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3317087

01/14/2021

$752.40

A PCD 94

APCD 94C

Associate Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3327501

01/25/2021

$459.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3327908

01/26/2021

$340.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3329179

01/28/2021

$595.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3335974

02/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3345684

02/17/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3345627

02/17/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3346323

02/18/2021

$340.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3348354

02/24/2021

$850.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3349113

02/25/2021

$1,020.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3350640

03/02/2021

$408.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3351368

03/03/2021

$884.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3355154

03/08/2021

$221.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3355787

03/09/2021

$68.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3357539

03/11/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3358599

03/15/2021

$102.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3364930

03/17/2021

$68.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3399622

05/12/2021

$272.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3400240

05/13/2021

$442.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2020-APP-006444

09/04/2020

Open

Chula Vista Energy Center LLC

3444108

06/29/2021

$255.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2000-SITE-03752

Yes

APCD2021-APP-006597

01/19/2021

Open

Chula Vista Energy Center LLC

3326686

01/22/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2000-SITE-03752

Yes

APCD2021-APP-006597

01/19/2021

Open

Chula Vista Energy Center LLC

3435446

06/17/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04087

Yes

APCD2017-APP-005184

10/23/2017

Open

SDG&E Cuyamaca Peak Energy Plant

3434904

06/17/2021

$425.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2017-APP-005184

10/23/2017

Open

SDG&E Cuyamaca Peak Energy Plant

3434873

06/17/2021

$850.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2017-APP-005184

10/23/2017

Open

SDG&E Cuyamaca Peak Energy Plant

3443499

06/28/2021

$255.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2017-APP-005201

11/07/2017

Open

SDG&E Cuyamaca Peak Energy Plant

3431953

06/16/2021

$850.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2017-APP-005201

11/07/2017

Open

SDG&E Cuyamaca Peak Energy Plant

3434898

06/17/2021

$425.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3244335

09/21/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3315189

01/11/2021

$188.10

A PCD 94

APCD 94C

Associate Engineer

-------
APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3315736

01/12/2021

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3316273

01/13/2021

$940.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3323362

01/19/2021

$718.20

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3326235

01/21/2021

$935.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3327500

01/25/2021

$391.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3335975

02/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3345687

02/17/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3351370

03/03/2021

$68.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3351372

03/03/2021

$51.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3353541

03/04/2021

$697.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3355151

03/08/2021

$595.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3357535

03/11/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3357536

03/11/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3358601

03/15/2021

$272.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3399620

05/12/2021

$340.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3400245

05/13/2021

$425.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3402747

05/17/2021

$442.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3403153

05/18/2021

$255.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3403897

05/20/2021

$323.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3410819

05/27/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3413223

06/01/2021

$221.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3424737

06/02/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04087

Yes

APCD2020-APP-006451

09/18/2020

Open

SDG&E Cuyamaca Peak Energy Plant

3434913

06/17/2021

$136.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04089

Yes

APCD2019-APP-006001

09/13/2019

Open

CalPeak Power - Enterprise LLC

3350653

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04089

Yes

APCD2019-APP-006001

09/13/2019

Open

CalPeak Power - Enterprise LLC

3437291

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04089

Yes

APCD2020-APP-006508

11/04/2020

Open

CalPeak Power - Enterprise LLC

3274388

11/04/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04089

Yes

APCD2020-APP-006508

11/04/2020

Open

CalPeak Power - Enterprise LLC

3435462

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04109

Yes

APCD2020-APP-006330

06/11/2020

Open

Larkspur Energy Facility

3399141

05/12/2021

$136.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04109

Yes

APCD2020-APP-006330

06/11/2020

Open

Larkspur Energy Facility

3435467

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04211

Yes

APCD2019-APP-006002

09/13/2019

Open

CalPeak Power Border LLC

3350681

03/02/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04211

Yes

APCD2019-APP-006002

09/13/2019

Open

CalPeak Power Border LLC

3437290

06/21/2021

$20.70

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04211

Yes

APCD2020-APP-006509

11/04/2020

Open

CalPeak Power Border LLC

3274964

11/05/2020

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04211

Yes

APCD2020-APP-006509

11/04/2020

Open

CalPeak Power Border LLC

3435460

06/17/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3243345

09/17/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3243345

09/17/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3243659

09/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3243659

09/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3271848

10/28/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3271848

10/28/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3291405

11/23/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3291405

11/23/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3292245

11/24/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3292245

11/24/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3292244

11/24/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3292244

11/24/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3293580

11/30/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3293580

11/30/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294085

12/01/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294085

12/01/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294833

12/02/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294833

12/02/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294932

12/03/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3294932

12/03/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3297959

12/07/2020

$444.60

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3297959

12/07/2020

$444.60

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3298542

12/09/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3298542

12/09/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3299470

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3299470

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3299852

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3299852

12/10/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307194

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307194

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307192

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307192

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307196

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307196

12/16/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307345

12/17/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3307345

12/17/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3308690

12/21/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3308690

12/21/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3309314

12/23/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

-------
APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3309314

12/23/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3311093

12/29/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3311093

12/29/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3312727

01/05/2021

$119.70

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3312727

01/05/2021

$119.70

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3313171

01/06/2021

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3313171

01/06/2021

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3316277

01/13/2021

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3316277

01/13/2021

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3335976

02/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3335976

02/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3347869

02/23/2021

$1,190.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3347869

02/23/2021

$1,190.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3350632

03/02/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3350632

03/02/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3437730

06/21/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2017-APP-005134

09/13/2017

Open

SDG&E PALOMAR ENERGY CENTER

3437730

06/21/2021

$170.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2018-APP-005375

04/16/2018

Open

San Diego Gas & Electric Company Palomar Energy Center

3243562

09/17/2020

$103.50

A PCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04276

Yes

APCD2018-APP-005375

04/16/2018

Open

San Diego Gas & Electric Company Palomar Energy Center

3298408

12/08/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD2001-SITE-04276

Yes

APCD2018-APP-005375

04/16/2018

Open

San Diego Gas & Electric Company Palomar Energy Center

3355791

03/09/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2018-APP-005375

04/16/2018

Open

San Diego Gas & Electric Company Palomar Energy Center

3390425

04/21/2021

$85.00

A PCD 94

APCD 94B

Assistant Engineer

APCD2001-SITE-04276

Yes

APCD2021-APP-006807

06/28/2021

Open

SDG&E Palomar Energy Center

3444138

06/29/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04276

Yes

APCD2021-APP-006807

06/28/2021

Open

SDG&E PALOMAR ENERGY CENTER

3444138

06/29/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04276

Yes

APCD2021-APP-006807

06/28/2021

Open

SDG&E PALOMAR ENERGY CENTER

3444138

06/29/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]

APCD200B-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3310151

12/24/2020

$517.50

A PCD 94

APCD 94D

Senior Engineer

APCD2003-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3311796

12/31/2020

$414.00

A PCD 94

APCD 94D

Senior Engineer

APCD2003-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3311797

12/31/2020

$621.00

A PCD 94

APCD 94D

Senior Engineer

APCD2003-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3381053

04/15/2021

$828.00

A PCD 94

APCD 94D

Senior Engineer

APCD2003-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3404688

05/20/2021

$1,035.00

A PCD 94

APCD 94D

Senior Engineer

APCD2003-SITE-04824

No

APCD2018-APP-005657

12/18/2018

Open

Hanson Aggregates Pacific Southwest Region

3404689

05/20/2021

$207.00

A PCD 94

APCD 94D

Senior Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3243134

09/16/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3243215

09/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3243653

09/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3246226

09/22/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3246888

09/23/2020

$684.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3247442

09/24/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3250018

09/30/2020

$598.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3250744

10/01/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3254404

10/05/2020

$684.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3254870

10/06/2020

$855.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3255394

10/07/2020

$427.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3255510

10/08/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3258739

10/15/2020

$207.00

A PCD 94

APCD 94D

Senior Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3267001

10/19/2020

$513.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3268967

10/20/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3269471

10/21/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3271849

10/28/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3272342

10/29/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3273896

11/03/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3274421

11/04/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3275259

11/05/2020

$414.00

A PCD 94

APCD 94D

Senior Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3280274

11/10/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3288766

11/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3288767

11/17/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3289282

11/18/2020

$256.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3291403

11/23/2020

$684.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3292242

11/24/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3293578

11/30/2020

$342.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3294095

12/01/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3297957

12/07/2020

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3298549

12/09/2020

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3311084

12/29/2020

$153.90

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3312180

01/04/2021

$102.60

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3311920

01/04/2021

$205.20

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3312726

01/05/2021

$239.40

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3313168

01/06/2021

$85.50

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3313664

01/07/2021

$171.00

A PCD 94

APCD 94C

Associate Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3396632

05/06/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

APCD2007-SITE-06289

No

APCD2017-APP-005154

10/02/2017

Approved

Orange Grove Energy, L.P.

3357864

05/12/2021

$604.10

A PCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD2007-SITE-06289

No

APCD2021-APP-006779

06/07/2021

Open

Orange Grove Energy, L.P.

3437769

06/21/2021

$74.00

A PCD MISC

APCD NBF

New Application Base Fee [FF]





APCD2019-APP-005685

01/09/2019

Open

El Cajon Energy, LLC

3437327

06/21/2021

$41.40

A PCD 94

APCD 94D

Senior Engineer

-------
Total

884,373.07

-------
SITE RECORD ID

FACILITY

TRAN DATE

INVOICE NBR

COST/INVOICED

REVENUE/PAYMENT

FEE ITEM

FEE DESCTIPTION

APCD1976-SITE-01130

SolarTurbines Inc

09/17/2020 09:01:41 AM

3141530



$494.20

APCD TVR

Federal Title V report review

APCD1979-SITE-00623

SFPPLP

03/18/2021 11:22:19 AM

3141527



$315.00

APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

02/16/202112:48:58 PM

3344978

-$248.40



APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

02/18/202103:04:55 PM

3346238

$496.80



APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

03/10/2021 10:19:30 AM

3346238



$496.80

APCD TVR

Federal Title V report review

APCD1996-SITE-09779

City of San Diego Environmental Services Dept

02/16/202112:50:33 PM

3344980

-$237.60



APCD TVR

Federal Title V report review

APCD1996-SITE-09779

City of San Diego Environmental Services Dept

02/18/202102:53:33 PM

3346226

$475.20



APCD TVR

Federal Title V report review

APCD1996-SITE-09779

City of San Diego Environmental Services Dept

03/10/2021 10:53:10 AM

3346226



$475.20

APCD_TVR

Federal Title V report review

Total	$486.00	$1,781.20

-------
SITE RECORD ID

APP RECORD ID

FACILITY

INVOICE NBR

TRANSACTION DATE

TRANSACTION AMOUNT

FEE SCHEDULE

FEE ITEM CODE

FEE DESCRIPTION

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

3101180

01/29/2020

$1,049.10

APCD TIV

APCD TIV

Title V

APCD1976-SITE-00145

APCD2019-APP-005991

General Dynamics NASSCO

2997087

08/30/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-00145

APCD2020-APP-006212

General Dynamics NASSCO

3121262

02/25/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-00145

APCD2020-APP-006308

General Dynamics NASSCO

3178341

06/03/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-01130

APCD2019-APP-005862

Solar Turbines Incorporated

3115788

02/13/2020

$207.00

APCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-02083

APCD2019-APP-006051

City of San Diego - PUD Point Loma Water Treatment Plant

3026764

10/16/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-02083

APCD2019-APP-006051

City of San Diego - PUD Point Loma Water Treatment Plant

3026763

10/16/2019

$6.15

APCD MISC

APCD CONVEN

2.19% Convenience Fee

APCD1976-SITE-02083

APCD2020-APP-006323

City of San Diego-Metropolitan Wastewater Dept

3181964

06/10/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1978-SITE-02756

APCD2020-APP-006230

Fleet Readiness Center Southwest

3130075

03/16/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1978-SITE-02756

APCD2020-APP-006301

Fleet Readiness Center Southwest

3175095

05/22/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1979-SITE-00623

APCD2019-APP-005961

SFPP, LP

2976812

08/07/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1980-SITE-02754

APCD2019-APP-005964

USN Air Station NORIS

2979991

08/09/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1980-SITE-02754

APCD2020-APP-006196

USN Air Station NORIS

3106781

02/10/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1981-SITE-00250

APCD2018-APP-005297

APPLIED ENERGY LLC NAVAL STATION

3121984

02/26/2020

$101.50

APCD 94

APCD 94D

Senior Engineer

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

3121988

02/26/2020

$142.10

APCD 94

APCD 94D

Senior Engineer

APCD1994-SITE-07517

APCD2019-APP-006052

City of San Diego - PUD, Metro Biosolids Center

3026765

10/16/2019

$6.15

APCD MISC

APCD CONVEN

2.19% Convenience Fee

APCD1994-SITE-07517

APCD2019-APP-006052

City of San Diego - PUD, Metro Biosolids Center

3026769

10/16/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1994-SITE-07517

APCD2020-APP-006321

City of San Diego PUD, Metro Biosolids Center

3181963

06/10/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1996-SITE-09688

APCD2019-APP-006050

City of San Diego - PUD NC LGE - South

3026760

10/16/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

3076199

12/18/2019

$3,021.68

APCD MISC

APCD REF FRF

Forfeited Refund to Customer [Calc]

APCD2001-SITE-04089

APCD2019-APP-006001

CalPeak Power - Enterprise LLC

3013857

09/18/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04109

APCD2020-APP-006330

Larkspur Energy Facility

3183133

06/12/2020

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2001-SITE-04211

APCD2019-APP-006002

CalPeak Power Border LLC

3013868

09/18/2019

$74.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

Total		$5,717.68

-------
SITE RECORD ID

FACILITY

TRAN DATE

INVOICE NBR

COST/INVOICED

REVENUE/PAYMENT

FEE ITEM

FEE DESCTIPTION

APCD1976-SITE-00007

Applied Energy LLC MCRD

03/26/2020 09:43:45 PM

3141335

$261.80



APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

10/30/2019 12:50:29 PM

2831314



$1,286.60

APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

03/27/2020 12:08:09 PM

3141483

$2,422.00



APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

04/22/2020 11:37:22 AM

3141483



$2,422.00

APCD TVR

Federal Title V report review

APCD1976-SITE-01130

Solar Turbines Inc

03/27/2020 12:50:40 PM

3141530

$494.20



APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

03/27/2020 12:35:16 PM

3141509

$309.40



APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

05/27/2020 10:28:47 AM

3141509



$309.40

APCD TVR

Federal Title V report review

APCD1978-SITE-02756

Navy Fleet Readiness Center Southwest

03/27/2020 12:02:31 PM

3141479

$560.00



APCD TVR

Federal Title V report review

APCD1978-SITE-02756

Navy Fleet Readiness Center Southwest

06/05/2020 12:17:47 PM

3141479



$560.00

APCD TVR

Federal Title V report review

APCD1979-SITE-00623

SFPP LP

03/27/2020 12:48:37 PM

3141527

$315.00



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

01/07/2020 12:54:33 PM

2831113



$450.30

APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

03/27/202011:50:53 AM

3141469

$560.00



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

05/20/2020 09:51:47 AM

3141469



$560.00

APCD TVR

Federal Title V report review

APCD1981-SITE-00250



03/26/2020 10:28:37 PM

3141336

$400.40



APCD TVR

Federal Title V report review

APCD1982-SITE-00195

Cabrillo Power LLC

03/27/2020 11:10:44 AM

3141437

$737.80



APCD TVR

Federal Title V report review

APCD1982-SITE-00195

Cabrillo Power LLC

04/24/2020 12:12:47 PM

3141437



$737.80

APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

03/27/2020 12:19:57 PM

3141496

$354.20



APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

04/29/2020 09:25:17 AM

3141496



$354.20

APCD TVR

Federal Title V report review

APCD1984-SITE-03594

Sycamore Energy LLC

03/27/2020 12:52:49 PM

3141531

$407.40



APCD TVR

Federal Title V report review

APCD1984-SITE-03594

Sycamore Energy LLC

05/15/2020 08:59:56 AM

3141531



$407.40

APCD TVR

Federal Title V report review

APCD1988-SITE-00024

Applied Energy North Island

03/27/2020 11:04:34 AM

3141429

$308.00



APCD TVR

Federal Title V report review

APCD1989-SITE-03596

Sycamore Landfill Inc

03/27/2020 12:57:38 PM

3141537

$268.80



APCD TVR

Federal Title V report review

APCD1989-SITE-03596

Sycamore Landfill Inc

05/18/202011:08:15 AM

3141537



$268.80

APCD TVR

Federal Title V report review

APCD1989-SITE-07494

Otay Landfill Inc

03/27/2020 12:16:10 PM

3141494

$1,463.00



APCD TVR

Federal Title V report review

APCD1989-SITE-07494

Otay Landfill Inc

05/15/2020 02:07:16 PM

3141494



$1,463.00

APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

03/27/202011:47:55 AM

3141464

$248.40



APCD TVR

Federal Title V report review

APCD1990-SITE-03325

SD Co of Pub Wks San Marcos Landfill

03/27/2020 12:25:07 PM

3141500

$369.00



APCD TVR

Federal Title V report review

APCD1990-SITE-03325

SD Co of Pub Wks San Marcos Landfill

05/01/2020 02:53:39 PM

3141500



$369.00

APCD TVR

Federal Title V report review

APCD1992-SITE-08447

Goal Line LP

03/27/2020 12:10:47 PM

3141486

$307.20



APCD TVR

Federal Title V report review

APCD1992-SITE-08447

Goal Line LP

04/28/2020 11:52:10 AM

3141486



$307.20

APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

03/27/2020 12:31:25 PM

3141505

$425.60



APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

03/27/2020 01:28:23 PM

3141559

$509.60



APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

04/13/2020 09:57:22 AM

3146405

-$425.60



APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

05/27/2020 10:23:48 AM

3141559



$509.60

APCD TVR

Federal Title V report review

APCD1995-SITE-09138

SDG&E

03/27/2020 12:42:24 PM

3141514

$483.00



APCD TVR

Federal Title V report review

APCD1995-SITE-09138

SDG&E

04/27/2020 09:16:02 AM

3141514



$483.00

APCD TVR

Federal Title V report review

APCD1996-SITE-09688

City of San Diego Public Utilities Department

03/27/2020 11:44:07 AM

3141462

$250.20



APCD TVR

Federal Title V report review

APCD1996-SITE-09688

City of San Diego Public Utilities Department

05/27/2020 10:50:50 AM

3141462



$250.20

APCD TVR

Federal Title V report review

APCD1996-SITE-09778

Minnesota Methane LLC San Diego Miramar Facility

03/27/2020 12:05:29 PM

3141481

$342.00



APCD TVR

Federal Title V report review

APCD1996-SITE-09778

Minnesota Methane LLC San Diego Miramar Facility

05/15/2020 12:08:57 PM

3141481



$342.00

APCD TVR

Federal Title V report review

APCD1996-SITE-09779

City of San Diego Environmental Services Dept

03/27/2020 11:33:37 AM

3141452

$237.60



APCD TVR

Federal Title V report review

APCD1999-SITE-10882

Otay Mesa Energy Center LLC

03/27/2020 12:22:07 PM

3141499

$560.00



APCD TVR

Federal Title V report review

APCD1999-SITE-10882

Otay Mesa Energy Center LLC

05/06/2020 09:35:12 AM

3141499



$560.00

APCD TVR

Federal Title V report review

APCD2000-SITE-03752

Chula Vista Energy Center LLC

03/27/202011:29:38 AM

3141449

$567.00



APCD TVR

Federal Title V report review

APCD2000-SITE-03752

Chula Vista Energy Center LLC

04/28/2020 11:53:04 AM

3141449



$567.00

APCD TVR

Federal Title V report review

APCD2000-SITE-03769

Escondido Energy Center LLC

03/27/2020 12:00:23 PM

3141475

$403.20



APCD TVR

Federal Title V report review

APCD2000-SITE-03769

Escondido Energy Center LLC

04/28/202011:57:23 AM

3141475



$403.20

APCD TVR

Federal Title V report review

APCD2001-SITE-04087

SDG&E Cuyamaca Peak Energy Plant

03/27/2020 12:45:57 PM

3141522

$301.00



APCD_TVR

Federal Title V report review

-------
APCD2001-SITE-04087

SDG&E Cuyamaca Peak Energy Plant

04/27/2020 09:14:17 AM

3141522



$301.00

APCD TVR

Federal Title V report review

APCD2001-SITE-04089

CalPeak Power Enterprise LLC

03/27/202011:23:23 AM

3141446

$1,633.80



APCD TVR

Federal Title V report review

APCD2001-SITE-04089

CalPeak Power Enterprise LLC

04/22/2020 11:41:03 AM

3141446



$1,633.80

APCD TVR

Federal Title V report review

APCD2001-SITE-04109

Larkspur Energy Facility

03/27/2020 12:59:45 PM

3141539

$294.00



APCD TVR

Federal Title V report review

APCD2001-SITE-04109

Larkspur Energy Facility

03/27/2020 01:12:46 PM

3141551

$210.00



APCD TVR

Federal Title V report review

APCD2001-SITE-04109

Larkspur Energy Facility

04/13/2020 09:49:27 AM

3146402

-$294.00



APCD TVR

Federal Title V report review

APCD2001-SITE-04109

Larkspur Energy Facility

04/29/2020 09:15:39 AM

3141551



$210.00

APCD TVR

Federal Title V report review

APCD2001-SITE-04211

CalPeak Power Border LLC

03/27/202011:17:15 AM

3141443

$560.00



APCD TVR

Federal Title V report review

APCD2001-SITE-04211

CalPeak Power Border LLC

04/22/202011:39:12 AM

3141443



$560.00

APCD TVR

Federal Title V report review

APCD2001-SITE-04276

SDG&E Palomar Energy Center

03/27/2020 12:28:17 PM

3141503

$399.00



APCD TVR

Federal Title V report review

APCD2001-SITE-04276

SDG&E Palomar Energy Center

04/27/2020 09:13:30 AM

3141503



$399.00

APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

03/27/2020 12:12:55 PM

3141490

$483.00



APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

04/21/2020 11:42:08 AM

3141490



$483.00

APCD TVR

Federal Title V report review

APCD2009-SITE-06554

El Cajon Energy LLC

03/27/202011:55:19 AM

3141472

$728.00



APCD TVR

Federal Title V report review

APCD2009-SITE-06554

El Cajon Energy LLC

05/04/2020 11:44:47 AM

3141472



$728.00

APCD TVR

Federal Title V report review

APCD2017-APP-004918

Applied Energy LLC MCRD

01/29/2020 11:33:37 AM

3101180

$1,049.10



APCD TIV

Title V

APCD2017-APP-004918

Applied Energy LLC MCRD

01/29/2020 11:34:50 AM

3101180



$1,049.10

APCD_TIV

Title V

Tota I	$18,503.10	$17,974.60

-------
SITE RECORD ID

APP RECORD ID

FACILITY

INVOICE NBR

TRANSACTION DATE

TRANSACTION AMOUNT

FEE SCHEDULE

FEE ITEM CODE

FEE DESCRIPTION

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2697316

07/27/2018

$616.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2697315

07/27/2018

$616.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2697915

07/30/2018

$616.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2700730

08/03/2018

$1,232.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2700332

08/03/2018

$924.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2728299

09/12/2018

$616.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-00007

APCD2017-APP-004918

Applied Energy LLC MCRD

2728300

09/12/2018

$616.00

APCD 94

APCD 94B

Assistant Engineer

APCD1976-SITE-01130

APCD2019-APP-005862

Solar Turbines Incorporated

2930221

06/03/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1976-SITE-02083

APCD2018-APP-005411

City of San Diego-Metropolitan Wastewater Dept

2684390

07/12/2018

$385.70

APCD 94

APCD 94D

Senior Engineer

APCD1976-SITE-02083

APCD2018-APP-005411

City of San Diego-Metropolitan Wastewater Dept

2759384

10/22/2018

$2.30

APCD MISC

APCD APP MIS

Labor charges to close Trust Account remaining balance [Calc]

APCD1978-SITE-02756

APCD2018-APP-005519

Fleet Readiness Center Southwest

2735142

09/17/2018

$154.00

APCD 94

APCD 94B

Assistant Engineer

APCD1979-SITE-00623

APCD2018-APP-005423

SFPP, LP

2700533

08/03/2018

$79.20

APCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

APCD2018-APP-005423

SFPP, LP

2717463

08/20/2018

$4.80

APCD TIV

APCD TIV

Title V

APCD1979-SITE-00623

APCD2018-APP-005535

SFPP, LP

2724907

09/05/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1979-SITE-00623

APCD2018-APP-005535

SFPP, LP

2775692

11/15/2018

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1979-SITE-00623

APCD2018-APP-005535

SFPP, LP

2823790

01/23/2019

$1.00

APCD MISC

APCD APP MIS

Labor charges to close Trust Account remaining balance [Calc]

APCD1980-SITE-02754

APCD2017-APP-004903

USN Air Station NORIS

2806095

12/27/2018

$177.00

APCD 94

APCD 94D

Senior Engineer

APCD1981-SITE-00250

APCD2018-APP-005297

APPLIED ENERGY LLC NAVAL STATION

2824812

01/25/2019

$170.00

APCD 94

APCD 94C

Associate Engineer

APCD1981-SITE-00250

APCD2018-APP-005297

APPLIED ENERGY LLC NAVAL STATION

2825221

01/25/2019

$255.00

APCD 94

APCD 94C

Associate Engineer

APCD1982-SITE-00195

APCD2019-APP-005818

Carlsbad Energy Center LLC

2889669

05/02/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1984-SITE-03438

APCD2019-APP-005733

Otay Landfill Gas, LLC

2847630

02/27/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

2717063

08/17/2018

$308.00

APCD 94

APCD 94B

Assistant Engineer

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

2728332

09/12/2018

$462.00

APCD 94

APCD 94B

Assistant Engineer

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

2728329

09/12/2018

$308.00

APCD 94

APCD 94B

Assistant Engineer

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

2729091

09/13/2018

$46.20

APCD 94

APCD 94B

Assistant Engineer

APCD1988-SITE-00024

APCD2018-APP-005363

Applied Energy LLC North Island

2729092

09/13/2018

$261.80

APCD 94

APCD 94B

Assistant Engineer

APCD1989-SITE-07515

APCD2019-APP-005736

City of San Diego/Environmental Svc Dept/Miramar Landfill

2848337

02/28/2019

$6.67

APCD MISC

APCD CONVEN

2.2% Convenience Fee

APCD1989-SITE-07515

APCD2019-APP-005736

City of San Diego/Environmental Svc Dept/Miramar Landfill

2848343

02/28/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1989-SITE-07515

APCD2019-APP-005745

City of San Diego Environmental Services Dept

2850036

03/05/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1995-SITE-09138

APCD2019-APP-005696

SDG&E - Miramar Energy Facility

2822339

01/17/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1995-SITE-09138

APCD2019-APP-005696

SDG&E - Miramar Energy Facility

2822333

01/17/2019

$11.02

APCD MISC

APCD CONVEN

2.2% Convenience Fee

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2681678

07/06/2018

$336.60

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2693224

07/18/2018

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2693858

07/19/2018

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2694445

07/20/2018

$118.80

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2695872

07/24/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2695870

07/24/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2702052

08/07/2018

$297.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2702915

08/08/2018

$297.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2709542

08/14/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2723192

08/31/2018

$495.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2723194

08/31/2018

$297.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2724533

09/05/2018

$198.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2735171

09/17/2018

$118.80

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2735056

09/17/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2853403

03/07/2019

$792.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2853388

03/07/2019

$792.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2853468

03/07/2019

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2749252

04/10/2019

$693.40

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2749252

04/10/2019

$176.38

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1996-SITE-09688

APCD2018-APP-005414

City of San Diego Public Utilities Department

2873409

04/10/2019

$1,299.20

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005666

City of San Diego Public Utilities Department

2805535

12/24/2018

$13.33

APCD MISC

APCD CONVEN

2.2% Convenience Fee

APCD1996-SITE-09688

APCD2018-APP-005666

City of San Diego Public Utilities Department

2853746

03/07/2019

$594.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09688

APCD2018-APP-005666

City of San Diego Public Utilities Department

2947354

06/17/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2697038

07/26/2018

$891.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2698140

07/30/2018

$495.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2698882

07/31/2018

$495.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2699687

08/02/2018

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2709520

08/14/2018

$118.80

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2709877

08/15/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2721401

08/29/2018

$237.60

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2722170

08/30/2018

$198.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2735052

09/17/2018

$99.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2735051

09/17/2018

$99.00

APCD_94

APCD_94D

Senior Engineer

-------
APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2735903

09/18/2018

$118.80

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2853517

03/07/2019

$792.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2853522

03/07/2019

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2749253

04/10/2019

$185.42

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2873286

04/10/2019

$142.10

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005413

City of San Diego Environmental Services Dept

2749253

04/10/2019

$344.60

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD1996-SITE-09779

APCD2018-APP-005637

City of San Diego/Environmental Svc Dept

2787501

12/04/2018

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD1996-SITE-09779

APCD2018-APP-005637

City of San Diego/Environmental Svc Dept

2853763

03/07/2019

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2018-APP-005637

City of San Diego/Environmental Svc Dept

2853764

03/07/2019

$396.00

APCD 94

APCD 94D

Senior Engineer

APCD1996-SITE-09779

APCD2019-APP-005735

City of San Diego Environmental Services Dept

2848323

02/28/2019

$6.67

APCD MISC

APCD CONVEN

2.2% Convenience Fee

APCD1996-SITE-09779

APCD2019-APP-005735

City of San Diego Environmental Services Dept

2848345

02/28/2019

$105.00

APCD MISC

APCD NBF

New Application Base Fee [FF]

APCD2000-SITE-03769

APCD2017-APP-005203

Escondido Energy Center LLC

2693458

07/18/2018

$188.44

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD2000-SITE-03769

APCD2017-APP-005203

Escondido Energy Center LLC

2693458

07/18/2018

$379.80

APCD MISC

APCD LGL NOT

Reimbursement of cost of Legal Notices

APCD2000-SITE-03769

APCD2017-APP-005203

Escondido Energy Center LLC

2693458

07/18/2018

$2,760.80

APCD 94

APCD 94D

Senior Engineer

APCD2001-SITE-04089

APCD2018-APP-005385

CalPeak Power - Enterprise LLC

2823317

01/22/2019

$2.60

APCD MISC

APCD APP MIS

Labor charges to close Trust Account remaining balance [Calc]

APCD2001-SITE-04211

APCD2018-APP-005384

CalPeak Power Border LLC

2759277

10/22/2018

$2.60

APCD MISC

APCD APP MIS

Labor charges to close Trust Account remaining balance [Calc]



APCD2019-APP-005685

El Cajon Energy, LLC

2820534

01/15/2019

$105.00

APCD_MISC

APCD_NBF

New Application Base Fee [FF]

Total	$26,465.43

-------
SITE RECORD ID

FACILITY

TRAN DATE

INVOICE NBR

COST/INVOICED

REVENUE/PAYMENT

FEE ITEM

FEE DESCTIPTION

APCD1976-SITE-00007

Applied Energy LLC MCRD

02/07/2019 08:43:44 AM

2831058

$478.50



APCD TVR

Federal Title V report review

APCD1976-SITE-00007

Applied Energy LLC MCRD

03/07/2019 09:59:19 AM

2831058



$478.50

APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

02/07/2019 09:06:33 AM

2831092

$599.20



APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

02/07/2019 12:53:17 PM

2831314

$1,286.60



APCD TVR

Federal Title V report review

APCD1976-SITE-00145

General Dynamics NASSCO

02/07/2019 12:58:46 PM

2831322

-$599.20



APCD TVR

Federal Title V report review

APCD1976-SITE-01130

Solar Turbines Inc

02/07/2019 09:09:02 AM

2831094

$163.10



APCD TVR

Federal Title V report review

APCD1976-SITE-01130

Solar Turbines Inc

02/28/2019 09:57:08 AM

2831094



$163.10

APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

02/07/2019 09:10:25 AM

2831096

$211.60



APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

02/07/2019 09:12:19 AM

2831098

$475.50



APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

02/07/2019 09:13:56 AM

2831099

-$475.50



APCD TVR

Federal Title V report review

APCD1976-SITE-02083

City of San Diego-Metropolitan Wastewater Dept

03/18/2019 11:09:34 AM

2831096



$211.60

APCD TVR

Federal Title V report review

APCD1978-SITE-02756

Navy Fleet Readiness Center Southwest

02/07/2019 09:18:21 AM

2831106

$475.50



APCD TVR

Federal Title V report review

APCD1978-SITE-02756

Navy Fleet Readiness Center Southwest

03/13/2019 01:28:49 PM

2831106



$475.50

APCD TVR

Federal Title V report review

APCD1978-SITE-02756

Navy Fleet Readiness Center Southwest

05/10/2019 10:53:26 AM

2577248



$297.70

APCD TVR

Federal Title V report review

APCD1979-SITE-00623

SFPPLP

02/07/2019 09:19:40 AM

2831108

$302.50



APCD TVR

Federal Title V report review

APCD1979-SITE-00623

SFPPLP

03/06/2019 12:59:18 PM

2831108



$302.50

APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

02/07/2019 09:21:45 AM

2831109

$45,030.00



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

02/07/2019 09:22:50 AM

2831110

$302.50



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

02/07/2019 09:23:58 AM

2831111

-$45,030.00



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

02/07/2019 09:25:04 AM

2831112

-$302.50



APCD TVR

Federal Title V report review

APCD1980-SITE-02754

Commander Navy Region SW

02/07/2019 09:25:52 AM

2831113

$450.30



APCD TVR

Federal Title V report review

APCD1981-SITE-00250



02/07/2019 09:29:01 AM

2831115

$302.00



APCD TVR

Federal Title V report review

APCD1981-SITE-00250



02/07/2019 01:05:45 PM

2831324

$588.90



APCD TVR

Federal Title V report review

APCD1981-SITE-00250



02/07/2019 01:06:52 PM

2831326

-$302.00



APCD TVR

Federal Title V report review

APCD1981-SITE-00250



03/07/2019 10:00:30 AM

2831324



$588.90

APCD TVR

Federal Title V report review

APCD1982-SITE-00195

Cabrillo Power LLC

06/24/2019 01:26:20 PM

2577398



$376.60

APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

02/07/2019 09:46:06 AM

2831134

$139.10



APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

02/07/2019 10:53:27 AM

2831210

$1,354.30



APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

02/07/2019 10:55:54 AM

2831213

-$139.10



APCD TVR

Federal Title V report review

APCD1984-SITE-03438

Otay Landfill Gas LLC

02/27/2019 01:32:39 PM

2831210



$1,354.30

APCD TVR

Federal Title V report review

APCD1989-SITE-03596

Sycamore Landfill Inc

02/07/2019 10:59:18 AM

2831217

$529.00



APCD TVR

Federal Title V report review

APCD1989-SITE-03596

Sycamore Landfill Inc

03/11/2019 12:59:43 PM

2831217



$529.00

APCD TVR

Federal Title V report review

APCD1989-SITE-07494

Otay Landfill Inc

02/07/2019 11:02:54 AM

2831222

$597.80



APCD TVR

Federal Title V report review

APCD1989-SITE-07494

Otay Landfill Inc

03/11/2019 12:53:59 PM

2831222



$597.80

APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

02/07/2019 11:11:15 AM

2831234

$1,065.30



APCD TVR

Federal Title V report review

APCD1989-SITE-07515

City of San Diego/Environmental Svc Dept/Miramar Landfill

03/18/2019 11:07:56 AM

2831234



$1,065.30

APCD TVR

Federal Title V report review

APCD1990-SITE-03325

SD Co of Pub Wks San Marcos Landfill

02/07/2019 01:34:43 PM

2831351

$156.00



APCD TVR

Federal Title V report review

APCD1990-SITE-03325

SD Co of Pub Wks San Marcos Landfill

03/11/2019 01:23:33 PM

2831351



$156.00

APCD TVR

Federal Title V report review

APCD1992-SITE-08447

Goal Line LP

02/07/2019 01:37:26 PM

2831353

$793.20



APCD TVR

Federal Title V report review

APCD1992-SITE-08447

Goal Line LP

03/06/2019 01:00:23 PM

2831353



$793.20

APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

02/07/2019 01:40:10 PM

2831356

$402.90



APCD TVR

Federal Title V report review

APCD1994-SITE-07517

SD City of Metro Wastewater Biosolids Center

03/21/2019 01:06:38 PM

2831356



$402.90

APCD TVR

Federal Title V report review

APCD1995-SITE-09138

SDG&E

02/07/2019 01:42:24 PM

2831359

$189.00



APCD TVR

Federal Title V report review

APCD1995-SITE-09138

SDG&E

03/04/2019 01:13:09 PM

2831359



$189.00

APCD TVR

Federal Title V report review

APCD1996-SITE-09688

City of San Diego Public Utilities Department

02/07/2019 01:44:22 PM

2831361

$465.80



APCD TVR

Federal Title V report review

APCD1996-SITE-09688

City of San Diego Public Utilities Department

03/21/2019 01:07:51 PM

2831361



$465.80

APCD TVR

Federal Title V report review

APCD1996-SITE-09778

Minnesota Methane LLC San Diego Miramar Facility

02/07/2019 01:47:14 PM

2831363

$430.60



APCD TVR

Federal Title V report review

APCD1996-SITE-09778

Minnesota Methane LLC San Diego Miramar Facility

05/08/2019 01:08:07 PM

2831363



$430.60

APCD_TVR

Federal Title V report review

-------
APCD1996-SITE-09779

City of San Diego Environmental Services Dept

02/07/2019 01:49:57 PM

2831365

$687.30



APCD TVR

Federal Title V report review

APCD1996-SITE-09779

City of San Diego Environmental Services Dept

03/21/2019 01:09:05 PM

2831365



$687.30

APCD TVR

Federal Title V report review

APCD2000-SITE-03752

Chula Vista Energy Center LLC

02/07/2019 01:52:11 PM

2831368

$554.00



APCD TVR

Federal Title V report review

APCD2000-SITE-03752

Chula Vista Energy Center LLC

03/04/2019 01:35:44 PM

2831368



$554.00

APCD TVR

Federal Title V report review

APCD2000-SITE-03769

Escondido Energy Center LLC

02/07/2019 01:53:59 PM

2831369

$437.90



APCD TVR

Federal Title V report review

APCD2000-SITE-03769

Escondido Energy Center LLC

03/04/2019 01:34:29 PM

2831369



$437.90

APCD TVR

Federal Title V report review

APCD2001-SITE-04087

SDG&E Cuyamaca Peak Energy Plant

02/07/2019 01:56:30 PM

2831371

$279.60



APCD TVR

Federal Title V report review

APCD2001-SITE-04087

SDG&E Cuyamaca Peak Energy Plant

03/04/2019 01:10:31 PM

2831371



$279.60

APCD TVR

Federal Title V report review

APCD2001-SITE-04089

CalPeak Power Enterprise LLC

02/07/2019 01:58:31 PM

2831374

$135.90



APCD TVR

Federal Title V report review

APCD2001-SITE-04089

CalPeak Power Enterprise LLC

03/07/2019 10:06:30 AM

2831374



$135.90

APCD TVR

Federal Title V report review

APCD2001-SITE-04109

Larkspur Energy Facility

03/14/2019 11:22:16 AM

2579272



$166.20

APCD TVR

Federal Title V report review

APCD2001-SITE-04211

CalPeak Power Border LLC

02/07/2019 02:02:17 PM

2831378

$785.20



APCD TVR

Federal Title V report review

APCD2001-SITE-04211

CalPeak Power Border LLC

03/07/2019 10:06:30 AM

2831378



$785.20

APCD TVR

Federal Title V report review

APCD2001-SITE-04276

SDG&E Palomar Energy Center

02/07/2019 02:03:53 PM

2831379

$437.90



APCD TVR

Federal Title V report review

APCD2001-SITE-04276

SDG&E Palomar Energy Center

03/04/2019 01:08:34 PM

2831379



$437.90

APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

02/07/2019 02:05:28 PM

2831380

$541.50



APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

02/07/2019 02:06:59 PM

2831382

$1,284.20



APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

02/08/2019 11:22:32 AM

2831828

-$1,284.20



APCD TVR

Federal Title V report review

APCD2007-SITE-06289

Orange Grove Energy LP

03/18/2019 01:03:48 PM

2831380



$541.50

APCD TVR

Federal Title V report review

APCD2009-SITE-06554

El Cajon Energy LLC

02/08/2019 10:52:37 AM

2831802

$1,284.20



APCD TVR

Federal Title V report review

APCD2009-SITE-06554

El Cajon Energy LLC

03/01/2019 02:46:57 PM

2831802



$1,284.20

APCD TVR

Federal Title V report review

APCD2018-APP-005423

SFPP, LP

08/20/2018 08:55:12 AM

2717463

$4.80



APCD TIV

Title V

APCD2018-APP-005423

SFPP, LP

08/20/2018 08:55:49 AM

2717463



$4.80

APCD_TIV

Title V

Tota I	$15,089.20	$14,192.80

-------
Appendix G. SDAPCD Record Retention Schedule

Page 55 of 59

-------
Retention Policy Schedule Report for Owning Department: APCD

09/09/2019

Series

Description

Retention Time Frame

File Number

Authority Code

Trusted System

Ownina Deot

ADMIN - APCD COMMITTEE
FILES

Internal/external advisory a committee, MT meetings, CAPCOA
files. Board Res 11-0159 (Vital - No) (Historical - No) (Security -
Sensitive)

2 years

Operational-3100-115

GC 26205.1

No

APCD

ADMIN-SPECIAL PROJECT
RECORDS

Departmental documents on any special projects. Board Res 11-
0159 (Vital - No) (Historical - No) (Security - Sensitive)

After Completion +5 Years

Ad m i n istrative-2000-119

GC 26205.1

No

APCD

COM-AIR POLLUTION
CONTROL HEARING BOARD
RECORDS

Staff files involving hearing board matters including
correspondence and research, notes, inspections reports and
Variances and Petitions. Board Res 11-0159 (Vital - No) (Historical
- No) (Security - Sensitive)

After Completion +7 Years

Operational-2000-101

GC 26205.1

Yes

APCD

COM-ENFORCEMENT
REPORTING AND
MONITORING RECORDS

Potential violations list, emission standards violations (HS Code
42706), CEM reports, cooling tower notification & registrations.
Burn program: permissive burn report permits. Title V: Annual
Certification, semi-annual records & monitoring, deviation reports,
correspondence. NESHAP reports, ATCM reports. HS 42406,
42409,13CCR2450 et.seq. 40CFR Pt.31.42, 40CFR Pt.51 et seq.
40CFR Pt. 61 40 CFR Pt. 70 et. (Vital - No) (Historical - No)
(Security - Open to Public)

5 years

Ad m i n istrative-13000-138

GC 26205.1

Yes

APCD

COM-

INSPECTION/INVESTIGATION
RECORDS, PORTABLE
EQUIPMENT REGISTRATION
PROGRAM (PERP) ASBESTOS
RECORDS AND VAPOR
RECOVERY RECORDS

Compliance inspection reports (excluding complaint
investigations), Portable Equipment Registration Program (PERP),
inspection fees, district registration program reports, breakdown
reports, bulk terminal notifications, asbestos test results, asbestos
notifications and respirator trainings records, vapor recovery test
results and notifications. Board Res 11-0159 (Vital - No)

(Historical - No) (Security- Open to Public)

5 years

Ad m i n istrative-2000-124

GC 26205.1

Yes

APCD

COM-NOTICE TO COMPLY,
NOTICE OF VIOLATION FILES,
COMPLAINT RECORDS

Notice to comply/Notice of Violation NTC/NOV files. Complaint
inspection reports and log sheets. Board Res 11-0159 (Vital - No)
(Historical - No) (Security - Confidential)

After Completion +7 Years

Ad m i n istrative-13000-104

GC 26205.1

Yes

APCD

ENG-EMISSION INVENTORY
TOXIC HOT SPOTS NON HRA

Includes emission statements, correspondence, source test data,
data requests, data submitted by facility, Trade Secret
information submitted for emission inventory and non-HRA Hot
Spots documents Board Res 11-0159
(Vital - No) (Historical - No) (Security - Confidential)

8 years

Ad m i n istrative-12000-106

GC 26205.1

Yes

APCD

Page 1 of 5

-------
Retention Policy Schedule Report for Owning Department: APCD

09/09/2019

Series

Description

Retention Time Frame

File Number

Authority Code

Trusted System

Ownina Dept

ENG-EMISSION REDUCTION
CREDIT (ERC) BANKING

Emission Reduction Credit (ERC), ERC Transfers submitted for
emission inventory and Trade Secret Information. Surrendered
means that entire amount of the originally issued ERC has been
surrendered to the District and that no amount is left. (Vital - No)
(Historical - No) (Security - Confidential)

After Surrender +7 Years

Fiscal-1000-107

GC 26205.1

Yes

APCD

ENG-PERMIT FILES

Incl but not limited to App Records, Complete-Incomplete Letters,
Relevant Correspondence,

Public Notification, Eng Evals (signed by the Senior eng), BACT
Analysis, HRA, AQIA, Calculations, Authority to Construct, Field
inspection rpts and pictures, VR test results, Engineer Compliance
docs, Startup Authorization, Hearing Board Decisions, Lead
agency CEQA docs, Title V docs (including 502(b)(10)) and Trade
Secret information.

(Vital - No) (Historical - No) (Security - Confidential)

After Permit is Retired +5
Years

Operational-3100-140

GC 26205.1

Yes

APCD

ENG-TOXIC HOT SPOTS HRA

Toxic Hot Spots HRAs and associated documents:

Public Notification
Risk Reduction
Inventory documents

HRA supporting documents Board Res. 11-0159 (Vital - No)
(Historical - No) (Security - Confidential)

After Obsolescence +4 Years

Ad m i n istrative-12000-104

GC 26205.1

Yes

APCD

MTS - CYLINDER RECEIVING

The APCD receives hazardous materials (compressed gases).
(Vital - No) (Historical - No) (Security - Open to Public)

3 years

Operational-6100-109

49CFR172.201(e)

No

APCD

MTS - CYLINDER SHIPPING

The APCD ships hazardous materials (compressed gases). (Vital -
No) (Historical - No) (Security - Open to Public)

3 years

Operational-6100-115

49CFR172.201(e)

No

APCD

MTS - DEPT OF HEALTH
FACILITY PERMIT

DEH permit for businesses that generate hazardous waste which
must be regulated for public safety. (Vital - No) (Historical - No)
(Security - Open to Public)

After Expiration of Permit

Operational-5300-106

GC 26205.1

No

APCD

MTS - EPA ID VERIFICATION
REPORTS

Submit chemical information regarding hazardous materials and
waste to EPA. (Vital - No) (Hisotrical - No) (Security - Open to
Public)

After Expiration of Report

Operational-5300-107

GC 26205.1

No

APCD

MTS - FIRE INSPECTION
REPORTS

Annual inspections by the fire department to assess and mitigate
potential fire and life-safety hazards. (Vital - No) (Historical - No)
(Security - Open to Public)

3 years

Operational-6100-124

GC 26205.1

No

APCD

Page 2 of 5

-------
Retention Policy Schedule Report for Owning Department: APCD

09/09/2019

Series

Description

Retention Time Frame

File Number

Authority Code

Trusted System

Ownina Dept

MTS - FORECASTING AND
SMOKE MANAGEMENT

Forecast files and smoke management plans. 17CCR80145 (Vital
- Yes) (Historical - No) (Security - Open to Public)

25 years

Operational-3100-118

GC 26205.1

No

APCD

MTS - HAZARDOUS WASTE
MANIFESTS

A shipping document that tracks hazardous waste from the point
of generation to ultimate disposal. This system is commonly
referred to as the "cradle to grave" system of hazardous waste
management. 22 CCR 66262.40 (Vital - No) (Historical - No)
(Security - Open to Public)

5 years

Operational-6100-135

40CFR262.40(a)

No

APCD

MTS - HAZMAT INSPECTION
REPORTS

DEH/Hazmat inspects all laboratory safety operations with respect
to Federal, State and Local requirements every 3 years. (Vital -
No) (Historical - No) (Security - Open to Public)

3 years

Operational-6100-134

GC 26205.1

No

APCD

MTS - HOOD INSPECTION

DEH inspects the hoods annualyy by measuring capture or fee
velocity and smoke testing (Vital - No) (Historical - No) (Security -
Open to Public)

After Equipment Retires +5
Years

Operational-6100-138

8CCR 5154.1(c)(2)
(C)

No

APCD

MTS - INDUSTRIAL
DISCHARGE REPORTS

City of San Diego Discharge Permit of industrial wastewater
including sampling methods, dates, and times, dates of analyses
and methods used, City staff names performing tests. (Vital - No)
(Historical - No) (Security - Open to Public)

5 years

Operational-6100-139

40CFR403.12(o)

No

APCD

MTS - LABORATORY
INSPECTIONS

Records of scheduled and periodic inspections required by
subsection (a)(4) to identify unsafe conditions and work practices,
including person(s) conducting the inspection, the unsafe
conditions and work practices that have been identified and action
taken to correct the identified unsafe conditions and work
practices. (Vital - No) (Historical - No) (Security - Open to
Public)

2 years

Operational-6100-141

8CCR3203(b)(l)

No

APCD

MTS - LABORATORY RECORDS

Laboratory records and QAQC Reports; data generated from
laboratory instruments collected from field samplers. (Vital - No)
(Historical - No) (Security - Open to Public)

10 years

Operational-6100-142

GC 26205.1

No

APCD

MTS - LABORATORY SAFETY
TRAINING

Training and enforcement of laboratory safety policies, safety
review of experimental designs; handling hazardous materials and
waste and the use of Personal Protective Equipment (PPE). (Vital
- No) (Historical - No) (Security - Open to Public)

After Termination +3 Years

Ad m i n istrative-12000-103

40CFR265.16(e)

No

APCD

Page 3 of 5

-------
Retention Policy Schedule Report for Owning Department: APCD

09/09/2019

Series

Description

Retention Time Frame

File Number

Authority Code

Trusted System

Ownina Dept

MTS - LIQUID NITROGEN
TANK INSPECTION REPORTS

Recommended maintenance schedule for periodic
inspections/examinations of compressed gas cylinders or related
equipment. (Vital - No) (Historical - No) (Security - No)

5 years

Operational-6100-149

GC 26205.1

No

APCD

MTS - METEOROLOGY
RECORDS

Non transport meteorological files Board Res 11-0159 (Vital - Yes)
(Historical - Yes) (Security - Open to Public)

5 years

Operational-3100-120

GC 26205.1

No

APCD

MTS - MONITORING
EQUIPMENT RECORDS

Station and equipment logs, maintenance records. Board Res 11-
0159 (Vital - Yes) (Historical - Yes) (Security - Open to Public)

After Disposal of Equipment
+3 Years

Operational-3100-117

GC 26205.1

No

APCD

MTS - SOURCE TEST
RECORDS

Source Test Reports including Application and Renewal Reports
(Vital - No) (Historical - No) (Security - Confidential)

After Equipment Retires +5
Years

Operational-3100-113

GC 26205.1

Yes

APCD

MTS - TRANSPORT
ASSESSMENT RECORDS

Transport Assessment analysis files. Board Res 11-0159 (Vital -
Yes) (Historical - Yes) (Security - Open to Public)

12 years

Operational-3100-119

GC 26205.1

No

APCD

PIO-SMALL BUSINESS
ASSISTANCE PROGRAM
RECORDS

SBA Program files (Vital - No) (Historical - No) (Security -
Sensitive)

After Completion +3 Years

Ad m i n istrative-2000-105

GC 26205.1

No

APCD

PLANNING & INCENTIVES -
AIR QUALITY PLAN RECORDS

Regional Air Quality Strategy (RAQ's) includes final plans and
updates, (IS, NOD, Neg Dec, NOP, EIR etc.) final feasibility
studies for control measures, and yearly published list of
regulations schedules for adoption. State Implementation Plan
(SIP) includes all submittals. Board Res 11-0159 (Vital - No)
(Historical - No) (Security - Open to Public)

Permanent

Operational-3100-112

GC 26205.1

Yes

APCD

PLANNING & INCENTIVES -
INDIRECT SOURCES RECORDS

Meeting notes, reports, research, photos, journals, misc meeting
agendas, presentations. Board Res 11-0159 (Vital - No) (Historical
- No) (Security - Open to Public)

After Completion +7 Years

Ad m i n istrative-2000-109

GC26205.1

Yes

APCD

PLANNING & INCENTIVES-
CARL MOYER RECORDS

Project records, including Lawn and Garden equipment and
including program administration records. Board Res 11-0159 Carl
Moyer Program Guidelines. (Vital - No) (Historical - No) (Security
- Confidential)

After Completion +3 Years

Fiscal-2500-102

GC 26205.1

Yes

APCD

PLANNING & INCENTIVES-
CARL MOYER VOUCHER
INCENTIVE PROGRAM VIP

Carl Moyer VIP project records. Carl Moyer Program Guidelines,
Board Res 11-0159 (Vital - No) (Historical - No) (Security -
Confidential)

After Award +5 Years

Fiscal-2500-105

GC 26205.1

Yes

APCD

Page 4 of 5

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Retention Policy Schedule Report for Owning Department: APCD

09/09/2019

Series

Description

Retention Time Frame

File Number

Authority Code

Trusted System

Ownina Dept

PLANNING & INCENTIVES-
GOODS MOVEMENTS
EMISSION REDUCTION
PROGRAM RECORDS

Goods Movements Emission Reduction Program (GMERP) project
files, original file records go to ARB after completion. GMERP
Program Guidelines Board Res 11-0159 (Vital - No) (Historical -
No) (Security - Confidential)

After Completion

Fiscal-2500-104

GC 26205.1

Yes

APCD

PLANNING & INCENTIVES-
LOW-EMISSION SCHOOL BUS
INCENTIVE PROGRAM
RECORDS

Low Emission School Bus Program (LESB) project files. LESB
Program Guide GC26205.1 Board Res 11-0159 (Vital - No)
(Historical - No) (Security - Sensitive)

After Completion +2 Years

Fiscal-2500-103

GC26205.1

Yes

APCD

PLANNING & INCENTIVES-
MITIGATION FUND RECORDS

Miscellaneous file records. (Vital - No) (Historical - No) (Security -
Confidential)

After Completion +2 Years

Fiscal-1000-117

GC 26205.1

Yes

APCD

PLANNING & INCENTIVES-
TRAFFIC ABATEMENT AIR
POLLUTION EMERGENCY
PREVENTION PLAN RECORDS

Final plans and updates. Board Res 11-0159 40 CFR51.150 et seq
(Vital - No) (Historical - No) (Security - Open to Public)

After Obsolescence +3 Years

Operational-3100-102

GC 26205.1

Yes

APCD

RULES-RULE DEVELOPMENT
RECORDS

Rulemaking files, including petitions for rule
adoption/amendments/repeal from interested persons requesting
such action, notices of proposed adoption, data and factual
information in support, comments received, final department rules
and regulations and Trade Secret and Attorney-Client Privileged
rules making files. HS40728 GC 26205.1 Board Res 11-0159 (Vital
- No) (Historical - No) (Security - Confidential)

Permanent

Operational-3100-106

HS 40728

Yes

APCD

RULES-RULE DEVELOPMENT
REFERENCE FILES

Memos, drafts, transmittal letters not required per to be retained
by HS40728 GC26205.1 Board Res 11-0159 (Vital - No) (Historical
- No) (Security - Open to Public)

After Obsolescence +2 Years

Ad m i n istrative-2000-113

GC 26205.1

Yes

APCD

Page 5 of 5

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Appendix H. Engineering Division Manual of Operating Procedures

Page 56 of 59

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Engineering Division
Manual of Procedures

Version 8.01

San Diego Air Pollution Control District
10124 Old Grove Road
San Diego, CA 92123

March 2022

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1.	GENERAL ENGINEERING DIVISION PROCEDURES	6

1.1	Public Information Requests	6

1.2	Media Contacts (July 2021)	6

1.3	Safety Program	6

1.4	Customer Service Survey Forms	6

1.5	Employee Recognition and Awards Program (revised July 2012)	7

1.6	Trade Secret" Designation (January 8,2004, Tom Weeks/Terry Dutton)	8

1.7	Annual Review of Permits (Tom Weeks, April 2008)	 11

1.8	Notice Procedure for Permit Condition Changes (Tom Weeks, April 2008)	 13

1.9	Customer Service for Phone and Walk-In Customers (Tom Weeks, May, 2010, Revised March 2013)... 15

1.10	Expectations for engineers working on permit applications	15

2.	PERMIT APPLICATION PROCESSING - GENERAL	17

2.1	Early Assistance/Pre-Application Procedures (Mike Lake, August 13,1993)	 17

2.2	CEQA	21

2.3	Application Schedule Management	30

2.4	Application Fiscal Management	35

2.5	BCMS Procedures	47

2.6	Reactivation of Inactive Status Permits (Tom Weeks, April 2009)	 73

2.7	Permit Process Overview (Nick Horres, October 2020)	 74

3.	REQUIREMENTS FOR ISSUING AUTHORITIES TO CONSTRUCT (A/CS)	81

3.1	Permit Evaluation Guidelines (Tom Weeks, October, 2007, revised April 2009, February 2013)... 81

3.2	Requirements for Issuing A/Cs (January 7,1982)	 85

3.3	Creating and Applying Permit Conditions (October 2020, Nick Horres)	86

3.4	Issuance of Authority to Construct Letters	92

3.5	Authority to Construct Evaluation Language (February 27,1980)	 93

3.6	AB3205 Review/Notification Procedures (July 28,1989, revised April 2009, revised December
2014) 94

3.8	Rule Applicability-New Rule Adoption (January 8,1982)	 98

3.9	Expedited Application Processing Procedure (Tom Weeks, September 1,2004)	 98

3.10	Supplemental Expedited Application Processing Guidance (Tom Weeks, October 2005, modified
April 2009)	 100

3.11	Application Tracking Data (November 8,1993)	 101

3.12	Verbal Permits Not Allowed (December 18,1979)	 103

3.13	Application Cancellations (November 1990)	 103

3.14	A/C Requiring Emission Source Testing (October 20,1992)	 103

3.15	IndependentSourceTestContractor Policy (January29,1999)	 104

3.16	Emission Factors and Calculation Methodologies (Tom Weeks, October 5,2000)	 105

3.17	Permit Conditions for AB2588 Air Toxic "Hot Spots" (August 21,1989)	 105

3.18	Permit Application Checklists (May 6,1999)	 105

3.19	Agricultural Exemptions from P/Os (October 16,1974)	 106

3.20	TankTruck Exemptions from P/Os (September 29,1977)	 106

3.21	A/Cs Required for Portable Equipment (November 9,1976)	 106

3.22	Basis for Permit Conditions	106

3.23	Periodic Source Testing Guidance (Tom Weeks, June, 2011)	107

3.24	BCMS steps for issuing an A/C (October, 2020)	 108

3.25	Guidance on performing the Completeness Review (October, 2020)	 112

3.26	Documents required to be uploaded during A/C Evaluation (October, 2020)	 115

3.27	A/C Extension Requests (October, 2020)	 116

3.28	Application deadline (Rule 18) extensions	119

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Engineering Division Manual of Procedures

3.29	Application review regulatory deadlines	119

3.30	Documenting Public Comments Received	120

3.31	Suggested A/C Permit Evaluation Process	122

4.	NEW SOURCE REVIEW	123

4.1	Interpretation of Rule 20.2(d) (August 11,1986)	 123

4.2	Emissions Counting for NSR Rules (April 9,1980)	 123

4.3	Cumulative NSR Emissions Summary Sheets (December 3,2002)	 123

4.4	RACT/BACT/LAER Clearinghouse Submittals (Tom Weeks, December 3,2002, Revised 2/2012). 126

4.5	Repeal of State Offset Requirements (December 23,1998)	 126

4.6	Interpretation of Rule 20.3(d)(4)(i) Procedure Regarding Timing of Final Actions on Applications
Requiring Public Notice and a 30-Day Comment Period (November 24,1999)	 126

4.7	Air Quality Impact Modeling Referrals (September 24,1993)	 127

4.8	EPA Allowable Preconstruction Activity Guidelines (November 4,1993)	 127

4.9	EPA Notifications Required (June 8,1992)	 128

4.10	Notice of EPA of Banking Actions	129

4.11	Implementation of 1998 NSR Revisions (December 1998)	 130

5.	TOXIC NEW SOURCE REVIEW	135

5.1	Rule 1200 Toxic Screening Procedure and Screening Emission Rates (April 12,1998, modified April,
2009, modified September 2,2010, modified May 2012, modified February 2016)	135

5.2	Rule 1200 Requirements for Health Risk Assessment (Tom Weeks, February 2001, modified April
2009) 154

5.3	Supplemental Guidance For Rule 1200 HRA Review (Tom Weeks, September 2004)	 162

5.4	Rule 11(a)(6) Interpretation (Tom Weeks, November, 2010)	163

5.5	Procedure for Updating Tables in Rule 1200 and 1210	164

6.	PERMIT TO OPERATE EVALUATIONS	164

6.1	P/O Engineer Evaluation Requirements and Process (October, 2020, Nick Horres)	164

6.2	Creating Conditions for PTOs (October, 2020 Nick Horres)	166

6.3	Permit Condition Languange Guidance (October, 2020 Nick Horres)	169

6.4	Preparing a PTO in BCMS	170

6.5	Permit Streamlining (October, 2020)	 177

6.6	Denials (October 9,1981)	177

6.7	Review of Conditions by Applicants (October 2020)	 180

6.8	Applications Required for Expired Permits (April 24,1979)	 180

6.9	Documents TO BE UPLOAD PRIOR TO submitting the PTO for approval	180

7.	STARTUP AUTHORIZATION (S/A)	181

7.1	S/A Issuance (February 22,1984)	 181

7.2	Implementation Procedures for Rule 24 (July 1,1997)	 182

7.3	Equipment Deficiency Letters (February 22,1984)	 191

7.4	S/As vs. AECPs (June 18,1990)	 191

7.5	Expired S/As (October 21,1991)	191

7.6	Startup Authorization/Permitto Operate Procedures (March 29,1993)	 192

8.	TITLE V PERM ITS	193

8.1	Instructions for Title V Application	193

8.2	Instructions for Title V Engineering Evaluation Process (revised 3/2014)	 204

8.3	Title V Permit Changes and Modifications	206

8.4	Title V Program Evaluation Program Changes (Tom Weeks, November 2010)	213

9.	REGISTRATION	219

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Engineering Division Manual of Procedures

9.1	Portable Engine Permitting and Registration (November 6,2000)	 219

9.2	Procedure for Review of Applications and Issuance of Certificates of Registration (January 2008)
219

10.	BANKING	221

10.1 Banking Procedures (July 22,1986)	 221

11.	CERTIFICATE OF EXEMPTION (COE)	230

11.1 Certificate of Exemption (COE) Procedures (June 1,2000)	 230

12.	CHEMICAL SECTION PROCEDURES	235

12.1	S/A vs. Alternative Emissions Compliance Plan (AECP) (June 18,1990)	 235

12.2	Rule 66	 235

12.3	Procedures for Estimating the Vapor Pressure of VOC Mixtures (June 20,1990)	 237

12.4	Equipment Descriptions for Surface Coating Operations (February 10,1983)	 246

12.5	Streamlined Permit Process Review (June 21,1993)	 246

12.6	Rule 67.5 Applicability to Sup Casting Operations (July 9,1992)	 248

12.7	Federal Restrictions on Uses of HCFCs	248

12.8	Dry Cleaning Operations Using Silicone Siloxane	249

13.	MECHANICAL SECTION PROCEDURES	249

13.1	Rule 50 Asphalt Plant Blue Smoke (March 22,1985)	 249

13.2	Allocation of Registration Fees under Rule 12.1	249

13.3	Rule 12 Registration Application Processing (December 30,1997)	 250

13.4	Applicability of Rules 52, 53, and 54. (May 12,1999)	 251

13.5	Emergency Generators, Horsepower Used for Exemption (July 1987)	 252

13.6	Mineral Industry Emission Calculations Procedure (April 9,1996)	 252

13.7	Mineral Industry Emission Calculations Procedures (November 5,1999)	 266

13.8	Clarifications to Rule 69.2 Requirements (November 6,2000)	 268

13.9	Permitting of New Emergency Backup Generators (Mike Lake-July 6,2001, Revised December
2010)		 272

13.10	Rule 69.4.1 Requirements - New Natural Gas-Fueled Emergency Standby Engines (February 7,
2002)		 275

13.11	Startup/Commissioning Periods for Turbines and Engines (February 11,2003)	 276

13.12	Evaluation of 40 Hour Testing and Maintenance Allowance for Hospital Facilities (July 7,2007-
Tom Weeks)	278

13.13	Mobile/Portable vs. Stationary Engines - Rules 69.4 and 69.4.1 Applicability (May 17,2001- M.
Lake/T.	Morris)	278

13.14	Procedure for Review of Applications and Issuance of Certificates of Registration	280

14.	VAPOR RECOVERY SECTION PROCEDURES	281

14.1	Rule 61.3 Enforcement Policy (May 25,2000-Rosa Salcedo)	281

14.2	Rule 61.2 Transfer of Volatile Organic Compounds (VOCs) into Mobile Transport Tanks
(December 10,1979)	 282

14.3	Issuance of A/Cs and P/Os to Vapor Recovery (VR) Systems Certified by Air Resources Board
(October 24, 2000 - Rosa Salcedo)	282

14.4	Documenting VR Violations by Engineers (August 20,1979)	 282

14.5	Vapor Recovery Station Rebuilds (July 28,1994)	 283

14.6	Inspection/Maintenance Manuals at Service Stations (December 4,2001)	 283

14.7	Test Cancellation Fee (July5, 2000- Rosa Salcedo)	283

14.8	Invoicing for Reinspection (July5,2000)	 284

14.9	Applicability of Rule 1200 to Gasoline Dispensing Facilities (October 2,2003)	 286

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Engineering Division Manual of Procedures

15.	EMISSIONS INVENTORY PROCEDURES (M LUTHER, JANUARY 2021)	 287

15.2 Guide to EIS	295

16.	TOXICS "HOT SPOTS" PROCEDURES (M LUTHER,REV. MAR 2022)	 337

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1. General Engineering Division Procedures

The Engineering Division processes permit applications for new, relocated and modified
emission units as well as banking applications and applications for Title V permits. New
and modified emission units are evaluated for compliance with New Source Review
(NSR) requirements (if applicable) and specific emission standards prior to issuing an
Authority to Construct (A/C) or Permit to Operate (P/O). This manual presents guidance
and procedures to be used by Engineering Division staff in processing applications.

1.1	Public Information Requests

Reserved

1.2	Media Contacts (July 2021)

From time to time the media contacts the District to obtain information or ask questions
related to a specific facility, permit application, inspection, complaints, District rules,
regulations or programs or District policies. All media inquiries or media contacts that
you receive must be referred to the Chief and/or to the Deputy Director overseeing the
division. If you receive a phone call, email or other in person inquiries from a reporter
(TV, Radio, etc.) or other media representative, you do not need to respond to the inquiry
but please forward that request to the Chief or Deputy Director immediately.

1.3	Safety Program

1.3.1 Respiratory Protection Program
Reserved

1.3.2 Safety Shoe Policy (October 12, 2000)

The District will provide up to $90.00 for the purchase of safety shoes for Air Quality
Inspectors I and II, and all other District field staff on a yearly basis or as requested.

All safety shoes will be purchased through various vendors and require an authorization
letter from the accounting department prior to purchase.

Safety shoes must be worn at all times when work is performed that may result in foot
injury. Districts purchased safety shoes are not to be worn on personal business (March
21, 1986).

1.4 Customer Service Survey Forms

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Engineering Division Manual of Procedures

Customer service surveys will be used to ensure the satisfaction of external customers
and to recognize staff for their high level of customer service. Surveys will be used to
evaluate customer satisfaction for each of the following activities:

•	Authority to Construct Permits

•	Permits to Operate

•	Emission Inventory Reports

•

1.5 Employee Recognition and Awards Program (revised July 2012)

The Engineering Division Awards Program shall be conducted in accordance with
District Policy and the following requirements. Changes may be made to this policy at
any time by a majority vote of the Engineering Division Awards Committee with the
concurrence of the Engineering Division Chief.

A.	Engineering Awards Committee

The Committee will be comprised of senior staff of the Division.

B.	Awards

Awards will be made up to quarterly but not less than biennially. The awards will be
presented at the Division staff meeting. The cash value of awards shall be established by
Department Management. The cash value of awards may adjusted by direction of the
Director.

1)	Maximum Award

The maximum total award, per person per fiscal year, will not exceed
$1,000.00 cash or 24-hours of Employee Recognition Leave.

2)	Eligibility Standards

All employees or teams in the District are eligible for the award. Awards for
recognition shall be based strictly on performance, not on popularity,
seniority, or the number of awards previously received. However, an
employee or team shall not receive a Division and a District award for the
same event. Nominees must have demonstrated sustained high quality or
extraordinary effort in one or more of the following categories:

•	Customer/Public Service

•	Productivity

•	Achievement in Special Projects

•	Outstanding Quality/Job Well Done

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Engineering Division Manual of Procedures

•	Leadership

•	Total Involvement

•	Continuous Process Improvement

3)	Nomination and selection process

•	Only one award will be granted to an individual/team in one fiscal
year. If more than one nomination for the same person or team is
selected for an award that person/team will receive only one award and
the other nominations bearing the name of that person/team will be
removed.

•	Any member of the Engineering Division can make nominations.
Nominations shall be directed to the nominee's supervisor who will
evaluate nominations prior to submitting them to the awards
committee. Nominations may be submitted at any time during the
year. The nominations shall be performance based.

•	Committee members will individually review and evaluate the
nominations, considering the eligibility standards and score each on a
scale of 0-10. The Chief shall fill out a ranking sheet and average the
points for each candidate.

•	The Chief or a designee will present the awards.

•	Generally, all awards will be issued for the fiscal year at a Division
meeting. The Committee shall complete and submit the selection
documentation at least one week prior to the awards ceremony to
ensure monetary awards come from the current fiscal budget.

4)	Reporting

The Chief or the chiefs designee will be responsible for maintaining a record
of employees selected for awards, their accomplishments, the award they
received and the name of the person nominating the individual for the award.
This information and a copy of the nomination forms will be conveyed to the
Chief of Support Services annually for the inclusion in the annual report of
awards to the CAO.

1.6 Trade Secret" Designation (January 8, 2004, Tom Weeks/Terry
Dutton)

District Rule 176 specifies District policy with respect to information supplied to the
District. In addition, confidential communications between attorneys and their clients are
privileged and are to be protected from disclosure to anyone except authorized District or
County staff. This document specifies procedures used to manage and protect trade
secret and attorney-client information.

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Engineering Division Manual of Procedures

Identification and Justification of Trade Secrets

To facilitate segregation and protection of trade secrets, it is necessary that the
applicant/facility clearly identify and provide justification for all information claimed to
be trade secret. It is the responsibility of the District associate that receives the
information to ensure that this happens. The following statement should be used to
ensure that this occurs:

Permit Process:

Your application submittal includes information that you have identified as "trade
secret." All information claimed to be Trade Secret must be clearly identified to allow
the District to separate it from non-Trade Secret information. To identify the information
you may use a highlighter or you may physically separate all trade secret information
from the remainder of the application submittal.

Please provide a written justification for information considered confidential or "trade
secret" as required by District Rule 176. The justification should explain why the
information is "trade secret" as defined in District Rule 175(a)(3) and should be as
detailed as possible without disclosing the "trade secret", as the justification is considered
public record. With written justification, this information will be designated "trade
secret" and will be disclosed by the District only in accordance with District Rule 177(g).

Upon receipt of an application containing claimed trade secret information the permit
engineer should include these paragraphs in an "incomplete" letter when a trade secret
justification has not been provided.

Emission Inventory Process:

The following paragraphs should be included in all emission inventory request packages:

All information claimed to be Trade Secret must be clearly identified to allow the District
to separate it from non-Trade Secret information. To identify the information you may
use a highlighter or you may physically separate all trade secret information from the
remainder of the emission inventory submittal.

Please provide a written justification for information considered confidential or "trade
secret" as required by the District Rule 176. The justification should be as detailed as
possible without disclosing the "trade secret" as the justification is considered public
record. With written justification, this information will be designated "trade secret" and
will be disclosed by the District only in accordance with District Rule 177(g).

Compliance Process:

Information and/or documents labeled "trade secret" and gathered during an inspection
shall be filed in the inspector's vehicle with the field file or in the appropriate senior

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Engineering Division Manual of Procedures

inspector's office. Additionally, the "trade secret" documents shall be segregated using
red file folders. This information shall not be filed in the main filing system.

Filing and Protection of Trade Secrets

Trade secret information should be separated from non-trade secret information in
District files to ensure that it is adequately protected. This will involve use of red trade
secret file folders. The District associate that receives information claimed to be trade
secret shall separate that information into the Trade Secret File Folders. Trade Secret
File Folders shall be stored with standard permit, emissions inventory and other publicly
available folders so that all information relating to the permit, emission inventory or
compliance is easily accessible.

District associates are not expected to make judgments concerning the validity of trade
secret claims. Information that is claimed to be trade secret and provided with written
justification, should be treated as trade secret. Health and Safety Code section 44346 and
District Rule 177(g) procedures are to be followed in the event that there are public
requests for information that has been designated trade secret.

Rule 176(a) requires the District to give notice in writing that the information provided
may be released (1) to the public on request, except trade secrets which are not emissions
data, and (2) to the Federal Environmental Protection Agency, which protects trade
secrets as provided in Section 114(c) of the Clean Air Act, and in Title 40 of the Code of
Federal Regulations, Chapter 1, Part 2. To implement these provisions, the following
statement shall be included on the general permit application form and in all emission
inventory request forms:

In accordance with District Rule 176, information provided may be released (1) to the
public on request, except trade secrets which are not emissions data, and (2) to the
Federal Environmental Protection Agency, which protects trade secrets as provided in
Section 114(c) of the Clean Air Act, and in Title 40 of the Code of Federal Regulations,
Chapter 1, Part 2.

Please confer with County Counsel if EPA, ARB or another agency or County
department requests access to designated trade secret information.

Protection of Attorney Client Privilege Information

When an attorney communicates with a client, or a client communicates with an attorney
in confidence, regarding legal advice, strategy, or other legal information, the law
provides that such confidential communications are privileged, and are protected from
disclosure to non-clients. The protection applies to such communications between
District (and County) staff and County Counsel attorneys, whether the communications
are oral, electronic or in writing; notes made about privileged conversations are also
privileged.

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Engineering Division Manual of Procedures

Unauthorized disclosures of attorney-client privileged communications might cause
waiver of the privilege even for other communications, and can jeopardize the District's
or the County's interests. Therefore care must be taken to ensure against unauthorized
disclosures of attorney-client privileged communications.

To protect confidential attorney-client privileged communications, all written
confidential material should be separated from non-confidential material and placed in a
file conspicuously marked "Privileged and Confidential Attorney-Client Communication
- DO NOT MAKE PUBLIC."

When sending written communications to a County Counsel attorney, the following
statement should be included in the upper right-hand corner of the correspondence:

CONFIDENTIAL

ATTORNEY-CLIENT

COMMUNICATION

For e-mail messages to a County Counsel attorney relating to any legal matters or issues,
the subject line of the e-mail should state: "Confidential: Attorney-Client Privileged
Communication." The e-mail must be transmitted confidentially to the attorney so
that it is not also transmitted to any non-District or non-County third parties.

Never turn over or agree to turn over a confidential attorney-client privileged document,
or any part of such a document, without first consulting with County Counsel. If
disclosure of a confidential communication from County Counsel is requested or desired,
first contact County Counsel, then obtain authorization from the Director, Assistant
Director or Division Chief. Also, all references to "confidential" or "attorney-client
privileged" must be removed from any copy of material authorized to be released.

1.7 Annual Review of Permits (Tom Weeks, April 2008)

California Health and Safety Code section 42301(e) specifies that permit systems must
incorporate provisions for annual review of permits prior to renewal. Specifically the
section states that the permit systems shall:

"Require, upon annual renewal, that each permit be reviewed to determine that the permit
conditions are adequate to ensure compliance with, and the enforceability of, district rules
and regulations applicable to the article, machine, equipment or contrivance for which the
permit was issued which were in effect at the time the permit was issued or modified, or
which have subsequently been adopted and made retroactively applicable to the existing
article, machine, equipment, or contrivance, by the district board and, if the permit
conditions are not consistent, require that the permit be revised to specify the permit
conditions in accordance with all applicable rules and regulations."

The District uses four processes to accomplish this requirement: 1) condition change
requests that result from review of permit conditions by the Compliance Division during

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Engineering Division Manual of Procedures

inspections; 2) global permit reviews by fee schedule; 3) general annual permit reviews;
and 4) review of reactivated permits. These processes are described in detail below.

1)	Condition Change Requests - As part of the Compliance Division inspection process,
all permit conditions are reviewed to ensure that they reflect current requirements and are
enforceable. If a permit condition is not enforceable, or consistent with existing rules
and/or other applicable requirements, a "Request for Change of Permit Conditions" form
is prepared and submitted in accordance with Compliance Division Policy 2.18.
Condition change requests are used only for changes that are site-specific. If issues of
clarity, enforceability and consistency are identified that affect multiple permits, the
issues should be forwarded to the Permit Streamlining Committee for evaluation. These
changes are handled using the fee schedule based permit reviews (number 2 below).

2)	Fee Schedule Based Permit Reviews - Permits are reviewed periodically by a
committee consisting of representatives of the Engineering and Compliance Divisions
with input, on an as needed basis, from the Monitoring and Technical Services Division
and Permit Processing Section. Reviews are conducted on each BEC in a specific fee
schedule. The goal of periodic permit review is to address global issues that affect
numerous permits. Examples of these global issues include: changes that are necessary as
the result of revised rules, changes to address enforceability concerns or condition clarity,
changes to address new permitting or compliance policy, and changes to standardize
permit condition language and consolidate BECs. The Permit Streamlining Committee
maintains a list of the "global" issues that can be used as a guide when reviewing
conditions. Steps of the periodic review process are as follows:

A)	The Permit Streamlining workgroup (or a subcommittee of the PSL) prioritizes
fee schedules for review.

B)	BECs in fee schedule under review are consolidated where possible.

C)	Each BEC (after consolidation) is reviewed and problem conditions (including
those identified on the Global Permit Condition List) are identified.

D)	Revised versions of the problem conditions are prepared, reviewed and approved
by the workgroup.

E)	A 30-day notice letter is prepared (see "Notice Procedure for Permit Condition
Changes" below).

F)	The 30-day notice letter is mailed to each affected permit holder by the Permit
Processing Section.

G)	All issues identified within the 30-day comment period are addressed as specified
above.

H)	Revised permits are issued (with 30-day appeal rights).

3)	Annual Permit Review - Permits that are not reviewed each year as part of the
Compliance Division inspection process are scanned to ensure that they reflect current
requirements and are enforceable. This review is performed by the Engineering Division
with input, on an as needed basis, from the Monitoring and Technical Services Division
and Permit Processing Sections. The Compliance Division will initiate this review,

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Engineering Division Manual of Procedures

generally at the beginning of each fiscal year, by the preparation of a list of all permits
that were not reviewed as part of an annual compliance inspection.

4) Review of Reactivated Permits - The District has a program that allows permits to be
placed in inactive status for indefinite periods. These permits are handled differently in
the existing database system and they will not be reviewed annually using the procedures
specified above. Therefore, prior to reactivation of any permit in inactive status, these
permits must be reviewed by the Engineering Division to ensure that they reflect current
requirements, are clear, enforceable and consistent. This review will be initiated by the
Permit Processing Section, upon a request to reactivate a permit, and must be completed
prior to reactivation of the permit.

1.8 Notice Procedure for Permit Condition Changes (Tom Weeks,
April 2008)

Prior to changing conditions on any permit, it is necessary to inform the applicant of the
proposed change, in writing, and provide them with an opportunity to comment. This is
important to ensure that permittees are aware of changes to their permits, understand the
changes and are able to comply. The following procedures shall be used:

Permits with No Open Application - If the District determines that a condition or
conditions on an existing permit requires correction or modification, the permit holder
must be notified in writing of the proposed change at least 30 days prior to the condition
change.

The written notice must:

Summarize the proposed changes.

Explain the reason for the proposed changes.

Provide a draft copy of the revised P/O or revised conditions.

Allow 30-days for the permit holder to provide written comments.

List at least one District point of contact and provide phone numbers for questions

concerning the proposed changes.

State that the permittee will have the right to appeal any revised condition to the Hearing
Board.

All comments received during the comment period must be considered and addressed.
Any significant comments must be discussed with senior staff and the Chief of
Compliance and/or the Chief of Engineering as necessary. The District must respond, in
writing, to all significant comments prior to issuance of the revised Permit to Operate.
Prior to a decision to revise a permit despite objections of the permit holder, the Chief of
Engineering and/or the Chief of Compliance must be consulted. In this instance, the
permit holder should be advised of their appeal rights under Rule 25(b).

The permit engineer must thoroughly document the condition change process in the
permit file. The Compliance Division should be consulted as necessary to ensure that the

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changes do not result in subsequent compliance issues. This can be accomplished
through the standard BEC review process.

If condition changes are industry-wide and a representative of the affected industry
requests that a workshop be held, the Committee should discuss the request with the
appropriate Chief prior to taking any action on the permit revision.

Permits with an Open Application - If the District determines that an existing condition or
conditions on an existing permit for which there is an open application requires
correction or modification, the permit holder must be informed of the proposed change at
least 15 days prior to issuance of a revised A/C. This can be done by underlining or
otherwise highlighting the proposed changes on a draft A/C.

The draft A/C must:

Clearly identify any proposed change that is not associated with the application for
modification.

Explain the reason for the proposed changes.

Allow at least 15 days for the permit holder to provide written comments.

The engineer must consider all comments received during the comment period. Any
significant comments must be discussed with the senior staff and the Chief of
Compliance and/or the Chief of Engineering as necessary. The permit engineer must
respond to significant comments in writing prior to issuance of the revised Permit to
Operate. Prior to a decision to revise a permit despite objections of the permit holder, the
Chief of Engineering must be consulted. In this instance, the permit holder should be
advised of their appeal rights under Rule 25(b).

The permit engineer must thoroughly document the condition change process in the
permit file. The Compliance Division should be consulted as necessary to ensure that the
changes do not result in subsequent compliance issues. This can be accomplished
through the standard BEC review process.

Minor Condition Changes or Changes that Relax Permit Requirements - If the District
determines that a condition or conditions on an existing permit requires correction or
modification, and that correction or modification is a minor change or results in a
relaxation of the permit requirements, the permit holder must be informed in writing of
the proposed change at least 15 days prior to issuance of a revised permit.

The written notice must:

Summarize the proposed changes.

Explain the reason for the proposed changes.

List at least one District point of contact and provide phone numbers for questions
concerning the proposed changes.

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State that the permittee will have the right to appeal any revised condition to the Hearing
Board.

Any issues raised by the permittee must be discussed with the senior staff and the Chief
of Compliance and/or the Chief of Engineering as necessary.

The permit engineer must thoroughly document the condition change process in the
permit file. The Compliance Division should be consulted as necessary to ensure that the
changes do not result in subsequent compliance issues. This can be accomplished
through the standard BEC review process.

1.9	Customer Service for Phone and Walk-In Customers (Tom Weeks,
May, 2010, Revised March 2013)

Phone Calls - The designated Engineering Technician (ET) is the primary point of
contact for phone calls. If the ET is out of the office but expected to be back in within
one working day, customers will be asked to leave a voice mail message. If the ET is
unavailable for more than one working day, the receptionist will route the call to the duty
desk engineer in the appropriate section.

Walk-In Customers - The designated Engineering Technician (ET) is the primary point of
contact for walk-in customers. If the ET is on a break or at lunch, the receptionist will
leave a message with the ET and inform the customer of when they can expect service (a
maximum of 30 minutes). If the ET is unavailable or out of the office for more than 30
minutes, the receptionist will route the call to the duty desk engineer in the appropriate
section. It is not necessary for an engineer to sign off on applications that are received at
the front desk. Permit Processing staff may ask an engineer to review an application if
there are questions.

Out of Office Procedures - If any staff will be out of the office for more than one working
day they must place a message on their voicemail and include a number to call if the
caller needs immediate assistance. The ET and the duty staff must always notify their
supervisor and the receptionist when they are away from their desks. In cases where the
ET and the duty person are both out of the office, the receptionist will contact the next
person on the duty roster.

1.10	Expectations for engineers working on permit applications

Engineers provide a vital role to the District by reviewing equipment for compliance with
District Rules and Regulations and issuing permits to authorize construction and
operation of equipment. To accomplish this important task, engineers are responsible for
the following:

• Engineers should be familiar with the overall permit application review process
including all policies and procedures and steps necessary to issue permits
including properly utilizing BCMS

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•	Being familiar with regulatory deadlines for reviewing and approving projects and
ensuring these deadlines are met except in allowable situations as determined by
Engineering management and listed in these policies and procedures

•	Reviewing technical information submitted by permit applicants and determining
if sufficient information has been received to evaluate an application.

•	Contacting permit applicants to inform them of important information regarding
application review including requesting additional technical data, communicating
anticipated schedule and other important deadlines.

•	Being familiar with rules and regulations that are applicable to the equipment you
are reviewing. This includes keeping up to date on revised
regulations/requirements and being able to read regulatory language and
determine applicability of requirements to equipment

•	Being familiar with emission calculation methodology for equipment you are
reviewing including using emission factors, mass balances or concentration-based
calculations as appropriate. Engineers will need to apply engineering judgment
and make appropriate assumptions and document calculations as appropriate.

•	Preparing complete and accurate Engineering Evaluation reports including all
required sections. Engineers are expected to utilize available templates and
formats as requested by their Supervisor and employ good technical writing
techniques

•	Creating permit conditions for Authorities to Construct and Permits to Operate
that are clear, enforceable and ensure that all applicable requirements are listed on
the permit

•	Engineers are expected to accurately track their time spent reviewing applications
according to all policies for labor tracking and fiscal management. Engineers
should actively monitor funds available for applications and request invoices for
additional fees in a timely manner.

•	Conducting engineering inspections to ensure that equipment meets regulatory
requirements and documenting these inspections including recording data or
taking photos as necessary.

•	Preparing permits and permit conditions in BCMS including correctly utilizing
condition sets (CONs)

•	Documenting all steps in the review process and ensuring that all documents are
uploaded to the proper place in BCMS/Documentum at the appropriate time.
Documents should be uploaded as soon as possible after they are received or
finalized since this ensures everyone at the District has access to up-to-date and
accurate information.

•	Completing all required data fields in BCMS prior to submitting applications for
approval

•	Assisting applicants by answering questions about the permit process and
providing estimates of application fees in accordance with Rule 40

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2. Permit Application Processing - General

2.1 Early Assistance/Pre-Application Procedures (Mike Lake, August
13,1993)

This procedure is to be used when assistance is requested by a potential permit applicant
prior to application submittal. It was developed collaboratively with industry
representatives and the APCD. This "early assistance" procedure is only a general
guideline to enhance the current permit processing system. Implementation of this
procedure does not constitute any change in District rules and/or regulations.

A. Complex Systems

1.	The applicant will phone and inform the District of his/her upcoming
application. This call should be made directly to the appropriate senior
engineer whose engineering group would typically handle this type of
application (i.e., chemical, mechanical, gasoline vapor control, etc.). In
general, the same engineer will be assigned to follow the application
throughout the process.

2.	The applicant will make an appointment with the assigned engineer and they
will hold a Pre-Application meeting (in person) to discuss all aspects of the
application. At a minimum, this meeting should accomplish the following:

a.	The applicant will bring a complete description of the equipment/process
to be applied for. This will include: identification of all air contaminant
emission points, a drawing showing the facility property lines,
equipment location and nearby streets and developed areas; and,
estimates of all air contaminant emissions including toxic air
contaminants (maximum pounds/hour, maximum pounds/day, and
maximum pounds/year).

b.	The District will issue a comprehensive checklist that will completely
outline the specific information required to deem the application
complete. The applicant will provide this information when the
application is formally submitted. New Source Review rules, Air
Quality Analysis, Best Available Control Technology, Risk Assessment,
and Source Testing requirements should also be noted on this checklist,
if applicable. If an Air Quality Analysis or Risk Assessment will be
required, and the submittal of a protocol on how such work will be
performed is necessary, such requirements will be explained at this time.

c.	The applicant will advise the District of any time sensitivities associated
with the processing of the application (e.g., construction deadlines,

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compliance schedule mandated by a District rule or Hearing Board
order, etc.).

d.	The District will explain the processing steps the application will follow
along with a noted timetable. The District will endeavor to process the
application within any reasonable timeframe requested by the applicant.
However, if the application cannot be processed within such timeframe
and this will cause the applicant to be in non-compliance with a District
rule or Hearing Board order, the District will advise the applicant that a
petition should be filed with the Hearing Board to address the non-
compliance issue or District Compliance action may result.

e.	The specific items on the checklist will be agreed upon and initialed by
both parties.

f.	The District will present to the applicant all expected permit processing
costs. If processing costs are expected to exceed the amounts initially
submitted, the District will immediately notify the applicant by phone
with a letter and detailed accounting statement to follow in the mail.

3.	If Air Quality Analysis and/or Health Risk Assessment protocols are required,
they should be submitted at least 30 days prior to application submittal. These
protocols will be reviewed within 30 days and the applicant will be advised, in
writing, of any changes necessary. The applicant will submit the Air Quality
Analysis and/or Health Risk Assessment at the time of application submittal.
If an application is submitted without a required Air Quality Analysis and/or
Health Risk Assessment, it will be deemed incomplete until these documents
are provided and reviewed for completeness.

4.	The application is submitted to the District with appropriate fees and an
attached note identifying who the assigned District engineer is. After initial
District review, most applications should be found to contain all of the
required information and be deemed complete retroactive to the date of
submittal, depending upon complexity. (If the application is still lacking
information, the District has 30 days to request more data. If no request is
made, the application will automatically be deemed complete on the 31st day).
If a health risk assessment was not required with application submittal, but a
District screening risk assessment indicates that a formal Health Risk
Assessment, including a modeling protocol, will be required, the applicant
will be advised of this within the 30 days after application submittal. If
required, a Health Risk Assessment protocol will be reviewed within 30 days.

5.	When the application is deemed complete, the 180-day clock noted in District
Rule 18 will automatically start. If upon review of the application package it
is determined that the application was complete when submitted, the submittal
date will start the initial 180 day clock.

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6.	The Authority to Construct (A/C) will be issued no later than 180 days from
the time the application is deemed complete, except for mutually agreed upon
extensions as provided for in Rule 18. Priority for permit processing will be
given to all applicants who follow this procedure. The A/C conditions should
include, at a minimum, all conditions that will subsequently be established on
the Start-Up Authorization/Permit to Operate, except for conditions that are
established as a result of source testing or inspection. If A/C conditions are
non-routine, the District will provide a copy to the applicant for review at least
10 days prior to A/C issuance. The applicant will advise the District of any
issues. If emissions source testing is necessary, the applicant will be required
to submit, prior to completing construction, a protocol describing how that
testing will be done. Source testing protocols will be reviewed by the District
within 30 days of submittal.

Note: It is recommended that any abuses of the Rule 18 time limits or threats
of application denial if processing deadlines are not extended, be reported to
the Chief of Engineering and/or the Engineering Deputy Director. All permit
denials must be approved by the Deputy Director.

7.	If the applicant makes substantive changes to the application during the above
evaluation period, the 30 day clock for completeness and 180 day clock for
District action, as appropriate, will be restarted.

8.	When construction of the project is complete and all A/C conditions have
been complied with (excluding conditions requiring emissions source testing),
the applicant will notify the assigned District engineer and establish a date for
the field evaluation/inspection. In most cases the District engineer should
perform this inspection within 15 days following the notification. Upon
successful completion of this field evaluation, a Start-up Authorization (S/A)
should be immediately issued, if practicable. The applicant will advise the
District of any issues associated with the S/A. Any required emissions source
testing or other analyses, monitoring or emissions control measures required
by the A/C should be accomplished within the time frames specified in the
A/C but in no case no later than 120 days after initial S/A issuance. Reports
of source testing or monitoring results, if required, will be reviewed within 30
days of submittal. Within 180 days from the initial S/A issuance date, a hard
copy of the final Permit to Operate should follow in the mail if all conditions
of the A/C have been satisfied and compliance with applicable District rules
has been demonstrated. If final Permit to Operate conditions differ
substantially from S/A conditions, the District will provide a copy to the
applicant for review at least 10 days prior to P/O issuance. The applicant will
advise the District of any issues.

Note: Application submittals will be required to include the following
information, along with all noted specifics from the pre-application meeting:

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•	Estimated emissions along with the calculation methodology.

•	General MSDS's for the process to be evaluated.

•	Maximum process throughput.

•	General System Description (flow diagram).

•	Hours/Number of days of equipment operation.

•	A definition of what "BACT' is for the process requiring the permit, if
applicable.

•	A drawing showing the location of the equipment within the facility,
the boundaries of the facility and any nearby public streets,
commercial, industrial, or residential areas or areas accessible to the
public.

•	Air Quality Analysis and/or Health Risk Assessment, if applicable.

Note: If the final A/C, S/A or P/O conditions are in dispute and cannot be
resolved with the section Senior engineer, contact should be made with the
Chief of Engineering. If agreement still cannot be achieved, contact should be
made with the Engineering Deputy Director. If agreement still cannot be
achieved, the applicant may file a petition with the APCD Hearing Board to
appeal any A/C or P/O conditions considered unacceptable. This petition
must be filed within 10 days from the recorded A/C or P/O issuance date
(District Rule 25).

a. Off the Shelf Equipment

The District will develop and utilize a standard engineering evaluation
and associated "boilerplate" permit for equipment that is used by a
number of sources for similar purposes. Using these "boilerplate"
evaluations and permits, applications for such equipment can be quickly
processed upon evaluation of certain site-specific criteria and New
Source Review requirements. Industry will encourage manufacturers of
such equipment to apply to the District, as appropriate, for certification
of this equipment.

In addition, an on-going Permit Improvement Working Group has been
established that consists of 3 members from the District and at least 3
members from industry. The Working Group's function is to collaborate
and make recommendations to the District on the following matters:

•	Development of the comprehensive checklists that are provided
to applicants at the pre-application meeting.

•	Revisions of this procedure that will result in continuous
improvement of the permit processing system.

•	Development of a check-off list to help sources determine what
toxic air contaminants exist at a facility.

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•	Development of permit processing and application filing
instructions to assist applicants in preparing complete permit
applications.

•	Categorizing permit applications for purposes of permit
streamlining and focusing permitting efforts.

•	Development of Best Available Control Technology guidance for
permit applicants.

9. Accounts which are created to track time charges for pre-application

consultation work or special projects will be called "Application Accounts."
The project engineer must complete the A-A request form by providing the
basic necessary information, the site ID number, the A-A type, the activity
labor code and the appropriate fee schedule.

A. The three different "Application Account" types are:

1.	Type Q A-A should be created when the work to be performed will
generate a new or revised permit. It is to be created when the project
engineer intends to spend more than two hours working with an
application prior to the submittal.

2.	Type J A-A should be created when the work to be performed will not
generate a permit but is permit related. This should be created when
the project engineer is assigned to work on a project that will not result
in a permit being issued.

3.	Type F A-A should be created when the work to be performed will not
generate a permit but is not permit related. This should be created
when the project engineer is assigned to work on a project that will not
result in a permit being issued.

2.2 CEQA

2.2.1 Permit Actions Involving CEQA (Mike Lake, January 24, 1995)

Recently, there have been several projects requiring District permits that have also
involved California Environmental Quality Act (CEQA) review & most have involved
other agencies as the lead agencies and the District's role has been as a responsible
agency. The significance of whether a project the District is evaluating for permits is also
subject to CEQA is that state law prohibits the District from issuing a permit (includes
Authority to Construct, Startup Authorization, modified Permit to Operate or new Permit
to Operate) if the project is subject to CEQA until the lead agency has completed the
CEQA review for the project and certified the findings. Typically, the CEQA review and
findings will be in the form of a Negative Declaration, Mitigated Negative Declaration or
Environmental Impact Report.

The vast majority of projects we evaluate are exempt from CEQA or have already
undergone a CEQA review. However, we need to be aware that occasionally, projects

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will come to us for permits before or during a CEQA review. If a project engineer
suspects that a project application is for all or a portion of a project that is subject to
CEQA review, the engineer should immediately advise his/her Senior engineer and
should not issue a permit until further advised (the application evaluation can and should
proceed). The Senior Engineer and Engineering Division Chief will look into the matter
and determine if the District's permit process will be impacted and how, then advise the
project engineer how to proceed. If a CEQA process is involved and District action will
be delayed, the District will advise the applicant that this is the case and that in the
interim, the application will be considered incomplete until CEQA requirements are
satisfied.

Because CEQA will not be an issue with the majority of permits we process, it is not
asked that engineers query every applicant or check CEQA applicability on every project.
Rather, it is requested that engineers be aware of the issue, recognize the following
indicators, and bring suspect applicants to the attention of their Senior engineer. The
following suggests a project that may likely be subject to CEQA:

The project also requires, but has not yet received, permits from a state agency such as
the Regional Water Quality Control Board, the Coastal Commission, the Integrated
Waste Management Board, the Energy Commission and/or the Public Utilities
Commission.

The project requires, but has not yet received, a conditional use permit, major use permit,
new or community plan amendment or zoning change/variance from a Environmental
Review Board or Board of Supervisors.

The project needs approval from, is under consideration by, or is to be heard by a City or
County commission or board.

An Initial Study, Negative Declaration or EIR is needed or is being prepared or the
District is asked to comment on or review documents related to one of these.

The project is likely to be very controversial and/or has raised considerable public
concern or media coverage.

Projects on military bases typically do not involve CEQA issues.

2.2.2 Question and Answer Document Discussing CEQA (Mike Lake, January 26,
1995)

The following is an excerpt of a Question and Answer document discussing CEQA. It
should answer some of the more basic questions regarding CEQA that may have arisen.

A. Roles: Who does what?

What types of agencies are involved?

A: CEQA review usually requires the participation of local planning agencies, air
pollution control districts, and state agencies. In some cases, agencies of the federal
government participate in CEQA reviews.

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Under CEQA. these agencies become lead agencies, responsible agencies, or
commenting/interested agencies.

What is a lead agency?

A: Lead agency is the public agency that has the principal responsibility for carrying
out or approving a project. Under CEQA, the lead agency is responsible for determining
whether the project will have a significant effect on the environment. The lead agency
also has the authority to require changes in any or all activities involved in the project in
order to lesson or avoid significant effects on the environment. The lead agency decides
whether an Environmental Impact Report (EIR) or Negative Declaration will be required
for the project and will cause the document to be prepared.

3) How do we determine which agency is the lead agency?

A: The lead agency will normally be the agency with general governmental powers,
such as a city or county, rather than an agency with a single or limited purpose such as in
air pollution control district or an agency that provides a public service or public utility to
the project.

Where two or more public agencies will be involved with a project, the
determination of which agency will be the lead agency shall be governed by the
following criteria:

If the project will be carried out by a public agency, that agency shall be the lead agency
even if the project would be located within the jurisdiction of another public agency.

If the project is to be carried out by a non-governmental person or entity, the lead agency
shall be the public agency with the greatest responsibility for supervising or approving
the project as a whole.

When more than one public agency is equally qualified to be the lead agency, the lead
agency shall be the first agency to act on the project, or the participating agencies may by
agreement designate a lead agency.

If there is a dispute over which of several agencies should be the lead agency for a
project, the disputing agencies should consult with each other in an effort to resolve the
dispute prior to submitting it to OPR. If an agreement cannot be reached, any public
agency, or the applicant if a private project is involved, may submit the dispute to OPR
for resolution.

4) What is a responsible agency?

A: The other agencies with discretionary permitting authority for a project,
besides the lead agency, are CEQA-responsible agencies. A responsible
agency may require, through its own permitting procedures, changes in a

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project to lesson or avoid the effects, either direct or indirect, of only that part
of the project which the responsible agency will be called on to approve.

What is a commenting/interested agency?

Agencies with no permitting authority for a project may still act as agencies which may
participate in the evaluation of the environmental impacts of a project. Generally, a
commenting/interested agency has expertise in or oversight responsibility for specific
geographic regions or environmental resources.

6)	How do local planning agencies participate?

Cities and counties have discretionary approval over land use regulation by way of
general plan amendments, specific area plans, zoning ordinance amendments, or special
or conditional use permits. Each city and county has a planning agency, an appointed
planning commission and an elected city council or county board of supervisors.

The local planning agencies generally have the principal responsibility for carrying out or
approving a project. A planning agency frequently is the CEQA lead agency for a
project.

7)	How do air pollution control districts participate?

A district may be a lead agency, a responsible agency, or a commenting/interested
agency.

A district may be the lead agency when considering the adoption of an air pollution
control measure or a hearing board's decision regarding a variance. The district may also
be the lead agency for the situation when a stationary source is undergoing a significant
modification, but no land use permit change is necessary. As lead agency, the district is
responsible for the preparation of CEQA environmental documents. Figure 1-1 presents
a flow chart describing the steps a district must follow when implementing CEQA as a
lead agency.

A district will generally be a responsible agency for a project that is a direct source of
emissions. In a situation such as this, the project may need a permit from the district. As
a responsible agency, the district's expertise is such that its task is to evaluate the air
quality impacts of the project. When participating as a responsible agency, the district's
decision making must consider the lead agency's findings regarding air quality impacts.
The district, in fact, cannot issue a permit until the lead agency's environmental
documents have been completed.

While districts have the legal authority to regulate indirect sources and require that they
receive permits, no district has yet enacted an indirect source review rule. The enactment
of the California Clean Air Act is expected to change this. If the districts adopt indirect
source review rules, they would comment as a responsible agency. Until that time, a

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district is considered a commenting/interested agency for indirect sources. As a
commenting/interested agency, the district should work with the lead agency to ensure
that the air quality impacts of projects which may be indirect sources of emissions are
minimized or mitigated.

8)	How do state agencies participate?

State agencies regulate the private use of state land and resources and certain activities of
statewide significance. Some state agencies have oversight responsibilities over local
agencies. The state Air Resources Board (ARS) has primary regulatory responsibility
over mobile source emissions and oversight responsibility over stationary sources. A
summary description of State agencies' areas of responsibilities is contained in Appendix
B.

Certain state agencies may regularly act as lead agencies; others have roles as responsible
or commenting/interested agencies. In addition, the Governor's Office of Planning and
Research (OPR) operates the State Clearinghouse to facilitate and coordinate the review
of CEQA projects subject to state agency authority.

9)	Do federal agencies participate in CEQA reviews?

Federal agencies are not public agencies as defined by CEQA. The National
Environmental Policy Act (NEPA) of 1969 applies to projects which are carried out,
financed, or approved in whole or in part by federal agencies (42 U.S.C.A. 4321-4367;
NEPA Regulations, C.F.R. Parts 1600-1508). NEPA authorized a broad policy requiring
consideration of environmental consequences for most federal activities. NEPA requires
each federal agency to prepare an Environmental Impact Statement (EIS) on projects that
may significantly affect the quality of the human environment. Therefore, a project
located in California may have to comply with both CEQA and NEPA.

State and local agencies can use an EPA Environmental Impact Statement (EIS) in lieu of
a CEQA Environmental Impact Report (EIR) if the EIS contains the same provisions as
the EIR would need to contain and is prepared before the EIR. A lead agency may
prepare a joint EIR/EIS if the federal agency cannot complete it in time.

If a joint EIR/EIS is used, federal law requires that the appropriate federal agency
participate in the preparation of the document.

10)	Documents: Use and Content

A checklist of CEQA documents. As part of a CEQA review, these documents,
described in detail later in this section, may be used:

Notice of Exemption
Initial Study
Negative Declaration

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Notice of Determination
Noti ce of Prep arati on
Notice of Completion
Environmental Impact Report

b. What is the District's role in the preparation of these documents?

Environmental documents required by CEQA are the responsibility of the lead agency.
The lead agency may prepare the documents or cause them to be prepared by the project
applicant. In either case, the lead agency is responsible for the complete document.

A District becomes involved in the preparation of environmental documents in these
instances:

When the District is a lead agency.

When the lead agency consults with the district in the district's role as responsible or
commenting/interested agency.

In either instance, the District should ensure that the documents contain relevant data that
address air quality issues.

2.2.3 Process Outline for Issuing a Negative Declaration (December 4,1995)

This document has been drafted based on the CEQA process for adoption of District Rule
67.11, where a Negative Declaration was issued. Changes to the process may be required
if CEQA is triggered by a Permit action. Additional information may be obtained from
the CEQA guidelines' issued by the Governor's Office of Planning and Research (OPR),
which is available in the District library. The Section (§) references listed in parenthesis
are from that CEQA guideline document.

A.	Define the project with a title that reflects the action (i.e., Adoption of Rule 67.11 —
Wood Coating Operations)

B.	Determine if the project is categorically exempt from CEQA requirements. (§
15061)

1)	If the project is categorically exempt:

•	The basis should be documented within the project file for reference

•	The standard categorically exempt from CEQA language should be
used in the board letter (In both the findings & background
information sections)

•	A Notice of Exemption should be prepared for the Clerk of the Board
to file w/ OPR.

2)	If the project is not categorically exempt:

•	An Initial Study (IS) is required to determine if:

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A Negative Declaration (ND) should be issued, or
An Environmental Impact Report (EIR) is required. (See steps
II.5(c)4,11.5(c)(5), and 11.5(c)(6)).

C.	Consult with ARSD regarding the effects of the proposed project on the SIP (i.e.
15% rate of progress, this an internal action not required by CEQA)

D.	Consult with ARB and any other interested "responsible" agencies for their input,
re: should an Initial Study (IS) and Negative Declaration (ND) or Environmental
Impact Report (EIR) be prepared? (§ 15063(g))

~ Current ARB contact for CEQA is Michael Tollstrup, (916) 323-8473.

E.	Determine if the project "may have a significant effect on the environment. (This is
a preliminary decision which will be supported by further work such as an IS or
EIR)

1)	If the project will likely not cause any "significant effect" on the environment,
then proceed with an Initial Study and Negative Declaration. (§ 15070 et seq.)

2)	If the project is likely to result in a "significant effect' on the environment,
then an Initial Study is not required, instead work on the EIR will be the first
step. (§ 15060(c))

NOTE—If the determination of what constitutes a significant effect' on the
environment relies solely on the District's judgment or there is public concern about
the project, an EIR should be performed.

F.	Prepare Initial Study. The IS provides documentation of the factual basis for the
ND finding that a project will not have a significant effect on the environment.
The document must include the following, (§ 15063) (A template IS, as described
below, is available on disk):

•	Project name, applicant and location

•	Project Description (This may include an explanation of any effects and a
determination of the significance of these effects.)

•	Checklist to identify environmental effects

•	Discussion of ways to mitigate significant effects identified, if any

•	Determination of consistency with existing zoning, plans including general
and specific plans, and other applicable land use controls

•	Determination of de minimis impact finding for Department of Fish &

Game

•	Determination of environmental document (This is the 'finding' of the IS —
see Step 7 for details)

•	Name of person who prepared Initial Study (Different than responsible
person who signs the IS)

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G. Formally determine if the project will result in a significant effect on the
environment.

•	The determination should be based on the information provided in the Initial
Study. (§ 15064)

•	The determination is used to justify the issuance of a Negative Declaration
(§ 15070) or the basis for requiring an EIR.

•	Record the final determination in the "determination of environmental
document" section of the IS.

Prepare a proposed Negative Declaration. The document must include the
following: (§ 1507 1)

•	Date of Negative Declaration

•	Project name, applicant and location

•	Project description

•	Proposed finding that project will not have a significant effect on
environment

•	Copy of Initial Study to support finding

•	Listing of mitigation measures, if any, included in project to avoid
potentially significant effects

•	Statement that "This action becomes final upon approval by the APCB."

I. Prepare Notice of Intent to issue Negative Declaration for publication in
newspaper. (§ 15072, 15073)

•	The notice requires a 30 day public review period (including other
government agencies)

•	Notice must be submitted to Public Info for publishing, allow 5-7 additional
days

NOTE—the public notice period may be shortened to 21 days with OPR approval.
(Request form is available on disk)

J. Notify OPR of CEQA actions taken by District. (§ 15073)

•	Current OPR contact for CEQA is Scott Morgan, Governor's Office of
Planning and Research, 1400 Tenth Street, Sacramento CA 95814, (916)
445-0613.

•	Send 15 copies of Initial Study and proposed Negative Declaration.

•	Send Notice of Completion form, (use the actual "supplementary document
'A' form, from the CEQA Guidelines, Revised 10/29/98).

•	Include one additional packet with cover letter.

•	OPR will assign a State Clearing House (SCH) number to the project.

K. Notify ARB of CEQA actions taken by District.

• Current ARB contact for CEQA is: Michael Tollstrup, Air Resources
Board, Stationary Source Division, PO Box 2815, Sacramento CA 95812,
(916)323-8473.

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•	Send copy of Initial Study and proposed Negative Declaration with cover
letter

L. Present intent to issue ND to the advisory committee if they will be making a

recommendation to the Board on the project. They must consider the proposed ND
before making their recommendation to the Board. (§ 15074(a))

M. At the end of the public comment period: (§ 15074)

•	Respond to any public comments (Format has not yet been determined).

N. Include the following CEQA information in the Board letter:

•	A finding in the board letter which states that the Board has considered the
ND and any comments prior to approving the project. (§ 15074(b))
(Approval of the ND and approval of the project may be incorporated into
the same letter, if the Board must approve both.)

•	A finding in the board letter that the ND is exempt from the $850 fish &
game fee. (Form is available on disk)

•	A summary of the District's action regarding CEQA requirements (A copy
of the Rule 67. 11 board letter is available as a reference.)

O. Complete Notice of Determination form with the following information: (§ 15075)

•	Project name, applicant and location.

•	Project description.

•	Date on which the agency approved the project.

•	Must include the SCH #, which was assigned by OPR.

•	Determination by agency that the project will not have significant effect on
environment Statement that a Negative Declaration has been prepared
pursuant to CEQA.

•	Address where a copy of the Negative Declaration may be examined.

•	This document must be included in the Board package.

P. Approval of project (i.e., board adopts rule).

Q. Notice of Determination is filed with County Clerk by the Clerk of the Board (§
15075(d) & (e))

•	The Clerk files Notice of Determination with OPR is required.

•	The Clerk files the finding of fee exemption document with Fish & Game.

Acronyms:

APCB
ARSD
CEQA
EIR
ND
OPR
SCH

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Air Pollution Control Board

Air Resources and Strategy Development

California Environmental Quality Act

Environmental Impact Report is Initial Study

Negative Declaration

Office of Planning and Research

State Clearing House

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2.3 Application Schedule Management

2.3.1 Rule 18 - AB884 (Mike Lake, March 19,1992)

Concerns have been raised regarding adherence to Rule 18/AB884 permit processing

deadlines. There appear to be two primary issues and one secondary issue:

A.	Not requesting additional information or determining an application is complete
within 30 days of receipt of the application.

B.	Requesting additional information after the initial 30-day deadline and/or coercing
an applicant to agree to processing time extensions by threatening denial of the
application.

C.	Not canceling applications when requested information is not provided.

1) Regarding issue #1

District Rule 18(a) requires the District to determine whether an application for
A/C, P/O or banking is complete or incomplete, and to so notify the applicant,
within 30 days of receipt of the application. If the application is determined to be
incomplete, the needed additional information must be specified in the notice of
incompleteness. The purpose is to ensure timely review and early identification of
deficiencies in the application information. It is the intent of Rule 18, and District
policy, that such notification be in writing. However, if only minor information is
needed for completeness, it can be requested by phone but must be documented in
the file. If the information is not provided before the end of the initial 30-day
period, it must be requested in writing.

It is important that the request for additional information be made within the
allotted 30-days and that the additional information requested include all
information we may need. The request for additional information needs to be
thorough and identify the specific information needed to complete the application.
Once the applicant has provided all of the information requested during the initial
30-day period, the application must be found complete and the applicant so notified.
This determination is to be made within 30 days of receiving the additional
information.

The maximum 180 days allowed for application processing begins on the date the
application is determined to be complete. This is 30 days after the date when all
additional information required in the first 30 days has been provided or 30 days
after application filing if the District fails to request additional information in that
30 days.

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Once the application is determined complete, whether by District action or inaction,
the District can request amplification or clarification of information already
provided by the applicant, or request additional information. However, such
requests do not stop the 180-day calendar for action on the application. If
additional information is needed in order to determine compliance during this
period, it should be requested and documented, but again such requests do not stop
the 180-day calendar. Such requests should not identify applications as incomplete.

As soon as possible after applications are assigned, but not later than two weeks
after District receipt of an application, project engineers should notify their Senior
Engineer if they will not be able to review an application for completeness and
request additional information within the initial 30-days. The Senior Engineers will
work with engineers to meet the 30-day requirement.

2) Regarding issue #2

District Rule 18(b) requires the District to act on a completed application within 90
days, if possible, or within a maximum of 180 days. Rule 18 also allows an
applicant to deem an application denied if not acted upon within the first 90 days.
With the concurrence of the applicant, the 180-day evaluation period may be
extended an additional 90 days. If no action is taken within the 180 days or 270
days if extended, the application shall be deemed approved. As noted above,
amplification, clarification or additions to application information may be requested
during this period but such requests do not delay the Rule 18 timelines for action.
By the memo of 1/24/90 (II.l (d)(4)), the procedures for use of the 90 day
extensions were specified. Briefly, a 90-day extension of the 180-day period should
be the exception and must be approved, in writing, by your Senior Engineer, with
documentation of the reasons for the extension in the permit file. Senior Engineers
will advise the Chief of any extensions. In the unlikely event that 270 days is not
sufficient to complete an evaluation, any further extension beyond 90 days must be
approved by the Chief of Engineering or Deputy Director.

Adherence is to this procedure is mandatory. Engineers who do not comply with
this procedure risk disciplinary action. If you have any applications that are
approaching or have exceeded the 180-day evaluation period, it is strongly
suggested that you discuss them with your Senior Engineer as soon as possible.

It has also come to attention that in some cases applicants are being threatened with
denial of their applications unless they agree to extensions of the evaluation period
and provide additional information. District Rule 20 places the burden of
demonstrating compliance on the applicant and authorizes District denial of an
application when a compliance demonstration is not made. However, such denials
may not stand if they are based on the District's failure to request additional
information in a timely manner (especially if the applicant provided a completed
application supplemental information form).

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Such threats are inappropriate, are certainly not consistent with the intent of Rule 18
and do not contribute to a cooperative permitting effort. If a proj ect engineer has an
application that lacks sufficient information to demonstrate compliance, the
engineer has not requested the additional information needed within the allotted 30
days and the 180 day deadline is approaching, the engineer should request the
applicant to provide the information as soon as possible. The engineer should
explain the requirements of Rule 20 in a positive sense (i.e. the additional
information is needed to determine compliance and issue a permit) and advise the
Senior Engineer. Threats of permit denial should not be used.

The best remedy to this problem is to request needed additional information within
the initial 30 days, and to complete evaluation of the completed application as soon
as possible (i.e. within 90 days) but no later than the 180 days allowed by Rule 18.

3) Regarding issue #3

District Rule 17(c) provides that an application shall be cancelled if the District
requests needed additional information and the applicant fails to furnish the
information within six months. This means that the applicant must provide all
requested information within the six months, not provide some and then be given an
additional six months. If an applicant submits some but not all of the requested
information, the applicant is to be notified in writing of any deficiencies within 30
days.

Engineering staff have been reluctant to cancel applications, anticipating that the
company will immediately re-file and additional paperwork will be generated.
However, this reluctance to cancel does, to some degree, add to the backlog and
permit delays. Accordingly, Rule 17(c) is to be followed by engineers. If there is
an exceptional case, such as a complex project requiring risk assessment or
emission offsets, a longer period for providing the information may be allowed,
with the written approval of your Senior Engineer. Such longer period must be
specified in the letter requesting the information, with the Senior Engineer's initials
approving the draft.

Current extensions should be honored but the applicant advised there will be no
further extensions. When an application is cancelled for failure to provide
requested information, such cancellations must be in writing and document the
reasons for cancellation. Any subsequent application should be placed at the back
of your applications pending 30-day review but processed consistent with Rule 18
timeliness.

From the above, it should be clear that the initial review of applications for
completeness, and identification of needed additional information within the
prescribed 30 days is critical. These actions set the tone for adherence to Rule 18
and District policy for the remainder of the evaluation period. Accordingly, these
Rule 18 requirements must be followed. It should also be clear that all requests for

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information, whether in writing, by phone or in person must be documented in the
application evaluation file. Further, any anticipated deviations from Rule 18
requirements must be discussed with the Senior Engineer prior to any action dates.

D. Rule 18 Time Extensions (January 24, 1990)

It has come to attention that Engineering staff are extending the 180 day evaluation
period allowed by Rule 18 by multiple 90 day increments with the concurrence of
the applicant. While County Counsel has opined that an applicant can waive their
rights to timely action on their application, thus foregoing the limits of Rule 18, this
practice is not in keeping with District objectives for action on applications and
should not be applied except in extraordinary cases and with the approval of the
Senior Engineer, Chief of Engineering or Deputy Director, as provided below. The
following Engineering policy will apply to Rule 18 time extensions for all new
applications and existing applications which are currently under extensions or may
need extensions in the future:

1)	Except as provided in #2 and #3 below, actions on applications shall be
accomplished within 90 days, if possible, but not more than 180 days as
prescribed by Rule 18.

2)	If unusual circumstances (e.g. source testing/report delays, delays in providing
additional information beyond the control of the applicant, late requests for
additional information, etc.) warrant an extension of the 180 day period, that
extension must be approved by your Senior Engineer, the applicant must
provide prior written concurrence to the extension, and the extension shall not
exceed 90 days. The reasons for the extension must be documented in a
memo to the file, signed by the project engineer and initiated by the Senior
Engineer. The Senior Engineer may discuss project specific circumstances
with the Chief

3)	Extensions beyond the 270 days provided for in #1 and #2 above will only be
allowed in extraordinary cases and must be approved by the Chief of
Engineering or, in my absence, the Deputy Director.

Currently granted extensions shall remain in effect. However, the project engineer is to
document the reasons for the extension in the application file and bring them to the
attention of her or his Senior Engineer. Applications for which the initial 90 day
extension has passed, or will pass shortly without final action on the application, shall be
brought to my attention

2.3.2 Excessive Time for Processing Applications (May 18,1983)

Applications will be processed in a timely manner. All activity related to application
processing will be documented. When an individual has taken unjustifiable excessive
time to process an application, the following disciplinary steps will be taken:

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A.	First occurrence -> discussion with staff member and verbal warning.

B.	Second occurrence -> discussion with staff member and informal written warning.

C.	Third occurrence -> discussion with staff member and formal letter to individual's
personnel file.

D.	Subsequent occurrence -> additional progressive disciplinary steps as appropriate.
2.3.3 160 Day Reports (Tom Weeks, November 2005)

Engineers are required to complete a 160 Day Report for any application that has been
complete for 160 days in an unapproved status. The report is intended to ensure the
supervisor is aware of the unapproved application so that issues can be addressed and
compliance with Rule 18 can be assured. Engineers are to complete the top portion of the
form (see below) and forward it to the Senior Engineer between days 157 and 163 from
the completeness determination. The Senior Engineer will discuss a course of action with
the engineer and fill out the bottom section of the report. All completed reports will be
forwarded to the Chief of Engineering.

160 Day Application Report

Submit for each Unapproved Application in-house for 160-days or more

Application No.:	 Report Date:	

Facility Name:	 Rule 18 Deadline (180 days):	

Problems with Application:	

Information, Guidance or Resources Needed for Approval:

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Plan of Action:	

For Senior Engineer Use

Date of Discussion(s) with Project Engineer:

Summary of Discussion:	

Date of A/C Issuance:

2.4 Application Fiscal Management
2.4.1 Permit Fee Procedure (revised June,2014)

The following procedure will be used in processing applications and related fees for A/Cs
and/or P/Os.

A.	Application fees must be substantially complete prior to acceptance of an
application. . Fees and applications that are delivered personally to Engineering or
Compliance personnel will be forwarded immediately to clerical staff for logging
and fee deposit. Fees and applications received by clerical staff will be logged in
when received and the fee payment deposited immediately before the application is
forwarded to the Compliance or Engineering divisions.

An exception is when an applicant brings in cash or a check and it is determined
while the applicant is still here (before the application is logged in by clerical staff)
that the fee amount is incorrect. In this case, the correct amount should be paid by
the applicant or the application returned for later filing with the correct fee. This is
actually not an exception, since the application is not accepted and logged in with a
fee payment.

B.	More than one application at a time received from an applicant with a payment
covering the combined fees will be handled the same way as for a single application
received, as far as logging in and fee deposit by clerical staff is concerned.

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Overpayment refund or collection of underpayment, if applicable, will be initiated
later and referenced to the payment for those applications submitted at the same
time.

C.	Engineering or Compliance staff will not attempt to apply an overpayment or
underpayment of a fee for one or several applications to balance the overpayment or
underpayment of a fee for another or several applications. This also applies to
applications received from the U.S. Navy. (August 7, 1978)

D.	If a refund is due an applicant, the staff handling that refund and application will
complete a refund worksheet form (available from the clerical department) and
submit only that form to Accounting for processing. The staff member will
continue processing the application. The issuance or denial of an AJC or P/O is to
occur regardless of the status of the refund. (October 24, 1979)

E.	If the source test is not performed by the renewal date within the permit year for
which it is collected, refunds for Schedule 92 fees will be initiated by the source test
program coordinator in the Compliance division within 60 days after the permit
renewal date.

F.	The monitoring and technical services division will notify the Compliance division
when scheduled tests are performed, missed or cancelled. A monthly summary of
source tests will be supplied to the Compliance division. This will ensure that both
divisions accurately track adherence to the annual schedule. This policy will apply
to all source tests on the annual schedule including the asphalt plant particulate tests
(Method 5) scheduled for the summer months.

2.4.2	Application Fee Schedules (August 13,1987)

The fee schedule placed on the application by Permit Processing when it is received is the

fee schedule that is assigned to the application file. In order for both the daily time sheets

and the application file to be correct, the following procedures will be used:

A.	If an application is received and the fee schedule is believed to be incorrect, the
proposed changes will be discussed with the senior engineer. If the fee schedule
will be changed, the senior engineer will initial the changed fee schedule on the
application. Then either the original application or a copy (with the senior
engineer's initials) indicating the changed fee schedule will be taken to permit
processing, who will access the application file and make the fee schedule change.

B.	Changing fee schedules on the application file will be done as soon as possible after
receipt of the application in engineering. This field affects other programs
including the deferred revenue program and the tickler reports that are issued to
request additional fees from applicants.

2.4.3	Financial Accounting of Time and Material Fees

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(October 12, 2000, Modified May 6, 2011)

A.	Labor charges to specific applications will not be allowed to substantially exceed
the fees requested for application processing. Rule 40 states that if any deposit is
insufficient to pay all actual costs, the applicant will pay an amount deemed
sufficient by the APCO to complete the work in progress. If the applicant fails or
refuses to pay such amount upon demand, the District may recover the same by
action in any court of competent jurisdiction. A Permit to Operate will not be issued
until all required fees are paid.

B.	Applicants shall be informed that additional fees will be required when total labor
costs are expected to exceed the fee deposit by more than $100 for time and
material charges. This includes labor expended by technical services staff and
toxics section staff. Such contact will be in the form of a written request for the
additional fees and a statement of why the initial estimate was exceeded. Section E
below provides procedures for preparing an invoice request.

C.	In cases where technical services staff are involved in the processing of an
application (i.e. air quality impact analysis or testing), the assigned project engineer
will advise the technical services division staff of the fees that have been allocated
for their services. The technical services division staff will advise the assigned
project engineer when approximately 85 percent of those allotted funds have been
expended and the total labor cost is expected to exceed the amount allocated. The
project engineer is responsible for requesting an invoice from the accounting
section for any necessary additional funds from the applicant.

D.	In cases where health risk assessments are being performed by the toxics section,
the assigned project engineer will advise the toxics section staff of the fees that
have been allocated for their services. The toxics section staff will advise the
assigned project engineer when approximately 85% of those allotted funds have
been expended and the total labor cost is expected to exceed the amount allocated.
The project engineer is responsible for requesting an invoice from the accounting
section for any necessary additional funds from the applicant.

E.	Project engineers shall review the open application report weekly to evaluate the
financial status of each application assigned to them. The column labeled "TA
BALANCE - ALL ASSESSED FEES PAID" presents information on the financial status
of applications including any invoices that may have been previously issued. If
total labor costs are expected to exceed the deposited fees by more than $100
(including charges by technical services division and toxics section charges), the
permit engineer shall forward a request for an invoice to the accounting section
specifying the additional number of hours (and associated job classification(s))
necessary to complete processing. The request must include a written justification
for the additional fees and must be approved by the Senior engineer. The
accounting section will prepare and distribute an invoice for the additional

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necessary fees taking into consideration the up-to-date financial status of the
application. A copy of the invoice will be made available to the project engineer.

2.4.4	Change in Use of Task Codes for Amendments, Modifications, and Changes
of Locations of Applications (July 1,1999)

As of July 1, 1999, the task codes AMD, MAL, and COL will no longer be used for
applications received for amendments, modifications or change of location.

As of July 1, 1999, the task codes for these types of applications will use the primary fee
schedule(s) associated with the existing permitted equipment. Permit processing will
assign the primary fee schedule to all new applications. Since the fee schedule, rather
than the AMD, MAL, COL, will be used in the as the task code, billable hours should be
charged to APP.

2.4.5	Fee Deposit Reference Sheet

The initial fee deposit reference sheet has been prepared as an aide in determining initial
new application fee deposits. The reference sheet is available on the "S" drive and shall
be updated as Rule 40 revisions are approved by the Board. The reference sheet does not
include costs associated with source testing, NSR reviews, air quality modeling, CEQA
or other required analyses as specified in Rule 40(d)(5). Estimated costs for Rule 1200
review is generally included based on prior experience with past similar applications.
The sheet is intended as an aide in determining fees however, actual fees can vary based
on application specific information.

2.4.7	Rule 40 Split Fee Payments (March 23,1993)

Rule 40(a) and Rule 40(b) have provisions for the District to accept partial payments for
new permit applications and renewals. Partial payment provisions in Rule 40 are
available for businesses, which can substantiate an inability to pay the application or
renewal fee in one payment.

Compliance and Engineering staff communicate with business in the field, at the front
counter, on the phone, and in correspondence. To minimize the submittal of unqualified
requests for partial payments, Compliance and Engineering staff are to advise business of
the option of partial payment in Rule 40 only at the request of business or other indication
of financial difficulty.

2.4.8	Additional Fees (October 12, 2000)

A. Review/Approval of Additional Fees - Senior Engineers are responsible for
approving additional engineering staff time charges and invoices for additional
application fees. It is important that the District ensure that time charges are
justified before invoices are sent.

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If additional time charges are due for Monitoring and Technical Services staff labor
hours, the Senior Engineer should obtain written concurrence with those time
charges from the Chief of Monitoring & Technical Services. In addition, when a
request for analytical services is sent to M&TS, the request is to contain
information on the amount of fees and time allotted for M&TS support. They will
also be tracking their time and are subject to the 85% criteria as well.

B. Charges for Additional Fees - This is a reminder that it is District policy that

engineers working on permit applications where fees are charged on a T&M basis
are to notify the applicant when the cost of the application related time charges
(including Engineering and Monitoring & Technical Services costs) has reached 85
percent of the deposited application fees if the anticipated costs to complete the
application evaluation will exceed deposited fees by $100. An invoice from
Accounting will also be forwarded. For purposes of complying with this policy, the
procedure described below must be followed.

1)	The project engineer should presume that M&TS costs will not exceed their
allotted portion of the application fees. Assigned M&TS staff are being
required to track their time and notify the project engineer when their time
reaches 85 percent of what was allotted for M&TS support. The engineer
should track Engineering time charges and notify the Senior Engineer when
the Engineering time charges reach 85 percent of the allotted engineering
evaluation time. If the engineer reaches the 85 percent level, assigned M&TS
staff, if applicable, should be contacted to determine the status of their time
charges and the need for any additional funds to cover anticipated additional
future costs.

Note: When an application-related request for analytical services is made to
M&TS by Engineering, be sure to include the amount of time and fees that
have been allotted for M&TS support.

2)	The Senior Engineer and project engineer are to determine what, if any,
additional fees will be required to complete action on the application. If
additional fees will be required, the project engineer is to notify the applicant
by phone (document in application file), email or letter, explaining the reasons
for the additional fees, and initiate a request for invoice. The invoice will
either be attached to the notification letter or the applicant will be notified that
it will be mailed.

3)	Once all fees received have been expended, no further work on the application
is to be done until the required additional fees are received, unless directed by
the Senior Engineer.

4)	If Engineering and/or M&TS staff are witnessing compliance source testing
and testing must be continued or repeated the next day and this will cause

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District costs to exceed fees received, the project engineer (if present) or
senior M&TS staff present will so advise the applicant. If the applicant
verbally agrees to pay the additional costs, District staff will document this,
invoice the additional costs, and may agree to return to observe testing, if
appropriate. If the applicant is not available to agree to the additional costs,
the project engineer or senior M&TS staff will contact the Senior Engineer,
Chief of M&TS or Chief of Engineering who may authorize the additional
time charges. If no one is available to authorize, or the applicant does not
agree to, the additional time charges, no further test witnessing shall occur
until the fees issue is resolved.

5) The need to request additional fees at the 85 percent level is critical to
ensuring that application processing is not delayed due to fee issues.
Insufficient funds do not stop the 180-day clock of Rule 18. Pursuant to Rule
40(a)(8), an application must be canceled if the applicant fails or refuses to
pay the additional fees and the provisions of Rule 18 require that an action be
taken.

The purpose of this policy is twofold: to ensure that limited District resources
are being expended appropriately; and, to allow the applicant to make an
informed decision regarding whether work on the application should continue
and if there are problems in the process that the applicant can control or
change to reduce costs.

In a related matter, it is noticed that the comments on some application time
sheets are too vague and cannot be reasonably used to validate the time
charges listed. This has been a problem in conjunction with additional fee
requests. Please ensure that you provide detailed comments on application
time sheets and that the associated time charges are appropriate. For example,
instead of writing "Engineering Evaluation", state more specifically the
activity such as "Evaluation-rule compliance review, emission calculations".
This information is important not only to address applicant concerns but also
to evaluate future fee schedule rates. As such, this practice applies for both
T&M and fixed fee applications.

2.4.9 Revenue Billing (October 12, 2000, revised September, 2007, June 2014)

Upon completion of the application and the P/O evaluation, the following procedures will

be used:

A. Engineers will approve the application in the APP file and forward the folder to the
Senior Engineer for P/O approval. All final billing will be prepared from the labor
tracking files by accounting staff. If the engineer has requested additional fees via a
request for invoice or tickler, he will indicate on the form if requesting final billing.

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B.	The Senior Engineer will approve the P/O and forward the site folder to accounting
staff for final billing/refund. The senior engineer can also approve the P/O and
return it to the permit engineer if minor revisions to the evaluation are required. If
this is the case, it is the permit engineer's responsibility to forward the file to
accounting after making the revisions.

C.	When the final invoice is paid, the accounting department will close the deferred
revenue file.

D.	If there is a time deadline, the accounting department will be notified of the time
frame. If the time limitations cannot be met by mailing the invoice, the invoice will
be prepared and the project engineer will notify the applicant by telephone to bring
in the required fee or the application will be denied, and permit cancelled.

E.	Without exception, $100 or more will be either invoiced or refunded. If there are
any erroneous charges, they will be removed via the labor tracking system. Each
daily must be changed if charges are to be either reduced or added. Accounting
staff will make these changes upon request.

2.4.10 Deferred Source Test and/or Permit Renewal Fee Policy (June 17,1997)

Local businesses have requested that the District allow source test and/or permit renewal
fees to be deferred for long lead-time projects expected to begin operation more than
fifteen (15) months after an application for Authority to Construct is submitted. In
response, the District has developed the following deferred fee policy for both fixed and
time and materials (T&M) fees:

A.	If operation of an emission unit is reasonably expected to commence more than
fifteen (15) months after the date an application for an Authority to Construct is
submitted, payment of the initial District permit renewal fees associated with such
emission unit may be deferred, at the written request of the applicant, to a time not
less than four (4) months before the emission unit for which the application is
submitted is first operated. In such case, the District engineer processing the
application shall include a condition on the Authority to Construct stating that "A
permit renewal fee shall be submitted to the District not less than four (4) months
before the emission unit is first operated. This fee shall be the applicable permit
renewal fee for the emission unit in effect at the time this deferred permit renewal
fee is due to be paid to the District. For purposes of Rule 24, this Authority to
Construct and the application(s) upon which this Authority to Construct is based,
shall not serve as a temporary permit to operate until this deferred permit renewal
fee is paid to the District."

B.	If initial source testing associated with evaluation of an application for Permit to
Operate an emission unit is reasonably expected to occur more than fifteen (15)

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Engineering Division Manual of Procedures

months after the date an application for an Authority to Construct -is submitted,
payment of District fees associated with such source testing may be deferred, at the
written request of the applicant, to a time not less than four (4) months before the
emission unit is first operated in conjunction with the Authority to Construct. In
such case, the District engineer processing the application shall include a condition
on the Authority to Construct stating that, "A source test fee or fee deposit, as
applicable, shall be submitted to the District not less than four (4) months before the
emission unit is first operated in conjunction with this Authority to Construct. This
fee shall be as specified in the appropriate fee schedule or as determined using the
labor rates in effect at the time this fee is paid, as applicable. It is the applicant's
responsibility to obtain the projected labor hours from the District. For purposes of
Rule 24, this Authority to Construct and the application(s) upon which this
Authority to Construct is based, shall not serve as a temporary permit to operate
until this deferred source test fee is paid to the District."

C.	Any request to defer fees shall be made in writing by the applicant when the
application for Authority to Construct and Permit to Operate is submitted to the
District. The Permit Processing Section will process the application without
renewal and/or source test fees (depending upon the request) when such a written
request is received. The Permit Processing Section will identify on the application
if any fee(s) have been deferred and the amount. The Permit Processing Section
will provide a hi-lighted copy of the application to the Compliance Division. The
Permit Processing Section will not subtract deferred source test and/or permit
renewal fees that would otherwise be due from the fees that are initially submitted
for the engineering evaluation.

D.	When the District engineer has completed the evaluation of the application, the
engineer will work with the applicant to develop a joint understanding of the
expected startup date and when deferred fees are due. The engineer will include the
previously specified conditions, as applicable, in the Authority to Construct and
ensure the Compliance Division is aware of such conditions. If there is
disagreement with the applicant over the expected time frames for emission unit
operation and/or source testing, this will be discussed with the Chief of Engineering
or the Deputy Director for Engineering.

When deferred fees are paid, the Permit Processing Section will send the engineer
handling the application and the Compliance Division a hi-lighted copy of the
application showing that payment of the deferred fee(s) has been made. The
deferred fees to be paid are those in effect at the time the deferred fees are due to be
paid to the District.

E.	Requests to defer other fees not covered by this policy shall be evaluated on a case-
by-case basis consistent with the intent of this policy. Such requests shall be
discussed with the Chief of Engineering or the Deputy Director for Engineering;
shall be coordinated with the Permit Processing Section, Accounting Section, and
Compliance Division; and shall be documented in the application file.

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Engineering Division Manual of Procedures

F.	This policy shall not apply to an emission unit installed or modified without a valid
Authority to Construct from the District.

G.	If the District determines a person/business which has deferred permit renewal or
source test fees has not submitted such fees as required by this policy, that
person/business shall no longer be eligible to defer fees to a later date. The
person/business no longer eligible shall include the owner/operator of the emission
unit and the applicant, if different from the owner/operator. In such case, the permit
processing engineer shall advise the Chief of Engineering and proceed with the
permit evaluation. However, a Start-up Authorization or Permit to Operate shall
not be issued until the deferred fees are paid. The Chief of Engineering shall advise
the appropriate person(s)/business(es), in writing, that the person(s)/business(es) is
no longer eligible to defer fees and the reason, and advise the Supervisor of the
Permit Processing Section. The Supervisor of the Permit Processing Section shall
maintain a listing of such ineligible persons/businesses.

H.	This policy will be revised to address any problems that may occur during
implementation.

2.4.11	Fee Estimates for T&M Applications (July 2012)

The District has received complaints about the length of time it takes to provide fee
estimates for T&M applications. To address this, please try to provide fee estimates
within one working day of a request. This may occasionally necessitate making your best
estimate of some components of the fee such as modeling and source testing.

If you have a particularly complex project, more time may be necessary to prepare an
accurate and complete estimate. If that is the case, please discuss it with your supervisor.

2.4.12	Labor Tracking Procedures (June 14, 2011, Modified June, 2012, February
20, 2013, October 14, 2013, September 29, 2020)

It is important for billing and fee development purposes that labor be tracked accurately
and consistently. In order to ensure the accuracy of the labor tracking, Engineering
Division staff are required to record their time on a daily basis, using the guidance in this
procedure. The supervisors are responsible for ensuring this is done. Additional
guidance on using BCMS time tracking functions is provided in Section 2.5 of this
Manual of Procedures.

With few exceptions, Engineering Division staff labor will be recorded in three BCMS
modules as specified below.

1) BCMS Workflow Module - All time spent processing applications (APP records)
shall be tracked in the BCMS workflow module under the appropriate workflow tasks
which are also tied to specific trust accounts. There are three types of tasks: tasks

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Engineering Division Manual of Procedures

common to all applications that are billed under the fixed fee portion of a fixed fee
application, tasks described in Rule 40(d)(5) as additional evaluation or processing fees,
both of which are tied to specific trust accounts used by Real Time Accounting (RTA),
and ad hoc tasks for other, less common tasks that are not tracked by RTA.

The following activities are the ones that are common to all applications for Authority to
Construct/Permit to Operate: application acceptance, initial application review,
completeness/incompleteness determination and notification, emission calculations, general
facility communications, engineering evaluation preparation, AC preparation and issuance,
field inspections and SA issuance, PO preparation and issuance, permit extensions and senior
reviews and approvals. The time spent on these activities shall be logged into the appropriate
workflow task closest to the activity.

Additional evaluation and processing activities time shall be tracked in accordance with
Rule 40 sections (d)(5), (d)(8)(ii) and Schedule 93, as well as Health and Safety Code
Section 42301.6 (AB3205). Specifically this will include time spent evaluating an
emission unit for compliance with Rule 51, Rule 1200 , Rules 20.1 through 20.8, Rules 26.0
through 26.10, Regulation X, Regulation XI, Regulation XII, Prevention of Significant
Deterioration (PSD), National_Emission Standard for Hazardous Air Pollutants (NESHAP),
State Airborne Toxic Control Measure (ATCM), CEQA or source testing. Only time spent
actually evaluating compliance with the rules and requirements listed above should be logged
under these workflow tasks (for both fixed and time and materials applications). Time spent
evaluating applicability of these requirements need not be logged under these workflow
tasks.

These workflow tasks shall be used to track labor as follows:

•	APCD Rule 51 - Time spent evaluating an application submitted to prevent a
nuisance or mitigate an existing nuisance (workflow task "Dist Prohibitory Rule
Analysis")

•	APCD Rule 1200 - Time spent evaluating compliance with Rule 1200 including time
spent for a deminimis screening (workflow task "Toxic NSR Rules Analysis"),

•	APCD NSR - Time spent evaluating compliance with Rule 20.1 - 20.8 when a
specific requirement of NSR is triggered such as BACT, AQIA or offset provisions
are triggered. Time spent on simple NSR tasks such as use of BACT look-up tables
need not be tracked as an Ad Hoc task if the time spent does not exceed one hour,
(workflow task "Dist NSR Rules Analysis" or "AQIA")

•	APCD TIV - Time spent on District permit applications for an enhanced ATC for
Title V facilities when those applications require action because they constitute a
Significant, Minor, Administrative, or Operational Flexibility Change as defined in
Rule 1410.

•	APCD NESHAP/ATCM/NSPS - Time spent evaluating compliance with and
implementing requirements of NESHAPS, NSPSs and ATCMs if other than standard
evaluation techniques and permit conditions are used(workflow task "State and
Federal Regulations" then pick the appropriate regulation from the drop down box -
HSC for state regulations, HAP for federal regulations).

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Engineering Division Manual of Procedures

•	APCD CEQA - Time spent evaluating applicability of and verifying compliance with
CEQA requirements if that time exceeds one hour, (workflow task "State and Federal
Regulations" then pick the appropriate regulation from the drop down box - CEQ)

•	APCD AB3205 - Time spent implementing the public notification requirements of
AB3205 in accordance with H&SC 42301.6. (workflow task "AB3205 Review and
Notification")

•	APCD PSD - Time spent evaluating and enforcing provisions of Rule 20.3.1 (upon
implementation), (workflow task "State and Federal Regulations" then pick the
appropriate regulation from the drop down box - PSD)

•	APCD Testing - Time spent witnessing a source test or reviewing source test results
in accordance with Rule 40, Schedule 93. (workflow task "Source Test")

Time spent considering and responding to public or oversight agency comments on
applications shall be logged under the appropriate workflow task the comment pertains to.

Ad Hoc tasks can be added to the workflow for activities that are not otherwise covered. One
of the common activities that would need an Ad Hoc task added is reinspection's:

•	APCD Reinspection - Additional time to inspect an emission unit if the initial
inspection could not be performed due to circumstances beyond the control of the
District in accordance with Rule 40(d)(8)(h).

For work done under an HRA record for AB2588 Health Risk Assessments, all time
spent after the emissions inventory was approved and the site notified they must
conduct a HRA shall be logged into the HRA record. This includes time spent on
reviewing emission factors and possibly revising the approved emissions inventory, and
all work associated with a required public notification. Risk reduction plan labor shall
be logged under the APP record for the PTO where the required permit conditions will
be placed.

For determining if a piece of equipment or process requires a permit where we need to spend
time on an evaluation (such as for emission factor development, health risk assessment, etc.),
the labor shall be logged into a JOB record and tracked pursuant to Rule 40(f)(10).

Logging overtime

Expedited Applications - If you are working on expedited application please make sure to
click the "overtime" box shown below to ensure accounting identifies the charge and pass the
cost to the applicant, as required by Rule 40.

Te .•	¦ - ....	-....

AUi.i'i 8/ 0:visw 1 rjirrK?.j,,j):yNj.;a	By	Assigned lo Division

rf.vHS-pf-v.-r,	Vj Y*I|.--v	v: APCD Engineering

Assigned to

Current Status

!	jAtt + S) »	Hours Spent {AH ~ HJ Status Date -

[		I	 [01/192021	jL3	: &Vertf,ie

Comments

a

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Engineering Division Manual of Procedures

Overtime approved by your supervisor - When working overtime to address special projects
or any other tasks, you do not need to click the "overtime" box as the cost associated with
these tasks are not passed to the applicant.

JOB records shall also be used for the following tasks (unless directed otherwise):

•	Rule Development support

•	Fulfilling Public Record Requests (when we must create documents or analyses, so
our time is billable)

•	Reviewing and commenting on Major Use Permit or CEQA projects that don't
involve current permit applications

2) Time Accounting Module - The following codes will be used to track time spent
on activities that support a primary activity of the Division but are not directly related to
application processing or currently permitted emission units:

•	Supervision - Supervision of staff (Seniors only)

•	Training - General or technical training such as safety training, BCMS training,
ARB or EPA classes, reviewing new rule and regulations, etc.

•	Labor tracking - Time tracking in BCMS and KRONOS.

•	General/Review - General activities not directly related to a permit application or
a currently permitted emission unit.

•	Meeting/Conferring - Discussions, meeting or other contact with District staff or
external customers when not directly related to a permit application or a currently
permitted emission unit.

•	El (Emission Inventory) Review - EI work (Toxics or Criteria) that is directly
related to producing EI Reports. In the notation box in Time Accounting, enter
the EIF ID of the facility(ies) worked on. Add a separate labor entry for each
facility. If a facility is also fulfilling AB-617 inventory requirements, split the
labor between EI Review and AB-617. If processing Industry-wide facilities,
include all the time in one entry and enter "Industry-wide" in the notation box.

•	EI General -EI work related to implementing the EI programs in a general sense
which includes, but is not limited to, tracking, administrative activities, working
with Compliance and addressing issues that affect many facilities.

•	EIS Development - Work associated with improving the EIS online database
application.

•	AB-197 - Work associated with applying for or reporting under AB-197
inventory grants. The actual inventory work is logged under EI Review.

•	AB-617 - Work associated with implementing AB-617. In the notation box,
indicate the type of work as follows:

o Meeting
o BARCT
o Permit Applications

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Engineering Division Manual of Procedures

o Community Emission Reduction
o Mobile Source Incentives
o Stationary Source Incentives
o Community Monitoring
o Emission Inventory
o Stationary Source Inspections
o Mobile Source Inspections
o Administrative

For emission inventory work, also include in the notation box the EIF ID of the
facility(ies) worked on, adding a separate entry for each facility. If a facility is
also fulfilling criteria or toxic inventory requirements, split the labor between EI
review and AB-617.

Costs for time logged to the Time Accounting Module will be recovered as part of the
hourly labor rate as specified in Schedule 94, except for EI Review and EI General (that
are paid from emission fees) and AB-197 and AB-617 (that are paid for from state
grants).

3) Equipment Type Modules - the following codes will be used to track all time spent

on currently permitted emission units, but are not associated with a particular permit:

•	Meeting/Conferring - Meeting and discussions necessary to address issues related
to multiple currently permitted emission unit.

•	Annual Permit Review - Annual review of specific categories of existing permits
per H&SC 42301(e).

•	General/Review - General activities related to multiple currently permitted
emission units.

•	NSP S/NE SHAP/ AT CM - Time spent implementing NSPSs/NESHAPs/ATCMs
for multiple currently permitted emission units.

•	Time spent reviewing equipment or processes required by a prohibitory rule that
does not require and application. As an example, review of coating spray
equipment required by Rule 67.20(d)(3)(vii).

Costs for time logged to Equipment Type Modules are recovered from renewal fees or
application fees, depending on the specific task(s), or, rarely, as part of an equipment type
special assessment. Approval of your supervisor is required if time charged to any
specific Equipment Type Module will exceed five hours for any project.

2.5 BCMS Procedures

2.5.1 B CM S record structure

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Engineering Division Manual of Procedures

As shown below the general structure of the records for every facility is the original
application and then the permit. Under each permit you will have all activities related to
that permit, including all modification applications and compliance records

Record ID: APCD1978-SITE-00031 *

Menu ^ List View Clone Sgl Clone Mult Upd

You can view all records (i.e. applications,
permits, compliance actions, etc..,) for a facility
under the site record

Go To ~ 4 istory(1) Related Records

Once you select the site record
click on "related records"

Loo

Wo

B-

^ APCP1973-SITE-00031 fLUEG-APCOAdminislrative.Stte.Nfll : Status: Active

-t.	APCD2OO0-APP-974536'

B U> APCD200S-PTO-974S35.

iLUEG-APCD.Acfmi

. J> APCD2C01 APP976803
D> APCD2003-NOV-213118
~ ~ APCD20Q7-NOV-219229
> APCD200Q-CAP-0Q5-33 -

Original application that generate
the permit



Perm it to Operate

|~> iLUEG-APCD.Comphsnc
¦>HUEG-APCD,CQmplifl n t

All activities related to the above
permit (including modification
application and compliance
actions)

LJ ~ APCD2000-OWC-97-903 -> [LUEG-APCD.AdminljS
B I l> APCD200l-CER-9773S4->[LUEC-APCD,Admifli:JMtivft3l

> APCD2002'PT0-9773S4 -> [LUEG-APCD.AdmlfHiMtjvt.F
B D ~ APCD2001-APP-97C771 -> [LUEG-APCD.Pwinit App.Mucetlan
B	APCD2Q06-PTO976771 -> [LiJE&AFCD.Adminiil»ti«,F

APCD20T3-APP-003144 JLUEG-APCDPffmit App.Miscellan#eu» EquipmentMA], Status Appi
B	APCD2001 -CER-976533 -» [LUEG-APCDrC*n.fic®!# App.Spa* IC Engine,MA], Status Approved

S i ~ APCD2003-PTO-97SJ33 -> [LUEG-.APCD.Aannir»iUf»tiv«,Pwmit To Opwate.NA]. Status: n*lir*d

~ > APCD2007-NOV-219229 -> JLUEG-APCD. Compliance Notice of Violation,NA]. Statu* Cloud

2.5.2 How to search records in BCMS

Click on the search bottom from the BCMS home page

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Engineering Division Manual of Procedures

Home Mv Tasks Contacts Addresses Inspections

GIS

Invoices

My Navigation

U _ ~

Record

~

D

y
~

Record Data
Record Tables
Related Records
Fees

Fee payment
Trust Account
Workflow
Inspections
Renewal Info
Contacts

Menu ~

Search

New

23456789 10

~ Record ID

Record Type

r|] APCD2014-HBD-0Q037 LUEG-APCD.i

~ APCD2014-VRT-0596 LUEG-APCD/(

Notification

You can search using any of the fields under search. The following screenshot labels the
most common fields used in engineering. You could also use multiple fields
simultaneously

Submit

Record ID

%PTO<*f

Cancel

New

Record Type

Group

ype

% is wildcard

Subtype
-Seted-

IUEG-APCD = -Seted-
Contael Orgnnlrabon Name Address Line 1

Help

Opened Date
From:

To: OeitM.OTU

City

~

Category
-Seted-

Hp

3

Statu*

•Seled.

/

Contact Type

-Setett-

Stiort Notes

Record Name

Contact Full Name

E-mail

Assigned to Division

Current Division

Assigned Date:

Assigned to Ss
-------
Engineering Division Manual of Procedures

3.	This field has the status of the record. So if you only want to see open records, for
example, you need to select "open"

4.	You should always select LUEG-APCD to expedite the time to generate the record(s)
you are searching

5.	The fields "Type", "Subtype", and "Category" should be used to specify the type of
record(s) you are searching. For example, the following screenshot shows a search for all
application records for cold solvent degreasers then that 5 ft2

Opened Date:

From;	L

To: 08/04/2014	[3

Record ID
%APP%

% is wildcard

Statu i

¦QiP|ar"f
— OCICC.L—

Record Type

U'OUD

vpo

ne I'm: App

Subtype
Deqreasc

r 		.

6.	Organization name is used for the facility name. You can also search on the address
(equipment location) using the address fields.

7.	These fields are very useful when you want to search records with a certain set of
conditions (i.e. BEC or CON) or records for a certain fee schedule. Please refer to the
following screenshots for examples

Record Data

Record Specific Info Label Record Speclic Info Value

Rpcwfl TABI F Data Record Specific TABLE Label	Record Specific Table Value

%91A%

Task Specific Data Ta,k Speclic Info Label	lath Specific Info Value

Or

Record Data

Record Speclic Info Label Record Specific Info Value

%CQN-000269

Record TABLE Data Record Specific TABLE Label Record Specific Table Value

Task Specific Data

Taik Specific Info Label

Task Specific Info Value

The following searches key words in the equipment description:

Record Data

Record Specific Info Label
Permit Description

Record Specific Info Value
%functional%group%

Record TABLE Data

Record Specific TABLE Label

Record Specific Table Value

Task Specific Data

Task Specific Info Label

Task Specific Info Value

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Engineering Division Manual of Procedures

2.5.3 How to prepare an Authority to Construct (ATC) or Permit to Operate (PTO)-
(August 13, 2009, revised June of 2014)

Make sure the contacts are complete

If you working on a PTO you will need to select the PTO record. The PTO record should
have the highlighted contacts shown below:

Record ID: APCD2013-PTO-001906

Menu ^	New	Delete LookUp	Help

Summary Record • Permit to Operate Activities (0) Activity Summary (1) Ac

~

Contact ID

Type

First Name

Last Name

Orq Name

D

62524235

APCD Customer

Lawrence

Kourie

Carlsbad Gas & Car Wash...

~

62524213

APCD Equipment Location

Lawrence

Kourie

Carisbad Gas & Car Wash-

O

62524236

APCD Equipment Owner

Lawrence

Kourie

Carlsbad Gas & Car Wash...

D

62524234

APCD invoice Mailing

Lawrence

Kourie

Carlsbad Gas & Car Wash...

¦

62524237

APCD PTO Mailing

Lawrence

Kourie

Carisbad Gas & Car Wash-

Existing permit records should have all contacts you need to create a PTO report. If you
encounter incomplete contacts please contact the permit processing department or the
senior engineer.

If you are working on an ATC you will need to select the Application (i.e. APP) record.
The APP record should have the highlighted contacts shown below:

Record ID: APCD2012-APP-002456







Menu 7

New

Delete

Look Up Help











Go To ~

Summary

Record

- [26 A E F] GDF Activities (0)

Activity Summary (14)

Addre:

i Contact ID

Type

First Name

Last Name

Ora Name

I 62171097

APCD ATC Mailing

Lawrence

Kourie

Carlsbad Gas & Car Wash-

I 62171094

APCD Customer

Lawrence

Kourie

Carlsbad Gas & Car Wash-

1 62171092

APCD Equipment Location

Lawrence

Kourie

Carlsbad Gas & Car Wash-

i 62171096

APCD Equipment Owner

Lawrence

Kourie

Carlsbad Gas & Car Wash...

i 62171093

APCD Invoice Mailing

Lawrence

Kourie

Carlsbad Gas & Car Wash...

How to create a new permit record

If you are creating a new permit record (i.e. you are issuing a new permit as opposed to
revising an existing permit) you will need to create the permit record as follows:

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Engineering Division Manual of Procedures

Select the application you are working on
and that will be associated with the permit
you are creating

Record ID: APCD2013-APP-003013*

Menu w List View Clone 5g1 Clone Mult Update Related Records

Search

Up

Go To ~

Related Records

Renewal Ir

SI '3 ~ APCD2009-SITE-06827 -»(LUEG-APCD.Admimstr
B $ ^ APCO2013 APP 003013 .> [LIIEG APCD.Penwt A, ,

atus Trust Al

Select related

records

Select "Clone Mult"

I Status: Opon

Click submit

»||i^!rd ID; APCD2013-APP-003013
Submit	Cancel	Help

Go To v 4

Related Records

Please select

EJ-"^p Record Type

Eh J LUEG-APCD
Eh _j| Administrative
Eh LLj Change
Eh _J Condition
Eh Cl Legacy Data
R} Permit To Operate

Eh Q Safety
Eh _J Site
Eh Cl Title V
Eh Q BCMS
Eh Cl Certificate App
Eh _l Complaint

Open these files until you can find "N/A"
under "permit to operate"

Status Trust Accounts (3) Workflow Workflow I

Please select I he Record Type

lUEG-APCDi'AcfmiiuslrativeyPermit To Operate/NA

Click "N/A" and then click on this arrow to
select the record

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Engineering Division Manual of Procedures

Click submit

8

7

Help

Rt-cord Specific Information:

C fee Menus

Wdrtflbw Static,
taapetUM) CSe4ect>

Record Sp«<»c Wo iSefeco
C	via

r Valuation Case

Woridkw T ask SpetrfK HormatKwi
Stall* « New Slatus -Select-
Status ttsfc**

G tn*rjl Record Infon

O Parcel
B PwcdOvmci
AtMrtiii.

23 Sftjcture
licensed
 APCD2009-SITE-06627-> [LUEi^fl^^Gmlristrative.Site.NA]; Status: Active

9 I	APCD2013APP 003Q13 ^[^ffT^ APCD.PermitApp,Pharmaceutical Manufacturing,fiA]; Status: Open

>¦ APCD2014-PTO-001836 -> [LUEG-APCD,Adminislrative.Permit To Operate,MA] Status. Unapproved

Record ID: APCD2013-APP-003013
Menu ^ List View Clone Sgl

Enter record specific information

When working on a PTO you will need to select the PTO record and click on the "permit
to operate" tab and complete the appropriate field as shown below:

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Engineering Division Manual of Procedures

Click on the "Permit to Operate" tab

Record ID: APCDI014-PTO-MH99
Save	Reset	Help

Go To '

Summitry Record - Peroirt So Operate ActiviSfi (0)

Enter the permit
equipment description

A4dt kite Calendar

Permit Description

One (1) enclosed heated rte^atsvefy venliialed pa: ni spray booth
Itanulacturer Saico,

Model GA

Serial Number 950615R

Dimensions T25 (eeE wide * 23-5 fee? long * 10 feet tagJr

Stadk heigrn 21 (eel.

Ram Op: FtUKt. HoWOTal,	sWltX,

Equpped with standard Mere.	

12.500 dm etfiaiisi
Integral t OimionfiTUper

check spoiling

BEC

APCOZOlJ-CON-OOOCTS"
Throughput

EQUIPMENT TYPES

Indicate if
stationary or
portable

Enter the CON or BEC number
which corresponds to the set of

Type ¦ [Portabte/Stationary]

Stalioraf*

V

F legacy Osta

Teg Information

Source tett Required

Yes " No

Source Test Frequency

unit crMMiil

Enterthe number of units and fee schedule and
whether or not it should be assessed as a renewal

Source Te*t Frequency

1

Number Of Unfai	j- Equipment TW»

I	|2TH] VertcteRefimshfigOpHaljore

Alien pn Renewal
¦> Yes No

VERSION HtS TORY

Version Numberi liiEfte r Revision Date

Application-" fat)

StteTTexU Reason

HoteiOwjSJ



1 M/1W014

3 APCD2011APP-003161

flPCO2SllSffEJMlS10 frtlial

* R10

After using the "add" button to add a new ro w you will
enterthe next version of the permit, date of review,
application U, select reason and add note if necessary

When creating an ATC report you will need to select the APP record, click on the
"workflow" tab and complete the appropriate field as shown below:

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Engineering Division Manual of Procedures

Record ID: APCD2014-APP-003518
Submit Assign	Reset

After selecting the APP record for which you are
issuing the ATCr you will need to click on the
workflow tab to view the workflow

Task Details Sub Tasks (0)

Workflow Tasks

~ Jj Appii canon Acceptance
It. £> Supeo*"" Pa*"ew
£ Jj Engint n iluation
S _j- Cotno £-
gj ._^j Bat*
if i_J Emus
IS |2j Dist

Jetermmalion

Click on the "process
description" tab

Analysis
Notification
ederal Regulations
ATC F^omn>c-ndJ3tjons_Conditi Dns
* _J Process Description

sk Details - Process Description

Action By Division " Current Division

APCD Engineering

Current Status

Billable (T&MJ

Action By [ACI

Mahiarty Luther
CI
fe<

New Status (Alt + S) (ACAJ

Complete

Hours Spent (Alt + H) •

Equipment Description

Comments [Ai
Bbstandarj

After entering the equipment description click on
complete and enteryour hours

check spelling

Complete the field name "equipment description"
to enter the description you want to appear on
the ATC report

Add conditions

There are three ways you can add conditions to a PTO or APP record: copying conditions
from an existing record (i.e. PTO, APP, or CON), adding individual conditions, or
creating new conditions. Please note that for PTO you will always copy conditions from
an existing CON record or BEC.

Often you will need to use all methods for ATCs because you might find another record
with most of the conditions that you need but you might need to delete some condition
and add others before you can generate your ATC report.

Copying conditions from existing records

-55-

-------
Engineering Division Manual of Procedures

Record ID

First select the record you want
to copy the conditions from

^ APCD?Ql1-CQN.0aQ263 LUEG-APCD/Adrr ^ BrfCbndtion/NA

Org

26E-Ph)

Select the
related record
tab

Clone Mult Update Related Records S

My QuickQueries

Copy	| Related Records

Print Page

3 ® ^ APCD2011 CON OOQ269 » [LU£G APtQ jWmimsliative.CondilioiuNAj ; Status: Active

Renewaffnfo Status Trust Accounts (l

Click submit



RecBI 10; APCD20t1-CON-G002*9
Sutwmt Reset Cincet

Copy To Record'

Copy To A Set:

Record Specific Information:

Fee Hems
'] Workflow Stalls
O Inspection (Ssjeeti

Record Speciftc Wo CSfitefiU
Additional Wo
VlkittonCftlC

WOddVW Tn^k Spfrtrfit Wc*mflbOn
Swius & sj«cu$ -Seifd- *

Help

Search the record you wantto
copy to. The search screen is
identical to the search screen



General Record Information:

G Parcef

Parcel Q#nei
B Address
CI Structure

Licensed Piolpssiwnfe

CI Comaa
Docurrwrl

You only need
to click "record
conditions"

R«.ofd Conditions issitai
msfseoton Condi lions [ggjj&U
Conditions & Approval JSsfeCt)
Education

Cortirung EduraSigfi
Ewmtrvilion

Once you click "submit" the records for which you copy the conditions to will have the
new conditions. You can copy condition from ANY record to another record.

Applying conditions individually (for ATC reports only)

-56-

-------
Engineering Division Manual of Procedures

After selecting the record for which you
want to apply the condition to, click on
"condition"

Conditions

Change Statu1 1
Status History
SusnflaoLEalnx

orts

td — Q

1y Reports
iPCD Accounting
iPCD Compliance

whimm

iPCD General
iPCD Permit Processing
iWM Admin
,UEG Finance
iystem Administration

Click on

n

¦	

*

¦

, .!





V



f	

Record ID: APCC*014-APP-Q03523
Menu "v	New	Reorder

Go To

Display Type
Order

Condition
Name

Delete

Summary Record • [26A

Short Com

Record ID: APCD2014-APP-003523

Submit

Reset

Cancel

,J" | Click on standard condition



/



w

Go To ~

Sunwran

Record

- :--n

P- 3



r

-Select-	'	-Select-

Short Comments S^Standard Comment

-57-

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Engineering Division Manual of Procedures

Record ID; APCD2014-APP-003623
Submit	Reset Cancel	Help

Go To ~
Condition Name

Severity

--Select-

You can enter the condition numberstartingwrth "C"

Search Tags

Condition Group

APCD

Short Comments

You can enter the BEC number, fee
schedule or CON number associated
with this condition using %

Display Notice

Accela Automaton
ACA

ACA Fee Estimate Page I

Condition Type

-Select-

Long Comments

You can enterthe condition verbiage or
part of the condition verbiage using "%"

check spelling

After specifying the search criteria click submit. The condition will appears as shown
below

Record ID: APC02014-APP-003523
Reset Cancel

Press "shift" and click on the
condition. If you don't press

"shift you will need to
conduct your search again

Help

Conditions

Ip' Si Standard Condition Typo * Stand J

0	- PTO Corete

w^

fommenl
fJ ]C290W-Sepa"Jleiisage

My Taska

~ Task Seamng
Menu V Assign

A separate screen will open and
you will be able to viewthe
condition and decide if it is the
condition you need. If so, click
submit and the condition will be
applied to your record

sta

At

Short Comments Btstandard Comment

C29099 • Separate usage records sta) be

chfrrit ipelHrvq

Long Comments tt'Standard Comment

Separate usage r ecords shal be maintained^ each spray booth, on-site on a montliiy basis for a penod of
fit (east three years a it) shafi be made readily available to Bie Oistnct upon request Records shall at
minimum certain the fc«owifia tnformairon
-type ot substrate coaled (metal parts, aerospace ewnponerts. etc)

¦the type of eoatrng applied Ibasecoat, harderier, thinner. dean-UK etc induing 1he majvulaclufef's
KJenbticati-on Number)

-mi ratios and uoUnes of eacii matenai cortaining VOC's used
IliLte 20,2)

|ri»ior

-58-

-------
Engineering Division Manual of Procedures

Creating new conditions (for ATC reports only)

Address [Inspection ^

Conditions
ciT^me Status
St.s^^^Jistory

Record ID: APCD2014-APP-003508
Menu ¥ New	Reorder

orts

Go To t

After searching the record you
want to copy the condition to, click
on the condition tab

1y R
vPCC

iPCD Compliance
kPCD FnainRerinn

Display Jmm
Order

Then click new

Delet

[26,

She

nainc

Record ID: APCD2014-APP-0Q3508
Submit Reset Cancel

Help

Go To w

Group Efc Standard Condition Type 3) Standard Condition C<

-Select-	' -Select-

Short Comments 9l Standard Comt 3

Then click on standard condition

Record ID: APCD2014-APP-003508
Submit	Reset	Cancel

Go To *
Condition Name

Severity

-Select--

Name the condition

APCD
Short Comments

Enter the condition verbiage
and click submit

¦Condition Type

ATC Conds

ong Comments

check spellinq

-59-

-------
Engineering Division Manual of Procedures

Once the condition is applied to the record you will need to renumber the conditions

Record ID: APCD2014-APP-003508

Menu w	New	Reorder	Delete

Go To

4 <

Summary
2 3 4 ~ tL

ec<

Then click

Display
Order

reorder

Name

~

m	2

0	3

~	4

H	5

n	r

Running the report

- [26A

IShort Cor

ATC REPORT

Se'ect the APP record for which you are
generating the ATC report

j - unanoesHiiK
Status History
Summary Entry

Record ID: APCD2O14-APPOO3508

Menu W New Reorder Delete Vi

Reports

>	My Reports

>	APCD Accountftiy

>	APCD Compliance

ATC Expiration Emal
App Complete Email1
Aulfi to Consl Email
Authority To Constni
CCN Notice

Certificate of Recislralioi
Condrtion History Ret
EASIER

Engine en na Evaluation
Engineering Peforman«

Select "Authority To
Construct" under the "APCD
Engineering" reports

~
~

Summary Record -[2 6 A Acl

report set Parameter - Window Internet Explot

Submit

ord ID ¦

Cancel

He>p

D2014-APP-003508

Aseparatescreen will open. Click
subm it to view the report

-60-

-------
Engineering Division Manual of Procedures

FTQ REPORT

¦H PrcoiTnqjfit>

£3 Add rg-»i f I	Hon 1

(_] CDiidj.lfr.ns

^ EhaftOfi-Slalits
f" jflaliis History
.d? Summary Entry

Reports

** _ ~

>	My

>	APCOAetOtittfoftg

>	A PC ti Comp4iartC«
yfrlikViIff ¦¦-"*' llfftj

atc Eieifation Email
Acs CommM* Ewa»
Mh\a ConstEmail

To Cwstnid
CON Nonet

CtnticMo i?i Rtoiitraiio
Condilien Hisioi-» Rtn
EASIER

EnfliiMWifla EvaUiaimn
£notn««rino Pt-toiwanc<
Coifj ftfiplleatiafli;
p«wnim Opfcfatt

CI-UlLi lin. il

jihan

manc< . A

in

Select the FTO record for which you are generating the report

: ' rt£eftset Parameter ¦ Window* Erd!D>

^b?i304-PTO-050?lO

rA

Record ID: APCD2OO6-PTO-fl3071O

Uwu ?

Go To

Murtsr

Sumnsar

RCOflttf

RCCOfC

tesfta*
Ordw

2

2 * N

tree

pro Cends
PTOConds
ptq conds
PTO Conds
PTOConds

02
Hi

022

C29

£22

C2S3M

C26323

A separate screen will open. Click submit to
view the report

SeJect "Perm it to Operate" under
the "APCD Eng ineeririg" reports

2.5.4 How to use documentum (created:September 25, 2009, revised in October of
2009, June of 2010, and June 2014

Section 1: What do I upload?

A.	The following documents should be posted under the APP record after the
Authority to Construct is approved:

Completeness Letter
Incomplete Letter
Relevant Correspondence

Complete Engineering Evaluation, including calculations and HRA/AQIA results (signed
by the Senior engineer)

Approved Authority to Construct (signed by the engineer)

B.	The following documents should be posted under the APP record prior to
submitting a Permit to Operate for approval:

Pre-backfill inspection reports (Vapor recovery sites)

-61-

-------
Engineering Division Manual of Procedures

Field inspection reports, including pictures

Test results

Startup Authorization

CCNs

Invoices

The following document should be posted under the PTO record:

Permits to Operate

Section 2: How do I upload my documents?

Click on the Document tab or Click on "Go To" =>"Documents"=>"Documents"

seu Hioiessiouais casmei session trust Accounting lime Accounting ui»

E3 Menu ' Search	j^j New	GIS	Help My QuickQueries i --Select-

iri * 1 i» \A

~ CAP Reference	Type

i—, APCD2008-APP-937052	LUEG-APCD/Permit App/Vapor

¦—1	Recovery/EVR Phase II OTC

Organization

V Module LUEG-APCD

Assigned to Staff	Status	Opened D

Joe Herzig	Open	07/31/20C

CAP Reference: APCD2008-APP-987052

New	Download (SQ Info V Help

+ Go To 4 | ciiendoi Classic Reports Comments (1)

Conditions (0)



EntitvTvwe

Cateciorv







Tvt>e







Size

Inspections
Hearings
Pi operties











CAP

APCD-General-Report

2048

OOl.Ddf

3.82 MB

pdf

Fees and Cashiei



¦"^" jGenera I - R ep ort





318.33 KB

pdf

Documents >

Documents





Workflow
Renewal Info

CAP

APCD-General-Report

2050

001.Ddf

2.92 MB

pdf

People

CAP

APCD-General-Report

2051

OOl.odf

722.95 KB

pdf



~

CAP

APCD-General-Report

2052

OOl.Ddf

285.44 KB

pdf

~

CAP

APCD-General-Report

2054

OOl.odf

394.07 KB

pdf

j—j APP 987052 TEST...

CAP

APCD-General-Test-Report

987052 TEST RES

4.73 MB

pdf

You will be prompted to enter your Documentum User Name and Password

https //bcim sdcounty ca gov - User Aut [«j

Connecting to DOCtTMENTTJM

Usemame:

Password:

~ Remember tins usemame and password
| OK | | Cancel |

&J Done	j0 Internet

-62-

-------
Engineering Division Manual of Procedures

You may be asked the following: Click "Yes".
Security Information

This page contains both secure and nonsecure
items.

Do you want to display the nonsecure items?

Yes

No

More Info

Click on "New"

sen Kioiessiuiidis liismei session 11 usi m;coiiihmy nine Auctjuiumy uis>

CAP

1H Menu	Search Q New	GIS V Help My QuickQueries I --Select--	"v| Modi

W 1 ~ i>*i

~ CAPFSefeieuce	Type	ui ionization	flssiinieil to

~

APCD2006-APP-987052 LUEG-APCD/Permit App/Vapor	Joe Herzig

Recovery/EVR Phase II OTC

CAP Refeience: APCD2008-APP-387052

IHl Menu CT,t Ne») jf^i Download Bj Info / Hel|)



M -il i 2 A







~

Descrmtion

EntitvTvue

Cateuorv

File Name

~



CAP

APCD-General-Report

2048 001.od

Click "Browse"

CAP

ill Menu	j search	Q New © GIS	Help My QuicfeQuerto [-Select-	|^~t Module I LUEG-APCD

M i i M	.		

Q CAP Reference	Tvtte	Oii ionization	AssiimeiltoM.iff Statu

n APCD2008-APP-9B705:	LUEG-APCD/Permit App/Vapor	Joe Herzig	Open

u	Recovery/EUR Phase II OTC

CAP Reference: APCD2008-APP-987052

~ Save O Reset

Q Cancel f Help

+ Go To ^Jn History

Assess Fee History Calendar Classic Reports Comments Conditions Contacts

File Name * up to smb /

" N



Browse... \)

Category

	^

--Select-

1 v3

Description



Source *



DOCUMENTUM [v



Department



APCD Engineering

ImI

-63-

-------
Engineering Division Manual of Procedures

Select the document you want to add: Click "Open"

Choose file

I

Look in:

Recent

Desktop

J

My Documents

&

My Computer

> 987052

il Recent
Desktop
m My Documents
i Scans for BCMS
l£l 10-8-09
S87052
« My Computer
Local Disk (C:)

DVD-RAM Drive (D:)
sharris3 on 'Cosdi035\Users' [H:)

<*; Apps on 'cosdal 86' (J:)

lueg on 'cosd.co.san-diego.ca.us\sandfsroot\
enterprise on 'cosd.co.san-diego.ca.us\sandf
•¦y aped on 'cosd.co.san-diego.ca.us\sandfsroot
My Network Places	

(S &

My Network Filename:
Places

Files of type:

987052 SA.PDF

| All Files ("1

"1]
"3

Open

Cancel

Choose file



Look in:

| _> 987052

3

E &

Jtl

Recent

Desktop

J

My Documents
My Computer

1987052 CAR.PDF;

937052 INSPRPT.PDF
987052 ISD.PDF
^ 987052 NTC.PDF
987052 PHOTOS.pdf
cT~987052 SA.PDF ~^>

987052 TE5T RESULT5.PDF

My Network Filename:
Places

987052 SA.PDF

Files of type: | All Files

"7]
3

Open

-64-

-------
2.5.5 How to name documents in BCMS (created on November 1, 2012, revised on December 12, 2013)

The intent of this procedure is to consistently name documents posted in BCMS (under documentum). The following table lists all
engineering related documents and describes how to name each document.

Type of
Document1

File Name

Document2

Group/Category3

Division4

Description5

Supporting
Application
Records

APPXXXXXX
Records

APCD-GEN-
Document

APCD-General-
Application



E.G. manufacturer information
on emission factors/source tests
supporting the emission
factor/BACT costs

Completeness
Letter

APPXXXXX
Completeness
Letter

APCD-GEN-
Document

APCD-General-
Letter





Incomplete
Letter

APPXXXXXX

Incomplete
Letter

APCD-GEN-
Document

APCD-General-
Letter





Relevant
Correspondence

APPXXXXXX
correspondence

APCD-GEN-
Document

APCD-General-
Correspondence

Click on "Current
Division"

Briefly describe the content of
the correspondence (e.g. permit
conditions, VOC limitation,
comments of draft ATC,
additional information required
for the HRA, justification of the
"trade secret" designation
etc...)/Variances/Appeals

Public
Notification

APPXXXXXX
_Public_Notice

APCD-GEN-
Document

APCD-General-
Correspondence



Notification/Proof of
publication/Transmittals to ARB,
EPA, etc ./Public
Comments/Agency
comments/Applicant Comments

-------
Engineering Division Manual of Procedures

502(b)(10)
determination

APPXXXXXX
_502(b)(10)

APCD-GEN-
Document

APCD-General-
Evaluation

Click on

"Current

Division"

502(b)(10) determination

Engineering
Evaluation
(signed by the
Senior eng.)

APPXXXXXX
ATCEng.
Evaluation

APCD-GEN-
Document

APCD-General-
Evaluation



BACT Analysis

APPXXXXXX
BACT

APCD-GEN-
Document

APCD-General-
Evaluation



HRA

APPXXXXXX
HRA

APCD-GEN-
Document

APCD-General-
Evaluation



AQIA

APPXXXXXX
AQIA

APCD-GEN-
Document

APCD-General-
Evaluation



Calculations

APPXXXXXX
Calculations

APCD-GEN-
Document

APCD-General-
Evaluation



Authority to

Construct
(signed by the
engineer)

APPXXXXXX
_ATC

APCD-GEN-
Document

APCD-General-
Authority-to
Construct

N/A

Pre-backfill
inspection
report (vapor
recovery sites)

APPXXXXXX

Pre-backfill
inspection

APCD-GEN-
Document

APCD-General-
Report



Field inspection
report, including
pictures

APPXXXXXX

Inspection
report

APCD-GEN-
Document

APCD-General-
Report



VR test results

APPXXXXXX
VR test results

APCD-GEN-
Document

APCD-General-Test-
Report



Startup
Authorization

APPXXXXXX
SA

APCD-GEN-
Document

APCD-General-
Startup-Authorization

N/A

-66-

-------
Engineering Division Manual of Procedures

PTO Eng.
Evaluation

APPXXXXXX
PTO Eng.
Evaluation

APCD-GEN-
Document

APCD-General-
Evaluation



N/A

PTO Request
changes7

PTOXXXXXX
_ Request
change

APCD-GEN-
Document

APCD-General-
Correspondence

Compliance PTO request change

ERC

ERCXXXXXX

APCD-GEN-
Document

APCD-General-
Certificate

ERC certificate/Surrendered
ERCs

ERC Transfers

ERCXXXXXX
letter

APCD-GEN-
Document

APCD-GEN-
Document

Letter from Buyer/Letter from
Seller/Purchase & Sale
Agreement

Hearing Board
decisions

APPXXXXXX
HearingBoard
Letter

APCD-GEN-
Document

APCD-General-
Correspondence



Lead agency

CEQA
documents

APPXXXXXX
CEQA

APCD-GEN-
Document

APCD-General-
Evaluation



xType of document: This column lists all engineering related document that is typically posted in BCMS

2	File Name: You will need no name the file when you are saving the document or scanning it. The first part of the name should be the
APP number

3	Document: This column indicates what should be selected in BCMS (i.e. GEN or SEC) from the following drop down list. "SEC"
should only be selected for documents that contain proprietary information. In accordance with Rule 176, written justification of
the "trade secret" designation shall be furnished with the records so designated, and the justification shall be a public record. When the
engineering evaluation or calculation contains information designated as trade secret, the engineer should prepare another version of
these documents, without the trade secret information, which will be available for public review.

-PCD Engineering

Current Division

-67-

-------
Engineering Division Manual of Procedures

Group-Category: This column indicates what type of document should be selected in BCMS from the following drop down list

Record ID: APCD2010-APP-001067
Save	Add	Delete

Go To ~

"GEN" document types are accessible tc
Document Group/Category *

GEN

Division Current Division

APCD Engineering
Description

check spelling

Please use the fields at the bottom of th(

Apply Definitions to Selected

[r] Fife Name* up to 100MB Document Grc

[r] FW_ PO Change	qEN

Request-
PT0050295.pdf

APCD-General-Application	/

APCD-General-Authority-to-Con struct	*

APCD-General-Certificate

APCD-General-Civil-Actions

APCD-General-Construction-Completion-Notice

APCD-General-Correspondence

APCD-General-Evaluation

APCD-General-lnvoice

APCD-General-Letter

APCD-General-MSDS

APCD-General-Meeting-Minutes

.APCD-General-Notifi cation

APCD-General-Permit-to-Operate

APCD-General-Photo

APCD-General-Receipt

APCD-General-Report

APCD-General-Schematic

APCD-General-Site-Plan

APCD-General-Source-Test-Report

APCD-General-Startup-Authorization

APCD-General-Test-Report

AWM-G eneral-Application

AWM-G eneral-Certificate

AWM-General-Certificate (Includes Permits & Licenses)

AWM-General-Civil-Actions

AWM-General-Correspondence

AWM-General-lnspection

AWM-G eneral-lnvoice

AWM-General-Letter

" APCD-General-Application

3Division: You should always click on "Current Division" in BCMS so the appropriate division will appear

Document Group/Category	Division	/ Description

GEN

» APCD-General-Application

•» * APCD Engineering

Current Division

check spelling

-68-

-------
Engineering Division Manual of Procedures

6Description-. This column specifies how to name the documents (i.e. what to enter under the following field). Some documents, such
as Permit to Operate, do not need to be named because the selected category from the drop down list already specifically describes the
document. This column has "N/A" for the documents that do not need to be named.

/

; " ' *r ^P0D-G?ri9raKpi-Beaton	•» • -PCD Enciineenns	Current Division	t Folloiv Docun

ctecjt sjMllmg	T/pe faeoiiiti t

7These documents will be posted under the PTO record

-69-

-------
1.5.6 How to enter time under the workflow and ad hoc tasks. (September 11,
2009, revised October 2, 2009, December 15, 2010, and June of 2014)

The labor track procedure is in section 2.4.12 of this MOP. This procedure will only
show how to enter the time using BCMS.

When entering time under the workflow for an application, the following tasks should be
used:

Completeness Determination - The time entered under this task represents the
time spent to review applications for completeness (i.e. review information
provided, contact the applicant, prepare completeness/incompleteness letters)
ATC Recommendation Conditions- The time under this task includes all
engineering charges up until when the ATC evaluation is submitted for approval
Field Inspection- The time under this task includes the time to conduct the
inspection and issue a SA Authorization, which should be issued during the SA
inspection.

PTO Recommendation Conditions- The time under this task includes the time
spent preparing the BEC and permit to operate evaluation.

Workflow Tasks

•Application Acceptance
Sucen/isor Review-
+• _j Engineer Re-evaluation

ComeIeteness Detemiination
B a c> ro u n d An a iys i s
Ernissicns Calculations
Dist Prohibitory Rule Analysis
Dlst NSR Rules Analysis
__ AQIh
+• _| Toxic M8R Rules Anal;,sis

State a no Feceral Regulations
ATG Recornmendations Conditions
Process Description
AB 3 2 0 : Rsvi evv and N otificati on

¦ to Construct
Issue Authorifv to Construct

noletion Notice

Fielc Inspection
Issue Startup .Authorization

Source Test

PTO Recommernfatipns Conditions
Approve Fern it to Operate

Issue Permit to Operate
ndliation

-------
Engineering Division Manual of Procedures

When entering your time, please use the comment box to describe the task you are
currently working on. For example, if you are conducting emission calculations, you
should enter "calculations" as follows:

Record ID: APCD2010-APP-001432
Hi Menu I—~ Submit Assign

0 Reset |j3 Calculate Hours

0) Cancel

? j

<1 .

Help

+ Go To 41

Record Specific Info Tables Record Status History Related Records

Renewal Info

Status Sti

Task Details - ATC Recommendations Conditions

Assigned to Division^

APCD Engineering

Status Date *

|ll/30/2010 F]

Action By Division

| APCD Engineering

CommentsElsiarfflard Comment

Assigned to

Action By FACA1* Current User
| Mahiany Luther

Calculationsr

"|



1

Current Status

New Status [ACA] (Alt + S) >

Hours Spent (Alt+ H):'



r

Due Date

|ll/23/2010 l3_

tees based on your labor rate,

APCD Process Form

Overtime: [~

The following list has examples of descriptions that can be used under "Completeness
Determination":

Incomplete Letter
Complete Letter
Review

The following list has examples of descriptions that can used under "ATC Recommendation
Conditions":

Prepare ATC

Calculations

Prepare conditions

Discussion with other staff members

Prepare evaluation

Meetings

Public contact

Reviewing

Prepare rule evaluation
Prepare S/A

-71-

-------
Engineering Division Manual of Procedures

The following list has examples of descriptions that can be used under "PTO
Recommendation Conditions":

Calculations

Review charges

Prepare conditions

Discussion with other staff members

Prepare evaluation

Meetings

Public contact

Reviewing

Prepare rule evaluation

Ad hoc tasks must be used in accordance with the labor track procedure is in section 2.4.12 of
this MOP. This section only covers how to use BCMS to enter your time.

Record ID: APCD2Q13-APP-Q03110

Menu ^ New Supervisor Task Activation

Help

GoT

: i,

Workflow Workflow History (2)



Click NEW

EH_j Application Acceptance
S--Q- Supervisor Review

Select the APP record and click on the
workflow tab

Ad Hoc Task

Task Name ¦

-Select-

Task Description •

jj. Division ¦ Current Ovrston

Current User ^

-Sel*d-

3

E



Asshgii Dale • Duration

A second screen will appear. You

f 06/1»2014 3

will need to complete the fields

EE

(select the task, name the task,

j i BtRable

etc..,)

I



omy

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Engineering Division Manual of Procedures

Conditions

UUUI^^ I "w »_> I

|±! 	| PTO Recommend

l+i '"i Approve Permit to

1+1"
Ei

Once the task is created you can
click on it to enter your hours

ft Ad Hoc Tasks"

Si Q: APCD AB32Q5" AB3205

Task Details ¦ Review ¦ TMSR
Division * Currenl Division
APCD Engineering

Action By Current User
Maliian, Lutner

Com P -Standard Cnmnienl

Enter your hours, always click
the billable box, and select
"pending" to keep the task
open. The task should remain

check spelling

Current Status

Penc&ng

Hew Status ¦

-Select-

w

1 -Seted-

Complele



; Pending	



Hours Spent •

~ Billable [T&M]

Overtime

2.5.7 How to generate timesheet

2.6 Reactivation of Inactive Status Permits (Tom Weeks, April 2009)

Permits can remain in inactive status for extended periods. Permit that are in inactive
status do not undergo annual permit review as required by Health and Safety Code
42301(e). Therefore, prior to reactivation they must undergo evaluation to ensure that the
permit is adequate to ensure enforceability and is consistent with current requirements in
accordance with the following:

42301(e) Require, upon annual renewalj that each permit be reviewed to determine that
the permit conditions are adequate to ensure compliance with, and the enforceability of
district rules and regulations applicable to the article, machine, equipment% or
contrivance for which the permit was issued which were in effect at the time the permit
was issued or modified., or which have subsequently been adopted and made retroactively
applicable to an existing article, machine, equipment, or contrivance, by the district
board and\ if the permit conditions are not consistent, require that the permit be revised
to specify the permit conditions in accordance with all applicable rules and regulations.

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Engineering Division Manual of Procedures

This evaluation may result in significant revisions to the prior permit to incorporate new
prohibitory rule requirements, new state and federal rule requirements (NSPSs,
NESHAPS, ATCMs, etc.) and to ensure that permit condition language is consistent with
currently active permits. If changes to the permit are necessary, a revised SA should be
prepared and discussed with the applicant prior to issuance and the changes documented
using a standard engineering evaluation. Because the emission unit is not considered new
and is not being modified, it would not be subject to New Source Review provisions.

Fees for reactivation are specified in Rule 40 (e)(5) and include evaluation fees and a pro-
rated renewal fee. The evaluation fee is a fixed amount (49(b)) regardless of the actual
cost.

2.7 Permit Process Overview (Nick Horres, October 2020)

The District has a general process used by Engineering for most permit evaluations.

There are some situations where not all steps are required, only an abbreviated review is
necessary or additional steps are required. These situations are discussed elsewhere in
these procedures and in District rules. You should expect to follow each of these steps
except as specifically indicated by your supervisor.

1.	Pre-Application. For more complicated applications, the Applicant may request
to discuss the application prior to submittal. Engineers also provide fee estimates
and assist with completing application forms and discussing rule applicability for
potential equipment.

If an applicant specifically requests an invoice before submitting an application, an
invoice request must be generated. In this case, the engineer will forward a request to
the Engineering Aide and provide a fee estimate including all the needed site and
contact information, the reason for the invoice, i.e. "Deposit for the expected fees to
review an application for a [specify type of equipment]", invoice amount and contact
person. The Aide will then create an application record in "Pending Funding" status
and forward the invoice request to Accounting including the application number and
adding the site ID for new sites.

2.	Application submittal. The applicant will mail, drop off or email the application
which will include a general application form and usually attachments and
supplemental forms. They must also include a check or can pay by credit in
person or over the phone. The Engineering Aide works with front desk and
accounting staff to set up the application in BCMS.

3.	Completeness Review. Engineers review the forms and attachments to determine
if sufficient information has been received to review the application and deems
the application complete if so. If Incomplete, the engineers put together a list of
missing information and communicates this to the applicant. It is important to
catch as much information at this stage as possible, but expanding upon the
information submitted or additional information requests may be made if

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Engineering Division Manual of Procedures

necessary. Note that because Rule 18 places limits on the length of time the
District may take for review, an accurate completeness/incompleteness
determination is necessary.

4.	Engineering Evaluation. Engineers calculate emissions, review the equipment
design, compare the equipment to rules and conduct other technical analysis to
determine if the equipment will meet all rules and requirements. The engineer
prepares an "engineering evaluation" report summarizing the findings.

5.	Prepare Draft A/C. Along with the engineering evaluation, the engineer prepares
an authority to construct by utilizing the application record in BCMS.

6.	Public Notice (if required). Certain types of applications may require conducting
a public notice. Drafts of the engineering evaluation and authority to construct
should be ready before starting any public notices.

7.	Senior Review/Approval. Senior Engineer reviews and may recommend
changes. When ready the application is approved in BCMS.

8.	Issue A/C. The Authority to Construct is issued from BCMS along with a
construction completion notice that the applicant will return once the project is
completed. In come cases, such as when the equipment has already been
constructed, we issue a startup authorization directly instead of an A/C.

9.	Applicant Returns CCN. After finishing construction, the applicant will return
the construction completion notice to us. It must be returned prior to beginning
operation of their equipment or they are in violation of District rules and can
receive a notice of violation.

10.	Initial Inspection & Source Testing. Once receiving the construction completion
notice, we typically schedule an initial inspection with the facility. Engineers
should contact the applicant within two weeks to schedule an inspection unless
otherwise discussed with your supervisor. During the inspection we verify that
equipment installed matches the proposal, take photos of equipment, and review
compliance with the permit conditions. For some basic equipment types we may
elect to do this inspection remotely by having the site contact send photos of the
equipment and explaining permit requirements. Permit conditions may also
require that the applicant conducts a source test to show compliance with
emission limits. All documentation from the inspection and testing should be
uploaded to the application in BCMS.

11.	Updates & Revisions to Conditions & Description. New/modified equipment
may require changes to the conditions or description on the permit. This is
typically based on information determined during the inspection or during initial
stages of operation. Minor changes can be made in BCMS and implemented when

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Engineering Division Manual of Procedures

the S/A is issued. Any changes that affect the original conclusions of the
evaluation should be discussed and approved by a Senior Engineer prior to
implementation. Changes from the ATC to the permit stage should be minimized
to the extent possible and significant changes should be provided to the applicant
for their review prior to issuing the final permit.

12.	Issue S/A. A startup authorization should always be issued for each application
unless you have discussed with your supervisor a reason not to. Typically the
startup authorization should be issued immediately after the inspection.

An S/A can also be issued with a shorter term duration when a small deficiency is
identified during the inspection that needs to be corrected. Common cases where a
shorter term S/A are warranted are things like a incorrectly sized exhaust stack,
lack of required maintenance manuals or deficient monitoring. The exact duration
and requirements should be discussed with your supervisor, but generally will
require meeting the requirements within 10-60 days. A major deficiency should
be brought to the supervisor's attention for possible permit denial or revocation of
temporary authority to operate.

13.	Prepare Conditions in BCMS (new conditions or new sets). Conditions should
be initially prepared on the application record. If the permit will involve any new
conditions or a new/modified set of conditions, some additional steps are involved
that ensure we use consistent wording on all permits. Engineers check that for any
new conditions or revised conditions, an equivalent reference condition does not
already exist. For any modified conditions or condition sets, the engineer also
checks whether the condition/set is used on any permits that are not affected by
the application. If any others are affected, new conditions/new set is created,
otherwise the condition/set should instead be modified.

14.	Review and Approval of Conditions (new conditions or new sets).

Immediately before permit issuance, the final conditions are sent to your senior
then Compliance for review and approval. The primary point of review is that the
entire set of conditions is enforceable. Once it is thought to be relatively sure that
no significant changes will occur, drafts can be sent to the facility (often as an
S/A). It usually helps your Senior if you can explain any changes in a simple
format.

15.	Prepare Inspection Report and PTO Engineering Evaluation. For PTO

issuance, we also prepare an inspection report/engineering evaluation. The
inspection report should be completed as soon as possible after the inspection and
makes up the bulk of the evaluation. The evaluation should also discuss any
changes to conditions, results of source testing or additional analysis, and will
recommend a condition set and approval of the permit.

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Engineering Division Manual of Procedures

16.	Prepare the PTO. The last step before submitting the application for review is to
prepare the PTO in BCMS. This requires adding the equipment description,
entering the BEC number, applying the conditions and setting the number and
type of emission units and updating the PTE emission table for each pollutant.

17.	Senior Approval. The senior engineer reviews the application and approves the
permit. The engineering Aide then sets certain parameters in BCMS to ensure the
permit will be issued correctly, checks the status of any outstanding renewal fees,
then either issues the permit or requests and sends an invoice for outstanding
renewal fees. Once the permit is issued, it finally goes to Accounting who does
the last step of renewal fees.

The following figures provide a graphical representation of the process.

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Preconstruction Phase

Process flow diagram for standard applications

-------
Engineering Division Manual of Procedures

Review Phase

Process flow diagram for A/C-S/As

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Engineering Division Manual of Procedures

No Construction {Permit Change Only)

Process flow diagram for A/C-P/O

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3.

Requirements for Issuing Authorities to Construct (A/Cs)

3.1 Permit Evaluation Guidelines (Tom Weeks, October, 2007,
revised April 2009, February 2013)

A.	It is very important that application reviews be thoroughly documented. Therefore
an engineering evaluation shall be prepared for each application. Engineering
evaluations are used by the District to demonstrate to interested parties (ARB, EPA,
the facility, the public and other District staff) how compliance with applicable
rules and regulations was determined. In addition they explain technical details
about the processes and operations under review, document the history of permit
reviews and approvals and contain all the necessary background information to
support the permit decision. They shall be written so that anyone with a technical
background can understand them. Moreover, they should be written so that even
the public, without a technical background, can understand the basic reasoning
(though they may not understand much of the technical detail).

B.	The engineering evaluation must generally follow the format template included in
this section. Where appropriate, boilerplate evaluations may be used for simple
equipment as determined by the senior engineer. Engineering Evaluations for some
special projects (i.e. Rule 20.5 Determination of Compliance reviews) as well as
Title V permit applications may deviate from the format outlined below.

C.	At the time of submittal to the Senior Engineer for permit approval, the application
file will be organized as follows:

•	Final Draft Permit to Operate (PTO)

•	Engineering Evaluation (ATC followed by PTO) with attachments

•	Startup Authorization (SA)

•	Construction Completion Notice (CCN)

•	Authority to Construct (ATC)

•	Pertinent correspondence with applicants in chronological order

•	Application Forms (116 and Supplemental)

•	Other application submittals

•	Red folder with confidential information (see MOP section 1.6)

D.	The application, engineering evaluation and the authority to construct shall be
identified in the permit file using tabbed pages.

E.	To the extent practicable the engineering evaluation should be a stand-alone
document that provides all the relevant information and analyses used in making the
permit decision. Each document referenced in the engineering evaluation shall be
dated and clearly labeled. The following documents (where applicable) shall be
incorporated into the evaluation:

-------
Engineering Division Manual of Procedures

•	Emission calculation spreadsheets or summaries

•	Health Risk Assessments (HRA)

•	Air Quality Impact Analysis (AQIA)

•	Source Test Results

F.	The following documents shall be downloaded to Documentum and identified with
a file name in accordance with accepted protocols

•	Incomplete/Complete letters

•	Engineering Evaluation (ATC followed by PTO) with attachments

•	Startup Authorization (SA)

•	Construction Completion Notice (CCN)

•	Field Inspection documents including pictures

•	Test results

•	Authority to Construct (ATC)

•	Relevant correspondence with applicants in chronological order

G.	Draft and duplicate documents should be purged from the file unless they are
necessary to document significant permitting process decisions.

ENGINEERING EVALUATION
AUTHORITY TO CONSTRUCT

Facility Name:		

Application Number:		

Equipment Type:		

Facility ID:		

Equipment Address:		

Facility Contact:
Contact Title:
Contact Phone:

Permit Engineer:		

Date Application Received:		

Date AJC Evaluation Completed:		

Date Evaluation Modified:		

Senior Engineer Approval:		

1.0 BACKGROUND

1.1 Type of Application - Is this new equipment, a modification to existing

equipment, a change of location, or an amendment to an open application?

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Engineering Division Manual of Procedures

1.2	Permit History - What is the previous history? For modifications, when was
the equipment originally installed and what is the modification history?

1.3	Facility Description - What does the company do at this location? What other
permitted equipment is at this location and are there any other open
applications?

1.4	Other Background Information (where pertinent) - Has there been any hearing
board actions, permit denials, legal settlements, NOVs or nuisance
complaints? Is this a Title V facility?

2.0 PROCESS DESCRIPTION

2.1	Equipment - Describe the new equipment (or how the existing equipment will
be modified). Include make and model numbers, serial numbers, capacities
etc.

2.2	Process - Describe the process (include specifics such as operating schedule,
raw materials, chemical reactions, throughput flowrates, production rates,
material balances).

2.3	Emissions Controls - Describe any emission control equipment.

2.4	Attachments - Provide supporting information such as schematics, process
flow diagrams or equipment manufacturer's data as attachments.

3.0 EMISSIONS

3.1	Emission Estimate Summary - The emission estimate summary must include
a summary of both Potential to Emit (PTE) and expected emissions increase
(to support no net increase calculations). Emissions total shall be presented
for new applications and emissions change (post project minus pre-project)
shall be presented for modifications.

3.2	Emission Estimate Assumptions - Assumptions used in the emission
calculations (such as maximum throughputs, hours of operation etc.) and the
basis for those assumptions must be listed.

3.3	Emission Calculations - Emission calculations (including units) should be
shown or attached to the evaluations in spreadsheet form. Emission
calculations for modifications should include analysis of the emission
increase.

3.4	Attachments - References to emission estimate techniques must be provide
where appropriate.

4.0 APPLICABLE RULES

4.1	Prohibitory Rules - List all prohibitory rules that apply to this source
category. List the standards of each applicable prohibitory rule and provide
an analysis of whether the equipment is expected to comply with the
requirement as well as a thorough discussion of the means of compliance.

4.2	NSR - Provide a determination of applicability of NSR requirements. List
standard of each applicable NSR rule and provide an analysis of whether the
equipment is capable of complying with the requirement as well as
information on the means of compliance.

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Engineering Division Manual of Procedures

4.3	TNSR - Provide a determination of applicability of TNSR. Summarize HRA
results where applicable.

4.4	AB3205 - Is this application subject to AB 3205 requirements? State the
method of compliance.

4.5	NSPSs, NESHAPs and ATCMs - List all NSPSs, NESHAPs, and ATCMs that
apply to this source category. List the standards of each rule and provide an
analysis of whether the equipment is expected to comply with the
requirement.

4.6	Title V - Is this permit being issued to a TIV site? If so, was the Title V
Engineer provided a draft A/C? Describe how the requirements of title V
have been satisfied.

4.7	Attachments - Reference and attach all supporting documentation such as
AQIA summary, HRA summary, BACT analysis etc.

5.0 RECOMMENDATION

Include a statement of whether or not compliance with applicable rules is expected
and a recommendation to approve or deny the A/C.

6.0 RECOMMENDED A/C CONDITIONS

List all conditions that are recommended to be included in the A/C. State which
rule(s) is the basis for each condition. If a standard BEC is used only the BEC need
be listed.

ENGINEERING EVALUATION SUMMARY
PERMIT TO OPERATE

Facility Name:		

Application Number:		

Equipment Type:		

Facility ID:		

Equipment Address:		

Facility Contact:
Contact Title:
Contact Phone:

Permit Engineer:

Date Construction Completion Received:

Date of Inspection:

Date S/A Issued:

Date P/O Evaluation Completed:

Senior Engineer Approval:

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Engineering Division Manual of Procedures

7.0 INSPECTION REPORT

Fully document the inspection. Include the name and phone number of your facility
contact. Verify that you reviewed and explained the permit conditions with the
facility contact. Note any equipment discrepancies or A/C compliance issues.
Include a Compliance Inspection Checklist where available. Verify that you issued a
startup authorization and attach a copy to this document.

8.0 RECOMMENDED P/O CONDITIONS

Discuss any changes in the condition set from the ATC to the PTO. If a standard
BEC is used only the BEC need be listed. Verify that any non-routine conditions or
BECs have been reviewed and approved by the Compliance Division per Manual of
Procedures section 6.3.

3.2 Requirements for Issuing A/Cs (January 7,1982)

A.	Applications will be evaluated based on the information submitted by the applicant.
Using this information, the project engineer will determine if the equipment and its
proposed operation are expected to comply with District requirements. These
requirements include Regulations IV (Prohibitions), II (Standards for Granting
Permits) and where applicable, Regulations X (NSPS) and XI (NESHAPS). The
A/C evaluation will consider all modes (including emergency operation) in which
the equipment may be operated unless specific limitations are included to prevent
such operation. An A/C will not be issued unless compliance with all applicable
regulations is demonstrated.

The engineering staff will not exempt equipment (including equipment used only in
case of emergency) from any requirement of any rule. If there are specific
problems with the application of certain rules, they will be brought to the attention
of the Chief of Engineering.

B.	A/Cs will be issued with conditions to ensure compliance with District
requirements. These conditions may limit throughputs, emission concentrations,
hours of operation or any other parameter that is appropriate.

C.	Where state law supersedes District requirements, the engineering evaluation and
A/C, including conditions, will be based on state requirements. The appropriate
section of state law will be referenced in the A/C issuance.

D.	If source testing of equipment must be done before a P/O will be issued, the
applicant will be so advised, as a condition of the A/C. The A/C also will note the
required fees. The Monitoring and Technical Services Division will provide input
regarding source test requirements as either part of the A/C or as an attachment to
the A/C. All source test requests will be in writing directed to the chief of
monitoring and technical services, through the respective senior engineer. Since the

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Engineering Division Manual of Procedures

District must take action within a specified time period, applicants will be
encouraged to have testing accomplished as early as possible.

When source testing will be required prior to issuance of a P/O, the AJC will state
that within 60 days of completion of construction, testing will be done at the
applicant's expense, to verify compliance with the emission limits. A test plan will
be submitted for approval to the District in writing at least three weeks prior to
emissions testing. A final report will be submitted for approval to the District no
more than 30 days following completion of testing. (September 19, 1983)

F. For all new or modified sources subject to the NSR rules, the engineering evaluation
will include a cumulative NSR emissions summary sheet. This also will apply to new
or modified permits that have emissions increase below NSR trigger levels but that
contribute to a stationary source cumulative emissions increase. The cumulative NSR
emissions summary sheet will be part of the permit evaluation documentation.
Conclusions relative to NSR applicability and cumulative emissions increases will be
documented in the evaluation. (August 11, 1990)

3.3 Creating and Applying Permit Conditions (October 2020, Nick
Horres)

After the process description is complete, conditions should be added to the application.
Conditions may be added by creating a new condition, applying an existing reference
condition (and possibly modifying it), or applying a whole set of conditions that have
been approved as a CON record. Typically applying a whole set is the most efficient,
applying existing reference conditions is second preference, and creating new conditions
is the last step.

A few suggested tips:

•	Do not revise existing conditions that you do not intend to change on all permits
with the affected condition. Instead create a new condition.

•	Do not use special characters that BCMS cannot recognize like smart quotes since
these will show up as upside down question marks.

•	Pay attention to the listed rule citations. If the correct wording is available but rule
reference is not updated, check with your supervisor whether this is okay or
perhaps the existing condition should be changed even if on multiple permits.

•	When copying conditions from CON records, there is a known glitch that Accela
won't address that can result in not all conditions copying over. For this reason,
after copying the conditions, check to ensure all conditions correctly copied.

The screen shots below show examples of each of these methods.

Create a New Condition

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Engineering Division Manual of Procedures

APCD2020-APP-006206 - Non-Retail Gas Dispensing Facility Fee Sched: 26E EFX
Submit Reset	Cancel	Help

Group * Standard Condition

Tvoe * S) Standard Condition

Condition Name *

Status

Severity [Notice]

1APCD v 1

iPTOConds vl

|newi

| Applied(Applied) v |

[ Notice v |



Short Comments LUStandard Comment

Complete all fields as shown on the
top row and name the condition

check spelling

Applied by User * Current User

I Nicholas Horres	vl

Applied By Division * Current Division

| APCD Engineering Chem ¦ v |

Long Comments ^Standard Comment

This is a condition requiring the owner or operator to meet an emission limit that we tell them to. [Rule 21]

Enter the condition
language here.

Search Tags

Add a reference condition

Click Add then "Standard Condition" then "Search''

Display Notice [None]

0 Accela Automation
0 ACA

D ACA Fee Estimate Page
Set Inheritable to "No"

Inheritable [No]

| No

Action by Dept Current Division

I -Select-	s/1

Action by User Current User

I -Select-	vl

Effective Date



Applied Date

109/30/2020 |H

Submit

Reset

Cancel

Help

G o To

Group

• a

Standa rd Condition Type

—Select—

Conditi

Short Comments

Bh Standard

Comment

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Engineering Division Manual of Procedures

APCD2020APP0(K>206 - Non-Retail Gas Dispensing Facility Fee Sched: 2fiE EFX
Menu - Search | Cancel	Help

Go To »

Showing 1-5 of 100

M

m
m

0J

Pane

of 20

Now enter the search parameters as shown below. Typically you either search by
condition number, or by a wording you are trying to find (use percent signs as needed)

APCD2020-APP-0(}S20'6 - Non-Retail Gas Dispensing Facility Fee Sched: 26E EFX
Submit Reset	Cancel	Help

Condition

Type

Comment

Group

Severity

Name









C45189

PTO Conds

C45189-AII screens, crushers, and transfer points shall be .

APCD

Notice

C45188

PTO Conds

C45t88-No air contaminant shall be discharged into the atmo

APCD

Notice

C45187

PTO Conds

C45187-PM10 emissions from this unit excluding area fugiti..

APCD

Notice

C45190

PTO Conds

C45190-A1I conveyors shall be covered, or shall utilize an ...

APCD

Notice

C45191

PTO Conds

C45t91-The following records shall be maintained at a centr.

APCD

Notice

Go To

Condition Name

C42132

Severity

-Select-

If you know the condition
name/number, search for
it here

checK spelling

Search Tags

check spelling

Condition Type



-Select- v





Long Comments





%Emissions of NOx from this





equipment shall not exceed 9%



^checl^pellm^^

Display Notice

~	Accela Automation

~	ACA

~	ACA Fee Estimate Page

Include In Condition Notiq

D Condition Name
~ Short Description

ft

Alternatively, search for a
wording you want to find

Pnhlir nicnlatr Mptmanp

Now click submit and check results. Open the conditions in new tabs if needed to check
without rerunning search.

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Engineering Division Manual of Procedures

APCD2020-APP-006206 - Non-Retail Gas Dispensing Facility Fee Sched: 26E EFX
Menu # Search Cancel	Help

Go To ~ I

mj

Ml

ndition Type

ime

C 12824

C 16107
C >4633
C 12821

PTO Conds
PTO Conds
PTO Conds
PTO Conds

Comment

C42824 - The maximum emissions of NOx shall
C26107 - The maximum emissions
C24633 - The maximum emissions of nox
C22821 - The maximum emissions of NOx shall not

If you find multiple conditions, right click on the corresponding
icon for the condition you want to view and open in a new tab

Group

Severity

APCD

Notice

APCD

Notice

APCD

Notice

APCD

Notice

(otherwise you have to search again)

Mv Tasks

Once you have found the condition you want, open it in the original tab and submit

PP-006206 - Non-Retail Gas Dispensing Facility Fee Sched: 26E EFX
Reset Cancel	Help

Group ' lib Standard Condition Type * Efc Standard Condition Condition Name :

| APCD

Status

7\ | PTO Conds "

Short Comments El:Standard Comment

3

| Applied(Applied)

C22821 - The maximum emtssions of NOx shall not

Applied by User * Current User

Severity [Notice]

| Notice	v |

Nicholas Horres

check spelling

Long Comments Ehstandard Comment

Applied By Division * Current Division

| APCD Engineering Chem s/1

The maximum emissions of NOx shall not exceed 30 PPMV when operated on a gaseous fuel or 40
PPMV when operated on a liquid fuel, calculated as Nitrogen Dioxide at 3% Oxygen, on a dry basis.

Revise a condition (only for conditions only on affected permits)

Display Notice [None]

~	Accela Automation

~	ACA

D ACA Fee Estimate Page

Inheritable [No] -

| No

v|

Action by Dept

Current Division

| -Select-

vl

Action by User

Current User

I -Select-

v|

First add the condition as indicated above, then open the condition and make changes and
mark the status as revised.

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Engineering Division Manual of Procedures

APCD2020-APP-006206 - Non-Retail Gas Dispensing Facility Fee Schett: 26E EFX
Submit Reset	Cancel View Log Help

Condition Detail Condition History

Group '

APCD

Type *

v PTO Conds

Short Comments B-Stanclard Comment

C22821 - The maximum emissions of NOx shall not

Condition Name
C22821

Applied by User « Current User

Nicholas Horres

Severity [Notice]

| -Select-- v

|)Hlll I'lStice [None]
Set status to Revised ~ Acceia Automation
~ ACA

D ACA Fee Estimate Page

check spelling

Applied By Division » Current Division

APCD Engineering Chem . v

Long Comments Bkstandard Comment

The maximum emissions of NOx shall nol exceed 30 PPMV when operated on a gaseous fuel or 40
PPMV when operated on a liquid fuel, calculated as Nitrogen Dioxide al 3% Oxygen, on a dry basis.

Malta the change to
the wording here

check spelling Use the search tags to identify if this condition is en
another permit. In this case it likely isn't since only
Search Tags	one legacy BEC is listed	

C22821
11225/13A

Inheritable [No]

| No

v|

Action by Dept

Current Division

| -Select-

v|

Action by User

Current User

| -Select-

"i

Effective Date

I l til

Applied Date



[09/30/2020

ia

In this case we should also check whether this legacy BEC is on any other permits which
can be done as follows.

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Engineering Division Manual of Procedures

Record ID [Alt + R]

% is wildcard

Opened Date
Fn

*pto%

Find permits

To

Record Type

Group

09/30/2020

a

Use this t ¦¦ : : up search

fype	Subtype

Category

St

E

LUEG-APCO v -S&ect-

v -Select-

v -Select-

Contact On

Address line 1

Short Notes

City

Record

Zi

C

Assigned to Division

PMaai

»e fiel
r the iridi

it to look in the SEC

number

Assigned to

-Setect"

Record Data

Q

Record Specific Info Label

Record Specific Info Value



%BEC%



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number and check Record Conditions as shown in shot below.

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Summary Record

- [26 A E F] 6DF Activities (0) Activity Summary

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2

C40239



The engine shall be operated exclusively during. .

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3.4 Issuance of Authority to Construct Letters

An Authority to Construct letter is to be issued in response to all applications for permits
except for the following cases:

1) Existing emission unit that was previously exempt from permit under Rule 11 and
for which a permit is now required because of a change to Rule 11, or a change in
the District's interpretation of Rule 11. This exception does not apply if the

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emission unit is being or will be modified, or was previously modified in such a
way that the Rule 11 exemption no longer applies.

2)	An existing emission unit that was previously under a permit to operate and that
permit expired, retired or was cancelled and the owner or operator is applying for
issuance of a new permit. This exception does not apply if the unit has been, is
being or will be relocated or modified from what was previously permitted or if
the application for permit is submitted more than 12 months after the permit was
retired or cancelled.

3)	Modifications to conditions or limitations on an existing permit where there is no
physical change to the emission unit or process and no change to the equipment
description (other than identical replacement) on the permit. A separate Authority
to Construct letter is not required, but may be issued. However, the modification
should be evaluated for compliance with all District rules, including NSR and
Rule 1200, as if an Authority to Construct were being granted. This includes any
procedural requirements such as AB3205 public notice and a public/EPA review
and comment period. If, in order to achieve compliance with any rule, the
emission unit or process must be physically modified or emission controls added
or emission offsets provided, then an Authority to Construct letter must be issued.

When a separate A/C letter is not issued, each Startup Authorization or modified
Permit to Operate that authorizes operations under the modified conditions must
be issued as a combined A/C-S/A and A/C-P/0, respectively. The document must
clearly indicate that it includes the Authority to Construct action. The date of
issuance of the first of these should be entered as the A/C issuance date in the
VAX.

4)	Emission units for which an application for registration has been submitted to the
District and which are eligible for registration under District Rules 12 and 12.1.

3.5 Authority to Construct Evaluation Language (February 27,1980)

The Engineering Division typically will issue an A/C prior to construction. Construction
may not commence until an A/C is issued. The following language will be part of the
A/C:

"This Authority to Construct authorizes temporary operation of the above specified
equipment. This temporary Permit to Operate shall take effect upon written
notification to the District that construction has been completed in accordance with
this Authority to Construct. This temporary Permit to Operate will remain in effect,
unless withdrawn or modified by the District and a revised temporary permit
(Startup Authorization) is issued or a permit to operate is granted or denied.

"Upon completion or modification in accordance with this Authority to Construct
and prior to commencing operation, the applicant must complete and mail, deliver

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or fax the enclosed Construction Completion Notice to the District. After mailing,
delivering or faxing the notice, the applicant may commence operation of the
equipment. Operation must be in compliance with all the conditions of this
Authority to Construct and applicable District rules.

"Within ten (10) days after receipt of this Authority to Construct, the applicant may
petition the Hearing Board for a hearing on any conditions imposed herein in
accordance to Rule 25.

"This Authority to Construct will expire on	"

3.6 AB3205 Review/Notification Procedures (July 28,1989, revised
April 2009, revised December 2014)

The following requirements for building departments, hazardous materials administering
agencies and local air pollution control districts concerning new or modified sources near
schools shall be complied with before issuance of an Authority to Construct.

A.	No city or county will issue a building permit for a facility to be constructed (or
modified) within 1,000 feet of a school, or issue a certificate of occupancy for any
facility, unless the applicant provides proof that the facility is exempt from District
permit requirements, or if not exempt, the requirements for District permits are
being met.

B.	Before approving an application for a permit to construct or modify a source located
within 1,000 feet of a school, the District must:

1)	Provide notice of the proposed approval to parents of children attending any
schools within one-quarter mile of the source and to each address within 1000
feet of the source.

2)	Provide a 30-day period to comment.

3)	Review and consider all comments received.

4)	Include written responses to the comments in the application file before taking
final action on the permit.

C.	If determined that there is a reasonably foreseeable threat of an air contaminant
release from a source within 1,000 feet of a school that would cause a violation of
Section 41700 of the health and safety code (equivalent to Rule 51) and that would
impact persons at the school, the District must notify the appropriate fire
department and administering agency (HAZMAT) within 24 hours.

D.	In determining that a reasonably foreseeable threat of a release exists, the air
pollution control officer (APCO) may issue an immediate order to prevent or

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mitigate the release (with HAZMAT written concurrence) and petition the hearing
board to issue an abatement order.

E.	The District must respond to a request from a school principal (for example for the
District to identify or take actions to prohibit or mitigate a threatened release)
within 24 hours and notify HAZMAT and the fire department having jurisdiction
over the school.

F.	EIRs for purchases of school sites or construction of a new school cannot be
approved unless the lead agency obtains a list of all sources within one-quarter mile
that are expected to emit hazardous or acutely hazardous air emissions from the
District.

G.	Full implementation of these requirements will require the cooperation of permit
processing, Compliance and engineering staff. Engineering staff will be
responsible for implementing substantial portions of these requirements. All
engineering staff are affected by these requirements.

H.	An air pollution control questionnaire will be provided to all building departments
to give to applicants for building permits and certificates of occupancy. Applicants
who may require District permits will need District authorization stamps on the
form. The following procedures will be used:

1)	Clerical staff will receive forms over the counter or by mail. Clerical staff
will maintain a log of the receipt, routing and disposition of all forms
received. These forms will not be handled by engineering or Compliance staff
without routing through clerical staff.

2)	If there is no application on file with the District for the equipment for which
the person is seeking a building permit or certificate of occupancy, the form
will be forwarded to the Compliance division for handling. Forms also will be
forwarded to Compliance staff if any application on file clearly is not for the
equipment for which the building permit or certificate of occupancy is being
sought.

3)	If there are applications on file with the District that are or may be for the
equipment, the form will be forwarded to the appropriate senior engineer for
assignment to an engineer.

4)	The engineer assigned will determine if the pending applications are for the
equipment. If not, the form will be forwarded through clerical to Compliance
staff for disposition.

5)	If an application is pending for the equipment for which a building permit or
certificate of occupancy is sought, the second block will receive a confirming
stamp by the senior engineer, whether or not the application has been deemed

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complete; the third block will receive a confirming stamp only if an A/C has
been issued for the specific source, building, process or equipment for which
the certificate of occupancy is being sought.

Stamped forms will be forwarded to permit processing for mailing/delivery to
applicants. A copy will be made by permit processing staff and retained in the
application file.

If there is not sufficient information on the questionnaire to determine whether
there is a corresponding application on file with the District, the engineer will
contact the applicant to obtain the necessary information, document the
information received and proceed with the disposition of the form.

I. All pending and new applications for A/Cs must be screened to determine whether
they fall within 1,000 feet of the outer boundary of a school. Schools include K-12,
public, private and also may include certified in-home study. Maps that locate all
schools have been prepared.

J. Applications pending issuance of a permit for equipment for which an A/C already
has been issued are not subject to the AB3205 public notification process. This also
applies in cases where a source has allowed its permit to lapse and must reapply for
a new permit (without a change in location).

K. All new applications for A/Cs or modifications to permits that require an A/C,

except those for change of ownership will be reviewed by the project engineer for
mapping prior to determining whether an application is complete.

L. The review is to determine if a source may be within 1,000 feet of the outer

boundaries of a school and to identify schools within 1,320 feet of the source. For
each source that may be within 1,000 feet of a school, the engineer will advise the
applicant of the public notice and comment period requirements of AB3205 and
request the applicant to provide a map showing the exact location of the equipment
and the associated discharge vent/stack, the location of the property lines of the
stationary source on which the equipment is located and the location of the property
boundaries of any schools located within 1,320 feet of the source.

M. Upon receiving this information, the project engineer will determine if the

equipment or its associated discharge points are located within 1,000 feet of the
outer boundaries of a school. If so, the project engineer will complete a draft public
notice for signing by the senior engineer once a preliminary decision has been made
to issue an A/C. This notice will identify (by name and address) all schools within
one-quarter mile (1,320 feet) of the discharge points. (This distance will be
measured from the discharge point, or equipment location to the outer boundaries of
any neighboring schools.) The project engineer will attach a map to the draft notice
showing, in red, the boundary that defines a distance of 750 feet from the property
lines of the source.

6)

7)

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O. Because of the delays in this process, (approximately six weeks from draft notice to
end of comment period), notices will be sent as soon as possible in the application
review process provided there is a reasonable expectation that an AJC will be
granted. Routine applications, such as for dry-cleaners, gas stations, automotive
refinishing facilities, etc. will be reviewed for notification requirements as soon as
received and the notices sent out early on so that the comment period can coincide
with the engineering evaluation. More complex applications will wait until the
application is complete, the process is known and emissions are established in order
to be responsive to the public inquiries that the notices may prompt. The AB3205
comment period for projects that trigger air quality analysis under Rule 20.3 will
coincide with the 30-day comment period required by Rule 20.3.

P. The draft public notice, with map, will be forwarded to permit processing,

finalizing the notice and initiating the mailing. The map will be used by a contract-
mailing firm to define the addresses to receive the public notice. At the time of the
mailing, the application file will be in a suitable form for public inspection, as there
may be such requests.

Q. Permit processing also will contact the affected schools to arrange the required
mailing to pupils' parents. The notices will be received approximately two weeks
after a draft notice and map is forwarded to permit processing. Applicants will be
advised that the comment period will take approximately six weeks from when the
draft notice is sent to permit processing. Applicants will be sent a copy of the
notice by permit processing. A copy also will be sent to the project engineer for the
application file.

R. During the 30-day comment period, the engineer will review and prepare responses
to comments as they are received. The comments and response must be contained
in a single document with a format similar to workshop reports. The
comment/response document will be reviewed and approved by the senior engineer
and placed in the application file after the close of the 30-day comment period. The
comment/response document will be retained in the application file permanently.
The District will consider all comments before taking final action on the permit.

S. Each individual who provided comments with his name and address will be sent a
copy of the comment/response document. The project engineer will provide a
mailing list and copy of the comment/response document to permit processing for
mailing. If possible, student workers will prepare the mailing lists.

T. If the public comment period will impact adherence to AB884/Rule 18 deadlines,
the applicant will be advised in writing and asked to concur with an extension as
necessary. If the applicant will not provide written concurrence, the application
will be denied.

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U. When there is a pending application, time spent meeting these requirements will be
charged to that application.

3.8	Rule Applicability - New Rule Adoption (January 8,1982)

Rule 20 specifies that an AJC cannot be issued unless an applicant demonstrates
compliance with all applicable rules. Thus, if new or modified rules become effective
after an application has been deemed complete, compliance with them must be
demonstrated or the AJC cannot be issued. Compliance will be demonstrated at the time
the AJC is issued.

If a pending rule change could potentially prevent an AJC from being issued, the
applicant will be notified as soon as possible of the rule proposal and the fact that, if
adopted, additional requirements must be met before an AJC can be issued.

Any instance where a rule change would cause an extreme hardship to the applicant who
submitted a completed application prior to the rule change date but will not receive an
AJC prior to that date, will be brought to the attention of the chief of engineering and the
deputy director.

An application for an AJC will be subject to evaluation under all rules and regulations
that are in force up until the time the AJC is issued. Such rules and regulations will
include any that are adopted after the application has been deemed complete. (September
23, 1980)

3.9	Expedited Application Processing Procedure (Tom Weeks,
September 1, 2004)

On June 23, 2004 the Board approved revisions to Rule 40 that include provisions for
Expedited Application Processing. The following procedures are to be used to
implement the program.

Application Receipt - Applicants must specifically request expedited application
processing by checking the appropriate box on the District general application Form 116.
This action initiates the expedited process. Permit Processing staff will ensure that these
applications are forwarded to the appropriate Senior Engineer within one working day of
receipt. The permit file folders should be clearly marked so that the application can be
given special attention when received by the Senior Engineer.

Engineering Evaluation - The Senior Engineer will evaluate the availability of a qualified
permitting engineer as soon as possible after receipt of the application. A qualified
permitting engineer would meet the following requirements: 1) they would have
experience processing similar applications, and; 2) they would be available to work on
the application during a weekend, days-off or after normal work hours within two weeks
of receipt of the application. To ensure that these applications are processed in an

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accurate and efficient manner, most of the application evaluation time should be during
weekends or days-off as opposed to after hours work when the engineer may not be
working at full efficiency.

If a qualified permitting engineer is not available, the Senior Engineer will contact the
applicant, in a timely manner, to inform them that the application will not receive
expedited processing. In the event that the evaluation cannot be expedited, the Senior
Engineer should make every effort, as with any application, to meet the applicant's
requested timeline through use of normal staff resources and scheduling.

If a qualified permitting engineer is available, the Senior Engineer will transfer the
application to the engineer for a completeness determination. The permitting engineer
will review the application and make a determination whether sufficient information is
available to begin processing the application. If necessary, the permitting engineer
should contact the applicant to request additional information. Requests for additional
information may be made by phone, however an application status letter must also be
issued within 30-days of receipt of the application. The permitting engineer will also
inform the applicant that the application will receive expedited processing and discuss the
evaluation review timeline to ensure that it meets the applicant's needs prior to working
overtime.

Application Cost Accounting - Upon issuance of an Authority to Construct, the
permitting engineer will submit, to the Accounting section via the Senior Engineer, a
request for an invoice for the expedited application processing fee. Expedited permit
processing fees would be charged only if the majority of the work done on the application
was performed on weekends, after hours or on days off.

For fixed fee applications the expedited application processing fees will be equal to 0.25
times the Initial Evaluation Fee minus the Emission Unit Renewal Fee (Column (1)
minus (2)) plus any Additional Engineering Evaluation Fees as specified in Rule
(40)(d)(5). The non-refundable processing fee, renewal fee, and any applicable air
contaminant emissions fees will be charged at the standard rate as specified in Rule 40.

For T&M applications, an expedited permit application fee equal to 0.25 times the
normal Rule 40 Fee Schedule 91 labor rate will be charged for all labor prior to issuance
of the Authority to Construct. If additional overtime work is required for issuance of the
Startup Authorization and or Permit to Operate a second supplemental invoice shall be
issued to cover this labor. The non-refundable processing fee, renewal fee, and any
applicable air contaminant emissions fees will be charged at the standard rate as specified
in Rule 40.

Invoices shall be prepared by the permit engineer for review and approval by the Senior
engineer prior to submittal to Accounting. Invoices should specify that they are for
recovery of expedited application processing fees per District Rule 40(d)(8)(iv). Account
code 73 should be specified on the request for invoice.

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If an application is denied or cancelled prior to issuance of an A/C, the Senior Engineer
or the Chief of Engineering should be consulted to determine if expedited processing fees
are to be applied.

Application Time Accounting - The District will re-evaluate the expedited application
processing labor cost multiplier periodically to determine if it accurately reflects
additional labor costs for implementation of the program. To do this it will be necessary
to track overtime labor hours. Initially, Senior Engineers will be asked to track the
number of overtime labor hours spent specifically on expedited applications. If the need
arises, a special labor code will be developed to facilitate this tracking.

Overtime should be coded at paid overtime (PF) on daily and weekly time sheets.

Addition to Form 116

Expedited Application Processing:

I hereby request Expedited Application Processing and understand that:

a)	Expedited Application Processing will incur additional fees and permits will not
be issued until the additional fees are paid in full, (see Rule 40(d)(8)(iv) for
details).

b)	Expedited Application Processing is contingent on the availability of qualified
staff.

c)	This request is not cancelable once engineering review has begun.

d)	Expedited Application Processing does not guarantee action by any specific date
nor does it guarantee permit approval.

3.10 Supplemental Expedited Application Processing Guidance (Tom
Weeks, October 2005, modified April 2009)

The intent of the expedited application processing program was to reduce application
backlog and offer a mechanism for issuing expedited permits. Although the program has
been quite successful a few issues have come up that need to be addressed. Those issues
are discussed below:

Paid Overtime Criteria - In order for the program to work as intended, additional permit
evaluation hours must be generated without increasing staff levels. That allows the
District to issue expedited permits without causing delays in issuance of normal (non-
expedited) applications. Overtime pay provides the incentive to generate additional
permit evaluation hours. However, if staff work paid overtime during the same week that
they take leave time (comp. time or vacation), the net effect is that no additional permit
evaluation hours are generated. This could result in non-expedited applications taking
longer because expedited applications are taking precedence. Therefore, in order to
ensure that the program operates as intended, expedited application labor should only be
charged on weeks that the employee works a full 40 hours and the employee has a
minimum of 20 billable application hours during the normal 40 hour work week unless a
deviation is approved by a Senior Engineer or the Chief of Engineering.

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Timeliness of A/C Issuance - It is important that the District meet the expectations of the
applicant when processing expedited applications. In general, expedited applications
should be processed within two weeks of receipt. If this is not possible due to the
complexity of the project, the applicant must be contacted. The permit engineer must
estimate the A/C issuance date and discuss it with the applicant to ensure that the
proposed A/C issuance date is acceptable. Some applicants may decide that the
expedited application option is of little value given the extended timelines inherent in
some district processes (AB3205, 30-day public notice, refined HRA, AQIA etc). This
discussion (including the estimated completion date and the applicant's approval to
proceed on an expedited basis) must be documented in writing in the permit file.

Work Hours Limitation - Applicants for expedited permits pay a premium for that
service. In return they deserve not only timely service but also quality work. We all lose
efficiency and accuracy when we are tired. Therefore, to ensure that applicants receive
the quality they deserve, work should not exceed 12 hours during any workday without
prior approval of a Senior Engineer or the Chief of Engineering.

Fee-for-Service - The District operates on a fee-for-service basis. Fees charged by the
District are intended to recover actual costs only. Rule 40 essentially specifies that
expedited applications are charged a fee of 125% of the standard application processing
fee. The additional 25% goes to pay the overtime salary of the engineer. If the engineer
works paid overtime for only a small portion of the total time spent on an application, the
District will recover significantly more in fees than it costs the District to process the
application. This would not be consistent with the fee-for-service mandate. Therefore, as
specified in the original expedited permit processing guidance, applications should not be
accepted as an expedited application and overtime should not be charged unless the
permit engineer intends to work on an application primarily (more than 50%) on
weekends, days off, or after hours (subject to the work hour limitations specified above).

In the future, engineers must ensure that all the program criteria (as specified in the
original program implementation guidance and this supplemental guidance) will be met
prior to working overtime on any expedited application.

3.11 Application Tracking Data (November 8,1993)

Part of our efforts to streamline permit processing involves creating systems by which we
can measure and track our progress in making improvements. As a benchmark to
evaluate future progress, we have been compiling and reviewing data on the time and
labor hours it takes to determine an application complete, to issue an A/C and to issue a
P/O. The data on time to process applications is being drawn from the information that
permit engineers enter in the application and permit files in the permit database.

Accordingly, engineering staff working on permits are to enter these data in the fields of
the application and permit computer files. In particular, the dates when the application is

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deemed complete, when an Authority to Construct is issued, when the initial Startup
Authorization is issued and when the Permit to Operate is approved must be completed.
As designated appropriate by the Section Senior Engineer, data may be entered by the
project engineer, by the Senior Engineer or by a student worker.

A.	Application Complete

If the application is complete on initial review, then the date of this determination is
to be entered in the appropriate field.

If the application is incomplete and the applicant is advised of the additional
information needed within 30 days of receipt of the application, then the date the
applicant is notified is to be entered in appropriate field. When all information
requested within the first 30 days is provided, the date when the last of the
information is received is to be entered in appropriate field.

If no determination of whether an application is complete is made within 30 days of
receipt of the application, then the date which is 31 days after receipt of the
application is to be entered in appropriate field.

B.	Authority to Construct

The date of the signed letter granting or denying the Authority to Construct is to be
entered in the appropriate field. These Fields are not to be completed until after the
letter granting or denying the Authority to Construct is signed.

If the application is for off-the-shelf, portable or already constructed equipment, and
a separate Authority to Construct letter will not be issued, the date of the first
Startup Authorization granted is also to be entered as the Authority to Construct
date in the appropriate field. (The Startup Authorization should be modified to state
that it is an Authority to Construct and Startup Authorization.)

If a separate Authority to Construct is not issued but a permit to operate is denied,
with no Startup Authorization issued, the date of the letter denying the permit is to
be entered as the Authority to Construct action date in the appropriate field.

C.	Startup Authorization

The date of the first startup authorization granted pursuant to the application is to be
entered in the appropriate field. This applies whether or not the S/A is for
shakedown and testing or allowing operation until a permit is issued. If subsequent
S/A's are issued, this date is not to be revised without a Senior Engineer's approval.

If subsequent S/A's are granted, the expiration date is to be updated. Do not update
the S/A granted field.

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D. Permit to Operate/Application Disposition

The date of P/O issuance is to be entered in the appropriate field.

Completing these data entry fields is important if we are to be successful in identifying
areas where we need to make improvement and documenting our progress. Completing
these fields, at the appropriate time, is also important to the timely processing of
applications and permits.

3.12	Verbal Permits Not Allowed (December 18,1979)

No verbal A/Cs or P/Os will be given for any reason. If a source is being built or
modified without an A/C or being operated without a P/O, the senior duty inspector for
that day will be notified in writing (copy to engineering file).

3.13	Application Cancellations (November 1990)

When planning to cancel an application that was initiated by a Compliance action, the
project engineer first will discuss the cancellation with one of the inspector Ill's or with
the Chief of Compliance. This will prevent the problem of engineering staff canceling an
application for a permit that was prompted by Compliance action, i.e. a Notice to Apply
or Notice of Violation. This action will prevent Compliance staff from following up on
the N/A or N/V with the site, only to be told by the applicant that engineering staff
canceled the application because a permit was not needed.

3.14	A/C Requiring Emission Source Testing (October 20,1992)

There have been several occasions recently where the source testing requirements for
new or modified sources have not been adequately coordinated with Monitoring and
Technical Services, especially with regards to requirements for access and platforms for
testing. This has resulted in the District having to require sources to modify stacks,
install or modify test ports or install scaffolding or testing platforms after construction of
the permitted equipment/emission controls has been completed. This can be a significant
additional expense and delay for applicants that can easily be prevented.

All Authorities to Construct which contain conditions requiring emissions source testing
shall also include the following standard condition:

• The (equipment identification or reference) exhaust(s) shall be equipped with a
circular exhaust stack with test ports and provisions for personnel access (e.g.,
scaffolding, platforms) for source testing. The stack design with the locations of
test ports, access provisions, platforms, etc. shall be submitted to, and approved by,
the District's Monitoring and Technical Services Division (Source Test Section,
694-3349) prior to issuance of Startup Authorization(s) for this equipment

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•	This will be in addition to the standard condition which requires submission and
approval of a source test protocol, such as follows:

•	Within (sixty) days after completion of construction, source tests of (equipment
identification or reference) shall be conducted by an independent tester at the
applicant's expense to determine (compliance with Condition Nos. X, Y and
Z/exhaust concentration of NOx/emission rate of VOCI etc.). A source test protocol
shall be submitted to, and approved by, the District's Monitoring and Technical
Services Division prior to issuance of Startup Authorizations for this equipment.
The applicant should allow 30 days for source test protocol approval and should
contact the Source Test Section at 694-3349 with any questions regarding the
submission or approval of a test protocol.

3.15 Independent Source Test Contractor Policy (January 29,1999)

The San Diego APCD requires certain sites to be source tested to determine if they are in
compliance with their Permit to Operate emission limits. These tests may be performed
by the District's Source Test Section or by an independent source test contractor.

A. An independent source test contractor is any person or company who conducts a
source test at a site for the purpose of furnishing data to the Air Pollution Control
Officer, the Air Resources Board or the Environmental Protection Agency for
demonstrating compliance with permit conditions or with District Rules and
Regulations provided that all of the following criteria are met:

•	The independent contractor has no financial interest in the source being tested,
or in the source's parent company, or in any subsidiary thereof;

•	The source being tested, or parent company, or any subsidiary thereof has no
financial interest in the independent contractor;

•	The independent contractor is not in partnership with, nor owns or is owned
by, in full or in part, the contractor who has provided or installed basic control
equipment, or monitoring systems, or is providing maintenance for installed
equipment or monitoring systems for the source being tested;

•	The independent contractor is not in partnership with, nor owns or is owned
by, in full or in part, the consultant or agent representing the source being
tested or its group association;

•	No company or facility responsible for the emission of significant quantities
of air pollutants, or parent company or any subsidiary thereof, shall have any
financial interest in the independent contractor.

An independent source test contractor shall provide satisfactory evidence and a
certification that it meets the above criteria with respect to the source(s) being tested, any
parent company or subsidiary, consultants or agents.

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Test contractors shall, in all cases, be subject to the approval of the District. The District
may, as its sole discretion, determine that a test contractor does not qualify as an
independent source test contractor for a particular source or for all sources.

The most recent ARB Independent Source Test Contractor List is available on the "S"
Drive in the Engineering folder. The list has been modified by the addition of some
testers who often test here, but who are not on the ARB list.

The program is designed to approve independent contractors for sources who may choose
to have them conduct compliance testing instead of the Air Resources Board. The Air
Resources Board does not require that contractors be approved prior to testing in
California. Approval is only required by the Air Resources Board if the contractor
wishes to test under this program. The District has added some testers who have
regularly tested in the District, but who do not appear on the ARB list.

3.16	Emission Factors and Calculation Methodologies (Tom Weeks,
October 5, 2000)

Emission factors and emission estimation techniques are provided on the following link
to the District's Website:

http://www.sdapcd.co.san-diego.ca.us/emission/emission.htm

This information was put together by the District's Toxic Section and is based on work
they reviewed and approved. Listed emission factors should be considered as default
values. Accordingly, they should be used and quoted only when no other emission factor
(AP-42, source-specific source testing, etc.) is available. When used, consideration
should be given to the development, during the evaluation process, of specific emission
factors for significant sources.

All emission factors and assumptions need to be properly referenced and documented in
all your evaluation work.

3.17	Permit Conditions for AB2588 Air Toxic "Hot Spots" (August 21,
1989)

The following condition will be included as a "hardwired" condition in all S/As and P/Os
for new or modified sources to comply with H&SC requirements:

The Permittee shall, upon determination of applicability and with written
notification by the District, comply with all applicable requirements of the air toxics
"Hot Spots" Information and Assessment Act (California Health and safety Code
Section 33200 ET. SEQ.)

3.18	Permit Application Checklists (May 6,1999)

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Engineering Division Manual of Procedures

Engineering has several application checklists to improve the completeness of permit
application submittals and to help the applicants in the process. These checklists include
the following:

•	General Permit Application Checklist. This should be provided with all general
permit application forms.

•	Schedule 13 supplemental Permit Application Checklist. This should be provided
with all fee schedule 13 supplemental forms.

•	Schedule 27 Supplemental Permit Application Checklist. This should be provided
with all fee schedules 27 supplemental forms.

•	Schedule 28 Supplemental Permit Application Checklist. This should be provided
with all fee schedules 28 supplemental forms.

•	Schedule 34 Supplemental Permit Application Checklist. This should be provided
with all fee schedules 34 supplemental forms. (Do not include with registration
forms.)

3.19	Agricultural Exemptions from P/Os (October 16,1974)

Pursuant to health and safety code Section 24265, permits are not required for boilers and
soil mixers used by nurseries in the raising of flowers. According to health and safety
code section 24251(c), the equipment is used in an agricultural operation.

3.20	Tank Truck Exemptions from P/Os (September 29,1977)

P/Os are not required for tank trucks after January 1, 1978, the effective date for AB1238.

3.21	A/Cs Required for Portable Equipment (November 9,1976)

A/Cs will be required for all appropriate equipment (including portable) prior to purchase
so that both the District and the purchaser of the equipment can be assured of compliance
with District rules and regulations.

3.22	Basis for Permit Conditions

District Rule 21 gives the District broad authority to impose conditions on permit as
necessary to ensure compliance with all applicable requirements. However as operating
requirements become more complex with the addition of new and revised State Federal
and District requirements, it can be difficult to determine the basis for permit conditions.

For a variety of reasons, it is advantageous to know the basis of each condition on a
permit. These reasons include justifying the conditions to the applicant upon request,
assisting the Compliance Division in performing inspections, and identifying conditions
requiring revision based on rule changes.

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Engineering Division Manual of Procedures

Therefore all new conditions must include a reference to the rule basis for that condition.
This will be accomplished by appending the specific rule reference as shown in the
examples below:

This diesel internal combustion engine shall not be operated more than 50 minutes per
day for maintenance and testing purposes. [Rule 20.2(d)(1)]

This diesel internal combustion engine shall not be operated more than 20 hours per
calendar year for maintenance and testing purposes. [Stationary Diesel Engine ATCM
Subsection (e)(2)(B)]

The permittee shall not use hexavalent chromium (chromium 6) or cadmium containing
coating in any motor vehicle or mobile equipment refinishing operation. [Title 17 CCR,
Section 93112]

The control devise shall reduce ethylene oxide emissions for each sterilizer exhaust by at
least 99.9% by weight [ETO ATCM Part 2, Subsection (D)]

3.23 Periodic Source Testing Guidance (Tom Weeks, June, 2011)

Periodic source testing is a useful tool for determining ongoing compliance with
applicable emission limitations and other requirements. District rules specify testing
frequency for some sources categories. These categories include: Electrical Generating
Steam Boilers (Rule 69), Industrial and Commercial Boilers, Process Heaters and Steam
Generators (Rule 69.2), Stationary Gas Turbines Engines (69.3.1) and Stationary
Reciprocating Internal Combustion Engines (69.4.1).

For other source categories, source test frequency is not specified by rule and will vary
based on a number of considerations. This guidance is intended to establish general
criteria for use in determining appropriate and consistent test frequency for these sources.

Test Frequency Considerations

As a general guideline, sources with an uncontrolled potential to emit greater than 5 tons
per year of criteria pollutants, should be tested every two years. Five ton sources have
significant emission potential and periodic testing also helps ensure accurate emission fee
calculation. Other factors that can be considered when establishing test frequency are:

•	Reliability and Maintenance Requirements of Proposed Emission Controls -
sources that use controls that have high maintenance requirements or are prone
to failure may warrant more frequent testing. Conversely sources with
reliable, low maintenance, controls may require less frequent testing.

•	Required Level of Emission Control - Sources that rely on very high control
efficiency to maintain compliance may warrant more frequent testing.

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Engineering Division Manual of Procedures

Conversely sources that can comply with a lower than anticipated control level
may require less frequent testing.

•	Facility Compliance History - New sources at existing facilities that have a
history of non-compliance may warrant more frequent testing.

•	Potential for Nuisance - Sources that have a high potential for nuisance due to
odor or dust emissions may warrant more frequent testing.

•	Potential Emission Level - Sources that exceed or have the potential to exceed
major source thresholds may warrant more frequent testing.

•	Accuracy and Reliability of Parametric Monitoring or Recordkeeping to
Determine Ongoing Compliance - Sources which have accurate and reliable
means of verifying compliance using parametric monitors and/or
recordkeeping may not require testing or may warrant less frequent testing.
For example, an uncontrolled VOC source that can demonstrate compliance
based on usage records and a material mass balance may not require testing.

•	Potential for Ancillary Toxic Emission Risks - Sources with emissions that
are close to a Rule 1200 threshold and/or rely on high levels of control to
mitigate risk may warrant more frequent testing.

Permit engineers should address these considerations and document their
recommendation in the engineering evaluations for review by the Senior Engineer. The
Monitoring Division should be consulted concerning technical issues, logistics and
resources, as necessary, prior to making a test frequency recommendation. The
Compliance Division will review and have an opportunity to comment on the proposed
source test frequency during their condition review.

3.24 BCMS steps for issuing an A/C (October, 2020)

In addition to adding conditions as described previously in these procedures, the
equipment description needs to be entered in BCMS prior to issuing the A/C. Contacts
also may need to be added or updated. Once approved the A/C is also issued from BCMS
and then electronically signed.

Adding the Equipment Description

Once the evaluation is prepared, you can prepare the A/C (or some parts can be done
simultaneously). The first step is to complete the process description task.

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Engineering Division Manual of Procedures

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All emissions vented to a custom, quad catalytic Filtration concentrator manufactured by to
odei 1,100,000 cfm. SM«#0+*QS

Run the A/C report and update contacts if necessary

The A/C report is in the reports section under engineering. Open the dialogue box and
click submit to generate the report.

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Engineering Division Manual of Procedures

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COUNTY OF SAN DIEGO, AIR POLLUTION CONTROI
10124 OLD GROVE ROAD. SAN DIEGO, CA92131
(859} 596-2600 FAX (858) 586-2601
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Sofrerto Vntity crematory
Douglas Tfohftugh
S60Ci Carre# Canyon Road

EQUIPMENT ADDRESS

sorrwuo Volay crematory
Douglas Tiotiaugh

The A/C report requires that the equipment description and A/C contacts exist in the
record. If there is an error in the report, check that these are entered and if not add them
or ask the engineering aide to add.

APCD2020-APP-006206 - Non-Retail Gas Dispensing Facility Fee Sched: 26E EFX

A notice was added to this record on 2020-09-30.

(l ) Condition: Severity: Notice

Total conditions: 1 (Notice: 1)

View notice

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Summary

Record - [26 A E F] GDF

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Activity Summary (2)

Address (1)

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United Rentals (North A...

791 East 64th Ave



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Kevin

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United Rentals (North A...

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United Rentals (North A...
United Rentals (North A...

100 First Stamford PI,S. ..
791 East 64th Ave
501 C St



I

Issuing the A/C

Once the application is approved, the A/C is issued through BCMS. Complete the
following fields in the issue A/C task, complete it and then the A/C report can be ran.

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Engineering Division Manual of Procedures

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-Ill-

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Engineering Division Manual of Procedures

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This Authority to Construct will expire on 11/28/2020 unless an extension is granted in writiJta.

This is not a Permit to Operate. Please be advised that installation or operation of this pcces^or equipment
without written authorization may be a misdemeanor subject to fines and penalties.

If you have any questions regarding this action, please contact me at (858) 586 2728 or v|a qmail at
Nicholas.Horres@sdcounty.ca.gov.

Use this button to
open signature tool,
then draw the
signature.

>	Nicholas Horres

Senior Engineer

3.25 Guidance on performing the Completeness Review (October,
2020)

1. When reviewing an application for completeness, engineers should focus on the
following areas. This review must be completed with 30 days of receipt of the
application.

•	Did they include the basic application forms

•	Can we tell some basic facts about the application from the proposal? (Can we
rule out an emission increase/TAC emission increase? Will the application trigger

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Engineering Division Manual of Procedures

BACT? Will a public notice be required? Is there information we don't need
because the proposal involves minimal review?)

• Based on these facts, do we have all the following information based on what
level of review is necessary:

o Information necessary to conduct HRA

o Sufficient description of the process including manufacturer data,

specifications
o Information to calculate emissions
o BACT determination including necessary cost data
o Material information (SDSs)
o Technical information regarding emission controls
o Other information necessary to show compliance with potentially
applicable rules

2. If the application is incomplete, a list of the missing information and/or questions
should be compiled into a letter or email to be sent to the applicant informing them that
the application is incomplete and that additional information is required. Applicants
should be requested to provide the information within 30 days and informed that the
application may be cancelled if incomplete for more than 180 days. Upload a copy of the
letter to BCMS. The BCMS Workflow task must be filled in as pending as shown here:

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Engineering Division Manual of Procedures

. it Details - Completeness Determination

Action By Division * Current Division Action By [ACA] * Current User

APCD Engineering Chen 4 ¥R

Nicholas Horres

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3. If the application is complete, engineers should complete the task in BCMS as follows
which will automatically notify the applicant that the application is complete. This email
should be uploaded to the application.

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Engineering Division Manual of Procedures

Task fMatifs - Completeness feterminafrou

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3.26 Documents required to be uploaded during A/C Evaluation
(October, 2020)

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Engineering Division Manual of Procedures

It is the Engineer's responsibility to upload all documents for engineering evaluations to
Documentum unless otherwise discussed and allowed by your supervisor. The following
documents should be present for all applications unless not relevant.

Uploaded before or at A/C Issuance (upload documents as they are available/finalized):

•	Application and attachments

•	Completeness Notification

•	Incompleteness notification

•	Response from applicant to incompleteness determination

•	Any other additional technical data provided by the applicant

•	HRA and AQIA reports

•	Copies of any NSR, AB3205 or other public notice

•	Invoices to the District for public notice and distribution costs (printing,
publishing, mailing)

•	Emission Calculations

•	Engineering Evaluation

•	Any public comments provided and District response (if any)

•	Any relevant correspondence with the applicant (while some routine applications
will not have any documents in this category, any discussion that clarifies the
application submittal or otherwise explains context of a permitting decision
should be included)

•	Any relevant correspondence with other regulatory agencies (e.g. EPA or CARB)
that justifies or explains a decision made in the application or in response to a
District notice.

•	Authority to Construct

3.27 A/C Extension Requests (October, 2020)

Authorities to Construct are issued for a one year period. If construction has not been
completed within this timeframe, the applicant may request an extension of an additional
year. This can be repeated up to 4 total times for a total of 5 years. If the applicant does
not request an extension or the A/C reaches the five year mark, we must cancel the
application. A/C extensions can only be issued when more time is needed to complete
construction. An A/C extension is not required once the CCN is submitted and authority
to operate under the A/C conditions is in effect until we withdraw the authorization or
issue an S/A or P/O.

A/C expiration dates are tracked with various tools including the open applications
report, the tickler report and BCMS notifications. BCMS will automatically notify the
applicant and cc the engineer prior to expiration. If the applicant does not respond to
request an extension, the engineer will make a second attempt to contact them within 5
days of the expiration of the A/C indicating that we intend to cancel the application. If
they do not respond within 14 days of A/C expiration, we should send a letter to them
indicating that we are cancelling the application. All three contact attempts (initial 30 day

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Engineering Division Manual of Procedures

reminder, second reminder and cancellation letter) should be uploaded to BCMS. The
supervisor should then be notified to cancel the application.

If the applicant does request an extension, we must ask them the following questions.
This can be done over email or verbally. Brief answers will typically be sufficient.
Why has construction not been completed?

Has construction begun?

How far along is construction and what is the expected completion date?

We ask these questions to determine whether or not any additional requirements need to
be added to the A/C. In rare cases prohibitory rules and state and federal rules may
change and we should revise the A/C to account for any changes prior to extending.
Additionally if construction has not begun, we can re-review the application for
compliance with BACT rules and can revise emission limits if a lower limit or new
technology has been found to be cost effective. The Engineer should briefly review
whether or not any of these situations can come into play and if so, obtain approval from
their supervisor prior to extending.

To extend an A/C, two separate BCMS task entries must be completed as shown in the
screenshots below. If the extension was requested by email the request should be
uploaded to documentum, otherwise the comments should be used to indicate a verbal
request.

First set the CCN task to "Reissue AC" in order to reopen the Issue Authority to
Construct task.

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Engineering Division Manual of Procedures

Task Delais - Construction Completion iefiee

Action if Division * Current Division Action By [ACAJ * Current User

APCD Engineering Chen & VR

Nicholas Hones

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the task. This will send an automatic email to the applicant listing the extension which
should be uploaded to Documentum automatically.

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Engineering Division Manual of Procedures

¦ Detail - Issue AiCthorvty rev Cons,tract

fiction By Division

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111/28/2018

111/28/2020

TSt; APCD I ATC V
-------
Engineering Division Manual of Procedures

etc.) to ensure projects are completed on time. Supervisors may also help by setting
shorter deadlines for simpler projects or incremental deadlines for more complicated
projects to ensure smooth work flow and prevent surprises near the end of the timeline.

Deem Application Complete/Incomplete - 30 days after receipt. Applications that are
not deemed either complete or incomplete within 30 days are considered by default to be
complete which may cause problems meeting the timeline to act on the application.

Act on Application for A/C- 180 days after deemed complete. If the District does not
approve or deny an application within 180 days, the application may be considered
approved by default may not have the appropriate conditions needed to ensure
compliance with District rules. While this does not relieve the operator of the need to
comply with rules, it is imperative that we meet this deadline. If this deadline cannot be
met, an extension must be requested from the applicant as discussed below.

Applicant Deadline to Respond to Incomplete Determination - 180 days after
deemed incomplete. If an applicant fails to respond we are required to cancel the
application. If an applicant requests an extension to the deadline, it should be documented
in writing in BCMS and discussed with your supervisor to determine if an extension can
be issued. Engineers should attempt to contact the applicant at least twice before
cancelling the application and upload the correspondence in BCMS. Applications may be
cancelled by providing written notice to the applicant. Cancellation notice may be sent
electronically for applications where email has been a primary method of communication
with the applicant.

Act on Application for P/O - 180 days after receipt of construction completion
notice. Engineers should finish the PTO engineering evaluation as soon as possible after
being notified that construction is complete but no later than 180 days unless there are
circumstances preventing approval of the application such as delayed startup testing. This
is important for two primary reasons: it helps ensure that the permit will be issued before
the startup authorization expires, and it minimizes the probability that additional renewal
fees will be due prior to issuing the permit.

3.30 Documenting Public Comments Received

The District is required to report on public comments received on an annual basis. To
facilitate this, Engineers are expected to log any comments received into BCMS as they
are received in addition to uploading any written comments received to Documentum.
Comments should be logged into the "comments" portlet in BCMS and should contain
the following information:

Public Comment Received
Date of Comment:

Type of Notification:

Was response provided?

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Engineering Division Manual of Procedures

Comment type:

Comment:

Response (if provided)

As an example, a comment should be entered similarly to this:

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3.31 Suggested A/C Permit Evaluation Process

To ensure that we meet the regulatory requirements for reviewing applications in a timely fashion, engineers should carefully plan
their work on applications so tasks that form the basis of later work are completed first, and any work that can proceed simultaneously
is identified to minimize the net time to review applications. The following figure provides an example of a typical A/C evaluation and
which steps can occur first or must occur later:

Step 1 - Emission Calculations

These are required for the HRA., determining rule &

CEQA applicability so must be done first. Revisions
may be necessary based on HRA or rule anaSysis.

Engineer should a'so check for schools within 1000 ft
and inform applicant early if AB32Q5 notice required.

Step 2 - HRA Request & CEQA

The HRA and CEQ.A Analysis can take a long time, so
process should be started early to keep on
schedule. Note CEQA will rarely require separate
analysts but is extremely important when required.

Step 3- HRA and Engineering Evaluation

These steps can all occur rough ly simu ltaneously: Engineer
should initially screen the proposal for potential issues with
NSR/BACT, prohibitory rule/ATCM/NSPS/NESHAP non-
compliance and HRA results (when available) and inform
applicant as soon as possible of concerns to avoid last minute
probiems.

CEQA
Considerations

School Distance
Check

Emission
Calculations

HRA

HRA Request

NSR Analysis

AB3205 Review

State & Federal
Rule Analysis

Prohibitory
Rules Analysis

Background/

Process
Description

Step 4 - Public Notice

Public notice will always occur last because a'l draft
evaluation must be finished prior to initiating any public
notice. Applicants should always be informed as soon as
the need for conducting a notice is discovered since this
can significantly affect timeline.

Public Notice

Title V

Recommendations

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4.

New Source Review

4.1	Interpretation of Rule 20.2(d) (August 11,1986)

Rule 20.2(d) requires BACT or LAER only for those specific pollutants that exceed the
"major source" thresholds. The rule was not intended to mean that cases where one
pollutant was major, all would be required to install BACT or LAER regardless of
emission levels. Accordingly, for new sources, BACT (attainment pollutants) or LAER
(non-attainment pollutants) will be required only for those pollutants that are "major,"
unless BACT is required at lower emission rates by application of Rule 20.2.

4.2	Emissions Counting for NSR Rules (April 9,1980)

A.	Non-vehicular emissions that are emitted directly from the stationary source (as
defined by Rule 20.1(a)(7) will be summed to determine if threshold levels are
exceeded. Direct emissions include, but are not limited to, those associated with the
new project from point source (stacks and chimneys), fugitive dust from vehicular
traffic, fugitive process emissions, emissions from the stacks and engines of ships
when they are in the "hotel" mode while loading or unloading cargo, on-site
emissions from railroad train engines associated with the source, etc.

B.	Emissions that should not be included with those from the source are:

1)	Increased power plant emissions that result from the production of additional
power to accommodate the source unless such power is generated on-site.

2)	Fugitive dust emissions that do not occur at the source.

3)	Emissions from ships that are in transit to or from the point of cargo transfer.

4.3 Cumulative NSR Emissions Summary Sheets (December 3, 2002)

A standard Cumulative NSR Emissions Summary Sheet should be used by engineers
processing permits at existing major sources for calculating and documenting cumulative
permitted emission increases to meet federal NSR and PSD requirements in Rules 20.3
and 20.4. The standard form is available on the S-drive.

A Cumulative NSR Emissions Summary Sheet is to be prepared for each permitting
action at every existing and proposed new stationary source that emits, or will emit, 25
tons per year or more of VOC or NOx, or 50 tons per year or more of PMio, SOx or CO.
A completed Summary Sheet is to be included as part of the permitting documentation
for permit actions at these stationary sources. Although major sources under NSR are
defined by emissions above 50 tons per year (NOx and VOC) or 100 tons per year (PMio,
CO and SOx), those thresholds are based on potential to emit. The 25/50 ton thresholds

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specified in this procedure will be used as a surrogate since in many cases inclusion will
be based on a stationary source's actual rather than potential emissions.

A stationary source is affected by this procedure if:

1.	It is an existing source with actual emissions equal to or greater than any of the
following:

•	25 tons per year of VOC

•	25 tons per year of NOx

•	50 tons per year of CO

•	50 tons per year of PMio

•	50 tons per year of SOx,

or

2.	It is an existing source with actual emissions below the levels specified in #1 but
will have emissions at or above any of those levels if the current application is
approved, or

3.	It is a new stationary source that will be permitted to emit at or above any of the
levels specified in #1.

A listing of existing stationary sources with emissions at or above the 25 and 50
tons per year thresholds is available on the S-drive, APCD /engineering/NSR
emission summaries/NSR and PSD 25 and 50 tpy list Sept 2002 share folder or from
the Emissions Inventory section.

If an engineer is processing an application for a new, modified, replacement or
relocated emission unit(s) at an affected stationary source, a Cumulative NSR
Emissions Summary Sheet must be completed as part of the Authority to Construct
(or modified Permit to Operate) evaluation. All criteria pollutant (VOC, NOx,
PMio, SOx and CO) emissions changes associated with new or modified permits
should be placed on a single NSR/PSD summary sheet for each affected stationary
source.

[Note: Summary sheets are not requiredfor stationary sources that emit less than
25 tons per year of VOC and NOx and less than 50 tons per year of PMio, SOx and
CO. However, some have been created in the past for smaller sources and are
available in the NSR Site Summaries folders.]

If the application is for an existing stationary source above a 25 or 50 tons per year
threshold, you will need to determine if an up-to-date complete Summary Sheet already
exists for the stationary source. The S-Drive share folders can be checked for an existing
Summary Sheet for the specific stationary source you are working on.

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If you open the folder and the icons appear as anything other than Excel icons, change the
"properties" of the files as follows: Right-click on any icon; Left-click on "Properties";
under the "General" tab, Left-click on "Change"; Left-click once to highlight the
"Microsoft Excel for Windows" option; Left click "OK". All of the icons should then
convert to Excel icons and should be accessible to you for use.

If a Summary Sheet already exists, update it by adding the information for the
Authority(ies) to Construct or permit(s) you are approving (and any missing permit
actions). Check the permit database and associated permit files for the last several permit
actions taken at the source and any other open applications that may be assigned to other
engineers. If only old worksheet(s) exist, transfer relevant emissions data to a new
Summary Sheet. If you are working on the first application for a new stationary source
or no sheet exists on the S-Drive, a new Summary Sheet for the stationary source using
the standard form needs to be created. If a Summary Sheet does not exist, or an existing
sheet is not up-to-date, the permitting engineer (or applicant - see above) will need to
prepare a current sheet that accounts for all permitting actions taken over the current and
preceding four calendar years (contemporaneous period under Rule 20.1).

The NSR Emissions Summary Sheet should also be updated if the allowable emissions in
the permit(s) are known to have changed from those currently shown on the Summary
Sheet for that stationary source.

Note that the form includes the BACT, AQIA, PSD, major source and offset trigger
levels at the bottom of the sheet.

Following completion (and Senior review and approval) of the new/updated Summary
Sheet, include a copy in the permit file as an attachment to your Engineering Evaluation
Cover Sheet. File the completed electronic version of the Summary Sheet in the
appropriate NSR Site Summaries folder. Filing is to be done alphabetically by stationary
source name.

Pursuant to Rule 20.3(d)(8), if an application is for a new major source or a modification
at an existing major source, the District project engineer can require the applicant to
prepare the contemporaneous emissions increase accounting. Either as part of pre-
application consultations or a request for additional information, the applicant should be
given the option of preparing the contemporaneous emissions increase accounting OR
having the District prepare the accounting as part of the NSR evaluation (at the
applicant's expense). If the applicant elects to prepare the accounting, the District must
provide access to or copies of previous/current permit application evaluation information,
if requested by the applicant. This can include the information described below. Any
accounting prepared by an applicant must be reviewed by the project engineer for
completeness, accuracy and that it has been prepared in accordance with the provisions of
the NSR rules. If changes are required, the applicant should be given at least one
opportunity to make corrections before the District determines either that the application
is incomplete and cannot be approved, or that the District will prepare the required
contemporaneous accounting.

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4.4	RACT/BACT/LAER Clearinghouse Submittals (Tom Weeks,
December 3, 2002, Revised 2/2012)

New BACT/LAER determinations must be submitted to ARB in a timely manner. These
submittals should not only include controls proposed for major stationary sources but also
any BACT determination for non major stationary sources.

BACT/LAER determinations must be submitted to ARB upon senior approval by
completing the form available at http://arbis.arb.ca. gov/bact/bact.htm (password
bact005). ARB has requested up to five determinations per District. Therefore, if you
make a determination that is already posted on the Clearinghouse website, you should
still complete the form unless there are already five of the same determinations from San
Diego.

Submittal of determinations was identified as an area for improvement in a past ARB
audit. Permit processing engineers use the Clearinghouse for information on the BACT
and LAER determinations made by other districts. Therefore, it is important that we
contribute our determinations to this shared resource.

Determination is based on the District's BACT Guidance Document look-up tables need
not be submitted.

4.5	Repeal of State Offset Requirements (December 23,1998)

As of December 17, 1998, Engineers no longer need to implement State offset
requirements on pending applications for Authorities to Construct or modified Permits to
Operate. The requirements to offset all VOC and NOx emission increases subject to
NSR at facilities with the potential to emit more than 15 tons per year of either VOC or
NOx is no longer in effect. BACT and AQIA requirements still apply. Also federal
LAER/BACT offset and PSD requirements still apply.

4.6	Interpretation of Rule 20.3(d)(4)(i) Procedure Regarding Timing
of Final Actions on Applications Requiring Public Notice and a 30-Day
Comment Period (November 24,1999)

A question has arisen concerning interpretation of Subsection (d)(4)(i) of Rule 20.3. This
subsection provides for a public notice of a proposed action on an application that will
result in emission increases sufficient to require an air quality impact analysis, notice of
such proposed action to ARB and EPA, availability of specified information for review,
and a thirty day period within which comments can be provided. This subsection also
requires that these actions be initiated 40 days prior to final action on the application, and
that the District consider all comments submitted. Subsection (d)(4)(ii) also provides for
a period of ten days after the close of the public comment period for the applicant to
respond to comments received.

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The question has been raised whether the District can take final action after the 30-day
comment period has closed but less than 40 days after the notice of proposed action is
given if no comments have been submitted or if the comments submitted can be
considered sooner than the 40 days. The intent of the 40 days was to allow the District
time to consider comments submitted and for the applicant to respond to comments if the
applicant so chooses. The intent was not to extend the opportunity for comment beyond
30 days or to unnecessarily delay taking final action.

Final action on such an application may be taken after the close of the 30 day comment
period and before 40 days after notice of the proposed action is given if:

•	No comments have been submitted.

•	For time critical projects, if all comments submitted have been reviewed and
considered before taking final action and the applicant has elected not to respond to
the comments or has responded and the applicant's comments have been considered
before taking final action. All comments shall be discussed with the Chief of
Engineering prior to taking final action.

4.7	Air Quality Impact Modeling Referrals (September 24,1993)

It has been brought to attention that some Engineering staff have been providing
guidance to applicants and their consultants with regard to modeling and procedures for
conducting air quality impact studies, both for criteria pollutant modeling and toxic air
contaminant impacts, that will be prepared by the applicant or a consultant. This has
resulted in incorrect or misunderstood guidance that must be subsequently corrected at
the time of modeling protocol submittal. District guidance should come from the group
responsible for reviewing and approving such modeling, i.e. the Meteorology and
Modeling Section of Monitoring & Technical Services.

To ensure that appropriate guidance is provided, all discussions with applicants or
consultants regarding either criteria pollutant or toxic air con t modeling that they will be
preparing, beyond just a general description of the APCD process (i.e. if modeling is
required, submit protocol for approval, model following approved protocol), are to be
referred to the appropriate M&TS Modeling Section staff. If you will be in a meeting
with an applicant or consultant at which modeling to be prepared by them may be
discussed, you should alert the M&TS Modeling staff and ask them to attend, or join the
meeting when modeling is discussed. If you are in a meeting when such modeling is
brought up, you should see if a M&TS Modeling staff person is available or, if not,
advise the applicant or consultant to contact the appropriate Modeling staff person. You
should then advise that staff person to expect the contact and what issues may arise.

4.8	EPA Allowable Preconstruction Activity Guidelines (November 4,
1993)

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This section reiterates EPA's longstanding interpretation concerning the range of
construction related activities that lawfully may occur prior to the issuance of a permit to
construct or modify a facility or emissions unit.

The Clean Air Act mandates a pre-construction review program for sources subject to
Prevention of Significant Deterioration (PSD) (§ 165) and New Source Review (NSR)
(§§ 172 and 173) requirements. In addition, under § 110 (a)(2)(c), State and local
agencies are required to include in their State Implementation Plans pre-construction
review programs necessary to assure that construction of any new or modified source is
consistent with attainment of the National Ambient Air Quality Standards. To fulfill this
requirement, most District rules require that any person building any article, machine, or
contrivance which may cause the issuance of air contaminants shall obtain authorization
for such construction prior to beginning actual construction. Pre-construction review is a
necessary precursor to engineering and public review processes. As a result of this
process, the permitting authority may require installation of air pollution control or
monitoring equipment that was not initially provided for in the design process. Thus, the
pre-construction review process is mandated both to ensure that Clean Air Act
requirements are met and to help sources avoid costly construction changes.

The question of what type of preliminary site activities may be conducted prior to permit
issuance was addressed by EPA policy memoranda on December 18, 1978, March 28,
1986 and May 13, 1993. These memoranda explain that certain limited activities that do
not represent an irrevocable commitment to the project would be allowed, such as
planning, ordering of equipment and materials, site clearing, grading, and on-site
temporary storage of equipment and materials. Any of these activities, if undertaken
prior to issuance of a permit, would be at the risk of the owner or operator.

In contrast, all on-site activities of a permanent nature aimed at completing construction
or modification of the source—including, but not limited to, installation of building
supports and foundations, paving, laying of underground pipe work, construction of any
permanent storage structure, and activities of a similar nature—are prohibited until after
the permit is issued and effective, under all circumstances.

4.9 EPA Notifications Required (June 8,1992)

We are required by District rules, EPA policies and our grant from EPA to notify EPA
Region 9 of certain proposed permit actions, and to provide specified background
materials. Notice of the following should be provided to EPA Region 9:

•	Receipt of an application for permit for any new major source that will cause an
increase in emissions greater than 100 tons per year of NOx, SOx or total
particulates. Notice to be provided within ten days of the receipt of the application.

•	Receipt of an application for permit for any major modification of an existing major
source that will cause an increase in emissions greater than 40 tons per year of NOx

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or SOx or 25 tons per year of total particulates or 15 tons per year of PM10. Notice
to be provided within ten days of the receipt of the application.

• Proposed Authorities to Construct for any new or modified source that will result in
an emissions increase equal to or greater than:

Except for PM10, these notice triggers are identical to that of Rule 20.3. For PM10,
the Rule 20.3 trigger of 25 tons of total particulates per year can be used as an
indicator of whether PM10 may exceed 15 tons per year. However, the latter is the
EPA requirement.

Notice to EPA should be provided 10 days prior to the beginning of the public
comment period of Rule 20.3 and should include copies of the public notice, the
draft AJC and the Engineering Evaluation Coversheet.

•	Proposed draft Authorities to Construct or modified permits for sources that
propose to use onsite emission reductions to net out of NSR or PSD review.

•	Proposed banking credit certificates. Notice should be provided with submittal of
the public notice for publication and should include copies of the draft emission
reduction credit certificate, the public notice and the Engineering Evaluation
Coversheet.

•	A copy of the final Authorities to Construct for projects listed above, including
responses to any EPA comments received.

All notifications should be sent to:

New Source Section (A-3-1)

EPA, Region 9
75 Hawthorne Street
San Francisco, CA 94105

4.10 Notice of EPA of Banking Actions

EPA must be notified of all banking actions. All notifications to EPA for permitting and
banking actions must include a copy of the public notice and a copy of the proposed
Authority to Construct, modified Permit to Operate (if no A/C) or banking certificate, as
applicable.

ROG

NOx
SOx
CO
PM10

250 lbs./day or 40 tons per year
250 lbs. /day or 40 tons per year
250 lbs./ day or 40 tons per year
550 lbs./ day or 100 tons per year
80 lbs./day or 15 tons per year

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4.11 Implementation of 1998 NSR Revisions (December 1998)

With ARB approval of the repeal of the state offset program in San Diego's NSR rules,
the requirement to offset all VOC and NOx emission increases from permitting actions
subject to NSR at facilities with the potential to emit more than 15 tons per year of either
VOC or NOx is no longer in effect. BACT and AQIA requirements still apply. Also,
federal LAER/BACT, offset and PSD requirements still apply. However, these are
triggered at the generally much higher major source, major modification or PSD
thresholds specified in the NSR rules.

Engineers should no longer be implementing state offset requirements -on pending
applications for Authorities to Construct or modified Permits to Operate. Engineers must
continue to calculate and document the emission increases for their applications. Under
the ARB approval we will need to periodically assess the overall regional emission
effects of repealing the state offset requirements. The Evaluation Coversheet includes a
table (and related database) for compiling emission increases (both permitted and
expected). This information will be used not only for the tracking required by ARB but
also as a means of identifying sources that should be inventoried under the criteria
emissions inventory and Toxic Hot Spots programs and as an aid in estimating emission
fees.

A. Applying Federal NSR/P SD Requirements

For the vast majority of permitting actions, BACT (and occasionally AQIA.

requirements) will be the only NSR requirements. Federal NSR/PSD requirements

apply only when the project under review:

•	By itself constitutes a new major source of VOC or NOx. This occurs when
the new project's post-project potential to emit is equal to or greater than 50
tons per year of either VOC or NOx (not combined).

•	By itself constitutes a new PSD major source. See Rule 20.1 for the emission
thresholds for this type source.

•	Is located at an existing major stationary source of VOC or NOx and, in
conjunction with other contemporaneous emission increases and decreases
from permitting actions occurring at the stationary source, constitutes a major
modification (an emissions increase equal to or greater than 25 tons per year
of VOC at an existing major VOC stationary source or 25 tons per year of
NOx at an existing major NOx stationary source).

•	Is located at an existing major PSD stationary source and, in conjunction with
other contemporaneous emission increases and decreases from permitting
actions occurring at the stationary source, constitutes a PSD modification (see
Rule 20.1 for the emission increase thresholds for a PSD modification).

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Few projects will by themselves constitute a new major source or PSD source or
even a PSD modification. However, applications for new or modified emission
units or permits at existing major VOC or NOx sources must be evaluated to see if
those applications constitute a major modification for VOC or NOx. This requires
determining not only the emissions increases from the project being evaluated, but
also all contemporaneous emission increases and decreases of VOC and NOx that
have been permitted at the major stationary source during the five year
contemporaneous period. (Note: because of changes in federal law, the
contemporaneous accounting period has changedfrom the period back five years
from receipt of a complete application to the period consisting of the calendar year
in which the project will commence operation and the four preceding calendar
years.)

Whether an existing stationary source is major for VOC and NOx is based on the
source's aggregate potential to emit (PTE). However, doing a PTE inventory on
every stationary source for which we receive an application to determine if it is
major based on PTE would be time consuming and inefficient. In order to
minimize the number of cases where a contemporaneous accounting is needed,
permitting engineers are to evaluate whether an existing stationary source is major
for VOC and NOx only in the following cases:

•	When the application for a new or modified emission unit results in an annual
emissions increase of VOC or NOx,

and

•	The actual emissions at the existing stationary source equal or exceed 25 tons
per year of VOC or NOx, whichever is the pollutant for which the application
results in an emission increase. The 25 tpy actual emissions will be used as a
surrogate for a PTE of 50 tpy or more.

•	A list of existing sources whose actual emissions inventory is equal to or
greater than 25 tons per year of VOC or NOx is available from Emissions
Inventory. Engineers should use this list to identify existing potential major
sources for initiating a more detailed NSR review. The list will be regularly
updated by Emissions Inventory and will be posted in Engineering's VAX
share file.

•	If actual emissions for the existing stationary source equal or exceed 50 tons
per year of VOC or NOx, then clearly the source is major for that pollutant
and a further evaluation of aggregate PTE is unnecessary.

•	If actual emissions are equal to or greater than 25 but less than 50 tons per
year of VOC or NOx, then the aggregate PTE must be evaluated to determine
if the stationary source is major for either VOC or NOx. The aggregate PTE

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should include all existing permitted emission units and any units/projects for
which an Authority to Construct has been issued.

The applicant is to be advised by the project engineer that an evaluation of
aggregate PTE will be needed to determine if the stationary source is major, and if
major, that a contemporaneous emissions increase accounting will be required. The
applicant must be given the option of preparing these evaluations for review by the
District or having the District prepare them. An applicant may elect to propose
limiting conditions on the total stationary source emissions to ensure that the source
PTE is less than major source levels. In this case, a new application should be
submitted by the applicant detailing how emissions would be limited and proposing
monitoring and records necessary to assure compliance with the aggregate
emissions limit(s). Rule 60.2 should be consulted since the procedures will be
analogous to that for creating synthetic minor source permits.

Once it is determined that the existing stationary source is major for VOC or NOx,
if the project will result in an annual emissions increase of whichever pollutant is
major, an accounting of contemporaneous emission increases and decreases must be
done to determine if the project is a major modification and subject to federal
LAER/BACT/offset requirements. This accounting must include any other units or
projects for which an application is pending review.

B. Permit Limits on Emissions

Another aspect of the NSR changes is that with the repeal of the state offset
requirements, the 15 ton per year offset threshold that frequently was used in
permits to limit emissions no longer applies. This can affect existing Authorities to
Construct and Permits to Operate as well as applications under current review. We
should expect that applicants and permit holders with 15 ton per year limits already
in their permits will request that the limit be removed. While this may be
permissible, it should not be done administratively on a wholesale basis. Releasing
the applicant/permittee from this threshold could have implications relative to toxic
air contaminant emissions, previous BACT cost effectiveness decisions or
compliance with a prohibitory rule.

Therefore, a request to remove a 15 ton per year limitation in a permit or AJC must
be done in the form of an application to modify the permit or amend the A/C,
respectively. The project engineer must charge the applicant for the costs of
evaluating the change, and the change must be evaluated under the provisions of the
current Rules and Regulations, including the revised (12/98) NSR rules.

For current open applications and future applications subject to NSR review,
emissions may be limited in permits by the most stringent of:

• the operating levels (e.g. hours of operation, fuel/materials usage, production
levels) requested in an application by a permit applicant,

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•	a Rule 1200 review,

•	B ACT or B ACT cost-effectiveness threshold (or limits on the applicability of
B ACT look-up tables in the B ACT Guidance Document),

•	AQIA thresholds or an AQIA result,

•	public notification thresholds,

•	compliance with a District rule or regulation, state ATCM or federal NSPS or
NESHAPs (or emissions/operational limits to avoid applicability of one or
more such standards),

•	the federal NSR or PSD thresholds for major sources /major modifications, or

•	the physical capacity of the unit to emit considering any emission controls that
are proposed/required for the unit.

In the absence of the 15 ton per year state offset threshold for VOC and NOx, the
allowable emissions for some projects could be relatively high (e.g. up to new
major source levels absent any other limiting rules). The District needs to ensure
that the apparent emission increases in permits are realistic, consistent with the
District's authority in Rule 21 to impose permit conditions necessary to ensure
compliance.

Accordingly, the procedure henceforth will be to include in permits as limiting
conditions the levels of operation requested by the applicant in the permit
application. Those levels may not exceed the physical capacity of the emission
unit, and the operations must be in compliance with all applicable District rules and
regulations, and with any state or federal rules the District is enforcing. The levels
should be those reflected in the final application information on which a permitting
decision is being made.

For example, an applicant may specify maximum coatings use in a paint spray
booth, at a non-major source, of 2 gallons per hour, 10 gallons per day and 1000
gallons per year. After completion of the engineering evaluation, the project
engineer determines that the applicant has proposed B ACT and the operations will
comply with all District rules. Even though the NSR and Rule 1200 analyses might
find that the emission unit would still comply with much higher coatings usage, the
permit must be written with conditions limiting usage to the levels requested in the
application. (Note: If there are no acute health effects issues, there may be no need
to include an hourly usage limit in the permit.) The permit must also include
conditions requiring the site to keep records necessary to assure on-going
compliance with the operational limits. These conditions should be discussed with
the applicant before proceeding with the A/C, S/A or P/0, as applicable.

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When the operational levels requested by the applicant are the determining
limitation on emissions, they are to be reflected in the permit as operational limits,
not as underlying emission limits. The permit may also contain emission limits that
coincide with emission limits in applicable rules. If the conditions that will be
imposed in an Authority to Construct or in a new or modified permit will allow
emissions from the emission unit under review to equal or exceed 15 tons per year
of either VOC or NOx, the project engineer must consult with their Senior Engineer
and advise the Chief of Engineering before proceeding with the authorization.

C. Deferred/Pending/Provided Offsets

Existing permit (or Authority to Construct) conditions that allowed previous
projects to defer small amounts of state offsets (VOC, NOx, PMio) can be
rescinded. This will be done administratively for existing permits to operate and
will not require a source to submit a new application. In the case where such a
condition appears in an A/C, the project engineer should not carry forward the
condition to the permit. However, this does not allow administrative removal of
any existing operational or emission limits in the permit or A/C. Any emission or
operational limits in the permit or A/C must remain in effect and can only be
changed by an application to modify the permit or amend the A/C and after a
reevaluation of the new request under current NSR and other applicable rules.

Where an A/C requires that an applicant provide state offsets before commencing
operations, but the ERC's have not yet been surrendered to the District, the
requirement to provide offsets is to be rescinded by the project engineer by issuing
a revised AIC (with the applicant's concurrence). An application to amend the A/C
would not be required for this change.

Where an application is pending and the Applicant was told that offsets were
required, the project engineer is to advise the applicant that offsets are no longer
required. This must be documented in the application file.

Where an applicant/permittee has already provided state offsets for a project the
ERC's have been surrendered to the District, and the operations being offset have
commenced, those ERC's are no longer valid and cannot be returned to the
applicant/permittee.

All labor spent on an application associated with the above procedures must be
charged to the application.

The above procedures do not apply to offsets required to meet federal NSR, to
mitigate a local air quality impact, or required as a result of a CEQA analysis.

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5. Toxic New Source Review

5.1 Rule 1200 Toxic Screening Procedure and Screening Emission
Rates (April 12,1998, modified April, 2009, modified September 2,
2010, modified May 2012, modified February 2016)

OVERVIEW

This procedure provides District engineering staff and permit applicants with a screening
tool that can be used to evaluate projects which undergo toxic new source review in
accordance with District Rule 1200. If a project meets the applicability criteria and has
emissions less that the screening emission rates in Tables 3 and4, the project is in
compliance with Rule 1200 and will not require further evaluation. Projects that do not
meet the screening criteria or which have emissions greater than the screening emission
rates on Tables 3 and 4 will require further evaluation using refined health risk
assessment (HRA) procedures.

The procedure is intended to be health protective. Therefore, caution should be exercised
when using the results of this procedure to set usage or emissions limits for equipment
being evaluated. Additionally, as with any application, equipment should not be
purchased or installed until after the District has issued an Authority to Construct.

Screening emission rates on Table 3 and 4 may be adjusted for projects with receptors
greater than 25 meters away or for sources with exhaust stacks 15 feet tall or greater.

This procedure will be revised periodically to reflect updates to health (dose-response)
data, addition or deletion of listed toxic air contaminants, and changes in risk assessment
methodology. The District Toxics Section is responsible for updating this procedure and
screening emission rate values as needed.

APPLICABILITY

The screening emission values specified in Table 3 can be used to evaluate point sources
that meet all of the following minimum criteria:

1.	Sources with vertical exhaust stacks without raincaps or other obstructions to vertical
flow.

2.	Sources with exhaust stacks 5 feet above ground level or greater.

3.	Sources with exhaust stack exit velocities of 2 feet per second or greater.

4.	Sources with a distance from the stack to nearest facility boundary (fence line) of 10
meters or greater.

5.	Sources with stacks exceeding the height of all buildings within a distance of 5 times
the height of the stack.

The screening emission values specified in Table 4 can be used to evaluate non-elevated
volume sources where the distance from the volume source to the nearest facility

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boundary (fence line) is 10 meters or greater. Non-elevated volume sources are typically
fugitive sources that are not captured and vented through an exhaust system. They can be
either inside or outside of a building. If you are unsure if a source can be evaluated as a
non-elevated volume source under this procedure, consult the District Toxics Section.

The procedure can be used to evaluate sources with multiple emission points. To do this
the total of the ratios of the potential emissions to the screening emissions values for each
source are assumed to be additive, and are summed to determine the aggregate impacts.

Per Rule 1200, a higher cancer risk is allowed for sources equipped with Toxics Best
Available Control Technology (TBACT). However, if the calculated emission rates are
greater than the screening level emission rates (for only one toxic air contaminant
emitted) or if the sum of the ratios of potential emissions to screening level emissions are
greater than 1.0 (for more than one toxic air contaminant emitted), further evaluation
using a refined HRA is required. The permit engineer shall provide all the pertinent
information to conduct an HRA to the District Toxics Section. The District Toxics
Section shall provide an HRA report to the permit engineer which presents the risks to
determine compliance with Rule 1200. Permit applicants may consult with the
appropriate District engineering section for assistance in determining if the proposed
level of control is considered to be TBACT.

These procedures are not applicable to projects with emissions of dense gasses or
emissions which are not continuous. A dense gas is an emission of high concentrations
of a TAC that is significantly heavier than air and/or is significantly below ambient
temperature. Emissions that occur for periods of less than one hour are not considered to
be continuous.

PROCEDURE FOR TOXIC SCREENING
Identify Toxic Air Contaminants

Emissions of any amount of a toxic air contaminant listed on Table 3 and Table 4 must be
evaluated. Many toxic air contaminants have a number of synonyms. For example,
methyl chloroform, TCA and 1,1,1-trichloroethane are the same substance. One way to
ensure you have evaluated all subject compounds is to cross reference the Chemical
Abstract Service (CAS) registry number (available on most MSDS sheets) against Table
3 and 4. EPA's cross-reference booklet, Common Synonyms (EPA 745-R-95-008), is
useful for this. The National Institute of Standards and Technology (NIST) has a useful
website at http://webbook.nist.gov/chemistry/ may also be used to cross reference the
CAS registry numbers and common synonyms.

In addition, several classes of compounds are identified by group, such as chlorofluoro-
carbons, zinc compounds, chlorinated dibenzodioxins and furans, and others. Consult
with the District Toxics Section for questions regarding identification of specific toxic air
contaminants with listed groups of compounds.

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Determine Averaging Times for Assessment

Source emission rates must be calculated to correspond to the averaging periods of the
screening emission rates listed in Tables 3 and 4. Based on the potential health effects
related to each toxic air contaminant, either or both the annual and/or maximum hourly
emission rates must be calculated. For example, nickel has both an annual and maximum
hourly screening emission rate listed on Tables 3 and 4, therefore, emission rates must be
calculated for both averaging times. Lead has only an annual emission rate listed on
Tables 3 and 4 and therefore, only the annual emission rate must be calculated.

Calculate Potential Emissions for each Applicable Averaging Time

Emissions can be calculated using emission factors, mass balance, engineering
calculations, source test results or toxic compound speciation profiles. The District
Toxics Section has compiled emission estimation methods for a number of common
processes. These methods are presented on the District's website at
http://www.sdapcd.org/toxics/emissions/emissions.html. You may consult with the
District Toxics Section concerning emission calculations unless a simple mass balance or
a previously established emission estimation method is available.

Annual emissions are the total potential emissions (expressed in pounds per year) of the
listed toxic air contaminant released under expected maximum operating conditions
during a one-year period. Maximum hourly emissions are the maximum potential
emissions (expressed in pounds per hour) of the toxic air contaminant occurring in one
hour under expected maximum operating conditions. Guidance on determining the
emission increases, potential to emit and emission reductions are presented in Rule
1200(e).

Calculate Receptor Proximity Adjustment Factor and/or Stack Height Adjustment Factor
(Option 1)

The screening emission rate values presented in Tables 3 and 4 are based on the
assumption that the nearest receptor is 10 meters from the emission source. If the nearest
receptor is a distance of 25 meters or more, dispersion from the source will be greater
which results in higher screening emission rate values. In addition, the screening
emission rate values presented in Table 3 are based on a stack height of 5 feet. If the
source being evaluated has a stack 15 feet tall or taller, dispersion from the source will be
greater which also results in higher screening emission rate values. This toxic screening
procedure allows the screening emission rate values to be adjusted for additional
dispersion by use of a dispersion adjustment factor (DA).

The source to receptor distance (D) must be known in order to calculate the DA factor.
Source to receptor distance is the minimum distance from any source of emissions from
the emission unit being evaluated to any receptor. The term receptor, as used in the
calculation of the DA factor is defined as a residence, business, school, daycare center,
hospital, hotel, government facility, retirement home, or any other location where

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extended public access is possible. When calculating a DA factor for use with an acute
screening emission rate value, the definition above is expanded to also include any
location where short-term (one-hour) public access is likely. This typically entails
determination of two DA factors; one for calculation of cancer and chronic DA factor,
and one for calculation of the acute DA factor. The two DA factors may be based on
separate receptor distances - one for cancer and chronic exposures and one for acute
exposure.

The Rule 1200 submittal package must include a map that shows the source location(s),
facility boundary, nearest receptor(s) and dimensions of any building(s) within 5 times
the height of the stack.

Table 1 is used to calculate dispersion adjustment factor (DA) as a function of receptor
distance and stack height.

Table 1

Dispersion Adjustment (DA) Factors

Source Type

Averaging
Time

Receptor Distance, D (meters)

10 to

<25

25 to

<50

50 to

<75

75 to
<100

100 to
<150

150 to
<200

>200

Point Source

(5 to <15 foot
stack height)

Annual

1.0

2.0

4.5

7.7

11.7

21.5

33.6

1-hour

1.0

1.9

3.8

6.4

7.1

9.5

12.1

Point Source

(>15 foot stack
height)

Annual

1.0

7.2

10.9

15.9

21.4

33.3

46.6

1-hour

1.0

8.3

14.3

19.0

22.8

30.5

40.1

Volume Source

Annual

1.0

3.4

9.8

18.7

29.7

57.7

92.6

1-hour

1.0

1.8

2.7

3.9

5.2

8.2

11.6

Ratio of Toxics Screening Dispersion Factors using the AERSCREEN Model
(Option 2)

A ratio of the dispersion parameter X/Q (ug/m3)/(g/s) from AERSCREEN to those listed
in Table 2 below may be used to adjust the screening emissions rates in Tables 3 and 4 as
follows:

(Toxics Screening X/Q from Table 2) / (AERSCREEN X/Q) * Screening Emission Rates
listed in Tables 3 and 4. As with Table 1, Table 2 Toxics Screening Dispersion Factors
are a function of receptor distance and stack height.

Table 2

AERSCREEN Dispersion Adjustment (DA) Factors, (ug/m3)/(g/s)

Source Type

Averaging

Receptor Distance, D (meters)



Time



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10 to

<25

25 to

<50

50 to

<75

75 to
<100

100 to
<150

150 to
<200

>200

Point Source

(5 to <15 foot
stack height)

Annual

5933

2276

935

546

362

197

126

1-hour

70156

37330

18353

11017

9893

7417

5790

Point Source

(>15 foot stack
height)

Annual

600

656

473

310

220

131

91

1-hour

16309

8486

4908

3691

3081

2296

1748

Volume Source

Annual

12120

3567

1237

649

408

210

138

1-hour

121200

61255

40645

28567

21291

13441

9474

Compare Calculated Emission Rates with Screening Emission Rate Values

Annual and maximum hourly screening emission rates for toxic air contaminants are
listed in Tables 3 and 4. Using the appropriate table (Table 3 for point sources or Table 4
for non-elevated volume sources), determine the screening annual emission rate and/or
the screening maximum hourly emission rate, whichever apply. If appropriate, these
emission rates may be adjusted for receptor proximity by multiplying them by the DA
factor presented in Tables 1 or 2 above. Note: if the screening emission rates are adjusted,
only one of the two adjustment options may be used.

If only one toxic air contaminant is emitted and the calculated emission rates for each
applicable averaging time is less than the screening level emission rates, the risks are
expected to comply with Rule 1200 and no further review is required. Documentation of
the evaluation must be provided to the District Toxics Section.

If more than one toxic air contaminant is emitted, the evaluation is based on the sum of
the ratios of potential emissions to screening emission rates for each toxic air
contaminant evaluated. This is done separately for each applicable averaging time. If the
sum of the ratios of potential emissions to screening emission rates are less than or equal
to 1.0, the risks are expected to comply with Rule 1200 and no further review is required.
This procedure is demonstrated in the example calculation below. Documentation of the
evaluation must be provided to the District Toxics Section.

The same method is used to determine the aggregate effect of multiple emission points or
sources that are considered to be part of the same project. To do this the total of the ratios
of the potential emissions to the screening emissions values for each source are assumed
to be additive, and are summed to determine the aggregate impacts. If the sum of the
ratios of potential emissions to screening emission rates are less than or equal to 1.0, the
risks are expected to comply with Rule 1200 and no further review is required.
Documentation of the evaluation must be provided to the District Toxics Section.

If more than one toxic air contaminant is emitted and the sum of the ratios of potential
emissions to screening emission rates are greater than 1.0, further evaluation using
refined HRA procedures is necessary. The permit engineer shall provide all the pertinent
information to conduct a refined HRA to the District Toxics Section. The District Toxics

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Engineering Division Manual of Procedures

Section shall provide a refined HRA report to the permit engineer which presents the
potential risks to determine compliance with Rule 1200.

The screening levels in Tables 3 and 4 should not be used to limit emissions for a source
whose emissions exceed those levels. This could result in unnecessarily limiting the
facility's operation due to the conservative nature of the screening level analysis.

Instead, a project that has emissions above the screening emissions should undergo
further evaluation using a refined HRA.

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Example Calculations 1:

A source is estimated to emit xylene at a rate of 10,000 pounds per year and 9.0 pounds
per hour. It is also estimated to emit toluene at a rate of 6,000 pounds per year and 3.0
pounds per hour. The source emits through an exhaust stack that is 20 feet tall at a
velocity greater than 2 feet per second. There are no buildings greater than 20 feet in
height within 100 feet of the stack. The stack is not fitted with a rain cap and is
uncontrolled and therefore not a TBACT source. The distance from the stack to the
nearest receptor is 65 meters.

From Table 3, the screening emission rates for xylene are 1.15E+04 pounds per year and
2.49 pounds per hour, and for toluene, 4.93E+03 pounds per year and 4.19 pounds per
hour. The dispersion adjustment factors from Table 1 are 10.9 (annual) and 14.3 (one
hour). For xylene, DA factor adjusted screening emission rates are 125,350 pounds per
year (11,500 x 10.9) and 35.6 pounds per hour (2.49 x 14.3). For toluene, the DA factor
adjusted screening emission rates are 53,737 pounds per year 4,930 x 10.9) and 59.9
pounds per hour (4.19 x 14.3). The acceptability test for the annual assessment is as
follows:

f 10,000 lb Xylene/yr \ f 6,000 lb Toluene / yr ^	^ ~ , , , , , ^

	-	= 0.0% + 0.\\ = 0.\9whichislessthan\.0

v 125,350lb Xylene/yr J ^53,737 lb Toluene/yr J

The acceptability test for the hourly assessment is as follows:

( o n /a	lu-w \ ( 2.0 lb TolueneIhr ^

9.0 lb Xylene hr
35.6 lb Xylene I hr J l 59.9lb Toluene I yr

= 0.25 + 0.05 = 0.30 which is less than 1.0

Both the annual emission rate and the one-hour emission rate pass the test and therefore
the

project does not need to be evaluated further.

Example Calculations 2:

Using the same information provided for Example Calculations 1, ratio of the dispersion
parameter X/Q (ug/m3)/(g/s) from AERSCREEN to those listed in Table 2 to adjust the
screening emissions rates in Tables 3 and 4 as follows:

AERSCREEN is run and results in an hourly X/Q of 510 (ug/m3)/(g/s) adjusted to an
annual concentration (0.1 * hourly) of 51 (ug/m3)/(g/s).

Table 2 Dispersion Factors are an annual concentration of 473 (ug/m3)/(g/s) and an
hourly of 4908 (ug/m3)/(g/s).

(Toxics Screening X/Q) from Table 2) / (AERSCREEN X/Q) * Screening Emission
Rates listed in Tables 3 and 4.

Annual Dispersion Factor Ratio:

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Engineering Division Manual of Procedures

(l 1,500 lb Xylene/ yr) = 106,657 lb Xylene/ yr

f 473XJ_Q)
51X/Q

^ 10,000 lb Xylene / yr ^

106,657 lb Xylene I yr
Hourly Dispersion Factor Ratio:

= 0.094 which is less than\ .0

4908 X/Q
510 X/Q

(2.49 lb Xylene / hr) = 24 lb Xylene / hr

r 9 lb Xylene / hr ^
24 lb Xylene / hr

= 0.38 which is less than1.0

Both the annual and hourly emission rates pass and therefore the project does not need to
be further evaluated.

Requests for Additional Toxic Evaluation

Sources which do not meet the criteria for this screening procedure and projects with the
sum of the ratios of potential emissions to screening emission rates are greater than 1.0
must be evaluated further through a refined HRA. It should not be assumed that a source
that fails this screening procedure would not pass a more site-specific review. Additional
review can be done by either the facility or the District Toxics Section.

The District Toxics Section typically conducts a screening-level HRA using a screening-
level dispersion program (AERSCREEN) and simplified procedures. The screening-level
HRA incorporates stack parameters (height, diameter, temperature, and flow rate),
distance to offsite receptors, and building dimensions. Sources with better dispersion
potential (generally higher stack heights, temperature and flow rate), and greater distance
to offsite property are more likely to benefit from this secondary screening.

If this secondary screening is not successful, the District Toxics Section, in conjunction
with the Meteorology and Modeling Section, will conduct a refined HRA using detailed
source, building, receptor and site information in conjunction with actual meteorological
data to evaluate potential risk.

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Table 3

Rule 1200 Screening Emission Rates for Point Sources

Chemical Name

Chemical

Annual

Hourly



Abstract

Emission

Emission



Number

Rate

Rate





lb/yr

lb/hr

ACETALDEHYDE

75-07-0

2.09E+00

5.32E-02

ACETAMIDE

60-35-5

2.99E-01



ACROLEIN

107-02-8

2.74E+00

2.83E-04

ACRYL AMIDE

79-06-1

4.65E-03



ACRYLIC ACID

79-10-7



6.79E-01

ACRYLONITRILE

107-13-1

2.09E-02



ALLYL CHLORIDE

107-05-1

9.96E-01



2-AMINOANTHRAQUINONE

117-79-3

6.34E-01



AMMONIA

7664-41-7

3.29E+03

3.62E-01

ANILINE

62-53-3

3.67E+00



ARSENIC AND COMPOUNDS (INORGANIC)

7440-38-2

6.82E-05

2.26E-05

ARSINE

7784-42-1

5.87E-02

2.26E-05

ASBESTOS

1332-21-4

2.85E-07



BENZENE

71-43-2

2.09E-01

3.05E-03

BENZIDINE (AND ITS SALTS)

92-87-5

4.18E-05



BENZIDINE BASED DYES

1020

4.18E-05



DIRECT BLACK 38

1937-37-7

4.18E-05



DIRECT BLUE 6

2602-46-2

4.18E-05



DIRECT BROWN 95 (technical grade)

16071-86-6

4.18E-05



BENZYL CHLORIDE

100-44-7

1.23E-01

2.72E-02

BERYLLIUM AND COMPOUNDS

7440-41-7

2.49E-03



BIS(2-CHLOROETHYL)ETHER (Dichloroethyl Ether)

111-44-4

8.36E-03



BIS(CHLOROMETHYL)ETHER

542-88-1

4.55E-04



POTASSIUM BROMATE

7758-01-2

4.27E-02



1,3 -BUTADIENE

106-99-0

3.49E-02

7.47E-02

CADMIUM AND COMPOUNDS

7440-43-9

1.39E-03



CAPROLACTAM

105-60-2

2.74E+01

5.66E-03

CARBON DISULFIDE

75-15-0

1.32E+04

7.01E-01

CARBON TETRACHLORIDE (Tetrachloromethane)

56-23-5

1.39E-01

2.15E-01

CHLORINATED PARAFFINS

108171-26-2

2.35E-01



CHLORINE

7782-50-5

3.29E+00

2.38E-02

CHLORINE DIOXIDE

10049-04-4

9.87E+00



4-CHLORO-O-PHENYLENEDIAMINE

95-83-0

1.31E+00



CHLOROBENZENE

108-90-7

1.64E+04



CHLOROFORM

67-66-3

1.10E+00

1.70E-02

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Engineering Division Manual of Procedures

CHLOROPHENOLS

PENTACHLOROPHENOL
2,4,6-TRICHLOROPHENOL
CHLOROPICRIN
p-CHLORO-o-TOLUIDINE
CHROMIUM 6+

BARIUM CHROMATE
CALCIUM CHROMATE

LEAD CHROMATE
SODIUM DICHROMATE
STRONTIUM CHROMATE
CHROMIC TRIOXIDE (as chromic acid mist)
COPPER AND COMPOUNDS
p-CRESIDINE
CRESOLS (mixtures of)

M-CRESOL
O-CRESOL
P-CRESOL

CUPFERRON

Cyanide And Compounds (inorganic)

HYDROGEN CYANIDE (Hydrocyanic Acid)
2,4-DIAMINOANISOLE
2,4-DIAMINOTOLUENE
1,2-DIBROMO-3-CHLOROPROPANE (DBCP)
p-DICHLOROBENZENE
3,3 -DICHLOROBENZIDINE
1,1 ,-DICHLOROETHANE (Ethylidene Dichloride)
DI(2-ETHYLHEXYL)PHTHALATE (DEHP)
DIETHANOLAMINE
p-DIMETHYLAMINOAZOBENZENE
N,N-DIMETHYL FORMAMIDE
2,4-DINITROTOLUENE
1,4-DIOXANE (1,4-Diethylene dioxide)
EPICHLOROHYDRIN (1 -Chloro-2,3-epoxypropane)
1,2-EPOXYBUTANE
ETHYL BENZENE
ETHYL CHLORIDE (Chloroethane)

ETHYLENE DIBROMIDE (1,2-Dibromoethane)
ETHYLENE DICHLORIDE (1,2-Dichloroethane)
ETHYLENE GLYCOL
ETHYLENE OXIDE (1,2-Epoxyethane)

ETHYLENE THIOUREA
FLUORIDES AND COMPOUNDS

N/A

87-86-5

88-06-2
76-06-2
95-69-2

18540-29-9
10294-40-3
13765-19-0
7758-97-6
10588-01-9
7789-06-2
1333-82-0
7440-50-8

120-71-8
1319-77-3
108-39-4
95-48-7
106-44-5
135-20-6
57-12-5

74-90-8
615-05-4

95-80-7

96-12-8
106-46-7
91-94-1

75-34-3
117-81-7
111-42-2
60-11-7
68-12-2

121-14-2
123-91-1
106-89-8
106-88-7
100-41-4
75-00-3

106-93-4

107-06-2
107-21-1
75-21-8
96-45-7

1101

1.16E+00
2.99E-01
6.58E+00
7.74E-02
1.29E-05
6.29E-05
3.88E-05
8.03E-05
3.25E-05
5.06E-05
2.48E-05

1.39E-01
9.87E+03
9.87E+03
9.87E+03
9.87E+03
9.50E-02
1.48E+02
1.48E+02
9.09E-01
5.23E-03
2.99E-03
5.23E-01
1.74E-02
3.67E+00
1.51E-01
4.93E+01
4.55E-03
1.32E+03
6.75E-02
7.74E-01
2.61E-01
3.29E+02
2.40E+00
4.93E+05
8.36E-02
2.90E-01
6.58E+03
6.75E-02
4.65E-01
1.36E+01

3.28E-03

1.13E-02

3.85E-02
3.85E-02

3.39E-01
1.47E-01

2.72E-02

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Engineering Division Manual of Procedures

HYDROGEN FLUORIDE (Hydrofluoric Acid)

FORMALDEHYDE

GLUTARALDEHYDE

GLYCOL ETHERS

ETHYLENE GLYCOL BUTYL ETHER - EGBE

ETHYLENE GLYCOL ETHYL ETHER - EGEE
ETHYLENE GLYCOL ETHYL ETHER ACETATE -
EGEEA

ETHYLENE GLYCOL METHYL ETHER - EGME
ETHYLENE GLYCOL METHYL ETHER ACETATE -
EGMEA

HEXACHLOROBENZENE

HEXACHLOROCYCLOHEXANES (mixed or technical
grade)

alpha-HEXACHLOROCYCLOHEXANE
beta- HEXACHLOROCYCLOHEXANE
gamma-HEXA CHT ,OR OCYCT .OHEXANF. (Lindane)
n-HEXANE
HYDRAZINE

HYDROCHLORIC ACID (Hydrogen Chloride)

HYDROGEN SULFIDE

ISOPHORONE

ISOPROPYL ALCOHOL (Isopropanol)

LEAD AND COMPOUNDS (inorganic)

LEAD ACETATE
LEAD PHOSPHATE
LEAD SUBACETATE
MALEIC ANHYDRIDE
MANGANESE AND COMPOUNDS
MERCURY AND COMPOUNDS (INORGANIC)
MERCURIC CHLORIDE

METHANOL

METHYL BROMIDE (Bromomethane)

METHYL tertiary-BUTYL ETHER

METHYL CHLOROFORM (1,1,1 -Trichloroethane)

METHYL ETHYL KETONE (2-Butanone)

METHYL ISOCYANATE
4,4'-METHYLENE BIS (2-CHLOROANILINE)
(MOCA)

METHYLENE CHLORIDE (Dichloromethane)
4,4'-METHYLENE DIANILINE (AND ITS
DICHLORIDE)

METHYLENE DIPHENYL ISOCYANATE
MICHLER'S KETONE (4,4'-
Bis(dimethylamino)benzophenone)

N-NITROSODI-n-BUTYLAMINE

7664-39-3
50-00-0
111-30-8

N/A
111-76-2

110-80-5

111-15-9

109-86-4

110-49-6
118-74-1

608-73-1
319-84-6
319-85-7
58-89-9
110-54-3
302-01-2
7647-01-0
7783-06-4
78-59-1
67-63-0
7439-92-1
301-04-2
7446-27-7
1335-32-6
108-31-6
7439-96-5
7439-97-6
7487-94-7
67-56-1

74-83-9
1634-04-4

71-55-6
78-93-3
624-83-9

101-14-4

75-09-2

101-77-9
101-68-8

90-94-8
924-16-3

1.37E+01
9.96E-01
1.32E+00

1.15E+03

4.93E+03
9.87E+02

1.48E+03
1.16E-02

3.10E-04
3.10E-04
3.10E-04
1.13E-03
1.15E+05
1.23E-03
1.48E+02
1.64E+02
3.29E+04
1.15E+05
1.87E-02
2.93E-02
2.43E-02
2.43E-02
1.15E+01
6.66E-01
4.90E-02
4.90E-02
6.58E+04
8.22E+01
1.16E+01
1.64E+04

1.64E+01

1.39E-02
5.97E+00

6.11E-04
1.15E+01

2.43E-02
1.90E-03

2.72E-02
6.22E-03

1.58E+00
4.19E-02

1.58E-02
1.05E-02

2.38E-01
4.75E-03

3.62E-01

6.79E-05
6.79E-05
3.17E+00
4.41E-01

7.69E+00
1.47E+00

1.58E+00

-145-

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Engineering Division Manual of Procedures

N-NITROSODI-n-PROPYL AMINE
N-NITROSODIETHYL AMINE
N-NITROSODIMETHYL AMINE
N-NITROSODIPHENYLAMINE
N-NITROSO-N-METHYLETHYLAMINE
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N-NITROSOPYRROLIDINE
NICKEL AND COMPOUNDS

NICKEL ACETATE
NICKEL CARBONATE
NICKEL CARBONYL
NICKEL HYDROXIDE
NICKELOCENE
NICKEL OXIDE
Nickel refinery dust from the pyrometallurgical process
NICKEL SUB SULFIDE

NITRIC ACID

p-NITROSODIPHENYLAMINE
OZONE

PARTICULATE EMISSIONS FROM DIESEL-FUELED
ENGINES

PERCHLOROETHYLENE (Tetrachloroethylene)

PHENOL

PHOSGENE

PHOSPHINE

PHOSPHORIC ACID

PHTHALIC ANHYDRIDE

PCB (POLYCHLORINATED BIPHENYLS)

(unspeciated mixture) [high risk]

PCB (POLYCHLORINATED BIPHENYLS) (speciated)

3,3',4,4'-TETRACHLOROBIPHENYL (PCB 77)

3,4,4', 5-TETRACHLOROBIPHENYL (PCB 81)

2,3,3',4,4'-PENTACHLOROBIPHENYL (PCB 105)

2,3,4,4',5-PENTACHLOROBIPHENYL (PCB 114)

2,3',4,4',5-PENTACHLOROBIPHENYL (PCB 118)

2,3',4,4',5'-PENTACHLOROBIPHENYL (PCB 123)

3,3',4,4',5-PENTACHLOROBIPHENYL (PCB 126)

2,3,3',4,4',5-HEXACHLOROBIPHENYL (PCB 156)

2,3,3',4,4',5'-HEXACHLOROBIPHENYL (PCB 157)

2,3',4,4',5,5'-HEXACHLOROBIPHENYL (PCB 167)

3,3',4,4',5,5'-HEXACHLOROBIPHENYL (PCB 169)

2,3,3',4,4',5,5'-HEPTACHLOROBIPHENYL (PCB 189)

621-64-7
55-18-5
62-75-9
86-30-6
10595-95-6
59-89-2
100-75-4
930-55-2
7440-02-0
373-02-4
3333-67-3
13463-39-3
12054-48-7
1271-28-9
1313-99-1

1146
12035-72-2
7697-37-2
156-10-5
10028-15-6

9901
127-18-4
108-95-2
75-44-5
7803-51-2
7664-38-2
85-44-9

1336-36-3

N/A
32598-13-3
70362-50-4
32598-14-4
74472-37-0
31508-00-6
65510-44-3
57465-28-8
38380-08-4
69782-90-7
52663-72-6
32774-16-6
39635-31-9

2.99E-03
5.81E-04
1.31E-03
2.32E+00
9.50E-04
3.12E-03
2.22E-03
9.96E-03
2.30E-02
6.92E-02
4.65E-02
6.68E-02
3.63E-02
4.66E-02
2.92E-02
2.30E-02
9.41E-02

9.50E-01

1.90E-02
9.96E-01
3.29E+03

1.32E+01
1.15E+02
3.29E+02

2.27E-04

2.40E-05
8.01E-06
8.01E-05
8.01E-05
8.01E-05
8.01E-05
2.40E-08
8.01E-05
8.01E-05
8.01E-05
8.01E-08
8.01E-05

2.26E-05
6.81E-05
4.58E-05
6.58E-05
3.57E-05
4.58E-05
2.88E-05
2.26E-05
9.26E-05
9.73E-03

2.04E-02

2.26E+00
6.56E-01
4.53E-04

-146-

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Engineering Division Manual of Procedures

POLY CHLORINATED DIBENZO-P-DIOXINS
(PCDD) (Treat as 2,3,7,8-TCDD for HRA)

2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN

1,2,3,7,8-PENT ACE1L ORODIBENZO-P-DIOXIN

1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN

1.2.3.6.7.8-HEXACHLORODIBENZO-P-DIOXIN

1.2.3.7.8.9-HEXACHLORODIBENZO-P-DIOXIN

1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXIN

1,2,3,4,6,7,8,9-OCTACHLORODIBENZO-P-DIOXIN
POLYCHLORINATED DIBENZOFURANS (PCDD)
(Treat as 2,3,7,8-TCDD for HRA)

2,3,7,8-TETRACHLORODIBENZOFURAN

1,2,3,7,8-PENT ACHL ORODIBENZOFURAN

2,3,4,7,8-PENT ACHL ORODIBENZOFURAN

1,2,3,4,7,8-HEXACHLORODIBENZOFURAN

1.2.3.6.7.8-HEXACHLORODIBENZOFURAN

1.2.3.7.8.9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLORODIBENZOFURAN

1.2.3.4.6.7.8-HEPTACHLORODIBENZOFURAN

1.2.3.4.7.8.9-HEPTACHLORODIBENZOFURAN

1,2,3,4,6,7,8,9-OCTACHLORODIBENZOFURAN
POLYCYCLIC AROMATIC HYDROCARBON (PAH)
[Treat as B(a)P for HRA]

BENZ(A)ANTHRACENE

BENZO(A)PYRENE

BENZO(B)FLUORANTHENE

BENZO(J)FLUORANTHENE

BENZO(K)FLUORANTHENE

CHRYSENE

DIBENZ(A,H)ACRIDINE

DIBENZ(A,H)ANTHRACENE

DIBENZ(A,J)ACRIDINE

DIBENZO(A,E)PYRENE

DIBENZO(A,H)PYRENE

DIBENZO(A,I)PYRENE

DIBENZO(A,L)PYRENE

7H-DIBENZO(C,G)CARBAZOLE

7,12-DIMETHYLBENZ(A)ANTHRACENE

1,6-DINITROPYRENE

1,8-DINITROPYRENE

INDENO(l ,2,3-C,D)PYRENE

3-METHYLCHOLANTHRENE

5-METHYLCHRYSENE

NAPHTHALENE

5 -NITROACENAPHTHENE

1086
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9

1080
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0

1151

56-55-3
50-32-8
205-99-2
205-82-3
207-08-9
218-01-9
226-36-8
53-70-3
224-42-0

192-65-4
189-64-0
189-55-9
191-30-0
194-59-2

57-97-6
42397-64-8
42397-65-9

193-39-5
56-49-5

3697-24-3
91-20-3
602-87-9

2.66E-09
2.66E-09
2.66E-09
2.66E-08
2.66E-08
2.66E-08
2.66E-07
8.86E-06

3.85E-09
3.85E-08
1.28E-07
1.28E-08
3.85E-08
3.85E-08
3.85E-08
3.85E-08
3.85E-07
3.85E-07
1.28E-05

7.49E-05
7.49E-04
7.49E-05
7.49E-04
7.49E-04
7.49E-04
7.49E-03
7.49E-04
2.13E-04
7.49E-04
7.49E-05
7.49E-06
7.49E-06
7.49E-06
7.49E-05
3.49E-06
7.49E-06
7.49E-05
7.49E-04
3.97E-05
7.49E-05
1.74E-01
6.72E-03

-147-

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Engineering Division Manual of Procedures

6-NITROCHRYSENE

7496-02-8

7.49E-06



2-NITROFLUORENE

607-57-8

7.49E-03



1 -NITROP YRENE

5522-43-0

7.49E-04



4-NITROPYRENE

57835-92-4

7.49E-04



1,3 -PROPANE SULTONE

1120-71-4

8.71E-03



PROPYLENE (PROPENE)

115-07-1

4.93E+04



PROPYLENE GLYCOL MONOMETHYL ETHER

107-98-2

1.15E+05



PROPYLENE OXIDE

75-56-9

1.61E+00

3.51E-01

SELENIUM AND COMPOUNDS

7782-49-2

4.28E-01



HYDROGEN SELENIDE

7783-07-5



5.66E-04

SELENIUM SULFIDE

7446-34-6

4.28E-01





7631-86-9





SILICA [CRYSTALLINE, RESPIRABLE]

[1175]

4.93E+01



SODIUM HYDROXIDE

1310-73-2



9.05E-04

STYRENE

100-42-5

1.48E+04

2.38E+00

SULFATES

9960



1.36E-02

SULFURIC ACID AND OLEUM

7664-93-9

1.64E+01

1.36E-02

SULFURIC ACID

7664-93-9

1.64E+01

1.36E-02

SULFUR TRIOXIDE

7446-71-9

1.64E+01

1.36E-02

OLEUM

8014-95-7



1.36E-02

1,1,2,2-TETRACHLOROETHANE

79-34-5

1.05E-01



THIOACETAMIDE

62-55-5

3.43E-03



TOLUENE

108-88-3

4.93E+03

4.19E+00

TOLUENE DIISOCYANATES

26471-62-5

5.36E-01



TOLUENE-2,4-DIISOCYANATE

584-84-9

5.36E-01



TOLUENE-2,6-DIISOCYANATE

91-08-7

5.36E-01



1,1,2-TRICHLOROETHANE (Vinyl Trichloride)

79-00-5

3.67E-01



TRICHLOROETHYLENE

79-01-6

2.99E+00



TRIETHYL AMINE

121-44-8

3.29E+03

3.17E-01

URETHANE (Ethyl Carbamate)

51-79-6

2.09E-02



VANADIUM COMPOUNDS

N/A





VANADIUM (fume or dust)

7440-62-2



3.39E-03

VANADIUM PENTOXIDE

1314-62-1



3.39E-03

VINYL ACETATE

108-05-4

3.29E+03



VINYL CHLORIDE (Chloroethylene)

75-01-4

7.74E-02

2.04E+01

VINYLIDENE CHLORIDE (1,1-Dichloroethylene)

75-35-4

1.15E+03



XYLENES (mixed isomers)

1330-20-7

1.15E+04

2.49E+00

m-XYLENE

108-38-3

1.15E+04

2.49E+00

o-XYLENE

95-47-6

1.15E+04

2.49E+00

p-XYLENE

106-42-3

1.15E+04

2.49E+00

-148-

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Engineering Division Manual of Procedures

Table 4

Rule 1200 Screening Emission Rates for Volume Sources

Chemical Name

Chemical

Annual

Hourly



Abstract

Emission

Emission



Number

Rate

Rate





lb/yr

lb/hr

ACETALDEHYDE

75-07-0

7.3E-01

3.4E-02

ACETAMIDE

60-35-5

1.0E-01



ACROLEIN

107-02-8

9.6E-01

1.8E-04

ACRYL AMIDE

79-06-1

1.6E-03



ACRYLIC ACID

79-10-7



4.3E-01

ACRYLONITRILE

107-13-1

7.3E-03



ALLYL CHLORIDE

107-05-1

3.5E-01



2-AMINOANTHRAQUINONE

117-79-3

2.2E-01



AMMONIA

7664-41-7

1.1E+03

2.3E-01

ANILINE

62-53-3

1.3E+00



ARSENIC AND COMPOUNDS (INORGANIC)

7440-38-2

2.4E-05

1.4E-05

ARSINE

7784-42-1

2.1E-02

1.4E-05

ASBESTOS

1332-21-4

1.0E-07



BENZENE

71-43-2

7.3E-02

1.9E-03

BENZIDINE (AND ITS SALTS)

92-87-5

1.5E-05



BENZIDINE BASED DYES

1020

1.5E-05



DIRECT BLACK 38

1937-37-7

1.5E-05



DIRECT BLUE 6

2602-46-2

1.5E-05



DIRECT BROWN 95 (technical grade)

16071-86-6

1.5E-05



BENZYL CHLORIDE

100-44-7

4.3E-02

1.7E-02

BERYLLIUM AND COMPOUNDS

7440-41-7

8.7E-04



BIS(2-CHLOROETHYL)ETHER (Dichloroethyl Ether)

111-44-4

2.9E-03



BIS(CHLOROMETHYL)ETHER

542-88-1

1.6E-04



POTASSIUM BROMATE

7758-01-2

1.5E-02



1,3 -BUTADIENE

106-99-0

1.2E-02

4.7E-02

CADMIUM AND COMPOUNDS

7440-43-9

4.9E-04



CAPROLACTAM

105-60-2

9.6E+00

3.6E-03

CARBON DISULFIDE

75-15-0

4.6E+03

4.5E-01

CARBON TETRACHLORIDE (Tetrachloromethane)

56-23-5

4.9E-02

1.4E-01

CHLORINATED PARAFFINS

108171-26-2

8.2E-02



CHLORINE

7782-50-5

1.1E+00

1.5E-02

CHLORINE DIOXIDE

10049-04-4

3.4E+00



4-CHLORO-O-PHENYLENEDIAMINE

95-83-0

4.6E-01



CHLOROBENZENE

108-90-7

5.7E+03



CHLOROFORM

67-66-3

3.8E-01

1.1E-02

CHLOROPHENOLS

N/A





PENTACHLOROPHENOL

87-86-5

4.1E-01



2,4,6-TRICHLOROPHENOL

88-06-2

1.0E-01



CHLOROPICRIN

76-06-2

2.3E+00

2.1E-03

p-CHLORO-o-TOLUIDINE

95-69-2

2.7E-02



CHROMIUM 6+

18540-29-9

4.5E-06



BARIUM CHROMATE

10294-40-3

2.2E-05



CALCIUM CHROMATE

13765-19-0

1.4E-05



LEAD CHROMATE

7758-97-6

2.8E-05



-149-

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Engineering Division Manual of Procedures

SODIUM DICHROMATE
STRONTIUM CHROMATE
CHROMIC TRIOXIDE (as chromic acid mist)

COPPER AND COMPOUNDS
p-CRESIDINE
CRESOLS (mixtures of)

M-CRESOL
O-CRESOL
P-CRESOL

CUPFERRON

Cyanide And Compounds (inorganic)

HYDROGEN CYANIDE (Hydrocyanic Acid)
2,4-DIAMINOANISOLE
2,4-DIAMINOTOLUENE
1,2-DIBROMO-3-CHLOROPROPANE (DBCP)
p-DICHLOROBENZENE
3,3 -DICHLOROBENZIDINE
1,1 ,-DICHLOROETHANE (Ethylidene Dichloride)
DI(2-ETHYLHEXYL )PHTHALATE (DEHP)
DIETHANOLAMINE
p-DIMETHYLAMINOAZOBENZENE
N,N-DIMETHYL FORMAMIDE
2,4-DINITROTOLUENE
1,4-DIOXANE (1,4-Diethylene dioxide)
EPICHLOROHYDRIN (1 -Chloro-2,3-epoxypropane)
1,2-EPOXYBUTANE
ETHYL BENZENE
ETHYL CHLORIDE (Chloroethane)

ETHYLENE DIBROMIDE (1,2-Dibromoethane)
ETHYLENE DICHLORIDE (1,2-Dichloroethane)
ETHYLENE GLYCOL
ETHYLENE OXIDE (1,2-Epoxyethane)

ETHYLENE THIOUREA
FLUORIDES AND COMPOUNDS

HYDROGEN FLUORIDE (Hydrofluoric Acid)
FORMALDEHYDE
GLUTARALDEHYDE
GLYCOL ETHERS

ETHYLENE GLYCOL BUTYL ETHER - EGBE
ETHYLENE GLYCOL ETHYL ETHER - EGEE
ETHYLENE GLYCOL ETHYL ETHER ACETATE -
EGEEA

ETHYLENE GLYCOL METHYL ETHER - EGME
ETHYLENE GLYCOL METHYL ETHER ACETATE -

EGMEA
HEXACHLOROBENZENE

HEXACHLOROCYCLOHEXANES (mixed or technical
grade)

alpha-HEXACHLOROCYCLOHEXANE
beta- HEXACHLOROCYCLOHEXANE
gamma-HEXA CHT ,OR OCYCT .OHEXANF, (Lindane)

10588-01-9
7789-06-2
1333-82-0
7440-50-8

120-71-8
1319-77-3

108-39-4
95-48-7
106-44-5
135-20-6

57-12-5

74-90-8
615-05-4

95-80-7

96-12-8
106-46-7
91-94-1

75-34-3

117-81-7
111-42-2
60-11-7
68-12-2

121-14-2
123-91-1
106-89-8
106-88-7
100-41-4
75-00-3

106-93-4

107-06-2
107-21-1
75-21-8
96-45-7

1101
7664-39-3
50-00-0
111-30-8

N/A
111-76-2

110-80-5

111-15-9

109-86-4

110-49-6

118-74-1

608-73-1
319-84-6
319-85-7

58-89-9

1.1E-05
1.8E-05
8.7E-06

4.9E-02
3.4E+03
3.4E+03
3.4E+03
3.4E+03
3.3E-02
5.2E+01
5.2E+01
3.2E-01
1.8E-03
1.0E-03
1.8E-01
6.1E-03
1.3E+00
5.3E-02
1.7E+01
1.6E-03
4.6E+02
2.4E-02
2.7E-01
9.1E-02
1.1E+02
8.4E-01
1.7E+05
2.9E-02
1.0E-01
2.3E+03
2.4E-02
1.6E-01
4.8E+00
4.8E+00
3.5E-01
4.6E-01

4.0E+02

1.7E+03
3.4E+02

5.2E+02
4.1E-03

1.1E-04
1.1E-04
1.1E-04
3.9E-04

7.2E-03

2.4E-02
2.4E-02

2.2E-01
9.3E-02

1.7E-02
1.7E-02
4.0E-03

1.0E+00
2.7E-02

1.0E-02
6.7E-03

-150-

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Engineering Division Manual of Procedures

n-HEXANE
HYDRAZINE

HYDROCHLORIC ACID (Hydrogen Chloride)

HYDROGEN SULFIDE

ISOPHORONE

ISOPROPYL ALCOHOL (Isopropanol)

LEAD AND COMPOUNDS (inorganic)

LEAD ACETATE
LEAD PHOSPHATE
LEAD SUBACETATE
MALEIC ANHYDRIDE
MANGANESE AND COMPOUNDS
MERCURY AND COMPOUNDS (INORGANIC)
MERCURIC CHLORIDE

METHANOL

METHYL BROMIDE (Bromomethane)

METHYL tertiary-BUTYL ETHER

METHYL CHLOROFORM (1,1,1 -Trichloroethane)

METHYL ETHYL KETONE (2-Butanone)

METHYL ISOCYANATE

4,4'-METHYLENE BIS (2-CHLOROANILINE)

(MOCA)

METHYLENE CHLORIDE (Dichloromethane)
4,4'-METHYLENE DIANILINE (AND ITS
DICHLORIDE)

METHYLENE DIPHENYL ISOCYANATE

MICHLER'S KETONE (4,4'-

Bis(dimethylamino)benzophenone)

N-NITROSODI-n-BUTYLAMINE

N-NITROSODI-n-PROPYL AMINE

N-NITROSODIETHYL AMINE

N-NITROSODIMETHYL AMINE

N-NITROSODIPHENYLAMINE

N-NITROSO-N-METHYLETHYLAMINE

N-NITROSOMORPHOLINE

N-NITROSOPIPERIDINE

N-NITROSOPYRROLIDINE

NICKEL AND COMPOUNDS

NICKEL ACETATE
NICKEL CARBONATE
NICKEL CARBONYL
NICKEL HYDROXIDE
NICKELOCENE
NICKEL OXIDE
Nickel refinery dust from the pyrometallurgical process
NICKEL SUB SULFIDE

NITRIC ACID

p-NITROSODIPHENYLAMINE
OZONE

PARTICULATE EMISSIONS FROM DIESEL-FUELED
ENGINES

PERCHLOROETHYLENE (Tetrachloroethylene)

110-54-3
302-01-2
7647-01-0
7783-06-4
78-59-1
67-63-0
7439-92-1
301-04-2
7446-27-7
1335-32-6
108-31-6
7439-96-5

7439-97-6
7487-94-7

67-56-1

74-83-9
1634-04-4

71-55-6
78-93-3
624-83-9

101-14-4

75-09-2

101-77-9
101-68-8

90-94-8
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
10595-95-6
59-89-2
100-75-4
930-55-2

7440-02-0
373-02-4
3333-67-3
13463-39-3
12054-48-7
1271-28-9
1313-99-1

1146
12035-72-2
7697-37-2
156-10-5
10028-15-6

9901
127-18-4

4.0E+04
4.3E-04
5.2E+01
5.7E+01
1.1E+04
4.0E+04
6.5E-03
1.0E-02
8.5E-03
8.5E-03
4.0E+00
2.3E-01
1.7E-02
1.7E-02
2.3E+04
2.9E+01
4.1E+00
5.7E+03

5.7E+00

4.9E-03
2.1E+00

2.1E-04
4.0E+00

8.5E-03
6.6E-04
1.0E-03
2.0E-04
4.6E-04
8.1E-01
3.3E-04
1.1E-03
7.8E-04
3.5E-03
8.0E-03
2.4E-02
1.6E-02
2.3E-02
1.3E-02
1.6E-02
1.0E-02
8.0E-03
3.3E-02

3.3E-01

6.6E-03
3.5E-01

1.5E-01
3.0E-03

2.3E-01

4.3E-05
4.3E-05
2.0E+00
2.8E-01

4.9E+00
9.3E-01

1.0E+00

1.4E-05
4.3E-05
2.9E-05
4.2E-05
2.3E-05
2.9E-05
1.8E-05
1.4E-05
5.9E-05
6.2E-03

1.3E-02
1.4E+00

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PHENOL
PHOSGENE
PHOSPHINE
PHOSPHORIC ACID
PHTHALIC ANHYDRIDE
PCB (POLYCHLORINATED BIPHENYLS)
(unspeciated mixture) [high risk]
PCB (POLYCHLORINATED BIPHENYLS) (speciated)
3,3',4,4'-TETRACHLOROBIPHENYL (PCB 77)
3,4,4', 5-TETRACHLOROBIPHENYL (PCB 81)
2,3,3',4,4'-PENTACHLOROBIPHENYL (PCB 105)
2,3,4,4',5-PENTACHLOROBIPHENYL (PCB 114)
2,3',4,4',5-PENTACHLOROBIPHENYL (PCB 118)
2,3',4,4',5'-PENTACHLOROBIPHENYL (PCB 123)
3,3',4,4',5-PENTACHLOROBIPHENYL (PCB 126)
2,3,3',4,4',5-HEXACHLOROBIPHENYL (PCB 156)
2,3,3',4,4',5'-HEXACHLOROBIPHENYL (PCB 157)
2,3',4,4',5,5'-HEXACHLOROBIPHENYL (PCB 167)
3,3',4,4',5,5'-HEXACHLOROBIPHENYL (PCB 169)
2,3,3',4,4',5,5'-HEPTACHLOROBIPHENYL (PCB 189)
POLY CHLORINATED DIBENZO-P-DIOXINS
(PCDD) (Treat as 2,3,7,8-TCDD for HRA)

2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
1,2,3,7,8-PENT ACHL ORODIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN

1.2.3.6.7.8-HEXACHLORODIBENZO-P-DIOXIN

1.2.3.7.8.9-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXIN
1,2,3,4,6,7,8,9-OCTACHLORODIBENZO-P-DIOXIN

POLY CHLORINATED DIBENZOFURANS (PCDD)
(Treat as 2,3,7,8-TCDD for HRA)

2,3,7,8-TETRACHLORODIBENZOFURAN
1,2,3,7,8-PENT ACHL ORODIBENZOFURAN
2,3,4,7,8-PENT ACHL ORODIBENZOFURAN
1,2,3,4,7,8-HEXACHLORODIBENZOFURAN

1.2.3.6.7.8-HEXACHLORODIBENZOFURAN

1.2.3.7.8.9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLORODIBENZOFURAN

1.2.3.4.6.7.8-HEPTACHLORODIBENZOFURAN

1.2.3.4.7.8.9-HEPTACHLORODIBENZOFURAN
1,2,3,4,6,7,8,9-OCTACHLORODIBENZOFURAN

POLYCYCLIC AROMATIC HYDROCARBON (PAH)
[Treat as B(a)P for HRA]

BENZ(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(J)FLUORANTHENE
BENZO(K)FLUORANTHENE
CHRYSENE
DIBENZ(A,H)ACRIDINE
DIBENZ(A,H)ANTHRACENE
DIBENZ(A,J)ACRIDINE

108-95-2
75-44-5
7803-51-2
7664-38-2
85-44-9

1336-36-3

N/A
32598-13-3
70362-50-4
32598-14-4
74472-37-0
31508-00-6
65510-44-3
57465-28-8
38380-08-4
69782-90-7
52663-72-6
32774-16-6
39635-31-9

1086
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9

1080
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0

1151
56-55-3
50-32-8
205-99-2
205-82-3
207-08-9
218-01-9
226-36-8
53-70-3
224-42-0

1.1E+03

4.6E+00
4.0E+01
1.1E+02

7.9E-05

8.4E-06
2.8E-06
2.8E-05
2.8E-05
2.8E-05
2.8E-05
8.4E-09
2.8E-05
2.8E-05
2.8E-05
2.8E-08
2.8E-05

9.3E-10
9.3E-10
9.3E-10
9.3E-09
9.3E-09
9.3E-09
9.3E-08
3.1E-06

1.3E-09
1.3E-08
4.5E-08
4.5E-09
1.3E-08
1.3E-08
1.3E-08
1.3E-08
1.3E-07
1.3E-07
4.5E-06

2.6E-05
2.6E-04
2.6E-05
2.6E-04
2.6E-04
2.6E-04
2.6E-03
2.6E-04
7.4E-05
2.6E-04

4.2E-01
2.9E-04

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DIBENZO(A,E)PYRENE
DIBENZO(A,H)PYRENE
DIBENZO(A,I)PYRENE
DIBENZO(A,L)PYRENE
7H-DIBENZO(C,G)CARBAZOLE
7,12-DIMETHYLBENZ(A)ANTHRACENE
1,6-DINITROPYRENE
1,8-DINITROPYRENE
INDENO(l,2,3-C,D)PYRENE
3-METHYLCHOLANTHRENE
5-METHYLCHRYSENE
NAPHTHALENE
5 -NITROACENAPHTHENE
6-NITROCHRYSENE
2-NITROFLUORENE
1 -NITROP YRENE
4-NITROPYRENE
1,3-PROPANE SULTONE
PROPYLENE (PROPENE)

PROPYLENE GLYCOL MONOMETHYL ETHER
PROPYLENE OXIDE
SELENIUM AND COMPOUNDS

HYDROGEN SELENIDE
SELENIUM SULFIDE

SILICA [CRYSTALLINE, RESPIRABLE]

SODIUM HYDROXIDE

STYRENE

SULFATES

SULFURIC ACID AND OLEUM

SULFURIC ACID
SULFUR TRIOXIDE
OLEUM

1,1,2,2-TETRACHLOROETHANE

THIOACETAMIDE

TOLUENE

TOLUENE DIISOCYANATES

TOLUENE-2,4-DIISOCYANATE
TOLUENE-2,6-DIISOCYANATE
1,1,2-TRICHLOROETHANE (Vinyl Trichloride)
TRICHLOROETHYLENE
TRIETHYL AMINE
URETHANE (Ethyl Carbamate)

VANADIUM COMPOUNDS

VANADIUM (fume or dust)
VANADIUM PENTOXIDE
VINYL ACETATE
VINYL CHLORIDE (Chloroethylene)
VINYLIDENE CHLORIDE (1,1-Dichloroethylene)
XYLENES (mixed isomers)

m-XYLENE

192-65-4
189-64-0
189-55-9
191-30-0
194-59-2
57-97-6

42397-64-8
42397-65-9

193-39-5
56-49-5

3697-24-3
91-20-3
602-87-9
7496-02-8
607-57-8
5522-43-0
57835-92-4
1120-71-4
115-07-1

107-98-2
75-56-9

7782-49-2

7783-07-5

7446-34-6
7631-86-9

[1175]
1310-73-2
100-42-5

9960
7664-93-9
7664-93-9
7446-71-9
8014-95-7
79-34-5
62-55-5

108-88-3
26471-62-5

584-84-9
91-08-7
79-00-5
79-01-6
121-44-8
51-79-6

N/A
7440-62-2
1314-62-1
108-05-4
75-01-4
75-35-4
1330-20-7
108-38-3

2.6E-05
2.6E-06
2.6E-06
2.6E-06
2.6E-05
1.2E-06
2.6E-06
2.6E-05
2.6E-04
1.4E-05
2.6E-05
6.1E-02
2.3E-03
2.6E-06
2.6E-03
2.6E-04
2.6E-04
3.0E-03
1.7E+04
4.0E+04
5.6E-01
1.5E-01

1.5E-01
1.7E+01

5.2E+03

5.7E+00
5.7E+00
5.7E+00

3.7E-02
1.2E-03
1.7E+03
1.9E-01
1.9E-01
1.9E-01
1.3E-01
1.0E+00
1.1E+03
7.3E-03

1.1E+03
2.7E-02
4.0E+02
4.0E+03
4.0E+03

2.2E-01

3.6E-04

5.8E-04
1.5E+00
8.6E-03
8.6E-03
8.6E-03
8.6E-03
8.6E-03

2.7E+00

2.0E-01

2.2E-03
2.2E-03

1.3E+01

1.6E+00
1.6E+00

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o-XYLENE

95-47-6

4.0E+03

1.6E+00

p-XYLENE

106-42-3

4.0E+03

1.6E+00

References:

Air Toxics "Hot Spots" Program Guidance Manual for the Preparation of Risk
Assessemnts (Guidance Manual) - SRP Draft [10/14/14]

Air Toxics "Hot Spots" Program Risk Assessment GuidelinesTechnical Support
Document for the Derivation of Noncancer Reference Exposure Levels. [12/19/08]

Air Toxics "Hot Spots" Program Risk Assessment Guidelines Part II: Technical Support

Document for Cancer Potency Factors.

[06/01/09]

Air Toxics Hot Spots Program Risk Assessment Guidelines: Technical Support
Document for Exposure Assessment and Stochastic Analysis, [08/27/12]

5.2 Rule 1200 Requirements for Health Risk Assessment (Tom
Weeks, February 2001, modified April 2009)

This document indicates the level of HRA review anticipated under Rule 1200 and the
fees and supplemental information that should be submitted with the permit applications
to allow expeditious review. It is the basis of the HRA time estimates used in the
Application Fee Deposit Reference Sheet (see Section 2.4 above).

Category 1 and 2 applications are expected to pass a screening level HRA using "look-up"
tables and generally will require approximately one hour of evaluation time. Category 3
applications are expected to require a site specific screening HRA using a simple
dispersion model and will require approximately four hours or evaluation time. Category
4 applications are expected to require a refined site specific HRA. The Toxics Section
must be consulted concerning the required evaluation time for Category 4 applications.

Permit engineers must be notified by the Toxics Section if actual costs incurred will
exceed the initial estimate and the permit engineer must prepare an invoice for the
additional fees prior to the additional analysis unless approved by a senior engineer.

HRA REVIEW CATEGORY

CATEGORY 0 - NO ANALYSIS REQUIRED (NEGLIGIBLE TOXIC EMISSIONS OR EXEMPT)
CATEGORY 1 - EXPECTED TO PASS HRA USING SCREENING EMISSION RATE TABLES
CATEGORY 2 - EXPECTED TO PASS HRA USING DISPERSION LOOK-UP TABLES
CATEGORY 3 - EXPECTED TO PASS SCREENING HRA
CATEGORY 4 - REFINED HRA REQUIRED

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NOTES AND QUALIFIERS

A - HRA required only if materials containing chromium, nickel, lead, or copper are used or
processed.

B - Facility uses propane or natural gas as fuel and annually cremates less than 300 human bodies
or

43,200 lbs of remains (human or animal)

C - HRA not required if electrically heated.

D - HRA required only if Rule 1200 listed materials are processed, produced or otherwise used.
E - HRA not required if the P/O is issued with a throughput limitation that assures risks are <
100E-6 and HHI 10.0

G - HRA not required if 2 gallons per day or less of all graphic arts materials are used (minus
water)

H - Should be Category 4 if initial application review indicates that a refined HRA is required or is
provided with the application for review.

FEE SCHEDULE	CATEGORY. QUALIFIER

SCHEDULE 1: Abrasive Blasting Equipment Excluding Rooms and Booths

(a)	Pot 100 Pounds Capacity or Larger with no Peripheral Equipment	2, A

(b)	Pot 100 Pounds Capacity or Larger Loaded Pneumatically or from	2, A
Storage Hoppers

(c)	Bulk Abrasive Blasting Material Storage System	2, A

(d)	Spent Abrasive Handling System	2, A
(x) Portable Abrasive Blasting Unit, Registration Under Rule 12.1	0

SCHEDULE 2: Abrasive Blasting Cabinets, Rooms and Booths

(a)	Abrasive Blasting Cabinet, Room or Booth	1, A

(b)	Cabinet, Room or Booth with an Abrasive Transfer or Recycle System	1, A

SCHEDULE 3: Asphalt Roofing Kettles and Tankers used to Store Heat, Transport, and
Transfer Hot Asphalt

(a)	Kettle or Tanker with Capacity Greater than 85 Gallons	0

(b)	Kettle or Tanker with Capacity Greater than 85 Gallons and Requiring	0
Emission Control Equipment

(w) Asphalt Roofing Kettles and Tankers, Registration Under Rule 12	0

(z) Asphalt Roofing Kettles and Tankers, Registration Under Rule 12,	0
Conversion from Valid Permit

SCHEDULE 4: Hot-Mix Asphalt Paving Batch Plants	3
SCHEDULE 5: Rock Drills

(a)	Drill with Water Controls	1

(b)	Drill with Controls other than Water	1
(w) Drill, Registration Under Rule 12	0
(z) Drill, Registration Under Rule 12, Conversion from Valid Permit	0

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SCHEDULE 6: Sand, Rock, and Aggregate Screens, when not used in Conjunction with

other Permit Items in these Schedules

(a) Screen Set	1

(x) Portable Sand and Gravel Screen, Registration Under Rule 12.1	0

SCHEDULE 7: Sand, Rock, and Aggregate Plants	3

(a)	Crusher System	3

(b)	Screening System	3

(c)	Loadout System	3

(d)	Aggregate Dryer System	3
(x) Portable Rock Crushing System, Registration Under Rule 12.1	0

SCHEDULE 8: Concrete Batch Plants, Concrete Mixers Over One Cubic Yard Capacity 3

and Separate Cement Silo System

(a)	Concrete Batch Plant (including Cement-Treated Base Plants)	3

(b)	Mixer over One Cubic Yard Capacity	3

(c)	Cement or Fly Ash Silo System not part of another system requiring a permit	3
(x) Portable Concrete Batch Plant, Registration Under Rule 12.1	0

SCHEDULE 9: Concrete Product Manufacturing Plants	2

SCHEDULE 10: Brick Manufacturing Plants	1

(a)	Clay Batching and Extruding System	1

(b)	Crusher-Screen System	1

(c)	Kiln	3

SCHEDULE 11: Tire Buffers	0

SCHEDULE 12: Fish Canneries and Smoke Houses

(a)	Dryer (also called Meal Drying and Grinding System)

(b)	Precooker

(c)	Vat and Vibrating Screen System

(d)	Scrap Cooker and Grinder System

(e)	Cooker

(f)	Dry Pet Food Processing System

(g)	Digester Tank

(h)	Smoke House

(i)	Loadout System

SCHEDULE 13: Boilers and Heaters

(a)	1 MM BTU/HR up to but not including 50 MM BTU/HR Input	2

(b)	50 MM BTU/HR up to but not including 250 MM BTU/HR Input	3, H

(c)	250 MM BTU/HR up to 1050 MM BTU/HR Input or up to but not including 100 3, H
Megawatt Gross Output whichever is Greater (Based on an Average Boiler
Efficiency of 32.5%)

(d) 100 Megawatt Gross Output or Greater (Based on an Average Boiler Efficiency of 3, H
32.5%)

(f) 1 MM BTU/HR up to but not including 50 MM BTU/HR Input at a Single Site 3, H
where more than 5 such Units are Located

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(g)	Notice of Intention - 250 MM BTU/HR up to 1050 BTU/HR or up to but not	3, H
including 100 Megawatt Output

(h)	Notice of Intention - Each 100 Megawatt Output or Greater	3, H

SCHEDULE 14: Non-Municipal Incinerators

(a)	Waste Burning Capacity up to and including 100 LBS/HR	2, B

(b)	Waste Burning Capacity Greater than 100 LBS/HR	2, B

(c)	Burning Capacity up to and including 50 LBS/HR used exclusively for the	2, B
Incineration or Cremation of Animals

(d) Emission Controls or Modifications	0
SCHEDULE 15: Burn Out Ovens

(b)	Wire Reclamation Oven	2

(c)	IC Engine Parts Refurbishing Unit	2
(z) Navy: Burn Out IC Engine Parts (98-99 Only)	0

SCHEDULE 16: Core and Plastics Annealing/Softening Ovens

(a)	Core Oven	2

(b)	Plastic Annealing/Softening Ovens	0, C

SCHEDULE 17: Brake Debonders	1

SCHEDULE 18: Metal Melting Devices

(a)	Sweat Furnace	2

(b)	Electric Arc Furnace	2

(c)	Pit or Stationary Crucible	2

(d)	Pot Furnace	3

(e)	Induction Furnace	3

(f)	Cupola 3

(g)	Reverberatory Furnace	3

(h)	Brass Metal Melting Furnace - U.S. Navy	3

SCHEDULE 19: Oil Quenching and Salt Baths	1

SCHEDULE 20: Gas Turbine Engines, Test Cells and Test Stands

GAS TURBINE, TURBOSHAFT, TURBOJET & TURBOFAN ENGINE TEST CELLS AND
STANDS

(a)	Aircraft Propulsion Turbine, Turboshaft, Turbojet or Turbofan Engine	2
Test Cell or Stand

(b)	Aircraft Propulsion Test Cell or Stand at a Facility where more than one	2
such Unit is located

(c)	Non-Aircraft Turbine Test Cell or Test Stand	2
GAS TURBINE ENGINES

(d)	Non-Aircraft Turbine Engine 1 MM BTU/HR up to but not including	1
50 MM BTU/HR input

(e)	Non-Aircraft Turbine Engine 50 MM BTU/HR up to but not including	2
250 MM BTU/HR input

(f)	Non-Aircraft Turbine Engine 250 MM BTU/HR or greater input	3

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(g)	Unit used solely for Peak Load Electric Generation	3

(h)	Standby Gas Turbines used for Emergency Power Generation	1

SCHEDULE 21: Waste Disposal and Reclamation Units

(a)	Paper or Wood Shredder or Hammermill Grinder	0

(b)	Metal Shredder	0

(c)	Garbage and Refuse Shredder	1

(d)	Air Classifier	1

(e)	Dryer	0

SCHEDULE 22: Feed and Grain Mills and Kelp Processing Plants

(a)	Receiving System (includes Silos)	0

(b)	Grinder, Cracker, or Roll Mill	0

(c)	Shaker Stack, Screen Set, Pelletizer System, Grain Cleaner, or Hammermill	0

(d)	Mixer System	0

(e)	Truck or Rail Loading System	0

SCHEDULE 23: Bulk Terminal Grain and Dry Chemical Transfer and Storage Facility Equipment

(a)	Receiving System (Railroad, Ship and Truck Unloading)	1

(b)	Storage Silo System	1

(c)	Loadout Station System	1

(d)	Belt Transfer Station	1

SCHEDULE 24: Dry Chemical Mixing and Detergent Spray Towers

(a)	Grain Mixing System (Includes Receiving, Transfer, Mixing or Blending, Storage,

Loadout Bagging)	1

(b)	Detergent Spray Tower	1

(c)	Dry Chemical Mixers with capacity over One-Half Cubic Yard	1

SCHEDULE 25: Volatile Organic Compound Terminals, Bulk Plants and Intermediate Refueler Facilities

PART 1 - BULK PLANTS AND BULK TERMINALS EQUIPPED WITH OR PROPOSED

TO BE EQUIPPED WITH A PROCESSOR	2

(a)	Per Tank 3

(b)	Tank Rim Seal Replacement	0

(c)	Per Truck Loading Head	3

(d)	Per Vapor Processor	3

PART 2 - BULK PLANTS NOT EQUIPPED WITH OR NOT PROPOSED TO BE EQUIPPED
WITH A VAPOR PROCESSOR

(e)	Per Tank 2

(f)	Per Truck Loading Head	2

PART 3 - FACILITIES FUELING INTERMEDIATE REFUELERS (IR) FOR SUBSEQUENT
FUELING OF MOTOR VEHICLES, BOATS OR AIRCRAFT

(h) Per IR Loading Connector	2

SCHEDULE 26: Non-Bulk Volatile Organic Compound Dispensing Facilities Subject to District
Rules 61.0 thru 61.6

(a) Phase I and Phase II Vapor Recovery Facility	0, E

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(b)	Replacement or Addition of Tanks at a Permitted Facility	0, E

(c)	Facilities where only Phase I controls are required	0, E

(d)	Addition of Nozzles at Permitted Facilities where Phase II is required	0, E

(e)	Non-Retail Facilities with 250-550 Gallon Tanks and no other Non-Bulk	0, E
Gasoline Dispensing Permits

(f)	Phase II Bootless or Mini-Booted Nozzles Vacuum Assist Systems Facility	0, E

SCHEDULE 27: Application of Materials Containing Organic Solvents (includes coatings,

adhesives, and other materials containing volatile organic compounds (VOC))
PART 1 - MARINE COATINGS

(t) Marine Coating Application at Facilities where combined coating and cleaning

solvents usage is < 3 gallons/day and <100 gallons/year	1

(a)	Marine Coating Application at Facilities emitting < 10 tons/year of VOC from	3
Marine Coating Operations

(b)	Marine Coating Application at Facilities emitting > 10 tons/year of VOC from	3
Marine Coating Operations

(c)	Each additional Marine Coating Permit Unit	2

PART 2 - INDUSTRIAL MATERIAL APPLICATIONS and MANUFACTURING

(d)	Surface Coating Application Station using > 1 gallon/day without Control	2
Equipment and not covered by other Fee Schedules at Facilities emitting

< 5 tons/year

(e)	Surface Coating Application Station without Control Equipment and not covered 2
by other Fee Schedules at Facilities emitting > 5 tons/year

(f)	Fiberglass, Plastic or Foam Product Process Line at Facilities emitting <10	3
tons/year from these types of Operations

(g)	Fiberglass, Plastic or Foam Product Process Line at Facilities emitting >10	3
tons/year from these types of Operations

(i) Surface Coating Application Station requiring Control Equipment	3

(j) Surface Coating Application Station Subject to Rules 67.3 or 67.9 without Control 2

Equipment at Facilities emitting < 5 tons/year
(k) Surface Coating Application Station Subject to Rules 67.3 or 67.9 without Control 2

Equipment at Facilities emitting > 5 tons/year
(1) Wood Products Coating Application Station without Control Equipment at Facilities 2
emitting < 5 tons/year and using > 500 gallons/year

(m) Wood Products Coating Application Station without Control Equipment at Facilities 3

emitting > 5 tons/year

(n) Press or Operation at a Printing or Graphic Arts Facility Subject to Rule 67.16	0, G

(o) Union Tribune Publishing Graphic Arts Operation	1, G

(p) Surface Coating Application Station without Control Equipment where combined 1
coating and cleaning solvent usage is < 1 gallon/day or < 50 gallons/year

(q) Wood Products Coating Application Station without Control Equipmentat Facilities 1
using <500 gallons/year

PART 3 - AUTOMOTIVE PAINTING

(r) Facility applying < 5 gallons/day of Coating Materials Subject to Rule 67.20	1

(as applied or sprayed)

(s) Facility applying > 5 gallons/day of Coating Materials Subject to Rule 67.20	1

(as applied or sprayed)

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PART 4 - ADHESIVE MATERIALS APPLICATION OPERATIONS

(u) Adhesive Materials Application Station without Control Equipment at Facilities	2

emitting < 5 tons/year of VOC

(v) Adhesive Materials Application Station without Control Equipment at Facilities	2

emitting > 5 tons/year of VOC

(w) Adhesive Materials Application Station without Control Equipment using	1
< 55 gallons/year of Adhesive Materials

SCHEDULE 28: Vapor and Cold Solvent Cleaning Operations and Metal Inspection Tanks

(a)	Vapor Degreaser (> 5 sq. ft.)	1

(b)	Cold Solvent Degreaser (> 5 sq. ft.)	0

(c)	Corrosion Control Carts	1

(d)	Paint Stripping Tanks	3

(e)	Vapor Phase Solder Reflow Unit	1

(f)	Remote Reservoir Cleaners	0, D

(h)	Vapor Degreaser (< 5 sq. ft)	0, D

(i)	Cold Solvent Degreaser (< 5 sq. ft)	0, D
(j) Metal Inspection Tanks	1
(k) Contract Service Remote Reservoir Cleaners	0, D
(1) Small Contract Service Cold Degreasers (< 5 sq. ft)	0
(m) Facility-Wide Solvent Application Operations	2

SCHEDULE 29: Solder Levelers and Hydrosqueegees	2

SCHEDULE 30: Kelp and Biogum Products Solvent Dryer	1

SCHEDULE 31: Dry Cleaning Facilities

(a)	Facility using Halogenated Hydrocarbon Solvents required to install Control	1, E
Equipment

(b)	Facility using Petroleum Based Solvents	0, D

(c)	Facility using Solvents not required to install Control Equipment	1

SCHEDULE 32: Acid Chemical Milling, Copper Etching and Hot Dip Galvanizing

(a)	Copper Etching Tank	3

(b)	Acid Chemical Milling Tank	3

(c)	Hot Dip Galvanizing Tank	3

SCHEDULE 33: Can and Coil Manufacturing and Coating Operations

(a)	Process Line Applying >1000 Gallons/Year	2

(b)	Research and Development Coil Coating Line	2

(c)	Process Line Applying <1000 Gallons Per Year	1

SCHEDULE 34: Piston Type Internal Combustion Engines

(a)	Cogeneration Engine with In-Stack Emission Controls	2

(b)	Cogeneration Engine with Engine Design Emission Controls	2

(c)	Emergency Standby Engine (for electrical or fuel interruptions beyond control of 2
Permittee

(d)	Engine for Non-Emergency and Non-Cogeneration Operation	1

(e)	Grouping of Engines (> 200 Horsepower) for Dredging or Crane Operation	2

(f)	Diesel Pile-Driving Hammer	2

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Engineering Division Manual of Procedures

(g) Engine for Non-Emergency and Non-Cogeneration Operation (< 200 Horsepower) 2

(w) Specific Eligible Engines, Registration Under Rule 12	0

(x) Specific Eligible Portable Engines, Registration Under Rule 12.1	0

(z) Specific Eligible Engines, Registration Under Rule 12, Conversion from Valid	0
Permit

SCHEDULE 35: Bulk Flour, Powered Sugar and Dry Chemical Storage System	0, D

SCHEDULE 36: Grinding Booths and Rooms	0, D

SCHEDULE 37: Plasma Electric and Ceramic Deposition Spray Booths	2

SCHEDULE 38: Paint, Stain, Ink, Solder Paste, and Dielectric Paste Manufacturing

(a)	Paint, Stain or Ink Manufacturing Lines Producing >10,000 Gallons	2

(b)	Can Filling Lines	2

(c)	Each Process Line for Solder Paste or Dielectric Paste Manufacturing	2

(d)	Paint, Stain or Ink Manufacturing Lines Producing <10,000 Gallons	2

SCHEDULE 39: Precious Metals Refining	2, A
SCHEDULE 40: Asphalt Pavement Heaters/Recyclers

(a) Processor	1

SCHEDULE 41: Perlite Processing	0

SCHEDULE 42: Electronic Component Manufacturing	1

(a)	Electronic Manufacturing Operations	1

(b)	Electronic Manufacturing Screen Printing	1

(c)	Electronic Manufacturing Coating/Maskant Application Excluding Conformal	1
Operations

(d)	Electronic Manufacturing Conformal Coating	1

(e)	Electronic Manufacturing Facility-wide Solvent Application	1

SCHEDULE 43: Ceramic Slip Casting	1

SCHEDULE 44: Evaporators, Dryers, & Stills Processing Organic Materials

(a)	Evaporators and Dryers	2

(b)	Solvent Recovery Stills	2

SCHEDULE 45: Rubber Mixers	0

SCHEDULE 46: Reverse Osmosis Membrane Manufacturing	3

SCHEDULE 47: Organic Gas Sterilizers	2

(a)	Organic Gas Sterilizers requiring control	2

(b)	Stand Alone Organic Gas Aerator requiring control	2

(c)	Organic Gas Sterilizer not requiring control	2

(d)	Stand Alone Organic Gas Aerator not requiring control	2

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Engineering Division Manual of Procedures

SCHEDULE 48: Municipal Waste Storage and Processing

(a)	Sanitary Landfill	3

(b)	Temporary Storage and/or Transfer Station	2

(c)	Landfill Gas Flare or Containment System	3

(d)	Municipal Waste Incinerator	4

(e)	North County Resource Recovery	3

SCHEDULE 49: (a) Non-Operational Status Equipment

(b) Activating Non-Operational Status Equipment	0

SCHEDULE 50: Coffee Roasters	1

SCHEDULE 51: Industrial Waste Water Treatment

(a)	Processing Line - Onsite	3

(b)	Processing Line - Offsite	3

SCHEDULE 52: Air Stripping and Soil Remediation Equipment

(a)	Air Stripping Equipment	3

(b)	Soil Remediation Equipment - Onsite	3

(c)	Soil Remediation Equipment - Offsite	4

SCHEDULE 53: Lens Casting Equipment

(a)	Lens Casting Equipment	3

(b)	Lens Coating Equipment	2

SCHEDULE 54: Pharmaceutical Manufacturing

(a)	Pharmaceutical Manufacturing	1

(b)	Protein Synthesis Employing Solvents	1

SCHEDULE 55: Hexavalent Chromium Plating & Chromic Acid Anodizing

(a)	Emissions Collection System serving one or more Plating and/or Anodizing Tank(s) 3

(b)	Decorative Plating Tank(s) Only	3

(c)	Hard Chrome Plating or Chromic Acid Tank	3

SCHEDULE 56: Sewage Treatment Facilities

(a)	Sewage Treatment Facility	3

(b)	Wastewater Odor Treatment System that is not part of a Permitted Sewage	3

Treatment Facility

(c)	Sewage Sludge Composting Facility	2
SCHEDULE 57: Laundry Facilities Processing Material Containing Organic Compounds 2
SCHEDULE 58: Bakeries	0

5.3 Supplemental Guidance For Rule 1200 HRA Review (Tom
Weeks, September 2004)

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Engineering Division Manual of Procedures

The following guidance shall be followed when performing Rule 1200 Health Risk
Assessments.

Toxics New Source Review (TNSR) Labor Tracking and Cost Accounting -Toxics New
Source Review (Rule 1200) applies to any new, relocated, or modified emission unit
which may increase emissions of one or more toxic air contaminant and for which an
Authority to Construct or Permit to Operate is required pursuant to Rule 10. Rule
40(d)(5) allows the District to recover fees for TNSR analysis by charging additional
engineering evaluation fees. Estimated HRA review time is presented in the Engineering
Division MOP Section 5.2.

Recent review of T&M applications indicates that HRA fees are not consistently
collected and that labor time is not always tracked correctly. Fees must be collected for
all sources that undergo TNSR. Facilities that undergo TNSR should be quoted and must
submit the combined application fee and TNSR fee (along with any other appropriate fee
add-on such as those for NSR, source testing, NESHAP and ATCM review) for all
emission units. Labor spent performing TNSR, either by the permit engineer or the
Toxics section must be coded as billable time in labor tracking.

Submittal of TNSR Deminimis Screening HRAs to the Toxics Section - Rule 1200
requires that the District "develop screening risk assessment procedures for common
equipment and toxic air contaminants to expedite and standardize review for compliance
with Section (d)" and "propose additional exemptions to Section (b) that the Air Pollution
Control Officer deems appropriate, based on the results of these screening procedures."
In order to do that it is necessary to review data on emission units that pass the District's
deminimis screening procedure. Therefore, all deminimis screening HRAs must be
submitted to the Toxics Section Aide.

Review of Applicant Prepared Health Risk Assessments - Health Risk Assessments
prepared by applicants and submitted with an application should be forwarded, upon
receipt, to the Toxics Section for review. Although it may, in some cases, be easier to
perform a deminimis screening HRA, refined HRAs submitted by the applicant cannot be
ignored. Refined HRAs often result in lower estimated risk than screening analyses
which can impact the results of the engineering evaluation. In addition, submittal of
these refined HRAs early in the evaluation process will help expedite permit issuance.

5.4 Rule 11(a)(6) Interpretation (Tom Weeks, November, 2010)

Rule 11(a)(6) states that the exemption from permit requirements specified in section (d)
. shall not apply to any new or modified equipment, operation or process which emits
or may emit toxic air contaminants, as defined in Rule 1210, and which the Air Pollution
control Officer determines has emissions which, in the absence of any emission control
device or limitation on material usage or production, may be expected to exceed any
standard specified in Rule 1200(d)(l)(i), (d)(2) or (d)(3)."

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In the past this has been interpreted to mean that any exempt emission unit that emits a
Rule 1200 toxic air contaminant in quantities greater than de minimis amounts, no longer
qualifies for an exemption and must obtain a District permit. However, de minimis toxic
emission rates are highly health protective and exceeding these levels does not mean that
an emission unit will "exceed a standard specified in Rule 1200(d)(l)(i), (d)(2) or (d)(3)."

Therefore, prior to imposing the Rule 11(a)(6) exclusion, a site specific health risk
assessment must be performed. Because most exempt equipment emit TACs and do not
to present a public health risk, the request to perform a refine HRA should be based on
knowledge that the subject equipment differs in some way from the other equipment in
the exempt category and may therefore be expected to exceed a standard specified in
Rule 1200(d)(l)(i), (d)(2) or (d)(3).

5.5 Procedure for Updating Tables in Rule 1200 and 1210

The following procedure shall be used to update tables in Rules 1200 and 1210.

1)	Edit the table and include the new revision dates on each table as applicable

2)	Publish a 30 day notice

3)	After the comment period ends, an Advisory is mailed to all permit holders and
the District's general mailing list. The advisory should include a brief description
of the nature of the changes, who to contact with questions.

4)	Revised table are distributed as rule book updates.

5)	Rules with revised tables are posted on the website.

6. Permit to Operate Evaluations

6.1 P/O Engineer Evaluation Requirements and Process (October,
2020, Nick Horres)

The purpose of the PTO evaluation is to explain the results of the initial inspection and
how any specific initial compliance requirements were fulfilled. It should also highlight
any changes made to the equipment since the A/C, discuss additional rule analysis if
necessary due to changes, and explain any changes made to the conditions. Finally, it
contains our recommendation for either approving or denying the permit. There is a
standard format for the evaluation available as a template which contains the following
sections:

7.0 Inspection Report

• This section should include the results of the initial inspection and any discussion
about changes to the equipment from the A/C to the proposed PTO. It should be
as specific as possible and not simply state that the equipment met the
requirements. Typical information that should be noted in the PTO evaluation
includes:

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Engineering Division Manual of Procedures

•	Listing of each piece of equipment inspected and whether it matched the
requirements of the A/C or there is a minor change. E.g.:

"The engine matched the A/C description, with a S/N o/BC204820485 which
was added to the S/A " or

"The installed burner was a slightly different model number, VC300-2 and
had a slightly lower heat input, 22 MMBtu/hr compared to 22.5 MMBtu/hr
listed in the application. "

•	Discussion of each permit condition that was reviewed during the inspection and
how compliance was demonstrated. If there was a source test conducted, state that
the source test results showed compliance with permit limits (or didn't). E.g.:

"The engine was equipped with an hour meter (with a reading of 6.5 hr) and
the operator provided the maintenance manual, maintenance records and
engine log book" or

"The baghouse was equipped with a magnahelic gauge; however, the
incorrect gauge was installed and the range (1 "-2 " H20) is not sufficient for
the range of the filter (1 "-6"). A new part had already been ordered, so a
requirement was added to the S/A to replace the gauge within 14 days and
provide a photo to demonstrate "

•	State that there are inspection photos available or explain why there aren't any.

•	If the equipment installed deviated from the equipment description in any way
that potentially could affect permit requirements, there should be a discussion of
how the change continues to comply with the same conditions on the A/C or
required reanalysis. Typical reasons you may need to consider changes/rule
analysis:

o The equipment installed is larger than the proposed equipment
o A different engine is installed that has higher diesel PM emissions
o A coating process is found to consist of different types of coating than
proposed (e.g. proposed as metal coating but during inspection you find
aerospace components)
o Initial material usage is higher than expected and causing exceedance of
emission limits

o Different monitoring equipment is installed than proposed
o The applicant requests changes to the A/C requirements that could affect
emissions

•	Explain any changes to permit conditions, potentially including attachments or
other aids to more easily show what is changing. A spreadsheet comparing A/C to
PTO or listing strikeout/highlight versions of the conditions in the evaluation
typically is the best way.

8.0 Recommended PTO Conditions

This section should state the conclusions of the evaluation and either recommend that
permit be issued or the application denied. If proposing approval, the CON record should

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Engineering Division Manual of Procedures

be listed and whether it was new or modified, and whether it deviated from the A/C
requirements.

6.2 Creating Conditions for PTOs (October, 2020 Nick Horres)

Conditions for permits will typically be very similar to conditions for the authority to
construct. Standard condition sets are maintained in BCMS as "CON" records. If an
already approved CON with no changes is being used (e.g. for a standard emergency
engine) then you only need to apply the condition set to the permit. If not, a new
condition set is prepared or an existing CON is revised.

The first step in preparing the conditions is typically to finalize all the conditions on the
application record and then copy them to the PTO. Alternatively, if you do not need to
issue an S/A with the final PTO conditions, conditions can be finalized on the new CON
record instead. For any new or revised conditions, the engineer should follow through the
steps outlined in the A/C evaluation procedures to identify if there is an already approved
reference condition that meets the same need, and if revised conditions are present only
on the permits affected by the application.

If creating a new CON, the next step is to create the record in BCMS. The following
steps show how to create and name the CON. To name the CON, the fee schedule and
brief description are listed as the organization name:

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Engineering Division Manual of Procedures

New Record By Single - Internet Explorer provrded by The County of San Diego

110/06/2020	|L5l	|	

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Entered t>v Division Current Division

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| Nicholas Horres V |

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Once the CON record is created, conditions should be copied from the APP record and
any updates made. The initial workflow step should then be completed by the permit
engineer. The engineer should then notify their senior engineer that it is ready for review
and provide any relevant information explaining what changes were made and why. The
senior engineer then completes the workflow step and forwards the request to a
representative from Compliance for review and approval. Compliance review is primarily
focused on enforceability. Compliance will complete their review and the workflow task
and forward the request to the engineering aide to finalize the condition setup. Finally,
the aide will notify the permit engineer that the set is ready and the permit issuance
process can proceed. Review time should be charged to the underlying applications, not
to the CON record itself.

The following diagram provides a rough outline of a typical permit condition/CON
record setup process.

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Condition Management Process

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Engineering Division Manual of Procedures

6.3 Permit Condition Languange Guidance (October, 2020 Nick Horres)
General Guidance

Writing good permit conditions is one of the most important steps in the application review process.
We utilize standard conditions whenever possible, but a high percentage of applications will need
new conditions. Engineers should generally consider the following principles when drafting
conditions and also follow any directions from their supervisor:

•	Utilize existing conditions whenever possible

•	Duplicate existing wording only changing the relevant sections. For example: if there is a
standard condition for a temperature limit at 700 degrees C and you need a limit of 750
degrees C, copy the existing condition and update the limit rather than attempting to write a
new condition.

•	Pay close attention to usage of "and", "or" and comma placement to ensure the condition is
enforceable as intended. Something that may be implied when used normally in spoken
English can be vague in the context of a permit condition. A common mistake is to use
phrasing similar to:

Emissions from this equipment shall be below 10 lb/day or 5 tons/year.

The usage of "or" in the above sentence can be interpreted as saying that the applicant only
needs to meet one of the limits rather than both. In this condition the "or" should be
replaced with "and"

•	Use definitive language. E.g. always specify "the operator shall do A..." not "the operator
should doB..."

•	Be clear and concise. It's better to have more, simpler conditions than fewer longer
conditions.

•	Utilize "permit streamlining" principles (if one rule requires meeting an emission limit of 10
ppm and one requires meeting 15 ppm, you can combine them and list an emission limit of
10 ppm)

•	There must be a mechanism (typically a test or monitoring requirement) to demonstrate
compliance with any condition on the permit

•	Many limits will also require recordkeeping conditions requiring the owner/operator to
maintain documentation to show they comply with all limits/requirements (maintenance
records, material usage records, etc.)

•	Include rule references in the condition. The ideal form of rule references is to place
brackets around them but parentheses are also acceptable. You may also cite multiple rules
in one condition so that the condition can be used on a greater variety of permits. For
example: All fuel used in this engine must be CARB diesel. [Rule 69.4.1 and/or 17 CCR
93115 and/or 17 CCR 93116]

•	Avoid employing complex calculations within conditions unless absolutely necessary

•	Pollutant and chemical names should be used, spelled correctly and for TAC limits include
the CAS #

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Engineering Division Manual of Procedures

•	Be specific whenever possible. The vaguer a condition is, the more likely that the facility
will eventually misunderstand it and it will be harder for Compliance to enforce the
requirement.

•	When stating things like calculation methodologies, test procedures or similar requirements
that are not specified in the regulation, consider including phrasing similar to ".. .or
alternative procedure approved in writing in advance by the District"

•	Do not refer to other conditions by number or as "below" or "above" since conditions can
easily be reordered/renumbered

•	Consider who the operator/permittee is. Larger, more sophisticated companies with
dedicated environmental staff and past experience working with permits will have an easier
time complying with more complex requirements than a small operation new to permitting

6.4 Preparing a PTO in BCMS

The last step in finishing a PTO evaluation is to prepare the PTO in BCMS. Depending on the
application type, this may require modifying an existing permit, relocating an existing permit, or
creating a new permit. When possible, modifying/relocating an existing permit should be utilized
instead of creating a new permit.

Modifying an existing permit

The two parts of a permit that need to be modified when finishing an application are the permit
record and the conditions.

In the permit record, the equipment description, equipment types, BEC and version history need to
be revised. For the version history, the PTE and expected actual emission values must be completed
for any application that involved emission calculations.

NOTE: It is extremely critical that the PTE and expected actual emissions are completed
accurately on any permit when the application involved emission calculations or emission
calculations are readily are available from previous applications. These will be utilized as data
made available to the public through AB423 changes, so accuracy and completeness is key.

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Engineering Division Manual of Procedures

APCD2020-PTO-003445 - Caterpillar Model: C175-20 DM 8854









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Record - Permit to Operate

Activities (0)

Activity Summary (1)

Address (0)

Ac

Permit Description





Emergency Diesel Engine Generator: Caterpillar Model C175-20 DM8854-02, S/N BXR01999; Engine Family
JCPXL106.NZS; tier 2 certified; 5646 bhp rated; turbocfiarged with air cooler; driving a 4 MW emergency
electrical generator





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Enter the BEC and throughput or capacity data, also whether equipment is portable or stationary

Fill in these fields to ensure that correct renewal fees are collected each year. You
can also add multiple types of fee schedule.

EQUIPMENT TYPES

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The equipment type section is what determines annual renewal fees. Some fee schedules are based
on each emission unit while some are based on each facility, so these should be set correctly as
listed in Rule 40. In some cases, such as rock plants, there may be multiple fee schedules on the
same permit that are set to assess renewal. For coating permits that involve multiple types of
coating, each fee schedule should be added, but only the highest renewal fee should be set to assess.

The last step is to apply the conditions from the approved CON by copying to the permit as shown
in other procedures.

Relocating a permit

Before submitting the final evaluation for approval, the existing permit needs to be moved to the
new site ID. This can be accomplished as follows. This covers only those additional steps for
changing a permit's location. All other steps should be followed as usually for BCMS and
completing the PTO evaluation. Permit Engineers can carry these steps out themselves or request an
aide to move the permit.

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Engineering Division Manual of Procedures

1.	Open the old site record that is associated with the permit to be moved in "related records".

Find the permit in question and check the box next to it.

Record ID: APCD2009-SITE-00296

Menu * List View Clone Sgl Clone Mult Update Related Records Search LookUp Create a Set Delete	Help f

GoTo w * ry (3) Related Records Renewal Info Status Trust Accounts	Workflow Workflow History (0)

l-SITE -00296 -> [LUEG-APCD .Administrative,Site,NA]; Stilus: Active
|Q9-APP-000902-> ILUEG-APCD.Permit App.Material Application,Automotive] ; Status: Approved
D2008-PTO-978 5 79 ILUEG-APCD,Administrative,PetmitTo Operate,NA]; Status: Active
APCD2002-CAR-00651 -> ILUEG-APCD,Compliance,Corrective Action Report,NA] ; Status Closed

~	> APCD2013-CMP-Q034 -> ILUEGrAPCD,Com plaint,N A.NAl; Status: Closed

~	~ APCD2013-CMP-0230 -> {LUEGrAPCD,Com plaint,NA.NA]; Status: Closed

D> APCD2014-NTC-00095 -> [LUEG-APCD, Compliance, Notice to Com ply, NAJ; Status Closed-Certified Compliance
llJ> APCD2014-CAR-00050 -> ILUEG-APCD,Compliance,Corrective Action Report,NA] : Status Open

~	> APCD2018-NO V-000216 —> ILUEG-APCD,Compliance,Notice of Violation,N A] ; Status: Closed -Paid

~ > APCD2010-NTC-00235 -> ILUEG-APCD,Com pliance,Notice to Comply,HA]; Status Closed-Certified Compliance

2.	Click "Delete'1 from the menu. Note that this does not delete the permit, it deletes the
association to the old SITE.

Record ID: APCD2009-SITE-00296	' "*N.

Menu « List View Clone Sgl Clone Mult Update Related Records Search LookUp Create a Set |

| Delete J

GoTo w * ry <3) Related Records Renewal Info Status Trust Accounts (0) Workflow Workflow History (0)

3 ~ APC02009-SnE-00296 [LUEG-APCDAdministrative,Site,MA]; Status: Active

Ei ¦ [U> APCD2009-APP-00 0902 -j> ILUE G-APCD. Perm it App.Material Application, Automotive!; Status: Approved
•3	APCD2008-PTO-978 5 79 ILUEG-APCD,Administrative, Permit To Operate, NA] ; Status: Active

D> APCD2002-CAR-00651 -> ILUEG-APCD,Compiiance,Corrective Action Report,NAJ ; Status Closed
D> APCD2013-CMP-0Q34 -> {LUEG-APCD, Com plaint, NA.NA]; Status: Closed
D> APCD201 3-CMP-Q23Q -> ILUEG-APCD,Com plaint,NA.NA]; Status: Closed

~	> APCD2014-NTC-00095 ILUEG-APCD,Com pliance .Notice to Comply.NAl ; Status Closed-Certified Compliance

~	» APCD2014-CAR-Q0050 -> ILUEG-APCD,Com pliance .Corrective Action Report,NA] ; Status Open

~	> APCD201S-NOV-000216 lLUEG,APCD.Compliance,Notice of Wolation.NAl; Status: Closed-Paid
D> APCD2010-NTC-00 235 -» [LLIEG-APCD,Compliance,Notice to Comply,NA] ; Status Closed-Cert Jed Compliance

After clicking the button, the old site will now no longer be connected to the permit.

Record ID: APCD2009-SITE-00296

Menu » List View Clone Sgl Clone Mult Update Related Records Search Look Up Crea

GoTo * ^ ryP) Related Records Renewal Info Status Trust Accounts (0) Workflow Wc

1 record(sj deleted successfully.

- D ^ APCD20G9-SI7E-0O296 -> [LUEG-APCD,Administrate e,Site,NA|; Status: Active

B< ~> APCD2Q09-APP-000902 [LUE G-APCD,Permit App.Material Application .Automotive! ; Status: Approved

~	> APCD2010-NTC-00235 -> ILUEG-APCD,Compliance,Notice to Com ply,NAJ ; Status Closed-Certi lied Compliance

3. Open the change of location application in the "related records" tab. Select the "look up"
function.

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Engineering Division Manual of Procedures

GoTo ~ ^ (2} Related Records Renewal Info Status Trust Accounts {16) Workflow Work Flow History (6)

© ~ > APCD201&-SITE-03207 -> [LUE G-APCD,Adminidrat»ve,Site,NA} ; Status Active

B ~ ^ APCD2019-APP-006078 —> {LUEG-APCD.Permit App,Material AppJication,Automotive]; Status:Open

Search for the permit that is being relocated.

Record ID: APCD2019-APP-006078

Submit	Reset	Cancel

Help ~ Enable SoundexSearch

GoTo » * (2) Related Records Renewal Info Status Trust Accounts {16) Workflow

Record ID [Alt + R]

%PT0-978579

Record Type

Group

Type

% is wildcard

Subtype

LUEG-APCD v

—Setect-

-Select-

Opened Date:

Status [AH + S]

-Select-

Category

-Select-

After clicking submit and finding the permit, check the box next to the application and click
"select as child". Since you are on the application record, this selects the permit as being under
it, following the typical record relationships.

Record ID: APCD2019-APP-0G

Menu » Select as Parent! ^

Search

Cancel

Help

GoTo ~ * (2)
Q Record ID

Related Records Renewal Info Status Trust Accounts (16) Workflow Workflow History ('

Brief Description

i

0 IAPCD2008-FTO-978579

Type

LUEE-APCD/Admin istraflve

Sub Type

PermitTo Operate/NA

After this, a window will pop up asking what parameters should be copied. Select only
"Contact" and click submit. This copies the application contact information, including
equipment location, to the permit.

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Engineering Division Manual of Procedures

Reset

Cancel

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CD Fee Items f Select i
I~1 Workflow Status
IZI Inspection fSelect'l
CI Record Specific Info (Select)

~	Additional Info
O Valuation Calc

~	Workflow Task Specific Information

~	Status or New Status: -Select-	

Status History	I	I Preserve Dates

This should successfully move the permit to the new site and place it under the application.

General Record Information

I I Record Details fSetAnplication Description'!
~ Parcel

I	i Parcel Owner

d] Address
EH Assets

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0 ContacUSetectt

Record ID: APCD2019-APP-006078

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m

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Renewallnfo Status Trust Accounts (16) Wotkflow Worlcfl

1 reconi(s) added successfully,
ffl ~> APCD2019-SITE-0 3 207 —> [LUE G^APCD.AdminiSrative^ite.NA!; Status Active

a ~ APCD2Q19-APP-006073 -> [LUEG-APCD.Permit App, Materia I Application, Automotiv e]; Status: Open
B\ ~> APCD2DOS-PTO-978579 —> [LUEG-APCD,Administrative.PetmitTo Operate,NAj ; Status Active

APCD2D02-CAR-00S51 -> [LUEG-APCD,Coropliance.Corrective Action Report,HAJ ; Status Closed

~	> APCD2013-CMP-0034 -> [LUEG-APCO,Com plaint,NA.NAJ; Status: Closed

APCD2D13-CM P-023D -> JLUE G-APCD,Com plaint,NA.NA]; Status: Closed

~	> APCD2014-NTC-00095 -> [LUEG^APCD.Compliance,Notice to Comply,HA); Status Clossd-CertiSed Compliance
i	] > APCD2014-CAR-00050 —> [LUEG-APCD,Compliance.Con'ective Action Report,NAj ; Status Open

~	> APCD2G1S-MOV-000216 —> [LUEG-APCD,Compliance,Notice of \^olatjon,HA]; Status: Closed -Paid

4. Now the data just needs to be cleaned up. First open the permit and delete the old contacts.
There should only be one of each contact type. Note that the new equipment location must
be changed to the primary contact to allow deleting the old equipment location.

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Engineering Division Manual of Procedures

Record ID: APCD2008-PTO-978579

Save	Reset	Cancel

Help

GoTo » Summary Record - Permit to Operate Activities (0) Activity Sumrnaiy (15) Address(l) Addtl
Type (Required) -	 RrstName LastName	Full Name

APCD EquipmentLocation

Relationship

Zartna

Gonzalez

[IZarina Gonzalez

Title

Organization Name

International Trailer Services Inc

Street Address

2001 Enrico Fermi Dr#D

Address Line 2

Address Line 3

State

Zip Code

San Diego

CA

92154

E-mail

After cleanup, there should only be one of each contact type.

Record ID: APCD20Q8-PTO-978579

Menu W Manage Contacts W View Log

Help

Country

-Select-

Summary

Record

- Permit to Operate Activities (0) Activity Summary (15) Address (1) Addtl Info Calenc

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2 record(s) deleted

[ |	Contact ID

~	64748742

~	64748744

~	64748743

~	64748746

~	64748745

First Name Last Name

Doug	Dickey

Barry	Denes

Org Name

International Trailer S...
International Trailer S...
InternationalTrailer S...
InternationalTrailer S...
Intern ationalTrailer S...

Address Line 1

1421 N Wanda Rd #140
9170 Siempre Viva Road
1421 N Wanda Rd #140
1421 N Wanda Rd #140
1421 N Wanda Rd #140

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5. After moving the permit, this has left the original application record by itself To prevent
loss of documents in accordance with the retention schedule, the original application should
also be moved and associated with the permit.

Finally, the PTO record data and permit conditions should be updated as necessary following the
same steps as for a modified permit.

Creating a new permit

To create a new permit, the application record will be "cloned" to copy key information over. This
is done from the related records tab in BCMS

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Engineering Division Manual of Procedures

APCD2018-APP-005644 I Use the Clone Mult function from the application

Menu ^ List View Clone Sgl 1



Update Related Records Search Look Up







Go To ~ 4

Related Records

Renewal Info

Status

Trust Accounts (0)

Workflow

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0 ~» ARCD1997-SFE-09S63 -> f^UEG-APCD Administrative. Site.NAl : Status: Active

B ~ ^ APCD2018-APP-€Q5644 [LUEG-APCD?Permit App.Vapor Recovery,EVR Phase II OTC] ; Status: Approved

Now set the record type to PTO and create the new record. When prompted, select to copy contact
information and then submit to create the new PTO record.

APCD2018-APP-005644 Last|yj pre„ 5ubmjt

Submit

New Set Existing Set Cancel

Help

Go To

# of Clones per Record Type

|i

Please select the Record Type

Related Records Renewal Info Status Trust Accounts (0)

Clone To Set:

Workflow Workflow History (10)

Clear

0- Record Type

0- LUEG-APCD
El- Administrative
0- CJiange
0- Condition
0- Legacy Data
0- Permit To Operate
	im	

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move the type over

0- Safety
0- Site
0- TrtleV
0- AQ Network

Set the record type
tree to Permit To
Operate/NA as shown

LUEG-APCD/Administrative/Perrrit To Operate/NA





»







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Record Specific information

~	Fee Items ("Select)

D Workflow Status

~	Inspection (Select)

~	Record Specific Info (Select)
n Additional Info

D Valuation Calc

~	Workflow Task Specific I nformation

~	Status or New Status: | -Select-
Status History

General Record Information

~	Record Details fSet Application Description)
D	Parcel

D	Parcel Owner

~	Address
D	Assets

]	Licensed Professionals (Select)

^^^ocumen^

D Preserve Dates

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Engineering Division Manual of Procedures

APC D2018-A PP-005644

Menu ^ List View

Clone Sgl

Clone Mult

Update Related Records

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Cr















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Related Records

Renewal Info Status

Trust Accounts (0)

Workflow

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1 record(s) added successfully.

E	APCD1697-SITE-Q9393 -> rLUEG-APCD.Adminisirative.Site.NAl : Status: Active

B- ~ } APCD2018-APP-005S44 -> [LUEG-APCD,Permit App,Vapor Recovery,EVR Phase II QTC] ; Status: Approved
APCD202Q-PTQ-003462 TLUEG-APCD .Administrative. Perm it To Operate.NAT : Status: Unapproved

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Now that the new permit is created, the same steps should be followed as for modifications to
create the record data and apply the conditions.

6.5 Permit Streamlining (October, 2020)

It is important that engineers finalize permit evaluations as soon as possible after compliance with
permit conditions has been established. Startup Authorizations are typically issued for 6 months,
and ideally the final permit should be issued before the startup authorization expires. Additionally,
applications for new equipment only include renewal fees for one year of operation, and extending
the startup authorization period beyond one year can result in an applicant having to pay fees before
their permit becomes active.

6.6 Denials (November 2021)

Before an application for an A/C is denied, the applicant generally will be notified by telephone of
the proposed action with the reasons and the call will be documented. The applicant will be given
an opportunity to submit any revised or new information in order to demonstrate that the
application should not be denied. This must be done through the submittal of a new application and
a fee that will be determined in accordance with Rule 40(a)(4). If such a demonstration is not made
as soon as is reasonably possible (within 10 working days), the denial action will be taken.

Proposed P/O denials will be reviewed with the supervisor. If there is a benefit in notifying the
applicant of the proposed action before it is taken, it will be done in a manner similar to that for an
A/C denial. All A/C or P/O denial actions (except routine, off-the-shelf equipment) will be
approved by the chief of engineering and the deputy director. The section's senior engineer will
sign all denial letters. The section's senior engineer will sign all denial letters.

Operation of equipment without written authorization is a misdemeanor subject to fines or
penalties up to $10,000 a day. If the withdrawal of an S/A or denial of an application is due to
an emission violation and operation of the equipment continues, an additional penalty of up to
$75,000 a day may be assessed

When denying or canceling an application, the applicant will be advised that if there is construction
without an A/C, Rule 10(a) will be violated or if there is operation without a P/O, Rule 10(b) will
be violated. Notice that a violation of any District rule or regulation will be subject to civil and
criminal penalties also will be stated. Similar language will be used when there may be the
potential to violate other District rules.

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Engineering Division Manual of Procedures

The following letter template, or an equivalent as approved by the Senior Engineer, shall be used
for all denials.

Month DIX YYYY

Applicant Name	APPLICATION

Applicant DBA	NO.: APCD20XX-APP-

Applicant Title	XXXXXX

Address
City, CA, ZIP

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Dear	,

This is in reference to the permit application filed by [Applicant DBA]
with the San Diego County Air Pollution Control District (District) for an
Authority to Construct (ATC) [Project Description] to be located at
[Equipment Location Address], After a detailed review, the District has
concluded the proposed project as specified in Application No.
APCD20XX-APP-XXXXXX, will not comply with applicable District
rules (and/or state and/or federal air quality laws & regulations).
Specifically, the proposed equipment will not comply with District Rule
[.. .list all District, state and federal rales, laws or regulations requirements not
met].

Therefore, in accordance with District Rule 22 - Denial of
Applications, this application for an Authority to Construct and Permit
to Operate is hereby denied.

Please note that [Applicant DBA] may appeal this denial through the filing
of a petition with the District Hearing Board for a public hearing. Such a
petition must be made within 30 days after receipt of this letter. [Applicant
DBA] may also submit another application to the District for an Authority
to Construct and Permit to Operate for equipment which will comply with
applicable District rules (and all applicable state and federal laws and
regulations).

Construction or operation of equipment without written authorization from
the District is a misdemeanor subject to fines or penalties as specified in
California Health and Safety Code.

If you have any questions regarding this action, please contact [District
Project Engineer] at (858) XXX-XXXX, [District Project Engineer e-mail
address] or the undersigned at (Tel. No. & email address).

Senior Engineer Name
Senior Engineer Title

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Engineering Division Manual of Procedures

6.7	Review of Conditions by Applicants (October 2020)

Before issuing a PTO, we must enure that the applicant/operator understands the
conditions and can comply with them. Conditions should initially be reviewed with the
operator before the S/A is issued. If any changes are necessary, the Engineer should
provide the applicant the opposrtunity to review and commont on the proposal. Typically
this can be done by issuing an S/A with the updated conditions prior to beginning work
on the CON approval or once reviewed by Compliance.

The engineer should consult with their supervisor to determine when conditions should
be provided to the applicant. For minor changes or changes that are expected to be
approved by the senior engineer and Compliance, the conditions my be provided
concurrently with CON review. If there is uncertainty, conditions should typically be
approved by Compliance prior to providing to the applicant unless they are made aware
that changes are likely.

6.8	Applications Required for Expired Permits (April 24,1979)

Rule 10(h) requires an application for an annual renewal permit prior to the expiration
date of the current permit. If no such application is made, the permit is expired.

In order to provide some flexibility to handle late applications for renewal in a reasonable
manner, Rule 10(h) provides a six-month period within which an expired permit can be
reinstated as though it were an annual renewal, provided an application for renewal is
made and all fees and penalties are paid. Submittal date is the postmarked date, if the
application is mailed.

Once the six-month period has passed, the permit is expired, and all current rules and
regulations of the District apply. Therefore, a new application for an A/C and P/O will be
required.

6.9	Documents to be upload prior to submitting the PTO for approval

In addition to the documents required to be uploaded during the A/C review and issuance
process, the following documents are expected to be uploaded as they become
available/finalized during PTO evaluation, prior to submitting the application for final
approval:

•	Signed CCN returned by applicant

•	Inspection Report/PTO Evaluation

•	Startup Authorization

•	Inspection Photos

•	Source Test Report

•	Supplemental test data or other information required as part of satisfying a
condition

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Engineering Division Manual of Procedures

•	Any relevant correspondence with applicant or other regulatory agencies

•	Invoices sent for additional fee deposits

7. Startup Authorization (S/A)

7.1 S/A Issuance (February 22,1984)

A.	When a P/O evaluation that clearly demonstrates that the subject operation is in
compliance with District requirements is done, an S/A will be issued allowing
operation until a P/O is issued. This type of S/A will be issued for six months.

B.	When equipment has been installed in accordance with an A/C or installed properly
if an A/C is to be issued concurrently with a P/O and appears to be operating
properly with no apparent violation of a District requirement, but will require
further evaluation (i.e. source testing), an S/A may be issued for shakedown and
test. The S/A will be issued for no longer than is reasonable to conduct the
shakedown/testing and for the District to verify compliance. S/As of this type will
not be issued for longer than 30 days without specific approval from the senior
engineer. The senior engineer will approve extension of this type of S/A.

C.	When the initial P/O evaluation indicates that operation of the subject equipment
does not meet District standards but the problem may be corrected readily, an S/A
will be issued for shakedown and test. A senior engineer will approve S/As of this
type in advance. They will be of limited duration (i.e 10 days) and will specify as a
condition of the S/A, what corrective action must be taken. When liquid leaks are
found, an S/A will be issued consistent with this type of policy only if a condition is
added to the S/A that requires such leaks to be corrected within one working day
from the issuance of the S/A.

D.	In the event a P/O evaluation indicates that operation of the subject equipment does
not meet District requirements and substantial rework or replacement would be
required for compliance to be achieved, the matter will be discussed with the
supervisor regarding possible denial, S/A issuance or notification that a variance is
needed to continue operation. The supervisor or deputy director will provide
guidance.

E.	Only the vapor control staff will issue Notices to Repair.

F.	For portable, off-the-shelf equipment, such as tar kettles and abrasive blast pots that
will not exceed any NSR rule thresholds and that are not subject to any emission
limitation other than Rule 50, the applicant will be advised that upon receipt of the
application, he must notify the District the first time the equipment will be used in
the county and that failure to do so will result in a violation of District rules. When

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Engineering Division Manual of Procedures

the District is so notified and either an engineer or an inspector observes the source
in operation, an S/A can be issued to cover the approximately 60-day P/O issuance
turnover time. For those cases where an inspector will issue the S/A, the District
will provide the Compliance division with the appropriate conditions that must be
included with the S/A. (December 19, 1979)

G. The S/A date cannot be changed once it has been entered on the VAX. The present
coding of the screen has been set up so that once the data has been entered and
saved (committed) users cannot modify it. This information can be modified by
Data Management. (March 10, 1994)

7.2 Implementation Procedures for Rule 24 (July 1,1997)

On March 20, 1996, the Board repealed old Rule 24 and adopted a new Rule 24 entitled
Temporary Permit to Operate. With the repeal of old Rule 24, applicants can no
longer deem their permit applications denied if not acted upon within 90 days and can no
longer appeal that presumptive denial to the Hearing Board.

New Rule 24 contains provisions that allow new, modified and existing equipment to
temporarily operate, under specified circumstances, without a Startup Authorization or
Permit to Operate or Hearing Board variance. You should already have a copy of new
Rule 24 in your Rules and Regulations.

In the past, businesses could not operate their emission units without written District
authorization. This meant that new or modified emission units with an A/C could not
operate until Engineering conducted an inspection and issued a S/A. It also meant that
new (or modified) units built without an A/C could not legally operate until their
applications were evaluated, an A/C was issued, and an inspection done and an S/A
issued. A facility's only recourse to obtain operating authority pending issuance of a S/A
was to petition the Hearing Board for a variance. This was time consuming and costly.

In 1996, the District decided to write a new Rule 24 to streamline this process. In
general, Rule 24 allows the A/C to serve as a temporary permit to operate new or
modified emission units, and a substantially complete application to serve as a temporary
permit to operate existing emission units installed without the required A/C. Compliance
action is still applicable to equipment installed without an A/C and operation must still be
in compliance with all applicable District rules.

Rule 24 does not significantly change current Engineering procedures for evaluating and
issuing Authorities to Construct, Startup Authorizations or Permits to Operate. However,
it does require change in two areas:

A. Authorities to Construct for new or modified emission units must contain provisions
that implement a temporary permit to operate once construction is complete and the
applicant provides the required notice to the District.

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Engineering Division Manual of Procedures

B. This procedure describes the process for the applicant to notify the District that
construction is complete in accordance with the A/C, for the District to document
this for the file, and for the Compliance Division to access information on the
status.

There may also be occasions when the Compliance Division will inquire if an
application submitted for a previously permitted or existing, unpermitted emission
unit is substantially complete and the project engineer will need to respond.
Guidance on whether an application will be considered substantially complete is
provided later in this memo.

When a facility operating under a Rule 24 temporary permit to operate is
determined by the District to not be in compliance, the temporary permit to operate
can be withdrawn. The procedures for withdrawing a temporary permit are also
discussed later in this memo.

Note: Rule 24 is not intended to provide a temporary Title V permit to operate.
Title V sources that operate new or modified emission units pursuant to
authorizations under Rule 24 are in compliance with District Rule 10 permit
requirements, but are obligated to ensure they have also met the requirements of
District Regulation XIV which prescribes the Title V permit program in San Diego.

Procedures

The temporary permits to operate provided by Rule 24 are not to be a basis for delays in
permit application processing. The requirements of Rule 18 still apply, as do all policies,
procedures and customer expectations for timely actions on applications.

A.	Rule 24, Sections (a) and (b) - New and Modified Emission Units:

The Authority to Construct for new or modified emission units will serve as a
temporary Permit to Operate once the owner/operator provides written notification
that construction is complete in accordance with the Authority to Construct. Note
that Rule 24(a) defines a new emission unit as one not previously authorized by the
District to operate in the county and for which a currently valid A/C has been (or is
being) issued.

For purposes of Rule 24, a relocated or replacement emission unit will be
considered a modified emission unit and the procedures described below apply.
However, an emission unit that has been relocated without an Authority to
Construct but for which a substantially complete application has been submitted
could be operated under the provisions of Rule 24, Section (d) as an existing
emission unit.

B.	To implement Rule 24, Sections (a) and (b):

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Engineering Division Manual of Procedures

1)	When issuing an Authority to Construct for a new or modified emission unit,
include the following as the last condition of the Authority to Construct:

"This Authority to Construct authorizes temporary operation of the
above specified equipment. This temporary permit to operate shall take
effect upon written notification to the District that construction (or
modification) has been completed in accordance with this Authority to
Construct. This temporary permit to operate will remain in effect, unless
withdrawn or modified by the District, until the equipment is inspected
by the District and a revised temporary permit (Startup Authorization) is
issued or a Permit to Operate is granted or denied."

"Upon completion of construction (or modification) in accordance with
this Authority to Construct and prior to commencing operation, the
applicant must complete and mail, deliver or fax the enclosed
Construction Completion Notice to the District. After mailing,
delivering or faxing the Notice, the applicant may commence operation
of the equipment-. Operation must be in compliance with all of the
conditions of this Authority to Construct and applicable District rules."

"This Authority to Construct shall be posted on or within 25 feet of the
above described equipment,' or maintained readily available at all times
on the operating premises."

2)	Delete the language in the Authority to Construct that states that the AJC is
not a permit to operate and that operation without District authorization or
Hearing Board variance is a violation.

3)	Include in the Authority to Construct conditions regarding operation of the
emission unit as necessary to ensure compliance. Under current permitting
procedures, A/C's should already contain anticipated P/O conditions. This
procedure must be diligently followed. This does not preclude revising
conditions for the S/A or P/O, as needed, to ensure compliance and with the
knowledge of the applicant.

4)	Word Processing will include a stamped, self-addressed Construction
Completion Notice with each Authority to Construct letter and with letters to
extend Authorities to Construct. A copy of the Notice form is attached. Word
Processing will fill in the following information on the Notice, before mailing,
based on information from the application and Authority to Construct:

Company Name (DBA)	

Application Number	

Equipment Address	

Type of Equipment	

Project Engineer Name/Phone Number

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Engineering Division Manual of Procedures

5)	The applicant must notify the District of construction, installation or
modification of the emission unit(s) by mailing, faxing or delivery of the
completed Notice. If the applicant calls to notify you, make a note in the file
but advise the applicant to complete and mail/fax/deliver the Construction
Completion Notice.

6)	The date of District receipt of all Construction Completion Notices will be
time-stamped by Clerical on the Notice. Permit Processing will enter the
"Construction Completion Date" and "Construction Notification Date" in the
corresponding fields in the application file on the VAX, using the information
provided on the Construction Completion Notice. Permit Processing will then
forward the Notice to the appropriate project engineer. Compliance will use
this VAX information to verify that Notices have been received.

If an engineer receives a notice directly, a copy should be forwarded to Permit
Processing for recording.

Note: The current "Equipment Installed Date" field in the VAX application
file is being deleted in favor of the "Construction Completion Date" field.
Also, the Construction Completion Date input by Permit Processing cannot be
changed except by a senior engineer.

7)	On receiving the Construction Completion Notice, the project engineer will
contact the applicant to inform them that the Notice was received, verify
construction completion and schedule an inspection. This contact should
generally be made within one working day, but not later than one week, of
receiving the Notice. The project engineer will add the Notice to the
application evaluation file.

8)	The current policies and procedures regarding inspections, Startup
Authorizations and permit to operate evaluations/actions will continue to be
followed.

9)	After inspecting the equipment and determining whether it has been
constructed/installed/modified in accordance with the AJC and in compliance
with applicable District rules, the project engineer must determine whether to
issue a Startup Authorization and also update the application file in the VAX
system. The date when the project engineer issues the initial startup
authorization should be entered by the project engineer in the "S/A Issued
Date" field. The "S/A Action Code" field should be completed with the
appropriate code depending on whether the S/A is for shake down and testing
or operation until a permit can be issued.

10)	If the Authority to Construct will expire after notice is received that
construction is complete, but before an inspection can occur and a S/A issued,

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Engineering Division Manual of Procedures

the project engineer should extend the Authority to Construct (not beyond the
5 years from original issuance allowed by Rule 17) by reissuing the AJC or by
a letter extending the AJC with the same terms and conditions. Make sure that
Compliance receives a copy of the reissued AJC or letter extending the AJC.

11)	If the project engineer finds that the emission unit is not constructed in
accordance with Authority to Construct, or is not in compliance with a District
rule, because of minor, easily correctable deficiencies (e.g. missing label,
pressure tap or temperature gauge), but can reasonably be expected to operate
in compliance with the substantive requirements of applicable rules, the
project engineer should issue a Startup Authorization for shake down and
testing for a reasonable period of time with conditions requiring the minor
deficiencies be corrected by specific dates.

(Note: This procedure is what the language in Rule 24, Sections (a) and (b) is
referring to when it talks about the APCO granting a reasonable period of time
for the construction to be completed in accordance with the AJC before acting
on the P/O. This is not a new procedure. Refer to the attached copies of
permit policy memos dated February 22, 1984 and March 29, 1993.)

12)	If the permit engineer finds that the equipment was not built in accordance
with the Authority to Construct, has major deficiencies, and/or is unlikely to
be able to operate in compliance with the Authority to Construct or applicable
District rules, the engineer should consult with their senior engineer and
inform the applicant verbally and in writing of the non-compliance. At that
time the engineer is to also advise the applicant that the temporary permit to
operate contained in the Authority to Construct is being withdrawn effective
10 calendar days after the date of written District notice.

The written notice to the applicant must cite the reasons why the temporary
permit is being withdrawn and advise the applicant that continued operation of
the emission unit without written District authorization or a Hearing Board
variance will be in violation of District Rule 10(b). When withdrawal of a
temporary permit is necessary, the project engineer will discuss with the
senior engineer and Chief of Engineering the appropriate disposition of the
pending application.

The engineer must also advise the Compliance Division if the noncompliance.
The Compliance Division will determine if any follow-up Compliance action
is appropriate.

C. Rule 24, Section (c) - Previously Permitted Emission Units

The provisions of Rule 24, Section (c) primarily affect emission units that had valid
permits but the permit has expired or has been retired. Section (c) allows the
application for permit to serve as the temporary Permit to Operate if the application

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Engineering Division Manual of Procedures

is substantially complete. Operation must be in compliance with the previous
permit description and conditions, and applicable District rules.

Section (c) only applies to emission units that are not portable (per Rule 20.1
definition), that have not changed ownership, have not been relocated to another
stationary source, and have not been altered or modified since holding the previous
permit. In these latter cases, Sections (b) or (d) of Rule 24 may apply depending on
whether the emission unit is being relocated or otherwise modified, whether an AJC
has been or is being granted, and whether the unit is portable. If the emission unit is
proposed to be (or has been) altered, modified, or relocated, an Authority to
Construct is required and NSR, Rule 1200 and AB3205 may be applicable. In these
cases, the implementation procedures described above for Rule 24 Sections (a) and
(b) would apply.

Section (c) also only applies if the application for permit is received within 18
months of when the previous permit expired. Since expired permits can be
administratively renewed or reinstated (by Permit Processing) within 12 months of
expiring (or within 6 months of being retired), Rule 24(c) will generally only have
relevance for Engineering when an application to reissue a permit is filed between
12 and 18 months after the previous permit has expired (or between 6 and 18
months after a previous permit was retired). These types of permit applications are
infrequent.

The following procedures regarding Rule 24(c) will apply for Engineering:

1)	If the emission unit has not been altered, modified or relocated (to another
stationary source or contrary to a permit condition) since the previous permit,
an Authority to Construct is not required, and NSR and the AB3205
notification process do not apply.

The permit evaluation would consist of determining whether the application is
substantially complete and whether the emission unit is in compliance with its
former permit and with currently applicable District rules. This will typically
be based on an inspection, review of the previous evaluation, permit
description and conditions, and an evaluation of compliance with current
applicable rules.

2)	For purposes of Rule-24, an application will be considered substantially
complete if:

•	the general application form has been completed and signed,

•	appropriate initial fees have been submitted,

•	the application is accompanied by complete supplemental forms, as
applicable, and

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• all information specifically identified by the District, in writing or on
the application or supplemental forms, prior to the filing of the
application has been provided.

This does not preclude an application from being determined incomplete for
purposes of Rule 18. However, if within 30 days of receipt of an application
the permit engineer does not inform the applicant in writing that an
application is incomplete, it is automatically deemed complete for purposes of
Rule 18, and would be considered substantially complete for purposes of Rule
24.

3)	If a substantially complete application has been submitted, that application
serves as a temporary permit to operate until the unit is inspected and a
revised temporary permit to operate (S/A) is issued, or the Permit to Operate
is granted to denied.

4)	The current policies and procedures regarding inspections, Startup
Authorizations and permit to operate evaluations/actions will continue to be
followed.

5)	If during the course of the evaluation, the project engineer determines that the
emission unit is not operating in compliance with any applicable District rules
and regulations, the engineer should consult with their senior engineer, inform
the applicant verbally of the noncompliance, and advise the Compliance
Division of the noncompliance. The Compliance Division will determine if
the temporary permit to operate will be withdrawn and provide written notice
of that determination to the applicant.

The project engineer must also advise the applicant, in writing, of the reasons
why the equipment is not in compliance and what the applicant must do to
bring the equipment into compliance. The project engineer should check with
Compliance as to their decision on the temporary permit. If the Compliance
Division has determined that the temporary permit to operate provided under
Rule 24(c) should be withdrawn, the notice of that determination should be
coordinated with the project engineer's correspondence regarding
noncompliance and required remedial action(s).

When withdrawal of a temporary permit (or Startup Authorization) is
necessary, the project engineer is to discuss with the senior engineer and Chief
of Engineering the appropriate disposition of the pending application.

D. Rule 24, Section (d) Existing Emission Units.

Rule 24, Section (d) provides that a substantially complete application can serve as
a temporary permit to operate for an existing emission unit that has been
constructed, erected or installed without a currently valid Authority to Construct.

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This section is intended to reduce the need for applicants to obtain a Hearing Board
variance while they wait for an Authority to Construct and a Startup Authorization
to be issued.

A facility might construct or install an emission unit without an A/C (in violation of
District Rule 10), but then operate it under Rule 24, Section (d) by submitting a
substantially complete permit application. However, Section (d) does not grant the
facility any immunity from Compliance of the violation of Rule 10(a), i.e.
constructing, erecting or installing the emission unit without an A/C, nor immunity
from having to comply with District rules.

Section (d) does not apply to applications for portable emission units, nor to
emission units subject to the AB3205 notification program, nor to projects that
would constitute new or modified major stationary sources as defined in Rule 20.1.
(Note: This does not mean that Rule 24(d) does not apply to all emission units at
major stationary sources. Instead, Rule 24(d) excludes only those emission units or
projects whose emission increases constitute a new major source or a major
modification of an existing major source.) Emission units must be operated in
compliance with all applicable District rules.

Section (d) should not significantly impact Engineering's permit processing
procedures. Engineers should be familiar with Section (d) so they can answer
applicant questions regarding it. Also, Compliance Division staff may periodically
ask if an application received is substantially complete. In such case, the criteria
described above in Section (c) and repeated below apply. If those criteria have been
met, the application is considered substantially complete for purposes of Rule 24,
but is not necessarily complete for purposes of Rule 18.

1)	For purposes of Rule 24 an application will be considered substantially
complete if:

•	the general application form has been completed and signed,

•	appropriate initial fees have been submitted,

•	the application is accompanied by complete supplemental forms, as
applicable, and

•	all information identified by the District, in writing or on the
application or supplemental forms prior to the filing of the application,
has been provided.

2)	Standard engineering evaluation, A/C issuance, inspection, S/A and P/0
issuance procedures will continue to apply except as follows.

3)	If NSR applies, no benefit should be accorded the applicant for installing the
equipment without an A/C. For example, in determining BACT cost-
effectiveness, no costs associated with retrofitting controls to the existing
emission unit should be allowed. Costs should be determined as if the

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emission unit had not yet been installed. Similarly, air quality impact analysis
(AQIA) requirements should be applied as if the emission unit had not yet
been installed.

4)	If Rule 1200 applies, again no benefit should be accorded the applicant for
installing the equipment without an A/C.

5)	Temporary permit to operate provisions should be incorporated into the
Authority to Construct, if approved. The procedures described above
regarding Rule 24, Sections (a) and (b), and new conditions in the Authority
to Construct apply.

6)	If during the course of the evaluation, the project engineer determines that the
emission unit is not operating in compliance with any applicable District rules
and regulations, the engineer should consult with their senior engineer, inform
the applicant verbally of the noncompliance, and advise the Compliance
Division of the noncompliance. The Compliance Division will determine if
the temporary permit to operate will be withdrawn and provide written notice
of that determination to the applicant.

The project engineer must also advise the applicant, in writing, of the reasons
why the equipment is not in compliance and what the applicant must do to
bring the equipment into compliance. The project engineer should check with
Compliance-regarding their decision on the temporary permit. If the
Compliance Division has determined that the temporary permit to operate
provided under Rule 24(c) should be withdrawn, the notice of that
determination should be coordinated with the project engineer's
correspondence regarding non-compliance and required remedial action(s).

When withdrawal of a temporary permit (or Startup Authorization) is
necessary, the project engineer is to discuss with the senior engineer and Chief
of Engineering the appropriate disposition of the pending application.

E. Rule 24, Section (e) - Withdrawal of Temporary Permit to Operate

Rule 24, section (e) codifies the District's ability to withdraw or modify a temporary
Permit to Operate that may derive from an Authority to Construct, substantially
complete application, or a Startup Authorization. Under Section (e), a temporary
permit to operate can be modified or withdrawn, in writing, if operation of an
emission unit is in violation of any condition of the temporary permit or an
applicable provision of the District rules and regulations.

This ability to withdraw extends to cases where the District requests additional
information on an application, the applicant fails to provide the information, and the
application is cancelled pursuant to Rule 17. When the permit engineer advises the
applicant, in writing, that the application is cancelled, the engineer is to also advise
the applicant that the temporary permit to operate (via Rule 24 or a startup

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authorization) is being withdrawn effective 10 calendar days following the date of
the District written notice.

To ensure that applicants are fully aware of this, the following standard condition is
to be included in all Startup Authorizations:

"This Startup Authorization shall expire on the date specified above, or 10
calendar days following written notice from the District that the equipment is
not in compliance with an applicable requirement and that this Startup
Authorization is being withdrawn, or upon receipt of a Permit to Operate, or
written notice of denial of a Permit to Operate, whichever is sooner."

7.3	Equipment Deficiency Letters (February 22,1984)

These letters will be used only when an equipment deficiency has been noted and an S/A
will not be issued. Such letters will notify applicants that operation of the equipment
without written authorization is a violation of Rule 10(b) and may be subject to a civil
penalty of $1,000 per day and that the letter "is not a written authorization to operate."

7.4	S/As vs. AECPs (June 18,1990)

The ARB audit report noted two occasions when S/As were issued to sources, intending
to comply by use of an alternative emissions compliance plan (AECP), before the AECP
had been developed, reviewed and approved. ARB pointed out that compliance could not
have been determined, and therefore an S/A should not have been issued, without an
approved AECP in place. To ensure that this is not repeated in the future, although we
expect few additional sources to comply with use of AICP'S, the following procedures
shall be implemented by Engineering staff:

A.	A startup authorization shall not be issued on any VOC source that proposes to
comply with a VOC rule through use of an Alternative Emissions Control Plan
(AECP) unless the AECP has been submitted to the District, reviewed and
approved, and the approved AECP is implemented as a condition of the S/A.

This requirement shall not apply to any current S/A's. However, if any such S/A's
have been issued without a deadline for submittal and approval of an AECP, then
the S/A shall be modified, in writing, within two weeks of this directive, to include
conditions that require the AECP to be submitted and approved within thirty days.

B.	Authorities to Construct for sources pro n to implement AECPs shall not be
approved until the source has submitted the AECP methodology and record-keeping
provisions, and they have been approved by the District.

7.5	Expired S/As (October 21,1991)

Procedures to be followed for facilities with expired Start-Up Authorizations (S/As).

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A.	If during a compliance inspection, the field inspector determines that a Start-Up
Authorization has expired, the inspector shall complete the Expired Start-Up
Authorization Report and submit it with the inspection report. The AQ HI will pass
the report to the APC Aide.

B.	The Aide completes the lower portion of the form with the expiration date, the
name of the appropriate AQ III and the date due back from Engineering. The form
is to be returned by Engineering within three (3) working days.

C.	The Aide provides a copy of the report to the appropriate Senior Engineer and puts
the original in the tickler file. Reports are filed according to the due date.

D.	The Aide will check the tickler file daily. All expired S/A reports which have been
returned by Engineering with revised expiration dates will be distributed to the
appropriate inspector with a copy to the engineering file. When the Aide
determines the report is late or is returned without a revised expiration date a copy
of the report will be annotated, dated and given to the appropriate AQ III for
follow-up.

E.	If the S/A is not extended, the AQ III will notify the field inspector to issue a
violation.

7.6 Startup Authorization/Permit to Operate Procedures (March 29,
1993)

In the context of discussing permit-streamlining issues with a local industry task force,

two concerns were expressed that seem readily addressed.

A. Startup Authorizations (S/A's) that are issued for short periods (30 or 60 days) and
are continuously being extended for short periods immediately before or after S/A
expiration. This places facility operators on near-constant alert, unsure whether the
S/A will be extended, whether they need to petition for a variance or are at risk of
receiving a Notice of Violation. On occasion, it also impose a burden on applicants
to remind the project engineer to extend S/A's when issuance of the permit is likely
beyond the applicant's control.

To correct this, the following revision to S/A procedures is to take effect
immediately:

1) If upon inspection the project Engineer determine that an operation is in

compliance with applicable requirements and a Permit to Operate (P/O) will
be granted, an S/A should be issued with appropriate conditions for a period
of 180s day. The S/A should be checked as being for purposes of allowing
operation until a P/O has been issued.

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2)	If an S/A is to be issued for purposes of shaking down, testing and/or
evaluating the operation, the S/A shall be issued for up to 60 days with
appropriate conditions. If more than 60 days is needed due to source test
scheduling or the nature of the operation a shakedown period of up to 120
days can be granted with the approval of the Senior Engineer. Shakedown
periods greater than 120 days must be discussed with Chief, Engineering
Division, and the Senior Engineer prior to approval.

3)	A standard condition shall be added to all S/A's as follows:

This S/A shall expire on the date specified above or 10 days following written
notice from the District that the equipment is not in compliance with an
applicable rule, receipt of a Permit to Operate, or notice of denial of a Permit
to Operate, whichever is sooner.

4)	Existing procedures regarding S/A's issued to allow operation while minor
deficiencies, which do not affect the compliance status of the equipment, are
being corrected shall remain unchanged.

B. P/O's that are issued with conditions different than the S/A are creating some

problems. If there are issues with the conditions, the applicant is faced with having
to try and resolve them or file an appeal within 10 days. The applicant may feel it
necessary to file an appeal so as not to loose their appeal rights.

To an extent practicable, S/A's issued to allow operation until a permit is received
should have conditions that mirror the BEC conditions that will be applied to the
permit. In addition, the project engineer shall provide the applicant with a copy of
the conditions recommended for the P/0, if they differ substantively from the S/A
conditions, at least 10 days prior to permit issuance. Any issues raised by the
applicant are to be brought to the Senior Engineers attention. It is suggested that
the applicant be provided the permit condition prior to or concurrent with the
submittal of the permit recommendations to the Senior Engineer for approval.

8. Title V Permits

8.1 Instructions for Title V Application

INTRODUCTION

This application package contains the instructions and forms to apply for a Title V permit.
All The application must be submitted with a base fee of $2200 and a deposit of $20,000
for permit evaluation and issuance.

The following forms are required for each application:

Stationary Source Summary [Forms 1401-A1 and 1401-A2]

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Insignificant Activity List [Form 1401-G]

Applicable Requirements Summary Check List [Form 1401-H1]

List of Permits by Equipment Category [Form 1401-H2]

Certification Statement [Form 1401-1]

Compliance Certification Schedule [Form 1401-K]

Abatement Devices [Form 1401-M]

The following form may also be required:

Schedule of Compliance [Form 1401-L]

The following forms are optional:

Alternative Operating Scenario [Form 1401-N]

Multiple Applicable Requirements Streamlining [Form 1401-O]

Outdated SIP Requirement Streamlining [Form 1401-P]

Permit Shield [Form 1401-Q]

EPA requires that you submit "information related to emissions sufficient to verify which
requirements are applicable to the source" and the calculations which form the basis for
this information. Generally, this means that facilities should submit emission unit-specific
forms for each source. However, the District has already gathered most of the necessary
information to calculate these emissions. EPA application streamlining guidance allows
the applicant to reference the calculations of emissions for permitted emission units.
Emission information is only required when the District would need to verify emissions
levels and monitoring approaches for the following:

1.	The facility proposes Plantwide Allowable Limits (PALs) or other plantwide
emissions limits; or

2.	The facility claims an exemption from an emissions-based applicable requirement for
a single emission unit or multiple emission units and expects a permit shield to be
granted by the District from this otherwise applicable requirement.

To avoid duplication of data, the applicant should only submit emission unit-specific forms
where there is more recent data that differs from data previously submitted to the District.
For information on emission unit-specific forms contact the District.

To avoid duplication of the data submitted, the District will send to the facilities a copy of
the permit descriptions, permit content, a permit applicable rules list, and variance activity,
and the dates of most recent inspection and source test that the District currently has in its
database. If the information is correct and complete, the facility may return this
information to the District.

Use the following forms if any part of the data is incorrect or missing:

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Combustion Emission Unit
Coating/Solvent Emission Unit

Form 1401-B
Form 1401-C
Form 1401-D
Form 1401-E
Form 1401-F

Organic Liquid Storage
General Emission Unit
Emission Control Unit

The District will require emissions data only if there is no data on record at the District. It
is the facility's responsibility to submit correct emissions data.

Each of these forms are available on diskette. Two paper copies of the application is
required. However, a facility may also submit a copy on diskette. Computer generated
lists may be attached to the Applicable Requirements Summary Check List, Insignificant
Activity List, and Compliance Certification Schedule forms in lieu of entering data on
these forms, if the data is in the same format.

An applicant submitting "Trade Secret" information must supply in writting a "justification
for this designation" pursuant to District Rule 176. The written justification is public
record.

THE FOLLOWING ARE INSTRUCTIONS FOR FILLING OUT EACH FORM

Form 1401 - A 1 Stationary Source Summary

This form is the basic facility application form and part of the Application Summary. The
District will send this form together with the emissions summary of Form 1401-A2 to EPA
instead of the text of the entire application. EPA does have the right to request the entire
application from any facility. Please keep one copy of your entire application in case a
copy is requested by EPA. The District will expect you to submit a copy to EPA if they
request it. Please note that EPA uses the term "source" to mean plant or facility. Only one
Stationary Source Summary form is required per facility.

Items 1.1, and 1.3 through 1.5 are self-explanatory.

Item 1.2, the SIC code, is a "Standard Industrial Classification" code. Use the SIC code
that most closely describes your facility.

Item 1.6, UTM coordinates, are Universal Transverse Mercator coordinates. These
coordinates are used to define the location of your plant precisely. The District will enter
the data on this line.

Item 1.7, Source located within 50 miles of a state line, refers to other states and tribal
lands. The District will provide a list of tribal lands and their location and has determined
all sources are located within 50 miles of tribal lands.

Items 1.8 through 1.10 are self-explanatory.

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If an agent or contractor operates the source (facility), please fill in item 1.11.

Item 1.12, the responsible official, is defined in Regulation XIV, Rule 1401. The respon-
sible official must sign the application and attachments where noted. This person is
responsible for all statements in the application.

Items 1.13 and 1.15 are self-explanatory.

Item 1.14, Application Contact, is the name of the contact person for this application.

Items 1.16 requires description of processes and products at the facility. Include process
flow diagrams if necessary for clarity.

The Federal Risk Management Plan referred to in Item 1.17 is a plan that must be filed by
facilities that store certain amounts of certain hazardous compounds. The compounds and
amounts are listed in Part 68 of Section 40 of the Code of Federal Regulations (CFR).

These facilities will be required to have a risk management plan that is registered with the
appropriate agency. The District will not review the plan, but the existence of a RMP will
have to be documented in the application and permit. Applications submitted before the
requirements are final will be accepted without verification that RMPs are registered with
appropriate agencies.

Item II requires the type of permit action: This application form will be used for initial
applications and subsequent modifications. Please check the type of application or permit
action.

Item III requires description of the permit action. The appropriate items should be
checked.

The applicant should list all supplemental attachments submitted with this application under
Item IV. The District forms themselves are not considered attachments but any attachments
to the forms must be listed. Attach an additional sheet if necessary.

Form 1401-A2 Stationary Source Emissions

If an applicant stipulates that it is a major source and subject to specific applicable
requirements, it need not provide additional information in its application to demonstrate
applicability with respect to those requirements. No emission information is required if the
applicant stipulates the facility is a major source. No emission information is required if
the applicant stipulates the facility is subject to specific applicable requirements.

Please check the major source threshold emissions which apply for the facility.

There is space allotted to reference emission inventory submittals to the District.

Reference the inventory by name and the inventory year.

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Note: The applicant only needs to submit annual potential emissions data if the facility is
new and there is no facility emissions inventory on file with the District. If this is the case
the applicant should check the box indicating emissions calculations have been provided
and attach them to the application.

Form 1401 -G Insignificant Activity List

Use this form as a checklist for all insignificant activities included in Regulation XIV,
Appendix A based on size or production rate. Regulation XIV, Appendix A, has the
required criteria to make this determination. Checking activities identified at the facility is
all that is required.

Any activity which is subject to an applicable requirement other than District Rules 50 and
51 cannot be considered an insignificant activity and must not be included in this listing.

Form 1401-H1 Applicable Requirements Summary Check List

This form is intended to list requirements. Applicable requirements which apply to an
entire facility are listed first. The applicant should fill in equipment categories at the top of
a column as needed. The applicant should then check appropriate boxes for applicable
requirements on the form and attach emission unit permit number lists for specific
equipment categories where necessary. Each column heading represents an equipment
category with a unique set of applicable requirements and the applicant needs to provide a
list of the permits for each of the equipment categories specified. The column "Future
Effective Date" should also be completed. Where streamlining is employed note on this
form and complete Form 1401-0 [Multiple Applicable Requirements Streamlining], Form
1401-P [Outdated SIP Requirement Streamlining], and Form 1401-Q [Permit Shield], as
needed. An example completed form for some specific equipment categories is available
from the District.

The applicant is encouraged to make use of application streamlining processes for
applicable requirements in completing this form. Not all the processes listed may be
applicable to a specific facility. Examples of streamlining are included in the appendix to
these instructions. The application streamlining processes are:

A. Multiple Applicable Requirements

The applicant can propose to combine multiple requirements. An applicant proposing to
streamline multiple requirements applicable to the facility or emission unit must take the
following actions to combine multiple requirements:

Step One - Provide a side-by-side comparison of all requirements that are currently

applicable and effective for the specific emissions units of a source. Distinguish

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between requirements which are emission and/or work practice standards, and
monitoring and compliance provisions.

Step Two - Determine the most stringent emission and/or performance standard (or any
hybrid or alternative limits as appropriate) consistent with the streamlining
principles and provide the corresponding supporting documentation relied upon to
make this determination. This process should be repeated for each emissions unit
and each pollutant combination subject to multiple applicable requirements for
which the applicant is proposing a streamlined requirement.

Step Three - Propose one set of permit terms and conditions (i.e., the streamlined

requirements) to include the most stringent emission limitations and/or standards,
appropriate monitoring and associated recordkeeping and reporting, and such other
conditions as are necessary to assure compliance with applicable requirements.

Step Four - The applicant must certify compliance with applicable requirements. If a
source is certifying compliance only with the streamlined limit this should be
indicated in an attachment to the certification, so that it is clear that the certification
is being made with respect to a set of terms and conditions that the source believes
"assure compliance" with all applicable requirements . In any event, a source may
only certify compliance with a streamlined limit if there is information on which to
base such a certification.

Step Five - Develop a compliance schedule (Form 1401-L) to implement any new

monitoring/ compliance approach relevant to the streamlined limit if the source is
unable to comply with it, upon permit issuance. The monitoring, recordkeeping, and
reporting requirements of the applicable requirements being subsumed continue to
apply in the permit until the new streamlined compliance approach is operative.

Step Six - Indicate on the application forms (Forms 1401-0 and 1401-Q) that streamlining
of the listed applicable requirements under a permit shield is being proposed and
propose that a permit shield would be in effect stating that compliance with the
streamlined limit assure compliance with the listed applicable requirements. All
emission and/or performance standards not subsumed by the streamlined
requirements must be separately addressed in the Title V permit application.

The applicant must demonstrate the adequacy of the proposed streamlined requirements

guided by the following principles:

a. The most stringent of applicable emissions limitations for a specific regulated air
pollutant on a particular emission unit must be determined taking into account:

• Emission limitation formats (emission limits in different forms must be
converted to a common format and/or units of measure or a correlation
established among different formats prior to comparisons);

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Averaging times; and

Test methods prescribed in the applicable requirement.

b.	Work practice requirements in streamlining procedures will be treated as follows:

A work practice requirement directly supporting an emission limit (i.e., apply-
ing to the same emissions covered by the emission limit) shall be considered
inseparable from the emission limit for the purposes of streamlining emission
limits. The proposed streamlined emission limit must include its directly
associated supporting work practices, but need not include any work practice
standards that are associated with and directly support the subsumed limit(s);

Where two or more analogous work practice requirements apply to the same
emissions or emission point(s) but do not directly support an emission limit,
they may be streamlined, as can multiple emission limits for the same emissions
or emission point(s) (e.g., different leak detection and repair programs);

When multiple work practice requirements apply to different emissions or
emission points, the multiple work practice requirements cannot be streamlined.

c.	Monitoring, recordkeeping, and reporting requirements should not be used to
determine the relative stringency of the applicable requirements to which they are
applicable.

d.	Facilities, where the preceding guidance does not allow sufficient streamlining, may
at their option perform the following to justify additional or different streamlining:

Construct an alternative or hybrid emission limit that is at least as stringent or
more stringent as any applicable requirement, where it is difficult to determine a
single most stringent applicable emissions limit by comparing all the applicable
emission limits with each other;

Use a "State-only or District-only" requirement as the streamlined requirement
(except that this streamlining is not allowed for a proposed District MACT
standard) when it is more stringent than any applicable Federal requirement (the
State-only or District-only requirement would then become federally
enforceable in the Title V permit);

Use a more accurate and precise test method than the one applicable (except that
this streamlining is not allowed for a proposed District MACT standard) to
eliminate doubt in the stringency determination; and

Conduct detailed correlations to prove the relative stringency of each applicable
requirement.

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e. The monitoring, recordkeeping, and reporting requirements associated with the most
stringent emission requirement are presumed appropriate, unless reliance on that
monitoring would diminish the ability to assure compliance with the streamlined
requirements. To evaluate this presumption, compare whether the monitoring
proposed would assure compliance with the streamlined limit to the same degree of
confidence as would the monitoring applicable to each subsumed limit. If not, and if
the monitoring associated with the subsumed limit is also relevant to and technically
feasible for the streamlined limit, then monitoring associated with the subsumed limit
(or other qualifying monitoring) would be included in the permit. The recordkeeping
and reporting associated with the selected monitoring approach may be presumed to
be relevant only to the monitoring with which it is associated.

B. Outdated SIP Requirements

An applicant proposing to submit its Title V permit application based on a District rule that
has been submitted for EPA approval rather than the current SIP version may take one of
two courses of actions to streamline the application:

The first type of action is appropriate for District rules that (1) have been previously
demonstrated to EPA's satisfaction to be at least as stringent as the approved SIP rule so as
to assure compliance with it for all subject sources or (2) have been specifically identified in
a formal agreement between the District and EPA for expeditious SIP processing. The latter
category typically involves District rules pending SIP approval which do or could represent
full or partial relaxations of the current SIP. The District and EPA have an up-to-date list of
District rules which meet either of these criteria.

In preparing initial Title V permit applications with respect to such District rules:

Step One - The applicant must list or cross reference in its application all requirements
from District rules which are eligible for this approach and refer to the list
established and maintained for this purpose by the District.

Step Two - The applicant must identify in the permit application the current SIP
requirements that the pending SIP revision would replace.

Step Three - The applicant may choose to certify compliance with all the requirement(s) of
the local rule in lieu of the current SIP if there is sufficient information on which to
base such a certification.

Step Four - The applicant may propose that a permit shield would be in effect upon permit
issuance. For those listed District rules which are recognized by EPA as being able
to assure compliance with the current SIP rule, the applicant would indicate in the
application that a permit shield is being proposed to be incorporated into the permit
to confirm this understanding. The permit shield request should be noted in Form
1401-Q [Permit Shield],

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The second type of action is appropriate where a District rule has not been demonstrated to
EPA's satisfaction to assure compliance with the existing SIP or has not been included in
the formal agreement as described above. An applicant may still propose to base its initial
Title V application on other District rules pending SIP approval, provided it can show that
compliance with the District rule would assure compliance with the current SIP (i.e., make
an adequate demonstration consistent with the demonstration of the adequacy of the
proposed streamlined requirements detailed under streamlining multiple requirements
above in section A).

Step One - The applicant must list in its application both the applicable requirement of the
current SIP and of the District rule and indicate that it has opted for streamlining
approach. The applicant must develop and submit with its application sufficient
documentation that demonstrates the District rule assures compliance with the
applicable SIP. Guidance that sets forth the necessary elements and guiding
principles are detailed above in Section A.

Step Two - The applicant may choose to certify compliance with the proposed require-
ments of the District rule if there is sufficient information on which to base such a
certification.

Step Three - The applicant may propose a permit shield or similar permit language which
would confirm that compliance with the District rule assures compliance with the
relevant requirements of the current SIP.

The applicant should note streamlining of this type in Form 1401-P [Outdated SIP
Requirement Streamlining],

C. Generic Requirements

The requirement to identify all applicable requirements, including those for insignificant
emission units, can be addressed by standard or generic permit conditions with minimal or
no reference to any specific emissions unit or activity. Different generic permit tables may
be necessary to cover the situation of a particular type of insignificant emission unit which
is governed by different applicable requirements (e.g., one to cover units subject to the SIP
and one to cover units also subject to NSR).

If the source is operating out of compliance with an applicable requirement, please use the
Schedule of Compliance form (Form 1401-N) to submit a proposal for achieving
compliance. If the facility is operating under an abatement order, judicial consent decree, or
administration order, please include the details in the Schedule of Compliance form.

The applicant needs to attach emissions information to this form for some specific requests.
The applicant needs to supply the facility-wide annual emissions when the level of emission
of a pollutant is to be used by the District in granting a shield relative to a decision of non-
applicability where a source is claiming an exemption based on an emissions level cutoff in
a standard that has been issued for the category to which the emissions unit potentially

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belongs. The emissions of a pollutant must also be provided if there is a Plantwide
Allowable Limit (PAL) or other plantwide emissions limit proposed for the Title V permit.

Form 1401-H2 List of Permits by Equipment Category

The applicant must list the permitted emission units on the form by equipment category for
equipment categories listed on the Applicable Requirements Summary Check List [Form
1401-H1], List the equipment category in the same order as Form 1401-H1 along with the
associated emission units by permit number (or application numbers where applicable).
Mark under the column "status" whether the emission unit is "O", operational, "N", non-
operational, or "S", new equipment without a permit operating under startup authorization
(only to be used with an application number).

Form 1401-1 Certification Statement

Check the boxes in front of the statements that are true for your facility and have the
responsible official sign the certification statement.

Form 1401 -K Compliance Certification Schedule

Compliance certifications must be submitted to the District periodically. This schedule
shows how often this certification must be submitted for each emission unit and applicable
requirement. For example, a facility may have a source for which monitoring data is
required every month. The default frequency, in the absence of other requirements, is once
per year. If an emission unit is not explicitly listed the default frequency is assumed. The
rule reference should be listed under the heading "Applicable Requirements".

A compliance certification is a certification by the responsible official that a source or
facility is in compliance with an applicable requirement. Reports of recordkeeping or
monitoring may be required to be submitted with the certification if so stated in the
underlying requirement.

The Applicable Requirement Summary Check List and the Certification Statement Forms
will be used for these certifications.

Form 1401 -M Abatement Devices

Please list the permit number for the equipment associated with the abatement device, the
abatement device description, and the sources or operations abated by the device.
Abatement devices should be listed which are associated with processes subject to
applicable requirements such as a scrubber or thermal oxidizer installed on a process to
meet a RACT rule or NSPS requirement or which are separately subject to applicable
requirements such as a RACT rule or NSPS requirement. Some equipment should not be
listed as abatement devices on this form. Some examples are a mist eliminator installed on
a tank containing water to eliminate, for safety purposes, water droplets generated or a
muffler on a lawn mower which abates noise but also reduces particulate matter emission.
Control equipment installed on insignificant activities such as welding operations should

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not be listed. Measures such as low NOx burners, injection timing retard, and the use of
high volume low pressure coating application equipment should also not be listed.

Form 1401 -L Schedule of Compliance

For each non-complying source, describe how the emission unit will achieve compliance.
Propose a schedule to correct the deficiencies. Include a schedule for progress reports.
Reports must be submitted at least every six months. If the source is operating under a
judicial consent decree or administrative order, the Schedule of Compliance must be at
least as stringent. The rule reference should be listed under the heading "Applicable
Requirements". Please enter the attachment identifier, e.g., Attachment A, under the
heading "Compliance Schedule Attachment". Please attach any associated Hearing Board
Order. The attachments should be numbered, LI, L2, etc.

Form 1401 -N Alternative Operating Scenarios

This form can be used by facilities that wish to describe alternative operating scenarios. If
desired, an alternate operating scenario with the maximum allowable throughput can be
described for the District's review. Examples of alternative operating scenarios are
included in the appendix to these instructions.

Form 1401 -O Multiple Applicable Requirements Streamlining

ments. The applicant should list the multiple applicable requirements and identify the
streamlined requirement. The detailed analysis including the permit shield proposed for
the streamlining should be attached. The process for streamlining multiple applicable
requirements includes proposing a permit shield. The process by which a facility would
determine a streamlined requirement and identify requirements to be considered under a
permit shield are discussed under the instruction for Form 1401-H. The detailed analyses
should be referenced on this form and numbered as Attachment 01, 02, etc. Examples of
streamlining are included in the appendix to these instructions.

Form 1401-P Outdated SIP Requirement Streamlining

This form can be used by facilities that wish to submit a Title V permit application based
on more recently adopted District rule requirements rather than the current SIP rule. The
applicant should list the outdated SIP rule and identify the current District rule and include
the District rule revision date. The applicant should indicate if a permit shield is proposed.
The detailed analysis including any permit shield proposed should be attached. The
detailed analyses should be referenced on this form and numbered as Attachment PI, P2,
etc.

Form1401-Q Permit Shield

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This form must be used by facilities that are requesting a permit shield. Identify the
emission unit(s), the requirements to be shielded and the basis for the shield. If the basis
for the shield doesn't fit in the space provided attach an additional sheet. These additional
sheets should be referenced on this form and numbered as Attachment Ql, Q2, etc.

8.2 Instructions for Title V Engineering Evaluation Process (revised
3/2014)

INTRODUCTION

For any action requiring a Title V permit application, given the District's permitting
structure, a District application will be required and therefore is expected to precede the
Title V application. Permit engineering staff should be vigilant for the receipt of a District
application from a Title V source. Upon such receipt, the project engineer must notify the
Title V engineer with the objective of discussing the nature of the project and determining
Title V requirements and, most importantly, into which Title V track it falls. The following
table lists District Title V permits, including those for which applications have been
received, but have yet to be issued.

Facilities With Issued Title V Permits

Permit Record#

Title V Facility Name

TVP-00037

Orange Grove Energy, L.P.

TVP-00036

El Cajon Energy LLC

TVP-00032

Fleet Readiness Center Southeast

TVP-00031

SFPP, LP

TVP-00030

SD City of Metro Wastewater Biosolids Center

TVP-00029

Otay Landfill Gas LLC

PTO-974746

Neo San Diego LLC

PTO-960391

Applied Energy LLC

PTO-960383

Fleet Readiness Center Southwest

PTO-960380

USN Air Station NORIS

PTO-971535

Minnesota Methane LLC Miramar

PTO-975482

Minnesota Methane San Diego LLC North City

PTO-979681

SDG&E Cuyamaca Peak Energy Plant

PTO-960991

Solar Turbines Inc.

PTO-978119

Chula Vista Energy Center LLC

PTO-978478

Escondido Energy Center LLC

PTO-960998

Applied Energy LLC MCRD

PTO-978585

Calpeak Power Border LLC

PTO-971227

Otay Landfill, Inc.

PTO-978586

Calpeak Power Border LLC

PTO-974488

Cabrillo Power 1 LLC

PTO-961008

SD City of Metro Wastewater Department

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PTO-960992

General Dynamics NASSCO

PTO-984123

SDG&E Miramar

PTO-978248

Wildflower Energy LP / Larkspur

PTO-961006

City of San Diego / Env Svc Dept / Miramar LF

PTO-961005

SD Co of Pub Wks San Marcos LF

PTO-971226

Sycamore Landfill Inc.

Faci

ities With Pending Title V Applications

APP-002026

Otay Landfill Gas, LLC (Toro Energy)

APP-001247

Otay Mesa Energy Center

APP-002924

Sycamore Energy

Each application for an initial Title V permit must be submitted with a onetime non-
refundable processing fee of $$95 and a deposit based on an estimation of the cost of the
permit work (the current default for initial permits) is $20,000 which has shown to be
reasonably representative of typical initial Title V permits in accordance with District Rule
40. Fees for permit renewals, revisions and other changes should be estimated on a case-
by-case basis. Fee estimates for Title V renewals have historically fallen in the range of
$8,500 - 9,000, and this estimate range appears reasonable for covering most renewals.

The following forms are required for each initial Title V permit application. These forms
and their completion are discussed on the District's website:

Stationary Source Summary [Forms 1401-A1 and 1401-A2]

Insignificant Activity List [Form 1401-G]

Applicable Requirements Summary Check List [Form 1401-H1]

List of Permits by Equipment Category [Form 1401-H2]

Certification Statement [Form 1401-1]

Compliance Certification Schedule [Form 1401-K]

Abatement Devices [Form 1401-M]

The following form may also be required:

Schedule of Compliance [Form 1401-L]

The following forms are optional:

Alternative Operating Scenario [Form 1401-N]

Multiple Applicable Requirements Streamlining [Form 1401-O]

Outdated SIP Requirement Streamlining [Form 1401-P]

Permit Shield [Form 1401-Q]

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EPA requires submittal of "information related to emissions sufficient to verify which
requirements are applicable to the source" and the calculations which form the basis for
this information. Generally, this means that facilities should submit emission unit-specific
forms for each source. However, the District has already gathered most of the necessary
information to calculate these emissions. EPA application streamlining guidance allows
the applicant to reference the calculations of emissions for permitted emission units.
Emission information is only required when the District would need to verify emissions
levels and monitoring approaches for the following:

1.	The facility proposes Plantwide Applicability Limits (PALs) or other plantwide
emissions limits; or

2.	The facility claims an exemption from an emissions-based applicable requirement for
a single emission unit or multiple emission units and expects a permit shield to be
granted by the District from this otherwise applicable requirement.

To avoid duplication of data, the applicant should only submit emission unit-specific forms
where there is more recent data that differs from data previously submitted to the District.

An applicant submitting information claimed to be "Trade Secret" must provide written
justification pursuant to District Rule 176.

8.3 Title V Permit Changes and Modifications
Operational Flexibility or Section 502(b)(10) Change

Under Section 502(b)(10) of the CAA, codified at 40 CFR § 70.4 (b)(12), certain changes
qualify as "operational flexibility." These are operational changes that do not require a
modification of the Title V permit.

A Section 502(b)(10) change cannot include any of the following categories:

1.	A change that would contravene an existing federally enforceable
monitoring, (including test methods) record keeping, reporting or
compliance certification permit condition. If the change necessitates changing
an existing permit condition for monitoring, record keeping, reporting, testing, or
compliance certification, then it cannot qualify as a 502(b)(10) change.

2.	Exceedance of an allowable emission limit in a permit. If the Title V permit
has an emissions cap for one or more pollutants on the entire facility or on part of
the facility, and the change would result in emissions above that cap (and
therefore necessitate an increase in the cap), it cannot be a 502(b)(10)

change. Also if a source has a specific expressed emission limit (i.e., mass per
unit time such as lb/hr or concentration such as gr/dscf) and that emission limit
must be increased due to the change, it also cannot be a 502(b)(10) change.

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A Section 502(b)(10) change only requires that the applicant file Form 1410-C for the
change along with the standard District general application form (Appl 16)and
supplemental application form (if necessary). The engineer receives a copy of the entire
application from permit processing. An applicant must provide EPA seven days notice
before making a Section 502(b)(10) change. More importantly, an applicant must first
obtain any necessary District Authority to Construct or revision to an existing Permit to
Operate before making such a change.

The project engineer, in reviewing the application for completeness, should note that the
applicant has requested a Section 502(b)(10) change. The project engineer should also
note if the applicant has requested an affirmative determination that the District agrees
the change is a Section 502(b)(10) change. Historically, requests for affirmative
determination are rare because they delay the applicant's ability to proceed. The engineer
should engage the applicant directly as a start if there is a question whether the proposed
change qualifies as operational flexibility or is actually another type of change under
Title V.

No Affirmative Determination Requested

Provided the applicant has not requested an affirmative District determination that the
change is a Section 502(b)(10) change, the project engineer follows the standard District
procedure to process the permit.

Affirmative Determination Requested

If, however, the applicant has requested an affirmative District determination, the project
engineer should consult with the Title V engineer (or Senior Engineer) to find out if the
District agrees that the change is a section 502(b)(10) change. In the case where the
District agrees with the applicant, the project engineer follows the standard District
procedure to process the application. If the District determines the change does not
qualify as operational flexibility, the engineer will notify the applicant about the
determination and the applicant will need to request that the change be processed under a
different modification track. If this should occur, the project engineer will need to follow
the instructions for the appropriate Title V modification track listed below.

Because District permitting requirements are often more stringent that federal
requirements, a District AJC or revised District P/O is often required prior to an
operational flexibility change under the CAA. Because it may result in an additional P/O
or revised P/O, and the District has an interest in mirroring District permit conditions
with those in the Title V permit, most op-flex changes are made at the time of the District
permitting process. However, the provision under Section 502(b)(10) allow changes that
qualify to be incorporated at the time of the next Title V permit action such as a renewal,
modification or administrative amendment.

Administrative Permit Amendment

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An administrative permit amendment is a change to the terms and conditions of a permit
that are approved pursuant to Rule 1410(i) and 40 CFR § 70.7(d). Types of changes that
qualify for administrative permit amendments include address changes, corrections to
typographical errors, changes of ownership and incorporation of NSR or PSD permits
issued according the enhanced authority to construct procedures specified in Rule
1410(q). The enhanced authority to construct, which is discussed in more detail in the
following section, fulfills substantive and administrative requirements under Title V, but
does so during the District's construction review. Because these requirements are
accomplished during construction review, the Title V change can be processed
subsequently as an administrative amendment, whereas normally it would require
additional work under another type of Title V change (minor or significant modification),
and may require public notification.

The administrative permit amendment requires only that the applicant file Form 1410-A
for the amendment, along with the standard District general application form (App 116)
and any supplemental application forms.

Enhanced Authority to Construct

Pursuant to District Rule 1410(q), and at the request of the applicant, Tthe Enhanced
Authority to Construct process allows for public comment and EPA review of a project
before installation. Because the procedural requirements of Title V are satisfied during
the A/C process the permit modification can be incorporated into the Title V permit once
the project is installed by the Title V administrative permit amendment process, without
further public notice. The steps detailed will be limited to the enhanced A/C process.

To file for Enhanced Authority to Construct, the applicant submits Form 1410-E along
with the standard District general application form (App 116) and any supplemental
application forms and, if necessary, additional Title V permit application forms for
compliance schedule, compliance assurance monitoring (under 40 CFR § 64, if
applicable), SIP gap streamlining, alternative operating scenario, etc.

The processing steps are:

•	The project engineer informs the Title V engineer that the applicant has requested
an enhanced process for issuing the A/C

•	The project engineer coordinates with the Title V engineer in developing the A/C
conditions.

•	The Title V engineer or Senior Engineer will ask the project engineer to include
an underlying rule reference for each condition and this must be reviewed by the
Title V engineer or Senior Engineer.

Note: Because EPA and the public review the proposed A/C conditions as
potential operating conditions, the project engineer and Title V engineer should
incorporate the operating conditions into the A/C (this is usually the case, but here

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it becomes particularly important that the conditions appear as they will in the
Title V permit). Any changes to these conditions will require an additional
modification procedure and potentially require a separate public notice and
another EPA review, which would largely eliminate the utility of the enhanced
A/C process.

•	The project engineer must include a condition requiring submittal of an initial
compliance certification as follows:

"The permittee shall submit to the District and to the federal EPA an
annual compliance certification for the modified equipment, in a manner
or form approved in writing by the District, for the previous calendar year
that includes the identification of each applicable term or condition of the
final permit for which the compliance status is being certified, the current
compliance status and whether the modified equipment was in continuous
or intermittent compliance during the certification period, identification of
the applicable permitted method used to determine compliance during the
certification period, and any other information required by the District to
determine the compliance status. The annual compliance certification for
each calendar year shall be submitted no later than March 1 following
each calendar year."

•	The engineer will send a draft copy to the facility for review and comment.

•	Under the enhanced A/C process, the applicant is not allowed to operate prior
to inspection and issuance of temporary authorization under Rule 1410(b)(2)
to operate. [Rule 24 does not apply and is supplanted by Rule 1410 for the
enhanced A/C process.]

•	Once the draft A/C is prepared by the project engineer, a 30-day notice is
prepared and sent to affected states. This includes Indian tribes, such as Pala,
that have requested and received EPA's agreement as to this designation. As
of April 2013, the District has extended its distribution to all tribes in San
Diego County via an email list.

•	The project engineer also prepares for EPA Region IX a cover letter that
details the project and transmits the proposed A/C for EPA's 45-day review.

•	If comments are received, responses to these comments are prepared and for
review by the Title V engineer or Senior Engineer. Should any comments
require substantive changes in the terms of the A/C, these changes will be
sent to EPA Region IX. The submittal of changes restarts EPA's 45-day
review period.

•	If EPA objects to any terms of the A/C, the Title V engineer or Senior
Engineer works with EPA to resolve the issues that EPA raises as objections
to the proposed A/C.

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• If EPA does not object, under the request of an administrative permit
amendment for the AJC conditions to be added to the Title V permit, the
project engineer prepares a BEC request for all conditions that includes the
condition rule references and adds, for the federal/local designation.

Once all issues are resolved, the equipment is ready for operation, and there is a
reasonable expectation that the equipment will operate in compliance with all
conditions and requirements, the project engineer can proceed to prepare a permit for
the Title V engineer.

Note: As indicated above the permit must contain unchanged conditions from the
A/C. The project engineer will inspect the equipment/operation and the Title V
engineer will issue a revised Title V permit (usually under a request for an
administrative amendment). If however, there is source testing or other testing that
needs to be completed (what would commonly be referred to as "shakedown and
testing"), the Title V engineer or Senior Engineer should issue written authorization
under Rule 1410(b)(2) until testing can be completed and results confirming
compliance with all applicable requirements are obtained. Changes that are deemed
necessary through the results of testing or from operating experience must be added
by going through an additional, separate Title V permit modification procedure.

Minor Permit Modification

A minor permit modification is a modification issued pursuant to Rule 1410(j) and 40
CFR § 70.7(e)(2) that will not trigger federally-mandated new source review.

Applicant applies with Form 1410-B along with the standard District general application
form (App 116) and any supplemental application form(s). The project engineer should
coordinate with the Title V engineer once it's determined that the applicant has
requested a minor permit modification. The application should contain the proposed
permit conditions.

Within 5 days of determining the application complete, the project engineer must notify
EPA Region IX and affected states of the receipt of a complete application, describing
the application. No other extra processing steps are required at this time. The applicant
must first obtain any necessary District AC. The project engineer should coordinate the
AC and conditions with the Title V engineer.

The object of the minor permit modification is to allow operation of modified equipment
under a new set of conditions. Therefore, there are only extra processing steps for the
project engineer for Title V prior to issuing the District permit to operate. The process is
as follows:

• The project engineer develops the final set of conditions and includes a rule
reference.

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•	The Title V engineer reviews the condition list, and prepares a cover letter and
the Title V application review summary (this can take the form of an abbreviated
Statement of Basis) that details the minor permit modification. The proposed
permit is attached and sent for EPA's 45-day review period.

•	If EPA has no objection, the project engineer prepares a BEC request for all
conditions that includes the condition rule references .

Significant Permit Modification

A significant permit modification is a modification that does not qualify as a minor
modification or that will trigger federally-mandated new source review. Significant
modifications are processed pursuant to Rule 1410(k) and are required to include an
opportunity for public review and comment as well as review by the federal EPA and
affected states.

The applicant applies for a significant permit modification by completing and submitting,
at a minimum, the following forms:

•	Stationary Source Summary [Forms 1401-A1 and 1401-A2]

•	Applicable Requirements Summary Check List [Form 1401-H1]

•	List of Permits by Equipment Category [Form 1401-H2]

•	Certification Statement [Form 1401-1]

Aside from these required forms, the applicant may request other Title V program options
such as, multiple applicable requirements streamlining or a permit shield, so that other
supplemental Title V application forms may also be submitted. The applicant must first
obtain any necessary District A/Cs. The project engineer should coordinate the AJC and
conditions with the Title V engineer.

The Title V engineer performs the following tasks after receipt of the Title V
application:

•	Application completeness determination within 60 days of receipt

•	If further information is required to determine completeness communicate any
deficiencies to the applicant prior to completeness determination. If the source
supplies the additional information promptly, the Title V engineer proceeds
toward determination of completeness. If the information is not forthcoming after
informal request, the engineer notifies the applicant in writing requesting (and
specifying) the additional required information, allowing approximately 60 days
for the applicant to provide the requested information.

•	Once the information is received from the applicant, the Title V engineer
completes evaluation of the application and prepares the permit documents for
public and EPA review.

•	Denial or cancellation of an application based on failure to receive the required
information from the applicant may, on occasion, be justified but is rare and must
only be initiated with the approval of the responsible senior engineer and/or the
Chief of Engineering.

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The project engineer should inform the Title V engineer about the project, and the two
engineers should discuss any issues associated with processing the two applications
(timing issues, questions of which Title V track is appropriate, Title V issues that affect
the District permit, etc.) . The objective is to ensure that the permit conditions for the
District P/O are the same in the subsequently issued Title V permit, and to ensure, as the
District P/O is being developed, that Title V requirements are included as necessary (for
example, when they are not included in the "FW" section of the Title V permit).

After the proposed permit conditions for the District P/O have been prepared, the Title V
engineer continues developing the proposed Title V permit. Ideally, the District P/O
will be finalized with its issuance pending before the proposed Title V permit is prepared
for public notice and EPA review, and communication between the project engineer and
the Title V engineer will have ensured all requirements are met and the Title V conditions
match the District P/O conditions. In the interest of matching the District P/O with that
contained in Title V permit, issuance of the District P/O may be held until completion of
the public comment period and EPA review. However, given that such comments are
infrequent, the District P/O is typically issued once all other procedures are complete.

When the project engineer has finalized the District P/O for issuance and the text of the
conditions is determined, the following should be performed:

•	The Title V engineer prepares conditions with rule references under the Title V
application and arranges each as either "District Enforceable Only Conditions" or
"Federally Enforceable and District Enforceable Conditions" .

•	The Title V engineer prepares a 30-day public notice to be submitted internally
for posting in local publications, on the District's website, and for distribution
pursuant to the County's list-server. (As of 2013, we are also distributing all
public notices of Title V actions to San Diego tribes via email.)

•	The Title V engineer prepares the Title V statement of basis (i.e., review report).
The public notice, permit, and statement of basis are sent to EPA and affected
states for review ;these documents also comprise the substance of the public
notice.

•	If EPA has no objections (and either no comments were received from the
public or any comments received were resolved before EPA's final review),
then appropriate revisions can be made to the statement of basis and the
revised permit can be issued. The project engineer likewise proceeds toward
issuance of the District P/O and submittal of a BEC as necessary .

•	The project engineer will inspect the equipment/operation and the Title V
engineer will issue a revised Title V permit.

•

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8.4 Title V Program Evaluation Program Changes (Tom Weeks,
November 2010)

In mid 2008, the EPA Region IX conducted an evaluation of the District's Title V program.
The findings and recommendations of that evaluation are included in a report titled "Title

V	Operating Permit Program Evaluation Final Report, September 30, 2008."

The objectives of the evaluation were to assess how the District administers its Title V
program and the overall effectiveness of the program; identify areas of improvement of the
program; areas where EPA's oversight role can be improved; and identify unique and
innovative aspects of the District's program as best practices that may benefit other Title

V	programs. To a large extent, EPA was complementary of the District program and
procedures. However, there were several areas where they recommended program
changes.

EPA's findings and recommendations as well as the District's agreed upon actions are
listed below. These program changes should be incorporated, to the extent feasible, in all
future TIV permit actions.

1.	Finding: Final Title V permits are not signed.

Recommendation: EPA recommends that all final Title V permits (initial
permits, renewals, and modifications) be signed by a District official authorized
to make permit decisions.

Action: The District Director will sign all final Title V permits.

2.	Finding: SDAPCD's statements of basis do not adequately describe regulatory
and policy issues or document decisions the District has made in the permitting
process.

Recommendation: SDAPCD should expand the scope of its Coversheets to
address all salient Title V permit issues. The District should supplement its
checkbox and tabular format with explanatory text. SDAPCD should review
Findings 2.7 through 2.10 of this report (and the associated recommendations),
and implement EPA guidance on statements of basis (listed in Appendix F).

Action: A revised standardized evaluation summary format will be developed
and used to provide summary and explanatory text and to document policy issues
and regulatory decisions for all future Title V permits or Title V permit renewals.

3.	Finding: SDAPCD does not address periodic monitoring in its Application
Review Coversheets.

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Recommendation: SDAPCD should add a periodic monitoring section to its
Application Review Coversheets and address monitoring on a case by case basis
in the Coversheets. The Coversheets should describe the nature and rationale for
any periodic monitoring that the District has added to the permit, or explain that
no additional monitoring has been added, either because the monitoring in the
underlying applicable requirement is sufficient to assure compliance or that the
monitoring that has been added does not depart from previously agreed-upon
levels.

Action: The District will add a periodic monitoring section to the evaluation
summary and address monitoring on a case by case basis.

4.	Finding: SDAPCD does not adequately describe its decisions to grant or deny
requests for permit shields in its Application Review Coversheets.

Recommendation: SDAPCD should expand its discussions of permit shields in
its Application Review Coversheets. The explanation should specify which type
of shield has been requested, i.e., whether the regulation applies to the source or
not. If a shield from an applicable requirement that a facility is subject to has been
granted, the Coversheet should refer the reader to the permit conditions that
incorporate the requirement. If a shield has been granted because a specific
regulation does not apply to a source, the District should explain its concurrence
with the applicant's nonapplicability determination with sufficient specificity to
justify the shield.

Action: For shields that are granted, the evaluation summary will indicate that
either the shield was granted based on a determination that the requirement was
not applicable or a determination that the requirement was subsumed by permit
condition. This information will be part of the standardized Coversheet.

5.	Finding: SDAPCD does not adequately document Compliance Assurance
Monitoring (CAM) in its Application Review Coversheets.

Recommendation: The District should address CAM in its Application Review
Coversheets with sufficient detail for the reader to understand whether or not any
emission unit at the facility is subject to CAM. When CAM does apply, SDAPCD
should summarize the facility's proposed CAM plan and state whether the
District is approving the plan or not. If the District is approving the plan but some
aspects of the CAM monitoring in the permit differ from facility's proposal, these
differences should be highlighted and explained.

Action: In the Coversheet, the District will add sufficient detail for CAM plans
required in the permit and address CAM applicability. The evaluation summary
will briefly summarize the facility's proposed CAM plan(s), if any, including the
pollutant(s) subject to CAM and the parameters monitored and note whether the

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plan is approved by the District or not. The evaluation will also address emission
units for which no CAM plan is required, but that would, a priori, appear to be
required to have a CAM plan. For such units, the evaluation will indicate the
reason no CAM plan is required (for example, the unit has a continuous emission
monitoring system consistent with 40 CFR §60.1 or its uncontrolled potential to
emit is less than the applicable major source threshold).

6.	Finding: SDAPCD does not discuss any applicability requirements or exemption
provisions in its Application Review Coversheets.

Recommendation: The District must discuss its applicability determinations in
its Coversheets in cases where additional explanation or analysis would be useful.

Action: The District will discuss applicability requirements and exemption
provisions, such as the examples noted, where additional explanation or analysis
would be useful in an added section of the evaluation summary report.
Information will be provided in sufficient detail to explain the basis of its
decisions for these applicability determinations and for exemptions.

7.	Finding: Title V permits for sources subject to CAM do not contain all the
required elements of 40 CFR Part 64.

Recommendation: SDAPCD should ensure that Title V permits for sources with
emission units subject to CAM contain all required elements of Part 64, including
parameter ranges and definitions of excursions or exceedances. To be consistent
with current Part 70 requirements, we also recommend that the District use the
updated compliance certification language in all future permits in which there are
any emission units subject to CAM.

Action: The District will ensure that Title V permits, including examples cited
by EPA, contain all the required elements of Part 64. This will include an explicit
definition of an "excursion" with respect to the CAM parameters. In addition, in
situations where the complexity of the CAM parameter ranges are not easily
incorporated in permit conditions (e.g., a complex relationship based on
operational parameters), the District will attach a document to the Title V permit
that clearly defines the CAM parameter ranges. Where it is necessary to refer to
the parameter ranges, the permit conditions will reference the attached document
in the Title V permit rather than an external document.

8.	Finding: SDAPCD does adequately not reach out to communities that have
identified environmental justice (EJ) issues with respect to permitting.

Recommendation: SDAPCD should consider the need for conducting Title V
permit-related outreach in ways consistent with the changing demographic
composition of communities near permitted sources.

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Action: The District will conduct Title V permit-related public outreach in
communities near permitted sources. The District has been extensively involved
in the EPA Region IX Barrio Logan Environmental Justice Demonstration
Project. Spanish is the second most commonly spoken language in the District. A
translated notice will be provided for action on applications for Title V facilities
if five percent or more of the residents within any census tract in the area
bordering a Title V facility are non-English speaking.

9.	Finding: The District's Office of Community Outreach and Training
primarily focuses internally on District staff training needs, not externally on Title

V	outreach to communities.

Recommendation: The District should consider balancing its community
outreach needs with its competing internal needs to ensure effective community
outreach.

Action: To enhance the outreach program and to better involve residents in Title

V	implementation decisions the District proposes to initiate the following
enhancements: For community members with computer e-mail access, a list
server system has been established. A marketing plan for promoting this system
will be developed by the end of 2009.

The local Environmental Health Coalition has a newsletter. The District will work
with them to explore including information about district programs in this
document. It is made available in English and Spanish.

This District is a department in the local county government. This gives staff the
opportunity to work with other governmental entities. Recently the District
worked with the local libraries to provide information on air issues for their
patrons. The District plans to explore using other public service locations for
posting notices and providing information brochures.

The District has developed a handout that explains the Title V process. The
District will make this document available for distribution at public outreach
activities. Public Information at the District will be exploring all opportunities to
reach out to affected communities.

10.	Finding: The District publishes notices of proposed permits in the Daily
Transcript which focuses on the business community. The Daily Transcript has a
significantly lower circulation among the general public when compared to other
newspapers of general circulation in San Diego County.

Recommendation: The District should publish its notices of proposed Title V
permits in a newspaper with a larger circulation, in addition to or instead of the
Daily Transcript, so that the greatest number of people in the County is aware of
its Title V permitting activities.

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Action: The District will publish notices of proposed Title V permits in a
newspaper of larger circulation as well as publishing notices in the Daily
Transcript.

11.	Finding: The District has never received any comments from community
members on proposed Title V permits.

Recommendation: SDAPCD should explore translations of notices and
outreach materials and publication of public notices in a newspaper of general
circulation to improve the effectiveness of the District's outreach and to provide
the public with an increased opportunity to provide input on proposed Title V
permits. (See Findings 4.1 and 4.3).

Action: The District will explore translations of notices and outreach materials
(besides publishing notices in a newspaper of greater circulation as discussed
above) to provide the public with increased opportunity to comment on
proposed Title V permits. The District will use procedures developed for the
Air Toxics Hot Spots program (as specified in District Rule 1210) to determine
when translations will be required.

12.	Finding: The District publishes public notices of proposed Title V permitting
actions on its website. However, additional information along with translations
of notices of proposed Title V permitting actions in languages other than English
would better inform the public regarding permitting actions.

Recommendation: EPA encourages SDAPCD to increase public access to the
permitting process by posting relevant Title V information on its website
including, but not limited to, proposed and final Title V permits, technical support
documents, public notices, responses to public comments, citizen petition
procedures, and general Title V information and guidance.

EPA recommends looking at websites of other permitting authorities for ideas.
For example, the website of Bay Area Air Quality Management District,
www.baaqmd.gov, includes the following Title V documents: proposed and final
permits, technical support documents, public notice documents, comments from
EPA and the public, and responses to comments.

Additionally, we strongly encourage SDAPCD to translate their notices of
proposed Title V permitting actions into languages other than English in order to
be responsive to the population in San Diego.

Action: The District will post notices, permits, supporting documents and other
associated information on its website. As noted above, staff will provide
translations of notices on a case-by-case basis.

13.	Finding: SDAPCD does not notify tribes of Title V permitting actions.

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Recommendation: SDAPCD should conduct outreach to tribes to assess their
interest in being notified of Title V permitting actions. EPA can assist the District
by providing contact information for tribes within San Diego County.

Action: The District has compiled a list of tribal contacts and will notify tribes in
the county of Title V permitting actions.

14.	Finding: SDAPCD would like EPA to provide environmental justice training.

Recommendation: EPA will provide the District with EJ training and work with
them on EJ issues identified by the District.

Action: The District is requiring staff to complete the EPA online course entitled
Environmental Justice (EJ).

15.	Finding: SDAPCD does not send synthetic minor permits to EPA for review.

Recommendation: SDAPCD should provide EPA the opportunity to review
proposed synthetic minor permits, and submit copies of the final permits.

Action: The District will in the future send proposed synthetic minor permits
issued pursuant to Rule 60.2 to EPA for informational purposes and consider any
comments by EPA. The District will also submit copies of final permits to EPA.

16.	Finding: SDAPCD uses parallel processing to streamline the issuance of
modified NSR and Title V permits. However, it is not clear that all of the parallel
processing procedural requirements are being consistently implemented.

Recommendation: SDAPCD should ensure that it follows all Title V procedural
requirements when processing enhanced NSR permitting actions. Proposed NSR
permits must be sent to EPA, ideally with a cover letter explicitly stating that the
District is using the enhanced NSR process and is applying the Regulation XIV
procedural requirements to the NSR permitting action, including submitting the
draft ATC for EPA's 45-day review. After SDAPCD has authorized the startup
of the new or modified emission unit, the District should amend the Title V permit
via an administrative amendment and send a copy to Region 9. The Title V files
should contain all relevant correspondence and documents related to enhanced
NSR actions. The District may want to review the practices of the San Joaquin
Valley Unified Air Pollution Control District, which effectively processes many
enhanced NSR actions by issuing certificates of conformity which confirm the
NSR action met the procedural requirements of Title V and submitting all
necessary documentation with EPA.

Action: The District will ensure that all Title V procedural requirements are met
with respect to enhanced NSR procedures. To accomplish this, additional training

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on existing enhanced NSR permitting procedures will be provided to staff. The
District has also added a checklist noting the dates of completion of procedure
elements.

9. Registration

9.1	Portable Engine Permitting and Registration (November 6, 2000)

Attached is a notice from ARB regarding information that should be verified when
permitting or registering portable engines. In summary, any portable engine
manufactured after January 1, 1996 must be certified by both U.S. EPA and ARB in order
to be sold or used as a portable engine in California.

As is noted in the attached, the engine must be labeled by the manufacturer with a 12-
character engine family name issued by U.S. EPA and ARB. When processing an
application for permitting or registration of a portable engine, the engineer should obtain
the make, model, serial number, year of manufacture, brake horsepower rating, and 12-
character engine family name, then verify with ARB (contact listed on the attached) that
the engine has been certified as meeting the required portable, non-road engine standards.

If it has not, the engine cannot be permitted or registered as portable.

This verification is in addition to determining compliance with all applicable District
rules. Time spent verifying the engine meets the certification standards (and evaluating
the engine for compliance) should be charged to the permit or registration application.

Fees for registration and permitting will be updated in the future to recover these costs.

9.2	Procedure for Review of Applications and Issuance of Certificates
of Registration (January 2008)

This procedure has been developed to provide guidance when issuing Rule 12 or 12.1
registrations. Two options are available to applicants as shown on the attached process
flow diagrams and the following procedure.

Option 1 - Application received electronically or via mail

1.	Application Submittal - Applicant submits the application forms (Appl 16 and the
appropriate supplemented form) with appropriate fees.

2.	Permit Processing Review - Permit Processing (PP) reviews the application to verify that
correct fees and forms were submitted, creates the permit file, logs the application into
the permit database and forwards the file to the Engineering Division (ED) after scanning
out the application. If correct forms or fees have not been submitted, PP will notify the
applicant and hold the application until sufficient fees are received to process the
application. The PP review step should be completed within one working day of receipt
of the application.

3.	Engineering Review - The ED representative will pick up the file and scan it in. The ED
representative will normally be an Engineering Technician but can be the assigned duty

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engineering as necessary to address staff availability issues. A completeness review will
be performed and an incomplete letter in the form of a standardized incomplete
letter/checklist will be issued, if necessary, within three working days of application
receipt. If the application is compete, the ED representative will perform emission
calculations, complete the engineering evaluation and draft the registration certificate.

4.	Consultation Meeting - The ED representative will contact the applicant and offer to meet
with them to review and issue the initial registration certificate. If the applicant declines
the consultation meeting, the ED representative will issue the initial registration
certificate via mail or email. Issuance of the initial registration for complete applications
shall be within 10 working days of receipt.

5.	New BEC Creation - If a new BEC is required to incorporate hours of use limitations the
ED representative will request the new BEC using a standardized BEC template and
forward the request to PP. Senior Engineer and Compliance Division approval is not
required for these limited BEC changes.

6.	Permit Database Entry - The ED representative will enter the permit information into the
permit database system and forward the file to the Senior Engineer. Permit database
entry shall be with in 30 days of application receipt.

7.	Senior Engineer Review - The Senior Engineer will review the file and approve it in the
permit database system or return it to the ED representative for revision. After approval
the Senior Engineer will forward the permit file to the Accounting Section for fee
reconciliation.

8.	Fee Reconciliation - Following fee reconciliation, the Accounting Section will forward
the file to PP.

9.	Application Cancellation - Incomplete applications for equipment subject to Rule 12 will
be cancelled if the requested information is not supplied within 90 day of such request.
Incomplete applications for equipment subject to Rule 12.1 will be cancelled if the
necessary information is not supplied within 30 day of application receipt. Proposed
cancellations must be approved by the Senior Engineer.

Option 2 - Walk-in Customer

Ja$>. Application Receipt - Applicant arrives at the front desk with and application. All

applications will first go to Permit Processing (PP) for verification that the correct forms
and fees are available. If correct forms and fees are available, PP will copy the Appl 16
form and contact the ED representative (the ED representative will normally be an
Engineering Technician but can be the assigned duty engineer as necessary to address
staff availability). If correct forms and fees are not available, PP will inform the
applicant and provide them with information on how to complete the application. PP and
the ED representative will work in parallel, where necessary from this point forward (see
process flow diagram).

2. Engineering Review - The ED representative will escort the applicant to a meeting room.
A completeness review will be performed and an incomplete letter in the form of a
standardized incomplete letter/checklist will be issued if necessary. If the application is
compete, the ED representative will perform emission calculations, complete the
engineering evaluation, issue the initial registration certificate and explain the registration
conditions to the applicant.

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3.	New BEC Creation - If a new BEC is required to incorporate hours of use limitations the
ED representative will request the new BEC using a standardized BEC template and
forward the request to PP. Senior Engineer and Compliance Division approval is not
required for these limited BEC changes.

4.	Permit Database Entry - The ED representative will enter the permit information into the
permit database system and forward the file to the Senior Engineer. Permit database
entry shall be with in 30 days of application receipt.

5.	Senior Engineer Review - The Senior Engineer will review the file and approve it in the
permit database system or return it to the ED representative for revision. After approval
the Senior Engineer will forward the permit file to the Accounting Section for fee
reconciliation.

6.	Fee Reconciliation - Following fee reconciliation, the Accounting Section will forward
the file to PP.

7.	Application Cancellation - Incomplete applications for equipment subject to Rule 12 will
be cancelled if the requested information is not supplied within 90 day of such request.
Incomplete applications for equipment subject to Rule 12.1 will be cancelled if the
necessary information is not supplied within 30 day of application receipt. Proposed
cancellations must be approved by the Senior Engineer.

10. Banking

10.1 Banking Procedures (July 22,1986)

The purpose of the following procedures is to ensure that the engineering evaluation
corresponds with the requirements of the District's banking rules. Each person assigned a
banking application first must become familiar with the latest version of the applicable
rules before proceeding with the evaluation. The procedures are similar to the approach
required for the evaluation of the A/C.

A. Application Review

1) Determine if the application is complete. Each initial application must have a
Page 1 (standard application form APCD-16) and a Page 2 banking form, both
of which must be filled out completely (see attachments). There must be a
separate application for each piece of equipment, product line, system, process
line or process that produces or performs a service independently of other
equipment, product lines, systems, process lines or processes. The separate
applications are needed to correspond with the provision of Rule 26.0(b) that
requires a separate authorization for each of the items listed above. (Note:
applications are not required for each pollutant.)

a. A second application package must be submitted for reclassifications
from Class B to Class A status.

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b. In addition, an application is required for the transfer of banked emission
reduction credits ERCs).

2)	Applications are not complete if an adequate fee deposit has not been made.
The supervising senior engineer will determine if the deposit is sufficient to
cover the "time and material" costs of the evaluation—estimated to be a
minimum of 30 hours of the project engineer's time for meetings with the
applicant, site inspections, calculations, preparing publication, report writing,
record-keeping, etc. for the first application. The supervising senior would
spend a minimum of two hours in meetings, reviewing the work, updating
records, calculating costs, etc. Each additional application submitted
concurrently with the first would require four additional hours of the project
engineer's time and 0.4 hours of additional time for the senior engineer. These
estimates are based on experience. In addition, there is a base fee and a
publication cost that must be part of the deposit.

The applicant will be notified that a refund will be made if the costs are less
than the deposit but that work will stop and additional money requested if the
deposit is depleted. The applicant also will be informed that additional
deposits may be required to respond to public comments and/or to hold a
public hearing, if needed. The initial fee estimate does not include these costs.

At the time these procedures were developed, there was no database to
estimate the "time and material" costs associated with evaluating a
reclassification from Class B to Class A status. Reclassifications should not
take as long as initial evaluations because the calculations and field
inspections probably will be completed. Until further data are obtained, the
deposit should be less than half the estimate for an initial submittal.

Rule 26.0(h) states that "...fees for an advisory opinion shall be paid..." This
applies whenever a person owning a Class B ERC wants the District to
determine whether the ERC is eligible for reclassification to Class A status
[see Rule 26.3(b)], Inform the owner of the Class B ERC that he will have to
submit a deposit before the reclassification can be discussed.

3)	According to Rule 18(a), the applicant will be notified that the application is
complete or incomplete within 30 days of the date the application was
received. (Note: The application is considered received when the requested
fee deposit has been made.) If incomplete, the applicant must be notified in
writing, what additional information is required to do the evaluation.

The project engineer will establish a tickler system for ensuring the work is
completed in a reasonable period of time. The engineer will follow up on any
request for additional information no later than three months after the initial
request for information. The engineer will cancel the application if the
applicant fails to finish any requested information within six months from the
date the request was made, as required by Rule 17(c).

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B. Application Processing

The evaluation will justify a recommendation to grant or deny an ERC and, if
granted, to justify a recommendation that either a Class A or a Class B ERC be
issued. "Justification" means relating rule requirements to the information in the
application. The evaluation report will consist of a logical discussion that can be
followed easily by anyone reviewing the evaluation. The report will document that
the following steps have been taken:

1) Determination of Whether an ERC(s) can be Issued

For initial applications only, first determine if the ERC(s) can be granted
according to Rule 26.2. The following example shows how the report should
read, assuming the application meets the requirements of Rule 26.2 after an
adequate investigation.

Application(s) No.(s)	was (were) found to be in compliance with the

requirements of Rule 26.2 Standards for Granting Banking of Emission
Reductions because:

•	(Name of applicant) was found to be in compliance with all the District
rules and regulations that are applicable to the source, the source was not
exempt from permit requirements and the applicant has kept current all
District permits applicable to the source. (The latter requirement means
that if a permit expires for failure to renew, the source is not eligible for
banking. There must be an existing active or inactive status P/O with
paid up fees in order for the source to be eligible for banking.)

•	The SIP was reviewed and it was found that the emission reductions will
be in excess of those required by the applicable SIP Control Measures or
the SIP was reviewed and there are no SIP Control Measures associated
with the emissions, if that is the case. Continue by stating that the
reductions are not now, nor will they be, required by any adopted or
proposed federal, state or District laws, rules, regulations, permits or
orders. Furthermore, there is no conflict with the District's list of SIP
Control Measures for which ERCs may not be issued. (The project
engineer should ask AR/SD for assistance when evaluating compliance
with the SIP provisions of the banking rules.)

•	The emission reductions applied for have not been used or taken under
any other provision of law.

•	There is no plan to amend the SIP in a way that would affect this
application.

•	The emission reductions occurred after July 5, 1979.

•	All the applicable requirements of the District's rules and regulations
will be met if the applicant adheres to the requirements specified on the
certificate(s), which are as follows: The emission reductions will be

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enforced by the surrender and cancellation of P/O No.(s). . . This (these)
permits were surrendered to the District on (enter date). (The
surrendered permits are to be attached to the evaluation. It is not
necessary to have the surrendered permits until it is determined that an
ERC(s) can be granted. Once this has been established, notify the
applicant that the permits for the shutdown equipment must be
surrendered within 10 working days of the date of the notification letter
or the application will be denied for failure to comply with Rule
26(a)(8). This paragraph applies only to shutdowns.

For modifications, the report should state that all the applicable
requirements of the District's rules and regulations will be met if the
applicant adheres to the following conditions added to P/O

No.(s)	. (List the conditions to be added and deleted. The

revised P/Os are to have their own BEC codes. The BECs associated
with banking are to be in the 2000 series.) Continue with the report as
follows:

•	The facility was inspected on (enter date). It was confirmed during the
inspection that the emissions reductions have been implemented as
required by Rule 26.2(a)(7).

•	Before the shutdown (or modification, if applicable), the source was in
operation for one year or more as required by Rule 26.1.

Therefore, having complied with all the requirements of Rules 26.2 and 26.1,
the applicant is entitled to receive Emission Reduction Credit(s). (If the
applicant hasn't complied, state that in the report instead. In that case, the
report would conclude with a recommendation for denial.)

C. Classification of ERCs

After determining that ERCs can be granted, document the reasons for their
classification to Class A or Class B status. For initial applications, the classification
will be done according to Rule 26.0(c) and the following section. For applications
requesting reclassifications, the determination will be made according to Rule
26.0(e) and the section on reclassification.

1) Initial applications:

For an initial application, state in the report whether the reduction is due to a
modification or limited use of existing equipment, or if it is the result of a
shutdown. State the reasons replacements are or are not likely to occur. If
they are likely to occur, state whether or not the replacements will be located
within the District and whether or not existing sources located elsewhere in
the county will increase their emissions as a result of the shutdown. (For
example, if an asphalt plant shuts down, the amount of asphalt produced in the

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county isn't going to change. The other existing plants will pick up the slack
since they can produce it cheaper than hauling additional asphalt from outside
the air basin. In this example, a Class A status can not be granted.) The
applicant must prove that replacements are not going to take place that would
offset the reductions. Rule 26.0(c) states, "The applicant has the burden to
show that an ERC is Class A rather than Class B."

Rule 26.0(c)(iv) states that possible emission increases from replacement
sources that will not likely be offset pursuant to Rules 20.4, 20.5, 20.8 or 26.8
should be considered. But this requires a knowledge of the future, which is
impossible to obtain. Therefore, this provision should be ignored.

If there are no potential replacement emissions from new, existing or modified
sources, the report should recommend that the ERC(s) be granted a Class-A
status and proceed to the "emissions reduction calculations" section of these
procedures.

If replacement emissions are possible, determine their amount (under
"emissions reduction calculations"). If the replacement emissions are less
than the reduction, document this in the evaluation and list the difference as
the amount that may be listed under Class-A reductions. This eventually will
require the issuance of two ERCs for the same equipment; one listing the
Class-A reductions and the other the Class-B credits. If the replacement
emissions are equal to or greater than the reduction, state this in the
evaluation. In the latter case, only Class-B ERCs can be issued. Specify in
the notification letter that this is one of the reasons the emissions are not
considered "real and permanent."

2) Application for reclassification:

The evaluation of reclassification will be in the form of an addendum to the
initial report. The addendum will state the reasons why the Class B status
should or should not be changed to a Class A status. The evaluation will
include the following information: (1) the length of time the equipment has
been out of service or operated at a reduced level or modified, (2) shifts in
economic demand within the District that are related to the product or service
produced by the equipment that was shutdown, modified or that was limited in
use, and (3) whether similar sources in the District have experienced an
increase in activity as a result of the shutdown, modification or curtailed use
of the equipment for which a Class B ERC was issued. The applicant is
responsible for supplying this information.

If a Class B ERC was issued for the reason that a new source was expected to
replace the reduced emissions, then that reason will be removed if an AJC for
the new source hasn't been issued within a year of the date the District entered
the ERC in the register. The applicant, according o Rule 26.0(f), must request

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that the above reason be removed. If this request is made, the search for an
AJC for the new source must be documented in the evaluation (i.e., searched
application card file, log, surveyed staff engineers, etc.).

It also must be documented in the report that the owner/operator surrendered
the certificate showing ownership of the Class B ERC.

If a reclassification is approved by the senior engineer, the project engineer
will ensure that accounting staff cancels the Class B ERC and issues a new
Class A certificate.

D.	Emissions Reduction Calculations

Calculations will be done according to Rule 26.1. The evaluation for an initial
banking application will state the period of time actual operating emissions were
averaged. The assumptions associated with each calculation will be documented as
to their source. As with all engineering calculations involving permit work, the
statement that a given number is based on "engineering judgment" with nothing
further to support that number is unacceptable. Every number and assumption will
be justified by references to test data and/or authoritative literature and/or
documented applications of engineering principles.

E.	Notification Letter

The applicant will be notified of the amounts of the emission reductions that can be
used for banking credits and given 10 working days to respond if he disagrees with
the amounts. If the District has decided to issue a Class B ERC, the notification
letter will include the reasons why the ERC is not real and permanent, in order to
comply with the last provision of Rule 26.0(c)(2).

F.	Publication

After the amounts of emission reductions for banking have been determined, the
next step is newspaper publication of a notice announcing the proposed issuance of
the ERC(s). The project engineer will submit a draft of a public notice, similar to
the example in the Appendix (which may be found following Section 3.9) and the
application, folder and evaluation to the senior engineer. After the senior engineer
has approved both the draft notice and evaluation, the project engineer will give the
District's public information officer a typed, double-spaced copy of the approved
notice and the proposed date of publication. The public information office needs to
be notified at least three working days before the expected date of publication.

The public information officer will obtain a purchase order number from
accounting. The public information officer then will call the San Diego Transcript
for a pickup. All notices must be received in the Transcript office by noon of the
day prior to the date of publication. The public information officer then will send a

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copy of the final notice and the date of publication to the deputy director in charge
of engineering and to the project engineer. The project engineer will note on his
calendar the date 30 days after the publication. This is the date when the period for
public comment ends.

The clerical section will be notified that written public comments, if any, are to be
sent to the senior engineer. If written comments are received, public hearing is
justified. If there are no comments within 30 days of publication, the project
engineer will proceed to the registration phase of these procedures.

G. Registration and Issuance of Certificate/Revised Permits to Operate
1) Registration

After the completion of the public comment period, the project engineer will
go to accounting and register each ERC. At the top of each form, the engineer
will enter the name of the company or organization owning the ERCs listed
and the address where the emissions were reduced. (A sample form is in the
Appendix following this section.) The registry forms will be organized in
alphabetical order according to ownership. A separate sheet or separate set of
sheets for each location where emissions were reduced will be completed.

Each column on the registry sheet contains the information associated with a
given certificate. The certificate number is entered at the top of the column.
This number is the same as the application number followed by a dash and a
number corresponding to the order in which the certificate was issued. For
example, 860134-1 may represent the same piece of equipment but a different
pollutant than 860134. When a reclassification occurs, the certificate is
cancelled and a new certificate is issued. The certificate number will be the
same as the previous number but followed by an "R" (i.e. 860134-1R).

"Status" is the next column. Write "active" on the first line when the ERC is
issued. When the ERC is cancelled, put a line through "active" and below it
on the second line, write "cancelled." On the third line, write "transferred" if
the cancellation was due to a transfer. When there is a partial transfer of
credits, the certificate is cancelled and a new certificate is issued listing the
reduced credits. When this occurs, write "reduced" on the third line. Write
"expired" on the second line when an ERC expires.

The rest of the column will be filled out as follows:

• For "ERC Class," enter "A" or "B." Enter the pollutant on the next
line. Enter the amount of the reduction in lbs./day and tons/year. The
"day of issuance" is the date the registry is filled out and the certificate
mailed. On the next line, enter the P/O number regardless of whether
or not the P/O was cancelled.

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• For "type of equipment," enter "boiler," "turbine," "cogen," etc. to
designate the equipment associated with the reductions. Enter the
make or model of the equipment on the next line. List the serial
number of the equipment if it is available. If not, use any available
equipment designation (i.e. "unit 1," "process line No. 2," etc.). When
an ERC is granted for a limited time period, enter the duration. Also
enter the expiration date. If there is no time limit, enter "none" in the
spaces labeled "ERC duration" and "date expired." When an ERC is
transferred, enter the date, the amount in tons/year and the name of the
organization receiving the ERC.

The person filling out the form will sign his name under the heading "person
entering data" and write the date of entry under the heading "entry date."

2) Issuance of the ERC Certificate and, if Applicable, Re-issuance or
Cancellation of the Associated P/O

After the ERCs are registered, the project engineer will fill in the blanks of
draft certificate of ownership forms using pencil. (See Appendix following
this section for sample form.) The certificate number is entered at the top of
the form. The "owner" is the DBA of the company or organization that owns
the ERC. For "source location," enter the location where the reductions took
place. This information is needed to determine the distance of the offset from
the new source. The "date the application for ERC was received by District"
is the date the initial fee deposit was recorded on the application. "Equipment
permit to operate No." and "pollutant" are self explanatory. The "I.D. No." is
the one identifying the site where the reductions occurred. The "transfer date"
is left blank until the certificate is returned to the District to be reissued
because of a transfer or to be used as an offset. If the transfer date is filled in,
the certificate is no longer valid. The "amount" of emission reduction is
recorded in lbs./day and tons/year because these are the units addressed in the
offset requirements of the NSR/PSD rules [see Rule 20.1(d)(4)], In the space
provided for "equipment description/credit qualifications," enter a brief
description of the equipment that was modified or removed. State whether the
equipment is operating with limitations, has been shutdown or removed. Add
any other comments that might affect the status of the ERC.

After the certificate forms are filled out, the computer record will be updated.
If the ERCs are due to a modification, a revised P/O with a new description,
new conditions on maintenance and/or limited use is to be entered into the
computer. (As stated earlier, the new BEC conditions will be in the 2000
series.) If the equipment is shutdown or removed, the project engineer will
send a memo to the permit clerk, with a copy to his supervising senior
engineer, requesting that the P/O for the equipment be cancelled.

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The certificate draft forms, the application folder, the surrendered P/Os and
the application time sheets will be sent to the senior engineer. The senior
engineer will review the draft certificates and P/O revisions or cancellations
and make corrections if necessary. After the senior approves them, the draft
certificate forms will be sent to clerical for typing. When the certificates are
returned, the senior engineer will proofread them and, if there are not
mistakes, sign them. He then will calculate the "time and material" costs. If
the fee deposit covers the costs, the senior will sign and send the ERCs to the
owner. A refund worksheet will be filled out, if the deposit exceeds the costs.
If the costs exceed the deposit, the applicant will be sent a letter requesting
additional funds. The senior engineer will withhold the certificates until the
requested money is received. After it is established that sufficient funds have
been received, the records of the engineering section will be updated to reflect
the completion of the application process.

Copies of the banking certificates will be placed in the inactive files with the
cancelled P/Os, in the active files if the equipment is modified and in a special
banking file in accounting.

H. Application of ERCs and On-going Compliance

1)	Each engineer will have a list of the owners of banked ERCs. The list will be
updated and distributed by accounting every time there is a change to the
banking registry. The list will be posted where it can be used as an easy
reference.

2)	Whenever an application that belongs to a listed ERC owner is received, the
project engineer will determine whether the equipment is a replacement for
equipment that was associated with banked emission credits. If so, the AJC
for the new piece of equipment will have, according to Rule 20.8, a condition
that either eliminates the ERC(s) granted or restricts the use of the new
equipment to the extent necessary to keep the ERC(s) real and permanent.

3)	ERCs cannot be used as "in lieu" reductions to avoid the BACT requirements
of Rule 20.2. In lieu reductions must be contemporaneous. ERCs can be used
only as offsets to achieve compliance with Rules 20.4 and 20.5 and no where
else.

4)	ERC certificates will be submitted with the applications for A/Cs when they
are to be used as offsets. The project engineer will use the information on the
certificate(s) in the A/C analysis. The certificates will be attached to the
evaluation reports. Also, the project engineer will cancel the ERC(s) in the
registry at the time the associated S/A is issued.

The engineering staff will contact the senior engineer in charge of their
section if they have any question. Every project engineer assigned a banking

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application will follow these procedures unless expressly authorized by the
senior engineer in charge of his section.

11. Certificate of Exemption (COE)

11.1 Certificate of Exemption (COE) Procedures (June 1, 2000)

A.	Elegibility

The following equipment/processes are not eligible for a Certificate of Exemption:

•	Categories of equipment/processes that are currently required to have
permits per District Rule 10. However if there are no specific thresholds or
design considerations in Rule 11, a COE may be considered for the
equipment/process if all other criteria are met. Also, if design
considerations are listed in Rule 11 and the equipment/process under review
was not evaluated when the design consideration was established, a COE
may be considered.

•	Any equipment/process, which has a current Permit to Operate.

•	Any equipment/process for which an application has been submitted for a
Permit to Operate unless Compliance and Engineering agree the source
could qualify for a COE provided no other District rules, state or federal law
apply to the facility or equipment and no compliance problems are expected.

•	Any equipment/process that is generally not regulated by the District.

•	Any equipment/process which emit toxic air contaminants and does not pass
the de minimus Rule 1200 screening. If the equipment/process can pass a
screening risk assessment and compliance can easily be demonstrated, a
COE may be granted at the discretion of the Engineering Senior and
Compliance Division Chief.

•	Any equipment/process which is not unique in nature and whose emissions
are negligible. Such a category of equipment/process may be placed on the
Permit Deferment List (PDL) at the discretion of the Engineering Senior and
the Compliance Division Chief.

B.	Routing of the COE application

•	COE applications are first handled by the Permit Processing staff, for assigning
and application number, deposit of fees and an application folder.

•	The COE application is then sent to Compliance for data entry and evaluation.

•	Based on the nature of the equipment/process emission source (VOC, combustion
or toxics) the COE application will be routed to an engineer section as follows:

o All VOC sources -> Chemical
o All other sources -> Mechanical
o Toxics which are not VOC's -> Toxics

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1) The Senior Engineer will assign the application.

•	After the engineering evaluation is complete, reviewed and approved by
the section Senior Engineer, the application is returned to Compliance for
approval by the Compliance Chief and final data entry. Engineering staff
does not have to perform any VAX data entry.

•	After final approval by the by the Compliance Chief, the Certificate of
Exemption will be printed and mailed by Permit Processing.

C.	Process for converting a Certificate of Exemption to a Permit to Operate.

If any equipment/process does not qualify for a Certificate of Exemption after
review by Engineering and Compliance, the COE application can be converted to a
permit application. A letter must be sent to the site informing them of the status of
the application. The COE application must be canceled. The applicant will be
required to complete a new application form and any applicable supplemental forms
along with the required fees. Any remaining monies from the COE application may
be transferred to the permit application at the applicants request.

D.	Process for converting a Permit to Operate Application to a COE.

When an engineer reviews a permit application and determines that no prohibitory
rules apply and the potential emissions will be minimal, the permit application may
be converted to a COE application by taking the following actions:

•	Obtain Senior Engineer and Compliance Division concurrence.

•	Complete a COE application and supplemental form.

•	Complete the normal COE evaluation process.

•	Any fees not expended can be refunded to the applicant.

E.	Timelines for processing COE applications - COE applications should be processed
within 90 days.

F.	Fees for COE applications.

In order to fully recover costs associated with COE applications, a base fee will be
charged to the applicants and additional time billed for equipment/processes that
may require toxic review and/or further engineering evaluation. The base fee is
calculated of using three hours of associate engineer time. The COE program is
intended to be full cost recovery and additional fees for toxic review and/or further
engineering evaluation will be calculated at the applicable labor rate. See Rule 40
schedule 94.

G.	The Certificate of Exemption Program Process Outlined below (see also the
attached flow charts):

1) Permit processing support staff will:

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a.	Verify that all forms are signed and money was received,

b.	Assign an ID# - if it is a new facility,

c.	Assign an application number, and

d.	Create a Certificate of Exemption file.

2)	The file will be sent to Compliance where it will be entered in the COE log
book. The senior inspector will:

a.	Review the COE application to verify that there are no specific
exemption in Rule 11, no prohibitory rules, or ATCM that may apply to
the equipment/process,

b.	Determine if an engineering review is needed, if yes, the COE
application will be forwarded to the appropriate engine-,ring division for
evaluation and review,

c.	Make a determination for the COE if an engineering review is not
needed, and

d.	Include inspector's reports, if applicable.

3)	Senior engineer will assign an engineer or a dedicated project engineer and
update the VAX app. file with the assigned engineer's initials and date.

4)	The project engineer will review the forms to make sure they are complete
and that all supporting information is included. If the forms are incomplete
and/or they did not include all the information needed to a make a
determination the engineer will contact the applicant to obtain the missing
information.

5)	The project engineer will review the inspector's report, review the facility
emissions estimate calculations, or calculate an emissions estimate if
calculations are not provided. The project engineer will make a
recommendation for exemption.

6)	If the equipment/process:

a.	Is recommended for exemption, the senior engineer will review and
approve the project engineer's recommendation.

b.	Does not qualify for an exemption, the engineer will return the file to the
Compliance Division and the Compliance Division will notify the
applicant by mail that they must submit an application with fees to
obtain a District Permit to Operate for the equipment/process.

7)	The file is then submitted to Compliance for approval by the Division Chief.

8)	Upon approval by the Division Chief, Compliance support staff will update
the VAX-COE-P/O file.

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COE-P/O
ID#

App#
P/O code

(input app#)

(input ID#)

(inputapp#)

(input c-for COE)

(input equipment description)

(input BEC code)

(input approval status A-approved D- denied
C- canceled)

(input date application approved by Division
Chief)

Equipment Description

BEC

Approval status

Date

The COE log book will be updated and the file returned to Permit Processing
to be filed.

9) Once approved, the Certificate of Exemption will be printed with the next
weekly run and mailed to the applicant. A copy will be sent to Compliance
and the COE file.

H. Conditions for the Certificate of Exemption

BEC conditions for the COE will be developed. These conditions will reflect the

operation of most of the equipment previously reviewed through the Permit

Deferment List (PDL) process. If the equipment/process requires specific

conditions, the assigned engineer will develop a new BEC.

Examples of standard COE conditions for the BEC include:

1)	The equipment shall be operated according to the manufacturer's
instructions/recommendation and as described in the COE application
submitted to the District.

2)	This Certificate of Exemption shall only apply to the equipment described
above.

3)	If applicable, records of material usage shall be maintained on a monthly basis
and retained on site for two years and made available upon request.

4)	The District reserves the right to change the exemption status of the above
equipment/process at any time. The facility will be notified at least 30 days in
advance of any changes which may affect the exemption status of the above
equipment/process.

5)	This Certificate Of Exemption must be maintained with the exempt
equipment/process or be readily available at all times.

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I. Procedures for Engineering Division Project Engineer for the Certificate of
Exemption (COE) Applications

The District has implemented the Certificate of Exemption Program. The
Certificate of Exemption (COE) program is designed for equipment/processes that
are not specifically exempt from permit requirements, but whose emissions are
insignificant or negligible. This program will enable facilities to have the
exemption status of such equipment/processes specified in writing without adding
these insignificant site specific sources to Rule II (Exemptions from Rule 10 Permit
Requirements).

Compliance Division will first review the COE application submitted by the
equipment owner/operator to determine if the equipment process meets the
requirements for an exemption from permits. The senior inspector will:

•	Review the COE application to verify that there are no specific exemption in Rule
II, no prohibitory rules, or ATCM that may apply to the equipment/process,

•	Determine if an engineering review is needed. If yes, the COE application will be
forwarded to the appropriate Engineering section for evaluation and review,

•	Make a determination for the COE if an -engineering review is not needed, and

•	Include inspector's reports, if applicable.

The project engineer will review the forms to make sure they are complete and that
all supporting information is included. If the forms are incomplete and/or they did
not include all the information needed to a make a determination the engineer will
contact the applicant to obtain the missing information.

The project engineer will review the inspector's report, review the facility emissions
estimate calculations, or calculate an emissions estimate if calculations are not
provided. The project engineer will make a recommendation for exemption,

If the equipment/process:

•	Is recommended for exemption, the senior engineer will review and approve
the project engineer's recommendation.

•	Does not qualify for an exemption, the engineer will return the file to the
Compliance Division and the Compliance Division will notify the applicant
by mail that they must submit an application with fees to obtain a District
Permit to Operate for the equipment/process.

The Senior Engineer will review and approve the COE application and
supplemental form. The file is then submitted to Compliance for approval by the
Division Chief.

COE applications are charged a one time fixed fee of $186.00. This fee is non
refundable. No additional fees are required to process the COE. Generally a site

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inspection of the equipment should not be required. Engineers should charge their
time spent on COF application to the following codes:

APP, COE, APPLICATION #, REVIEW

The labor data will not impact current COE fees but will be needed to make any
appropriate adjustment to COE fees in the future.

12. Chemical Section Procedures

12.1	S/A vs. Alternative Emissions Compliance Plan (AECP) (June 18,
1990)

A/Cs for sources proposing to implement AECPs will not be approved until the source
has submitted the AECP methodology and record keeping provisions and the District has
approved them.

An S/A will not be issued on any VOC source that proposes to comply with a VOC rule
through the use of an AECP unless the AECP has been submitted, reviewed and
approved by the District, and the approved AECP is implemented as a condition of the
S/A.

12.2	Rule 66

A.	Rule 66 (m) Organic Materials Definition (July 24, 1992)

Rule 66(m) broadly defines "organic materials" to include a wide range of materials
from organic solvents to fuels and solid, non-solvent materials. The District
intended this rule to apply to liquid organic solvents, or liquid materials containing
organic solvents. Therefore, for the purposes of this rule, Rule 66(k)'s definition of
"organic solvent" will be substituted for Rule 66(m)'s "organic material" definition.
For example, although Rule 66(o) addresses record-keeping for "organic material"
(which is defined in 66(m)),"organic material" is to be read "organic solvent"

(which is defined in 66(k)).

B.	Rule 66(o) Record-keeping Requirements (October 24, 2000 - Jorge Lopez)

Rule 66(o), which became effective January 9, 1992, requires detailed daily record-
keeping for a wide range of processes and operations. The District never intended
to require daily organic material usage records for operations emitting small
amounts of air contaminants. Accordingly, all Compliance action concerning Rule
66(o) is suspended for Dry Cleaning Equipment exempt from Rules 67.2,
Distillation Equipment, Coating Application Cleaning Equipment Asphalt Tar
Kettles. Asphalt Tankers. Grass Coating and equipment or which are not required to

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have Permits to operate. Please be advised, this does not relieve sites from the duty
to maintain records required to substantiate Rule 11 exemptions or required to be
kept by Rule 21.

1)	Sources will not be required to keep daily records of the usage of materials
containing organic solvents that are exempt pursuant to Subsections 66(n)(3),
(4) and (5).

2)	For materials containing non-photochemically reactive solvents and used at
temperatures at or below 200° F, daily records are not required but the
applicant must keep monthly records which show the quantities of materials
purchased. Daily usage records must be required if there is a reasonable
expectation that a Rule 66 emission limit (e.g., 3,000 lbs./day) will be
exceeded.

a. Rule 66 Policy Memo Comments (October 22, 1992)

A problem exists in item X.10 (c)(4). This item requires "usage" records
and then states that purchase, inventory, and disposal (PID) "may" be
acceptable. This equating of usage and PID has the potential to conflict
with the established concept that usage equals emissions (that is,
monthly usage records can be used to accurately calculate monthly
emissions). PID records can be kept in a manner which equals monthly
emissions. However, the type of PID records required to obtain accurate
monthly usage/emissions is for the most part not kept by business at this
time. Furthermore, such required PID records are tedious, time
consuming and therefore burdensome.

For monthly PID records to equal monthly usage/emissions, all purchase
records indicating mfg., ID#, and amount (container size) must be
maintained and is being maintained in general by business. In addition,
the site would have to conduct a detailed end of the month inventory.
This inventory would have to list each item in the inventory by mfg.,
ID#, and amount (container sizes vary, and some containers may be
partially full). Ending inventory for one month equals beginning
inventory for the next month. This type of inventory record-keeping is
not typically maintained at the type of small business affected by Rule
66.

Finally, the monthly disposal (or waste) records would have to list the
Mfg., ID#, and amount of each material added to the waste drum.

Current hazardous waste manifests, which are routinely kept at most
sites, do not contain this information. Manifests generally indicate the
date the waste was hauled off-site (not the month the waste was added
into the drum), and the amount of a category of waste, such as "paint
related waste" or "solvent".

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In summary, for sites to maintain PID records which equal monthly
usage, and can therefore be used to accurately calculate monthly
emissions, sites will very likely have to greatly modify their current
inventory and disposal record-keeping methods. Given the tedious and
time consuming nature of maintaining PID records which reflect
monthly usage and monthly emissions, it is recommended that policy
item IX(c)(4) be removed. Alternatively, it is recommended that
specific operations or processes which are known to emit much less than
3,000 lbs. of organic solvent per day, do not use photochemically
reactive solvent, and are not used at temperatures above 200° F, be
added to the list of operations not required to keep daily usage records in
the July 24,1992 Rule 66 memo. We can always review a site's
purchase records over a 12 month period to obtain a reasonable estimate
regarding whether an operation in question emits close to 3,000 lbs. per
day on worst case assumptions and average usage per operating day).

However, if the intent of this Rule 66(o) policy is not to be able to
calculate monthly emissions from monthly usage records, then I
recommend that the word "purchased" be substituted for the word "used"
in the first sentence. In addition, I recommend that the second sentence
be removed and the word "usage" be inserted between "daily" and
"records" in the third sentence. This will eliminate the potential conflict
between different forms of PID records and the meaning of the word
'usage". In addition, this would eliminate the burden on business from
having to greatly modify their inventory and disposal record-keeping.

1) For materials containing photochemically reactive solvents or solvents

exposed to temperatures above 200° F, daily records of materials usage are
required except as noted in the July 24, 1992, Chief, Compliance Division,
memo regarding Rule 66.

12.3 Procedures for Estimating the Vapor Pressure of VOC Mixtures
(June 20,1990)

Estimating the vapor pressure of solvents that are blends of several VOCs will require
either the volume or weight percentage of every component of the mixture be available
from the manufacturer's specifications or from material safety data sheets. The
calculation method in this procedure provides a value to be used in rule compliance
determination for the vapor pressure of a mixture when there is no vapor pressure data for
the mixture available. Results that are near rule limits and were obtained using this
procedure may need additional evaluation.

The estimate uses the approximations that the liquid solution behaves as an ideal solution
and that the gas phase behaves as an ideal gas. The calculation involves converting
volume or weight percentage data to mole fractions of the liquid mixture and using these

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mole fractions and pure component vapor pressures to estimate the vapor pressure of the
mixture at a temperature. The calculation may not apply to water-based mixtures or
emulsions/suspensions. In this calculation, the portion of the vapor pressure of the
mixture contributed by exempt solvents, i.e. 1,1,1-trichloroethane and others as stipulated
in the definition of VOC, will not be included in arriving at a mixture vapor pressure.

Pure component vapor pressure is available from a variety of references. Additionally,
vapor pressure data for specific mixtures may be available from the manufacturer of the
mixture and also may be found in material data files in the engineering division. If the
manufacturer's vapor pressure data are used, the source of the data and test method need
to be verified to substantiate using this data.

A. When using volume percentage of the liquid mixture, follow this procedure:

1)	Check that the volume percentages add up to 100.

2)	Convert the volume percentage to a fraction by dividing each by 100.

[Volume fraction] comp. = [Volume percent] comp./lOO

3)	Convert the volume fraction to weight per gallon of mixture by multiplying
the volume fraction by the density of the component of the mixture.

[Weight per gallon] comp. = [Volume fraction] comp. x [Density] comp.

4)	Convert the weight of component per gallon of mixture to moles of
component per gallon of mixture by dividing by the molecular weight of the
component.

[Moles per gallon] comp. =

[Weight per gallon] comp. / [Molecular weight] comp.

5)	Sum the number of moles of the individual components of the mixture.

E [Moles] = [Moles] comp. A + [Moles] comp. B+ ... + [Moles] last comp.

6)	Calculate the mole fraction of each component by dividing the number of
moles of a component by the total number of moles obtained from the
previous step.

[Mole fraction] comp. = [Moles] comp. / E [Moles]

7)	Repeat the calculation in the previous step for each component.

8)	Add the mole fractions of all the components of the mixture. This should be
equal to 1. If it is not equal to 1, the total may be recalculated equal to 1 by

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multiplying the component mole fraction by the ratio of 1 to the total of all the
component mole fractions.

[Mole fraction] comp. (normalized to 1) =

[Mole fraction] comp. x 1/ E [Mole fraction] comp.

9)	To calculate the vapor pressure of the component of the mixture, multiply the
vapor pressure of the pure component at the desired temperature specified by
the rule times the mole fraction of the component in the liquid mixture.

[Vapor pressure] comp. in mix. =

[Vapor pressure] comp. pure x [Mole fraction] comp.

10)	The total vapor pressure of the mixture is the sum of the vapor pressures of
the components in the mixture.

[Vapor pressure] total mix. = E [Vapor pressure] comp. in mix.
and [Vapor pressure] VOC = Z [Vapor pressure] VOC comp.

B. When using weight percentage, follow this procedure:

1)	Check that the weight percentages add up to 100.

2)	Convert the weight percentage to a fraction by dividing each by 100.

[Weight fraction] comp. = [Weight percent] comp. /100

3)	Convert the weight fraction of the component to weight per gallon of the
component by multiplying by the density of the mixture.

[Weight per gallon] comp. = [Weight fraction] comp. x [Density] mix.

Then follow Steps 4) through 10).

A. 1 Calculating VOC Content of Mixtures When Water or Exempt Compounds are
Present

To determine compliance with most District volatile organic compound (VOC) standards,
VOC content is expressed as the mass of VOC per volume of material not including the
volume of water and exempt compounds present in the material. This measure of VOC
content is referred to as the mass of VOC per volume of material less water and exempt
compounds. Exempt compounds are organic compounds that are not considered VOCs
for purposes of determining compliance with VOC standards.

Situations often arise where the VOC content of a material must be calculated from the
VOC contents of one or more components that are mixed together. For example, if two

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coating components are mixed together prior to application, the VOC content of the
mixture must be calculated since compliance is based on the VOC content of the coating
as applied. When there is no water or exempt compounds present, calculating the VOC
content of such a mixture is relatively simple (see equation 4 below). However, if one or
both of the coating components contain water or exempt compounds the calculation of
the VOC content of a mixture expressed as mass of VOC less water and exempt
compounds is more complex. The methods for calculating the VOC content in this case
are discussed below.

Consider a volume, Vm\, of material 1 and a volume Vm2 of material 2. If these two
volumes are mixed together, the total mass of VOC present in the mixture is given by:

where:

Wca is the total mass of VOC present in the mixture,

Cmi is the VOC content of material 1 expressed as mass of VOC per volume of material,
and

Cm2 is the VOC content of material 2 expressed as mass of VOC per volume of material.
Assuming no volume change on mixing, the total volume of the mixture is given by:

where Vma is the total volume of the mixture. However, total volume of the mixture less
water and exempt compounds is given by:

where:

V,iXa is the mixture volume less water and exempt compounds,

vx\ is the volume fraction of water and exempt compounds of material 1, and

vx2 is the volume fraction of water and exempt compounds of material 2.

Therefore, for a mixture of two materials, a formula for calculating the VOC content as
mass of VOC per volume of material less water and exempt compounds is:

Wca Vm\Cm\ + Vm2Cm2

Vma Vm\ + Vm2

Vnxa (1 vxl)Vml + (1 vx2)Vm2

nxa

(1)

wr

ca 	

nxa



where:

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Cca is the VOC content of the mixture expressed as mass of VOC per volume of material
less water and exempt compounds,

Cmi is the VOC content of material 1 expressed as mass of VOC per volume of material,
Cm2 is the VOC content of material 2 expressed as mass of VOC per volume of material,
vx\ is the volume fraction of water and exempt compounds of material 1, and
vx2 is the volume fraction of water and exempt compounds of material 2.

Calculating VOC Content as Mass per Volume

In cases where the VOC content expressed as mass of VOC per volume of material is
needed, the following formula can be used:

/n\		 ^ml^ ml ^m2^ m2

~~ ~V	V V

ma	ml	ml

where Cma is the VOC content of the mixture expressed as mass of VOC per volume of
material.

Calculating Volume Fraction of Water and Exempt Compounds

If the volume fraction of water and exempt compounds for an individual material are not
known directly but the weight fractions of water and each exempt compound in the
material are known, the volume fraction of water and exempt compounds can be
estimated. For each component of an individual material, the volume fraction of that
component in the material can be calculated by:

Vi = Wi

f Pn ^

Pi J

where:

Vi is the volume fraction of the component in the material,
Wi is the weight fraction of the component in the material,
Pi is the partial density of the component in the materialand
pm is the density of the material.

1 Note that the partial density of a component in the material is in general not equal to the
density of the pure component. However, in the likely absence of other information, the
partial density of the component in the material, pi, can be assumed to be equal to the
density of the pure component in order to estimate the component volume fraction. This
is equivalent to assuming that there is no volume change on mixing (or that the solvent is
an ideal solution).

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The volume fraction of water and each exempt compound are calculated separately. The
total volume fraction of water and exempt compounds in the material, vx, can then be
determined by summing the volume fractions of water and all components that are
exempt compounds.

Alternatively, if the volume fraction of VOCs and volume fraction of solids are known,
the volume fraction of water and exempt compounds in the material can be found from:

Vx = 1 - Vc ~ V,

where:

vc is the volume fraction of VOCs in the material and
\'v is the volume fraction of solids in the material.

The volume fractions of VOCs and solids can be estimated from their individual or
composite weight fractions and densities, if necessary (see above).

Additional Calculation Techniques

For a given material, the VOC content expressed as VOC mass per volume of material
less water and exempt compounds is related to the VOC content expressed as VOC mass
per volume of material, Cm, by:

(3)	Cc= °m

1 — v,„

where Cc is the VOC content expressed as mass per volume of material less water and
exempt compounds. Note that, if Cm and Cc are greater than zero, equation 3 can be
rearranged to give the volume fraction of water and exempt compounds, vx:

r

vx= 1 - —

Cc

In this case, the volume fraction of water and exempt compounds can be determined if
the VOC content of material and the VOC content of material less water and exempt
compounds are known. Substituting for vx in equation 1 gives an alternate formula2 for
calculating the VOC content of the mixture expressed as mass VOC per unit volume less
water and exempt compounds:

2 This is equation is not valid if either of the materials do not contain any VOC. In this
case, both Cc and Cm for the material would be zero.

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v c +v c

^2 3,^	(2 = ml ml	m2 m2

c	c

ml if	j_ ml if

ml	m2

^cl	^ c2

Equations 1 and la can be extended to more than two components by simply including
appropriate terms in the numerator and denominator on the right hand side of the
equations for each additional component (see Appendix).

If no exempt compounds or water are present, then vx\ = 0,Cc = Cm, and equation 1 for
calculating the VOC content, Cca, of a 2-material mixture can be rewritten as:

'c2

V )	CG	-j j -j j

Kl +K2

where and Cc\ and Cc2 are the VOC contents expressed as mass of VOC per volume less
water and exempt compounds of materials 1 and 2, respectively3. However, equation 4
will not give correct results if exempt compounds or water are present—and the error
may be large. Some examples calculating Cca with equations 1 (correct) and equation 4
(incorrect) are given below. Using equation 4 to calculate the VOC content may give
mixture VOC contents that are too high (Example 1), too low (Example 2), or—
fortuitously—correct (Example 3).

3 Even though no water or exempt compounds are present in either material the VOC
content of the material is still specified as mass of VOC per volume of material less water
and exempt compounds for compliance purposes. Since there is no water or exempt
compounds present, this specified VOC content is identical to the VOC content expressed
as mass of VOC per volume of material.

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Conclusion

The key to calculating VOC contents of mixtures when water and exempt compounds are
present is knowing the volume fraction of water and exempt compounds. This can be
determined in several ways when one of the following pieces of information is known for
a material:

(1)	The volume fraction of water and exempt compounds (see equation 1); or

(2)	If the VOC contents are not zero, the VOC content expressed as mass per volume of
material less water and exempt compounds and the VOC content expressed as mass
per volume of material (see equation la); or

(3)	The volume fraction of solids and volume fraction of VOCs; or

(4)	The weight fraction of water and all exempt compounds, the partial density of water
and each exempt compound, and the total density of the material; or

(5)	The weight fraction of solids, the density of each solid, the weight fraction of
VOCs, the partial density of each VOC, and the total density of the material.

EXAMPLES

Example 1.

	Material property	Coating 1	Coating 2	

Cm—VOC content, g/1	200	80

vx—Volume fraction water	0	0.9

and exempt compounds

Cc—VOC content, g/1 less	200	800

water and exempt

compounds

Vm—volume of material	1	1

added to mixture, liters	

VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 1:

= (1X200)-K1X80)

Uca (1-0)(1) + (1-0.9)(1) 8/1

VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 4:

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Cc«

_ (1)(200) +0X800) = 500g/|



Example 2.





Material property

Coating 1

Coating 2

Cm—VOC content, g/1

600

20

vx—Volume fraction water

0

0.9

and exempt compounds





Cc—VOC content, g/1 less

600

200

water and exempt
compounds





Vm—volume of material

1

1

added to mixture, liters





VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 1:

Cca =

(1X600) +(1)(20) . „



' (1-0X1)+ (1-0.9X1) 8



VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 4:

Cca

= (1)(600) +(1)(200) ^4QQg/1



Example 3.





Material property

Coating 1

Coating 2

Cm—VOC content, g/1

200

20

vx—Volume fraction water

0

0.9

and exempt compounds





Cc—VOC content, g/1 less

200

200

water and exempt
compounds





Vm—volume of material

1

1

added to mixture, liters





VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 1:



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= (1X200) +(1)(20)

Uca (1-0)(1) + (1-0.9)(1) /UUg/1

VOC content expressed as grams per liter less water and exempt compounds calculated
by equation 4:

Ca,	+(1X200) ^0Qg/|

12.4	Equipment Descriptions for Surface Coating Operations
(February 10,1983)

All equipment descriptions contained in A/Cs, S/As and P/Os for surface coating
operations will contain a description of the coating application equipment including type
(conventional air atomized,HVLP airless spray, air electrostatic, disc electrostatic,
Electro-deposition, etc.), the quantity (number of tanks, pressure pots, spray guns, other)
and the manufacturer and model designations. Serial numbers will not be included
because identical replacements are not a concern. These data will assist in future
assessments of coating transfer efficiencies and the impacts of mandated transfer
efficiencies on District rules. Also, these data can be used by the Compliance division to
discern coating application equipment changes not made pursuant to A/Cs.

12.5	Streamlined Permit Process Review (June 21,1993)

Rule 11 currently requires permits for vapor degreasers with vapor-air interface less than
5 square feet and cold solvent degreasers with liquid surface areas greater than 1 but less
than 5 square feet. These degreasers are required to comply with the requirements of
Rule 67.6. They can be summarized and provided for equipment operators to follow.
Permit applications for these degreasers, therefore, should not require rigorous
engineering evaluation and documentation. Additionally, the estimated ROG emission
reduction from compliance with Rule 67.6 from these small degreasers is relatively small.

Accordingly, the District established a streamlined permit review process for small
degreasers. The streamlined permit review process enables the District to expedite the
determination of small degreaser's compliance with District rules, reduce permit review
costs, and improve utilization of District resources.

Equipment owners are requested to submit a complete application package consisting of:
District application form, SPR (Streamlined Permit Review)-R67.6 Form, Material Safety
Data Sheets for the degreasing solvents, and the required permit fee. (see section XII.3 -
Streamlined Permit Review Forms)

A. The streamlined permit review process will operate as follows:

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Owners of small degreasers will submit an application, SPR-R67.6 forms, and the
applicable permit fee according to Rule 40. The SPR R67.6 forms contain
checklists for equipment and standards of Rule 67.6. It requires owners to certify
the equipment for compliance with Rule 67.6. A separate application will be
required for up to 99 units of the same manufacturer and model number. A separate
SPR-R67.6 form will be required for each manufacturer/model type using the same
solvent.

Permit processing staff will log the application(s), assign application number(s), file
documents in folders, and briefly review the SPR-R67.6 Forms to ensure all
equipment and solvent information is provided, the boxes on Section 4 (for
Standards of Rule 67.6) are marked, and SPR-R67.6 forms are signed.

If either an application or SPR-R67.6 form is unsigned or incomplete, permit
processing staff will notify the applicant by phone and may attempt to obtain
information not provided on the SPR-R67.6 form. Information obtained by phone
must be documented on the SPR-R67.6 form or on a separate memo. Otherwise,
the incomplete Supplemental Forms will be returned to the permit applicant with a
form letter specifying the deficiencies. The permit processing staff will ensure that
the application package is complete prior to forwarding to the assigned project
engineer. Permit renewals will be handled in accordance with current District
policy.

The assigned project engineer will briefly review the information in the package for
compliance with applicable District rules. If the application package indicates that
the equipment meets the standards of Rule 67.6 (and there are no NSR or toxic
issues), the project engineer will not inspect the equipment prior to issuance of
Permit to Operate. The project engineer will advise the applicant, by phone, of the
requirements of Rule 67.6 and the need to ensure compliance with District rules.
The Permit to Operate will be initiated immediately instead of issuing a Startup
Authorization. The project engineer will update the VAX for issuance or denial of
the Permit to Operate. If an application or SPR- R67.6 form does not demonstrate
compliance, the project engineer will so advise the applicant by phone and in
writing, and the application will be handled under the normal permit review
process. Minor, easily corrected deficiencies may not kick an application out of the
streamline process once they are corrected.

Compliance staff will inspect the facilities having only small degreaser Permit once,
every three (3) years. Small degreasers installed at facilities that have other
permitted equipment (i.e., paint spray equipment, >5 sq. ft. degreasers, I/C engines,
boilers, etc.) will be inspected on a regular basis. If an inspector finds that the
equipment described in a permit has been replaced with a unit of the same
manufacturer and model number, but different serial number, the Inspector will
request the Chemical Section (via the Senior Engineer) to update the Permit
description for the next renewal. If a replacement unit is not the same
manufacturer/model as a unit already permitted, or there is a new unpermitted unit,

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the Inspector will advise the permittee or owner to send the District a Rule 1 l(n)
similar equipment replacement notice, if applicable, or to apply for a new/revised
permit.

The goals of this process are to expedite determination of small degreaser's
compliance with District rules, to reduce permit review costs, and to improve
utilization of District resources.

12.6	Rule 67.5 Applicability to Slip Casting Operations (July 9,1992)

Rule 67.5, revised in 1990, deleted the exemption for paper, fabric and film coating
operations that do not use heating ovens.

The District does not consider ceramic slip casting to be a coating process therefore it is
not subject to Rule 67.5. As a part of the District's Air Quality Strategy implementation,
slip casting operations will be regulated under a separate source specific rule for
semiconductor manufacturing.

12.7	Federal Restrictions on Uses of HCFCs

Attached is a notice from EPA regarding allowable and unapproved uses of HCFCs in
Solvent Cleaning Operations. A number of HCFCs are identified as exempt from the
VOC definitions of District rules and regulations and are not identified as toxic air
contaminants under Rule 1200. In summary, under Title VI of the federal Clean Air Act,
EPA has established restrictions on the use of HCFCs in many solvent cleaning and
aerosol solvent applications.

As is noted in the attached:

A.	EPA prohibits the use of HCFC-141b in nearly all cleaning applications.

Production and import of HCFC-141b will halt on 1/1/2003.

B.	No HCFCs (except HCFC-225) have been submitted for approval as substitutes for
CFC-113 and TCA in non-aerosol solvent cleaning. Use of HCFCs in most solvent
cleaning applications is prohibited by EPA. Not included are certain specific
cleaning applications listed on page 2 of EPA's information sheet.

C.	EPA will likely list HCFC-141b as an unacceptable alternative to CFC's or TCA in
adhesives, coatings and inks.

D.	No other HCFCs have been submitted for approval as substitute solvents in
adhesives, coatings and inks. Use of HCFCs in most adhesives, coatings and inks is
prohibited by EPA.

If reviewing an application for permit for a solvent cleaning operation, or a coating,
adhesive or ink application operation, and the materials proposed for use contain an

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HCFC, the engineer should advise the applicant that such use may be prohibited by
federal law. The engineer should provide the applicant with a copy of the attached
fact sheet on prohibited HCFC uses from EPA. The advice to the applicant should
be documented in the application file.

If the applicant declines to change the permit application to propose alternative
materials or formulations that would not conflict with these prohibitions, the
engineer should proceed with the evaluation and permitting pursuant to District
rules, but notify the Chief of Engineering of the potential federal non-compliance.

12.8 Dry Cleaning Operations Using Silicone Siloxane

Dry cleaning operations employing Green Earth are exempt from permit requirements. Green
Earth is the trademark name for Silicone Siloxane (CAS # 541-02-6) and is manufactured by GE
Silicones. The MSDS indicates the material is greater than 95 percent

decamethylcyclopentasiloxane and the solvent is odorless according to the physical and chemical
properties listed.

In late 2002, the District's Chemical Engineering section reviewed technical data submitted by GE
and determined that this solvent is an exempt compound in accordance with Rule 2 and not a
volatile organic solvent as defined in Rule 11. Consequently, dry cleaning operations using Green
Earth are not subject to permit requirements [per Rule 1 l(c)(l 1), 1 l(d)(18)(v), and 1 l(d)(18)(vii)]
or Rule 67.2 or the Dry Cleaning ATCM.

13. Mechanical Section Procedures

13.1	Rule 50 Asphalt Plant Blue Smoke (March 22,1985)

Only those blue smoke emissions in excess of 40 percent opacity that occur in the loading
area of an asphalt plant will be aggregated against the pug mill or silo to determine
compliance with Rule 50. When the truck or trailer leaves the loading area directly under
the pug mill or silo, it becomes a separate stationary source. Emissions in excess of 20
percent opacity from trucks or trailers that have left the loading area are not to be
aggregated against the loading area. In addition, the District will not require controls for
trucks or trailers that have the potential to violate Rule 50 outside of the pug mill or silo
loading area.

13.2	Allocation of Registration Fees under Rule 12.1

All fees associated with all registration applicants submitted under Rule 12.1 (fee
schedules ending in "X" with a registration application fee) as specified in Rule 40 shall
be allocated as follows:

A. 3/4 of the fee per application (unit) to Engineering for application processing.

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B. Vi of the fee per application (unit) to Compliance for first year renewal costs.

13.3 Rule 12 Registration Application Processing (December 30,1997)

Many Registration applications have been received under Rule 12. These are
distinguished from Rule 12.1 Registration for portable equipment. Rule 12 does not
consider portability nor does it provide involved emission limitations.

Fees provided with registration applications are very low. Therefore processing must be
done expeditiously. We must not exceed the fees during processing.

The emissions from the equipment allowed to qualify for this rule were considered to be
insignificant. Each application should include sufficient information to identify the
registered equipment. The information should include the manufacture's name, model,
serial number and capacity of the unit. Conditions in the BEC's reflect the operating
requirements needed to minimize the emissions from the units. The BEC's for respective
units are noted below. The only units that will require emissions calculations are the
Stationary Internal Combustion Units located at Non-major Sources. These units must
have been installed prior to April 5, 1983 and are limited to emit no more than 100
pounds in any day of the 5 criteria pollutants. These units are also limited to emit no
more than no more than 3 pounds of lead in any day (as lead is not added to fuel any
longer this should not be an issue.)

34W: Internal Combustion Emergency Standby Engines.

BEC 10929

34W: Stationary I/C Engines Installed Before April 5, 1983.

BEC 10931

Verify that the site specified for the engine is not a major source. If no emission data is
provided with the application, the default factors in the engine work sheets should be
used to calculate the emissions. Make a comment in your review if the unit might exceed
emission standards. Indicate the number of operating hours at which the 100-pound
threshold would be exceeded. Call Registrant to verify to verify that the operator has no
intent to exceed 100 pounds per day. If the Registrant is vague about operating hours,
print a copy of the P/O print out and write the number of operating hours at which the
100-pound threshold would be exceeded. Copy the form and send it to Compliance. Add
the original to the file.

03W: Asphalt roofing Kettles and Asphalt Roofing Day Tankers.

BEC 10926

05W: Rock Drills
BEC 10927

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Rock Drills are usually engine driven. An application for a Rule 12.1 engine should be
processed with the rock drill application.

34W: Auxiliary Aircraft Power Units Rated 200 Horsepower or less.

BEC 10930

20W: Aircraft Air Starts Units Rated 500 Horsepower or less.

BEC 10928

27W: Adhesive Material Application Station without cont. <55 gal/yr.

BEC ???

13.4 Applicability of Rules 52, 53, and 54. (May 12,1999)

Because of the broadness of these rules, interpretations can be made to reach outside of
the scope of the intended meaning of these rules. Therefore, some clarification must be
made as to the true intent of these rules.

1)	Rule 52 Particulate Matter

The rule's concentration standard prohibits a source from emitting more than 0.1
grains of particulate matter per dry standard cubic foot. Rule 52 applies to all
sources of particulate matter except stationary internal combustion engines,
equipment exempt from permits or registration and emission units' subject to rule
53.

Rule 52 does not specify an average time for determining compliance. Therefore
when crafting permit conditions or performing engineering evaluations, the permit
engineer should specify that the standard is instantaneous or choose an average time
consistent with good air pollution control practice in consultation with your senior
engineer.

2)	Rule 53 Specific Air Contaminants - Rule 53 limits particulate emissions from
combustion sources and emission of gaseous sulfur compounds from both
combustion and non-combustion sources. The standard prohibits most combustion
sources from emitting more than 0.1 grains of particulate matter per dry standard
cubic foot corrected to 12% CQ2 or more than 0.05% by volume on a dry basis.
Sources typically subject to Rule 53 are broilers (gas and liquid fired), gas-fired
engines, combustion turbines and incinerators.

Exemptions Include:

•	Stationary liquid fueled piston-type internal combustion engine.

•	Natural gas, liquefied petroleum gas, or propane fired boilers with a
maximum heat input of less than 50 million Btu per hour.

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•	Liquefied fired boilers with a maximum heat input of less than 10 million
Btu per hour.

•	Process heaters and steam generators.

•	All equipment that is subject to Rule 54 is exempt from Rule 53
Subsections d.2 and d.3.

3) Rule 54 Dust and Fumes - Rule 54 sets standards for particulate emissions based on
weight of materials introduced into a process per hour. The standard varies
depending on the hourly rate at which the material is introduced into the process.
This rule was developed to regulate very large-scale sand and gravel operations that
had very high emissions despite their ability to comply with the Rule 52 particulate
concentration limit.

Exemptions include:

•	Exclusively combustion processes that are fueled with liquid or gaseous
fuel.

•	Combustion processes that generate only light, heat, team or power.

•	All internal combustion engines, turbines, boilers, process heaters and steam
generators.

13.5	Emergency Generators, Horsepower Used for Exemption (July
1987)

In the case of the Doubletree Hotel the following legal decision was issued. An
emergency generator with less than 500 bhp existed on site and an additional
cogeneration unit of less than 500 bhp was proposed with the emergency generator
operating concurrently with the cogeneration unit for maintenance purposes and the
remainder of the time, the emergency generator would operate only when the
cogeneration unit was down.

A legal decision stated that the District will consider the operating horsepower, and not
the dormant horsepower when determining if an exemption from an AJC or P/O applies,
even when there is concurrent limited operation during maintenance operations. The
source will provide the District a written commitment that there will be no concurrent
operation except for maintenance purposes not to exceed "X" hours per year. The source
will be required to keep records of emergency generator operation and make them
available to the District upon request.

13.6	Mineral Industry Emission Calculations Procedure (April 9,1996)

As a result of discussions with the mineral industry the District Management has agreed
to implement emission factors as described herein. All District Staff shall implement
these approaches immediately. Before any variation to these methods are implemented
the Chief of the Engineering Division must approve them in advance. It is understood
that there will be a difference to inputs when determining potential to emit versus actual
emission, however this should not require variation from the methods describe herein.

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These methods do not address certain categories of mineral industry operations. Until
guidance is provided, such categories will continue to be calculated as before. It is
essential however that all District staff use consistent methods throughout the District.

A. Conveyor Transfer Points

EPA AP-42 (Fifth Edition) PM10 emission factors for conveyor transfer points
(Table 11.-.-) will be used as follows.

1) The appropriate factors are as follows.

DRY: 1.4 x 10-3 Lb. of PM10 per ton of material transferred

WET: 4.8 x 10-5 Lb. of PM10 per ton of material transferred

a. When aggregate streams are composed of 70 percent (%) or more by
weight of aggregate larger in size than a number 4 NIESH (typically all
except crushed fines):

i) For material with less than 1.5 percent (%) moisture the "DRY"
factor above will be used.

ii) For material with 1.5 percent (%) moisture or more the "WET"
factor above will be used.

iii) These factors are to be used according to the following criteria
when considering specific site or equipment operating conditions.

b. When aggregate streams are composed of 70 percent (%) or more by
weight aggregates that are smaller in size than a number 4 MESH
(typically pit fines, crushed fines, rock dust, and recrushing circuits):

i) For material with less than 3.0 percent (%) moisture the "DRY"
factor above will be used.

ii) For material with 3.0 percent (%) moisture or more the "WET"
factor above will be used.

2) Control Efficiencies

It will become necessary to use control efficiencies when utilizing the "DRY"
factor above. These are to be used in the following manner.

a. When transfer point are vented to central fabric filter collectors the

collection efficiency will be assumed at 95.0 percent (%) when vented to
a centralized collector.

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b. When transfer points are controlled by means of insertable fabric filter
collectors, a control efficiency of 97.5 percent (%) will be assumed.

i)	Fogging of an enclosed transfer point, will be assumed to have a
control efficiency of 75 percent (%).

ii)	Control of a transfer point with water containing surfactant used in
accordance with the surfactant manufacturer's specifications will
be assumed to have a control efficiency of 50 percent

iii)	When transfer points involve reclaim from a tunnel or an enclosed
chute, 50 percent (%) control will be assumed if the transfer point
is "DRY"; no additional control will be assumed for "WET"
transfer points.

The District may adjust the above efficiencies based upon a visual
inspection and or testing during the Permit to Operate phase of permit
processing.

3)	Use of Emission Factors in Authority to Construct Evaluations

In order to qualify for this emissions calculation approach, an applicant must
provide the District with a list of transfer points, including hourly throughputs,
on a process flow sheet. Based on the design and planned operation of the
plant, the applicant should designate these transfer points as "DRY" or
"WET", and specify any additional control techniques which will be
employed.

Consistent with the design and operation of similar transfer points at existing
facilities, the District will review the applicant's "WET" and "DRY"
designations and make an independent determination of the factors to be used
in the Authority to Construct evaluation. The APCD staff will have the final
decision regarding emission factors used in the A/C evaluation.

Conditions limiting hourly, daily and yearly production can be placed on the
A/C to implement the District's assumptions on transfer point emissions.
Language can be incorporated requiring, or allowing testing to verify these
assumptions.

4)	Use of Emission Factors in Permit to Operate Evaluations

Once construction at a facility is completed and has undergone shakedown
testing, the moisture content of each transfer point can actually be measured,
and the appropriate emission factor (and associated control efficiency, if any)
will be assigned.

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The District may impose conditions on the Permit to Operate in order to
assure that actual site emissions match the assumptions in the permit
evaluation. These conditions may include aggregate size, moisture content,
and opacity limitations as stated below if this facility was not yet in existence
on the date of this memorandum, or if the operation has been modified and the
APCD feels these are appropriate.

Opacity Condition:

All conveyor to conveyor transfer points which qualify for use of the "WET"
emission factor shall have unique and easily readable identification numbers
posted beside them for identification purposes. Except for non-repeatable
momentary readings, opacity at these conveyor to conveyor transfer points
shall not exceed 10 percent (%) at any time.

5)	Use of Factors for Existing Facilities

For existing facilities, it is expected that sufficient data already exists from
previous testing to characterize the emissions from transfer points.

In the event existing data is judged inadequate by the District, the moisture
content of each transfer point at a site will be determined on a one-time basis,
and the appropriate emission factor and control efficiency, if any, will be
assigned.

After this one-time determination, no further testing will be performed by the
facility, but the District may elect to conduct testing to verify that the moisture
contents of various transfer points have not changed appreciably.

The District may add conditions for new or modified facilities requiring
moisture content limits as assumed in the emission calculations.

6)	Water Washed Aggregates

Transfer points when handling aggregates which have been washed, either in a
log washer, over a wet screen, or by similar devices, will have an emission
factor of 0.0 (ZERO) Lbs./ton assigned, for as long as the aggregates retain
their visible moisture during handling, stockpiling or conveying.

7)	Aggregate Streams with greater than 5.0 percent (%) moisture

Transfer points involving aggregate streams having a moisture content of 5.0
percent (%) or greater will be assigned an emission factor of 0.0 (ZERO)
Lbs./ton.

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B. Crushing Operations

EPA AP-42 (Fifth Edition) PM10 emission factors for crushing emissions will be
used as follows.

1) The appropriate Rock Crushing factors are as follows:

Primary Crushing

7.0 x 10-4

Lb. of PM10 per ton of material processed

Process Crushing (Dry)

2.4 x 10-3

Lb. of PM10 per ton of material processed

Process Crushing (Wet)

5.9 x 10-4

Lb. of PM10 per ton of material processed

Fines Crushing (Dry)

1.5 x 10-2

Lb. of PM10 per ton of material processed

Fines Crushing (Wet)

2.0 x 10-3

Lb. of PM10 per ton of material processed

These factors are to be used according to the following criteria when
considering specific site or equipment operating conditions.

a.	For feed streams having +4 inch material, (principally jaw and gyratory
crushers) use the Primary Crushing factor.

b.	For feed streams whose largest aggregate is in the range of -4 inch
material, (most standard and shorthead cones, some gyradisc and impact
crushers) use the Process Crushing factors as follows:

i)	For material fed to the crusher with less than 1.5 percent (%)
moisture, the "Dry" factor will be used.

ii)	For material fed to the crusher with 1.5 percent (%) moisture or
greater, the "Wet" factor will be used.

c.	For a crusher whose aggregate feed stream is exclusively an aggregate
below 1/2 inch material, or for a crusher whose product is composed of
30 percent (%) or more by weight aggregates that are smaller in sized
than a number four (4) MESH, use the Fines Crushing Factors as
follows:

i)	For material fed to the crusher with less than 3.0 percent (%)
moisture, the "Dry" factor will be used.

ii)	For material fed to the crusher with 3.0 percent (%) moisture or
greater, the "Wet" factor will be used.

2) Control Efficiencies

It will be necessary to utilize control efficiencies when utilizing the "Dry"
factors above. These are to be used in the following manner:

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Type of

Default Control



Air Pollution Control

Efficiencies (Percent)

Emission Multiplier

Water Spray

50

0.50

Water Spray w/ Surfactant

75

0.25

The only additional requirement for assuming the above listed default control
efficiencies will be a pen-nit condition requiring the use of the specified
control technique.

3) Capture Efficiencies

It will be necessary to utilize control efficiencies when utilizing the "Dry"
factors above. These are to be used in the following manner:

Default Capture Ef

Iciencies



Type of

(Percent)

Emission Multiplier

Air Pollution Control





Venting to Central Fabric Filter

95

0.05

Venting to Insertable Fabric Filter

97.5

0.025

The only additional permit requirement for assuming the above listed default
capture efficiencies will be a pen-nit condition requiring the use of the
specified control technique.

4)	Higher Efficiencies

Control or Capture efficiencies higher than the default values listed above
may be utilized if an additional condition is accepted listing the specific
performance of the control technique.

5)	Use of Emissions Factors in Authority to Construct Evaluations

In order to qualify for this emission calculation approach, an applicant must
provide the District with a list of crushing systems, including hourly
throughputs, on a process flow sheet. Based on the design and planned
operation of the plant, the applicant must designate these crushing systems as
"Dry" or "Wet", and specify any additional control techniques which will be
employed.

Consistent with the design and operation of similar crushing systems at
existing facilities, the District will review the applicant's "Wet" and "Dry"
designations and make an independent determination of the factors to be used
in the Authority to Construct evaluation. The APCD staff will have the final
decision regarding emission factors used in the AJC evaluation.

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Conditions limiting hourly, daily and yearly production can be placed on the
AJC to implement the District's assumptions on emissions from crushing
systems. Language can be incorporated requiring, or allowing, testing to
verify these assumptions.

6)	Use of Factors in Permit to Operate Evaluations

Once construction at a facility is completed and the facility has undergone
shakedown testing, the moisture content associated with each crushing system
can actually be measured, and the appropriate emission factor with the
associate control efficiency, if any, will be assigned.

The District may impose additional conditions on the Permit to Operate in
order to assure that actual site emissions match the assumptions in the permit
evaluation. These additional conditions may include aggregate size, moisture
content and opacity limitations, as stated below, if this facility was not yet in
existence on the date of this memorandum, or if the operation has been
modified, and the APCD feels these are appropriate.

Opacity Condition:

All crushing systems which qualify for use of the "Wet" emission factor shall
have unique and easily readable identification numbers posted beside them for
identification purposes. Except for non-repeatable momentary readings,
opacity at these crushing systems shall not exceed 10 percent (%) at any time.

7)	Use of Factors for Existing Facilities

For existing facilities, it is expected that sufficient data already exists from
previous testing to characterize the emissions from most crushing systems.
Occasionally, data may not yet exist.

In the event existing data is judged inadequate by the District, the moisture
content associated with material being fed to each crushing system at a site
will be determined on a one-time basis, and the appropriate emission factor,
control efficiency and/or capture efficiency, if any, will be assigned.

After this one-time determination, no further testing will be performed by the
facility, but the District may elect to conduct testing to verify that the moisture
contents of the various crushing systems have not changed to any significant
degree.

The District may add conditions for new or modified facilities requiring
moisture content limits as assumed in the emission calculations.

8)	Facilities with Controls on "Wet" Crushing Systems

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Facilities which have controls installed on crushing systems which qualify as
"Wet" systems shall be evaluated as in Section 2. The District may adjust the
control efficiencies based upon a visual inspection and/or testing during a site
visit.

9) Emissions Calculations Associated with Exhaust of Fabric Filter Control
Systems

If a fabric filter control system is used to control emissions from crushing
and/or transfer points in addition to the fugitive process emissions calculated
by using emission factors and capture efficiencies, stack emissions from the
exhaust of the fabric filter control system must also be calculated.

In the absence of any source test data, a PM10 particulate concentration of
0.008 grains per dry standard cubic foot will be assumed. The volumetric
flow rate of the stack (DSCFM) will be used in conjunction with the
concentration to calculate hourly emissions. A PM10 emission factor per ton
of rock can then be determined by dividing the maximum hourly production
rate of the plant into the calculated hourly emission rate.

If stack concentration data for total suspended particulates is available from
Method 5 testing a multiplier of 0.50 will be used to estimate the PMIO
emissions for use in calculating a stack emission factor.

This stack emission factor should then be used to determine hourly, daily and
annual emissions.

C. Screening Operations

EPA AP-42 (Fifth Edition) PMIO emission factors for screening emissions will be
used as follows.

1) The appropriate Rock Screening factors are as-follows:

Process Screening (Dry)

1.5 x 10"2

Lb. Of PMio per ton of material processed

Process Screening (Wet)

8.4 x 10"4

Lb. Of PMio per ton of material processed

Fines Screening (Dry)

7.1 x 10"2

Lb. Of PMio per ton of material processed

Fines Screening (Wet)

2.1 x 10"3

Lb. Of PMio per ton of material processed

These factors are to be used according to the following criteria when
considering specific site or equipment operating conditions.

a. When the aggregate stream being fed to a screen is composed of 70

percent (%) or more by weight of aggregates that are larger in size than a
number four (4) MESH, use the Process Screening factors as follows:

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i)	For feed material with less than 1.5 percent (%) moisture, the
"Dry" factor will be used.

ii)	For feed material with 1.5 percent (%) moisture or greater, the
"Wet" factor will be used.

b. When an aggregate stream being fed to a screen is composed of 30

percent (%) or more by weight aggregates that are smaller in sized than a
number four (4) MESH, use the Fines Screening factors as follows:

i)	For feed material with less than 3.0 percent (%) moisture, the
"Dry" factor will be used.

ii)	For feed material with 3.0 percent (%) moisture or greater, the
"Wet" factor will be used.

2) Control Efficiencies

It will be necessary to utilize control efficiencies when utilizing the "Dry"
factors above. These are to be used in the following manner:



Default
Control
Efficiencies



Control Technique

Percent

Emission Multiplier

Covered Screen

50

0.50

Covered Screen with Water Added

75

0.25

Covered Screen with Surfactant Added

90

0.10

The only additional permit requirement for assuming the above listed default
control efficiencies will be a permit condition requiring the use of the
specified control technique.

3) Capture Efficiencies

It will be necessary to utilize control efficiencies when utilizing the "Dry"
factors above. These are to be used in the following manner:

Default Capture Efficiencies

Control Technology

(Percent)

Emission





Multiplier

Covered Screen, Vented to Central Fabric Filter

95

0.05

Covered Screen, Vented to Insertable Fabric Filter

97.5

0.025

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The only additional permit requirement for assuming the above listed default
capture efficiencies will be a permit condition requiring the use of the
specified control technology.

4)	Higher Efficiencies

Control or Capture efficiencies higher than the default values listed above
may be utilized if an additional condition is accepted listing the specific
performance of the control technique.

5)	Use of Emissions Factors in AJC Evaluations

In order to qualify for this emission calculation approach, an applicant must
provide the District with a list of screening systems, including hourly
throughputs, on a process flow sheet. Based on the design and planned
operation of the plant, the applicant must designate these screening systems as
"Dry" or "Wet", and specify any additional control techniques which will be
employed.

Consistent with the design and operation of similar screening systems at
existing facilities, the District will review the applicant's "Wet" and "Dry"
designations and make an independent determination of the factors to be used
in the Authority to Construct evaluation. The APCD staff will have the final
decision regarding emission factors used in the AJC evaluation.

Conditions limiting hourly, daily and yearly production can be placed on the
AJC to implement the District's assumptions on emissions from screening
systems. Language can be incorporated requiring, or allowing, testing to
verify these assumptions.

6)	Use of Factors in Permit to Operate Evaluations

Once construction at a facility is completed and the facility has undergone
shakedown testing, the moisture content associated with each screening
system can actually be measured, and the appropriate emission factor with the
associate control efficiency, if any, will be assigned.

The District may impose additional conditions on the Permit to Operate in
order to assure that actual site emissions match the assumptions in the permit
evaluation. These additional conditions may include aggregate size, moisture
content and opacity limitations, as stated below, if this facility was not yet in
existence on the date of this memorandum, or if the operation has been
modified, and the APCD feels these are appropriate.

Opacity Condition:

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All screening systems which qualify for use of the "Wet" emission factor shall
have unique and easily readable identification numbers posted beside them for
identification purposes. Except for non-repeatable momentary readings,
opacity at these screening systems shall not exceed 10 percent (%) at any
time.

7)	Use of Factors for Existing Facilities

For existing facilities, it is expected that sufficient data already exists from
previous testing to characterize the emissions from most screening systems.
Occasionally, data may not yet exist.

In the event existing data is judged inadequate by the District, the moisture
content associated with material being fed to each screening system at a site
will be determined on a one-time basis, and the appropriate emission factor
and control efficiency, if any, will be assigned.

After this one-time determination, no further testing will be performed by the
facility, but the District may elect to conduct testing to verify that the moisture
contents of the various screening systems have not changed to any significant
degree.

The District may add conditions for new or modified facilities requiring
moisture content limits as assumed in the emission calculations.

8)	Water Washed Aggregates

Screening systems when handling aggregates which are being washed with
water will have an emission factor of 0.0 (ZERO) Lbs./Ton assigned.

9)	Aggregate Streams with Greater than 5.0 Percent (%) Moisture

When aggregates having a moisture content of 5.0 percent (%) or greater are
being fed to a screening system, an emission factor of 0.0 (ZERO) Lbs./Ton
will be assigned.

10)	Facilities with Controls on "Wet" Screening Systems

Facilities which have controls installed on screening systems which qualify as
"Wet" systems shall be evaluated as in Section 2. The District may adjust the
control efficiencies based upon a visual inspection and or testing during a site
visit.

11)	Emissions Calculations Associated with Exhaust of Fabric Filter Control
Systems.

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If a fabric filter control system is used to control emissions from screening
and/or transfer points in addition to the fugitive process emissions calculated
by using emission factors and capture efficiencies, stack emissions from the
exhaust of the fabric filter control system must also be calculated.

In the absence of any source test data, a PMio particulate concentration of
0.008 grains per dry standard cubic foot will be assumed. The volumetric
flow rate of the stack (DSCFM) will be used in conjunction with the
concentration to calculate hourly emissions. A PMio emission factor per ton
of rock can then be determined by dividing the maximum hourly production
rate of the plant into the calculated hourly emission rate.

If stack concentration data for total suspended particulates is available from
Method 5 testing a multiplier of 0.50 will be used to estimate the PMio
emissions for use in calculating a stack emission factor.

This stack emission factor should then be used to determine hourly, daily and
annual emissions.

D. Paved and Unpaved Haul Roads, Emissions and Control Efficiencies

EPA AP-42 (Fifth Edition) emission factor relationships will be used as follows:

1) Predictive Equation and Samples Required

The District has already implemented the revised Paved Haul Road Factor in
spreadsheet form. These spreadsheets must be reviewed to assure accuracy.

It is agreed that the following conversion factor will be used in all paved haul
road calculations.

1 ounce per yard2 | =33.9 grams per meter2

The District agrees that existing test procedures for determining silt content of
paved roads can be easily modified by adjusting the four, 2 square yard sub
samples to four, 2 square meter samples, and weighing the -200 MESH
fraction of the sample, as in the current procedure.

The number of samples required at a site in order to be representative may
vary from 1 to 7, with 5 samples (each consisting of four, 2 square meter sub
samples) being the preferred number. An arithmetic average of the silt
loading of each sample will continue to determine the silt loading for the site.

The "default" value for sites where no silt loading data exists (e.g., in
Authority to Construct evaluations) should remain approximately the same as
the old value of 0.40 ounces per yard2, which corresponds to a value of 13.6
grams per meter2.

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2) Control Efficiencies - Paved and Unpaved Haul Roads

Control efficiencies proposed by the mineral industry are troublesome in that
there is no evidence to provide as a basis for their use. Most controls involve
cleaning of the road surface. This directly impacts the silt loading (sL). The
equation has been designed to take these controls into account.

EPA indicates in AP-42 (Fifth Edition) at page 13.2.1-12 the following:

"Because available controls will affect the sL (silt loading), controlled
emission factors may be obtained by substituting controlled loading
values into the equation."

To add a control efficiency in addition to the silt loading reduction would be
to double count the reduction. This will likely lead to a significant under
statement of emission and is contrary to the purposes of the given equation.
This would be true for any form of sweeping flooding or any washing of
roads.

It is, however, appropriate to assign control efficiency to control measures that
do not impact the silt loading such as simple watering where the road surface
in maintained in a wet state. Therefore control efficiency will be assigned
according to the following:

a.	An 80 percent (%) control efficiency will be assigned as default for all
plants whose current watering practices keep emissions from exceeding
a 20 percent (%) opacity for more than three minutes in any consecutive
60 minute period.

b.	A 90 percent (%) control efficiency will be assigned for any plant
willing to accept a permit condition requiring watering of paved and
unpaved haul roads at 4 hour intervals, unless the road surface appears
visibly wet. In addition, as a condition of the permit to operate, such
watering must, except for non-repeatable momentary readings, prevent
visible emissions eight feet above the road surface from exceeding 20
percent (%) opacity.

c.	A 95 percent (%) control efficiency will be assigned for any plant
willing to accept a pen-nit condition requiring watering of paved and
unpaved haul roads at 2 hour intervals, unless the road surface appears
visibly wet. In addition, as a condition of the permit to operate, such
watering must, except for non-repeatable momentary readings, prevent
visible emissions eight feet above the road surface from exceeding 10
percent (%) opacity.

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d. Site specific control efficiency will be allowed in excess of the 80
percent default based on negotiations with the District and the source
accepting enforceable conditions acceptable to the District.

3)	Treatment of Existing Facilities

Existing facilities will be allowed, if they desire, a one time opportunity to
trade in their existing wet sweeping or flooding conditions for other time
intervals, so long as a redetermination of the silt loading of the paved haul
road is made based on the new wet sweeping schedule and such change is not
inconsistent with any required Best Available Control Technology (BACT).

Existing facilities without wet sweeping conditions would be allowed to
establish, if they desire, a wet sweeping or flooding permit condition, and then
reestablish a new silt loading based on that sweeping schedule, provided such
change is not inconsistent with BACT requirements applicable when the
Permit to Operate was issued.

It is the intent that updates would be completed during the month of April
1996, such that the emissions calculations from haul roads could be modified
in time for the 1993 criteria and toxics inventory updates.

4)	Treatment of New Facilities

New facilities will be evaluated during the Authority to Construct evaluation
by using a default value of 13.6 grams per meter2 for silt loading, 15 percent
(%) for silt content, and a control efficiency based on either the 80 percent
(%) default value, or an additional efficiency based on the watering conditions
outlined above. This is not intended to be inconsistent with any BACT
requirements or considerations.

Once a facility is constructed and operating, it will undergo testing for the silt
loading of the paved haul roads and the silt content of the unpaved haul roads,
and these emissions calculations will be finalized based on the watering
conditions, if any, the facility proposes for the Permit to Operate.

5)	Air Toxics

Rock Producers will continue to differential between paved haul road and
unpaved haul road emissions for both criteria and air toxic calculations.

Separate speciation profiles will continue to be developed for trace metals and
crystalline silica present in the PM10 fraction of material taken from unpaved
and paved haul roads.

6)	Vehicle Weight and Truck Wheels

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Emission calculations should continue to be performed based on the type of
haul vehicle as shown below.

Default values for vehicle weight and truck wheels for three typical haul truck
configurations for asphalt and rock plants are shown below:

Empty

Loaded

Net Haul

Average



Weight

Weight

Weight

Weight

Wheels

(tons)

(tons)

(tons)

(tons)

(number)

15

40

25

27.5

18

11

25

14

18

10

8

15

7

11.5

6

The population of 6, 10 and 18 wheel trucks will be established on a site
specific basis; based on the facilities best judgment with either site historical
data or similar facilities currently in operation in the County.

The weight of transit-mix concrete trucks may differ significantly from site to
site. Therefore, no general guidance for concrete batch plans is given. -The
Rock Producers will work with the District to develop default values for ready
mix trucks at some point in the future.

Also, at some time in the future it would be helpful if a relationship between
silt content and visible emissions were developed cooperatively with the Rock
Producers.

13.7 Mineral Industry Emission Calculations Procedures (November 5,
1999)

HOT MIX ASPHALT PLANTS
(SOx, ROG and TOG Emissions)

CONCRETE BATCH PLANTS - PMio Emissions
(Weigh hopper loading)

(Mixer loading, central mix)

(Truck loading, truck mix)

In response to recent requests from representatives of the mineral industry, the District
has reconsidered some of the emission estimation methodologies applicable to the above
source categories. As a result, there is consensus that the following emission estimating
methodologies shall be followed for permitting, emissions inventory (criteria and toxics)
and any other emission estimating efforts:

A. HOT MIX ASPHALT PLANTS [SOx, ROG and TOG Emissions]

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1)	SOx emissions will be based on the sulfur content and amount of the fuels
used as follows:

•	Natural gas-fired dryers:

SOx = 0.6 x S* lb/million scf fuel burned where S* is the ratio of gas
fuel sulfur content (gr/MMscf) to a standard value of 2000 gr/MMscf.
(ref. AP-42, Table 1.4-2, including footnote d)

•	Oil-fired dryers:

SOx = 142 x S lb/1000 gallons liquid fuel burned, where S is wt.%
sulfur in fuel (generally 0.05%). (ref. AP-42, Table 1.3-1)

2)	ROG emissions will be based on the TOC emission factor found in Tables
11.17 and 11.1-8 of AP-42 (1/95) minus the acetone content listed in the
speciated organics emissions data in Tables 11.1-9 and 11.1-10. TOG
emissions will be based on the TOC emission factor in Tables 11.1-7 and
11.1-8 plus the methane content listed in the speciated organics emissions data
in Tables 11.1-9 and 11.1-10. The resulting emission factors are:

BATCH MIX PLANTS
Natural gas-fired dryers:

ROG =0.011 lbs/ton
TOG = 0.029 lbs/ton

Oil-fired dryers:

ROG = 0.046 lbs/ton
TOG = 0.050 lbs/ton

DRUM MIX PLANTS
Natural gas-fired dryers:

ROG =0.051 lbs/ton
TOG = 0.073 lbs/ton

Oil-fired dryers:

ROG = 0.068 lbs/ton
TOG = 0.0891bs/ton

B. CONCRETE BATCH PLANTS [PMio Emissions from Weigh hopper loading,
Mixer loading (central mix), Truck loading (truck mix)]

The emission factors in Table 11.12-2 (attached), AP-42, Fifth Edition will be used
for estimating emissions. Specifically, the PM emission factors for weigh hopper
loading, mixer loading (central mix) and truck loading (truck mix) will be used for
those operations where there is no further control of those emission points beyond

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Shrouding. Shrouding constitutes the level of control used at the sources tested in
the past to develop these emission factors. PM-10 will be calculated as 92% of the
PM emissions. This is based on an ARB recommended value. If a central fabric
filter system is used, an additional capture efficiency shall be applied to the affected
emission points as follows:

Central fabric filter: 95% capture

In addition, a PMio emission rate of 0.008 grains per dry standard cubic foot of
exhaust from the baghouse will be applied in the absence of site-specific or
otherwise representative source test data.

13.8 Clarifications to Rule 69.2 Requirements (November 6, 2000)

Several issues have arisen regarding implementation of Rule 69.2 requirements. After
discussions with the NOx Rules Implementation Work Group, the following
clarifications have been developed:

A. Issue #1 - When does Rule 69.2(e)(1) require fuel meters?

1)	Fuel meters are required by Rule 69.2 (e)(1) for:

a.	Gas only-fired boilers exempt from NOx limits per Rule 69.2(d)(2).

b.	Liquid only-fired boilers exempt from NOx limits per Rule 69.2(d)(2).

c.	Dual-fuel boilers subject to the NOx emission limits of 69.2(d)(1).
Meters are required for both fuels. An exception to having a liquid fuel
meter applies when liquid fuel is only fired as a back-up fuel under 69.2
(b)(2) circumstances (i.e. for testing and during natural gas curtailments
and emergencies).

d.	Dual-fuel boilers that are exempt from the NOx emission limits per
69.2(d)(2) are required to have meters for both gas and liquid fuels,
except where a liquid fuel inventory and fuel purchase system is
proposed to track fuel use to a specific boiler and records necessary to
assure compliance are kept as approved by the District permit engineer.
A further exception to the requirement to have a liquid fuel meter
applies when liquid fuel is only fired as a back-up fuel under 69.2(b)(2)
circumstances (i.e. for testing and during natural gas curtailments and
emergencies).

2)	Fuel meters are not required by Rule 69.2(e)( 1) for:

a. Gas-only and liquid-only fired boilers subject to the NOx emission
limits of 69.2(d)(1).

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b.	Gas-fired boilers with liquid-firing backup capability subject to the NOx
emission limits of 69.2(d)(l where liquid firing is limited to 69.2(b)(2)
circumstances (i.e. for testing and during natural gas curtailments and
emergencies). The permit conditions must limit liquid fuel use to (b)(2)
circumstances and require the records specified in 69.2(e)(4) and (e)(5).

c.	Liquid fuel meters for dual fuel-fired and liquid-only fired boilers
exempt from the NOx limits per 69.2(d)(2) where a liquid fuel inventory
and fuel purchase system is approved by the District to track fuel use to
a specific boiler and the records necessary to assure compliance are kept
as approved. The permit engineer must review the proposed inventory
system and the records to be kept to ensure the records are able to show
the boiler complies with the applicable annual therm or capacity factor
limit.

A single fuel meter (or an approved alternative system of tracking and recording
fuel inventory and purchases) may serve more than one boiler provided the
aggregate usage of all boilers served by that meter (or system) is less than the single
boiler usage limit (220,000 therms) in the rule. Permit conditions are to be
imposed on all aggregated boilers to enforce this. A single meter cannot be used to
serve more than one boiler if any of the boilers is exempt from NOx emission limits
based on an annual capacity factor of less than 10%, since the capacity factor limit
applies to each boiler and cannot be averaged over multiple boilers.

Fuel meters should be accurate to within +/- 1% at the time of installation. This
requirement should be the same as the SDG&E requirement for meter accuracy.
Therefore, an SDG&E installed meter will be considered sufficient to satisfy this
accuracy requirement unless found otherwise.

B. Issue #2 - When does Rule 69.2(e)(2) require continuous monitors?

Rule 69.2(e)(2) requires that each boiler subject to the NOx emission limits of
69.2(d)(1) be equipped with continuous (parametric) monitors to allow for
instantaneous monitoring of the operational characteristics of the boiler and of the
flue-gas NOx reduction system "as applicable".

However, most boilers subject to the NOx emission limits are complying through
use of low NOx burners with flue gas recirculation (FGR). Often, the rate of
recirculation is fixed (either mechanically or within the boiler's automatic controls)
based on fuel flow rate and there is little, if any, benefit to "continuously
monitoring" the FGR rate or stack 02 content. Moreover, boilers equipped with
low-NOx burners and FGR that initially comply with the rule's NOx limits have
demonstrated on-going compliance in their annual source tests.

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Accordingly, no additional continuous parametric monitoring is required under
Rule 69.2 for boilers that are complying with use of low-NOx burners and FGR
where the FGR rate is pre-set to follow fuel-firing rate. The permit should describe
the type of FGR rate control and require the operator record any repairs or
modifications made to the FGR controls or burners. Should either source testing or
spot testing with a portable analyzer demonstrate that a boiler is not meeting the
applicable NOx emission limits, additional parametric monitoring may be required.

For boilers that comply through the use of other NOx controls such as SCR or
SCONOx, continuous parametric monitoring is necessary to ensure on-going
compliance. In deciding upon appropriate parametric monitoring, the project
engineer must consider that the rule requires compliance with the NOx emission
limits continuously (24x7x365). Monitoring requirements should be developed by
the project engineer on a case-by-case basis for the NOx controls used, with senior
engineer review and Compliance Division input. Permit conditions should specify
that proper calibration and maintenance procedures for the monitors will be
followed and require the operator to record calibration, maintenance, repair and
replacement activities related to the monitors. If the boiler is located at a major
stationary source required to have a Title V permit, monitoring requirements should
be reviewed with the Title V senior engineer assigned that source.

C. Issue #3 - When does Rule 69.2(e)(3) require a record of the higher heating value
(HHV) of each fuel.

Rule 69.2(e)(3) requires the operator of a boiler exempt from the NOx emission
limits per 69.2(d)(2) monitor and record the higher heating value and annual usage
of each fuel. This was to ensure compliance with the annual therm (or capacity
factor) exemption limit of 69.2(d)(2) when annual fuel use is limited by permit
conditions.

Where a boiler is fueled primarily on utility supplied natural gas, monitoring and
recording of the gas HHV is generally unnecessary. Therefore, boiler operators will
not be required to monitor and record the higher heating value under Rule 69.2
when all the following apply:

1)	Utility supplied natural gas is the primary fuel and liquid fuel is only used as a
backup under 69.2(b)(2) circumstances.

2)	A serving utility natural gas meter is used to determine the gas usage rate.

3)	A permit condition specifies the allowable annual (calendar year) usage of
natural gas in cubic feet. A standard higher heating value of 1,020 BTU per
cubic foot of natural gas is to be used to calculate allowable gas usage under
Rule 69.2(d)(2). [Source of HHV: AP-42, Table 1.4-1 (2/98 revision)].

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When boilers are permitted to burn liquid fuel for more than backup, the higher
heating value of the liquid fuel must be monitored and recorded. Information on the
HHV from the fuel supplier or as determined by one of the test methods specified in
Rule 69.2(f)(2) is acceptable. The permit should contain a condition requiring the
operator to maintain a record of the HHV of liquid fuels based on fuel supplier or
test information. The requirement to maintain and record the HHV of liquid fuel
does not apply if the liquid fuel is only used as a backup fuel consistent with
69.2(b)(2).

The above does not apply when the fuel HHV is needed for purposes other than
Rule 69.2 (e.g. to enforce an NSR requirement).

D. Issue #4 - What tuning procedure options are available to Rule 69.2(d)(2)(iii)
exempt boilers?

Sites have three choices to fulfill the tuning requirement of Rule 69.2(d)(2)(iii):

1)	Rule 69.2(j) Tuning Procedure

2)	SCAQMD Rule 1146 Attachment 1(B) Equipment Tuning Procedure for
Natural Draft-Fired Boilers, Steam Generators and Process Heaters. Note that
SCAQMD's tuning procedure for forced-draft and natural draft-fired boilers
allows the use of a "different" tuning procedure provided a copy of the
procedure is kept with the unit records for three years and is made available to
District personnel on request.

3)	An alternative tuning procedure recommended by the boiler manufacturer or
by a licensed boiler servicing company. In this case, the procedure does not
require prior District approval at this time, but must be provided to the District
upon request.

The permit shall contain a condition requiring annual tuning be performed and
specifying that any of the above procedures may be followed. The permit
shall also contain a condition requiring that records of the annual boiler tuning
be maintained in accordance with Rule 69.2(e) and specifying that if a
manufacturer's or boiler servicing company's alternative tuning procedure is
used, the procedure shall be identified on the tuning record and a copy of the
procedure shall be provided to the District upon request.

Table 1

Summary of Rule 69.2(e)(1) Requirements to Install Fuel Meters:



Gas Only

Liquid Only

Gas w/ Liquid
Backup

Duel-Fired Gas or 1
Liquid |

Boilers - 5 MM Btu/hr





Gas - No

Gas-Yes ||

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Fuel use - 220,000 therms
Subject to Rule 69.2(d)(1)

No

No

Liquid - No (b)

Liquid - Yes

Boilers - 50 MM Btu/hr





Gas - Yes

Gas - Yes

Fuel us - <220,000 therms
Subject to Rule 69.2(d)(2)

Yes (a)

Yes

Liquid - No (b)

Liquid - No (c)

Boilers - >50 MM Btu/hr





Gas - Yes

Gas - Yes

Fuel use <10% capacity
Subject to Rule 69.2(d)(2)

Yes

Yes

Liquid - No (b)

Liquid - No (c)

(a)	One meter can be used to determine compliance for multiple boilers if the fuel
use for all equipment served by that meter is less than 220,000 therms.

(b)	Boilers with liquid fuel back-up complying with Rule 69.2(b)(2)(i) and (ii) for
emergencies, during gas curtailment or for testing to maintain the fuel oil
back-up system must have records of hours of fuel oil firing in accordance
with Rule 69.2(e)(4) and (e)(5) but are not required to install liquid fuel
meters.

(c)	Duel fuel fired boilers complying with Rule 69.2(d)(2) may have fuel tank
inventory and fuel purchase records, as approved by the District, in lieu of a
liquid fuel meter.

13.9 Permitting of New Emergency Backup Generators (Mike Lake -
July 6, 2001, Revised December 2010)

Due to concerns with the possibility of rolling electrical blackouts, facilities submit many
applications for new emergency backup engines/generators (referred to as BUG's). The
applications are running approximately 90% diesel-fueled, 10% natural gas-fueled. It is
common for applicants to request authority to install generators very quickly. In some
cases, applicants may have already purchased generators.

There are several issues to be addressed in evaluating and approving these applications:

•	Rule 69.4.1 - New and replacement emergency backup engines are subject to the
NOx limits of this rule.

•	Rule 20.2-BACT (Criteria Pollutants) -BACT is required when NOx, SOx or
PMlOio emissions exceed 10 lbs/day. Rule 20.2 provides that BACT only applies
to non-emergency emissions, which typically last one hour or less per day. Engines
greater than approximately 650 brake-horsepower will likely trigger BACT for
NOx. BACT for PMlOio is unlikely to be triggered under Rule 20.2 but may be
triggered to comply with Rule 1200. SOx BACT may be triggered depending on
fuel use. BACT for NOx and SOx emissions from BUG's can be natural gas fueled
engines or ARB certified diesel engines using CARB diesel, depending on technical
feasibility and cost.

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•	Rule 20.2-AQIA (Criteria Pollutants) - Air Quality Impact Analysis is required if
NOx or SOx emissions exceed 25 lbs/hour or 250 lbs/day or if PM10 emissions
exceed 100 lbs/day. Only multiple engine projects or large engines, greater than
approximately 1,625 brake-horsepower, are likely to trigger AQIA for NOx if based
on non-emergency operation emissions. An AQIA for PM10 is unlikely to be
triggered. An AQIA for SOx may be triggered depending on fuel use. The few
AQIA's that have been done recently for BUG's have been based on non-
emergency operations but could be based on emergency plus non-emergency
operations.

•	Rule 1200 - Toxics New Source Review - Requires a project-specific health risk
assessment, T(oxics)-BACT if risk is greater than 1 in a million, and non-cancer
impacts below OEHHA recommended levels. Diesel-fueled BUG's emit diesel
particulates, a state toxic air contaminant. Risks from diesel BUG's can exceed 1 in
a million (or 10 in a million) depending on receptor distance, emission rates, stack
configuration and anticipated hours of operation. T-BACT will typically be the use
of catalyzed diesel particulate filters or alternative diesel fuels. Acrolein emissions
from natural gas-fueled engines can pose potential adverse acute health risks, but
this relies on a recent EPA emission factor that may be questionable. Rule 1200
provides that risk be evaluated based on the emission unit potential to emit. This
includes both emergency and non-emergency hours. However, the number of
emergency hours of operation is unknown with certainty. Electrical utility
estimates in 2001 ranged from zero to more than 200 hours. Recent data indicates
that actual emergency operations are infrequent.

Procedures for Evaluating and Permitting

Engineering will proceed with the permitting of new and replacement emergency backup

generators applying the following requirements:

1. For applications for new or replacement BUG's received after July 9, 2001 and
having NOx or SOx emissions that will exceed 10 pounds per day on a non-
emergency day, the applicant must either propose as BACT a natural gas-fueled
engine compliant with Rule 69.4.1 or demonstrate why a natural gas-fueled engine
or a dual-fuel engine (gas as primary, diesel as backup) is not technologically
feasible or cost-effective (@ $6.60 or $9.00/lb NOx).

An advisory was sent in 2001 to all permit holders and interested parties informing
them of this requirement.

For existing pending applications for new and replacement diesel emergency
BUG's and for new applications where natural gas or dual-fueled engines are not
technologically feasible or cost-effective, a diesel-fueled engine can be accepted.
BACT will be based on compliance with Rule 69.4.1, including use of CARB
diesel. (Note: This is intended to apply to emergency backup generators only. If

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an applicant is requesting to operate more than the allowed maintenance/non-
emergency use or further controls must be evaluated for BACT.)

2.	An Air Quality Impact Analysis must be conducted if emissions from one or more
new BUG's at a stationary source are expected to exceed the AQIA trigger levels of
Rule 20.2 (or Rule 20.3 if applicable). Rules 20.2 and 20.3 do not exclude
emergency operation emissions from this analysis. However, the most recent
information received from SDG&E indicates that emergency operations under
rolling blackouts are not expected to exceed 6 hours in duration in a day, nor more
than 8 hours in a day worst case. For purposes of determining whether an AQIA is
required, and conducting the AQIA, it will be assumed that each engine will not
operate more than 6 hours on any given day. Under this assumption, the hourly
AQIA emission trigger will likely be the most stringent.

A replacement engine is not subject to an AQIA if it does not result in an emission
increase. This will be assumed to be the case for a replacement emergency BUG if
the NOx, SOx, PMio and CO (as applicable) hourly mass emission rates (lbs/hr) of
the replacement engine are less than that of the engine it is replacing. For those
replacement engines with higher emission rates, the hourly and daily (assuming 6
hours operation in any day) emissions difference (i.e. increase) will be used to test
whether an AQIA is triggered.

3.	Compliance with Rule 69.4.1, and all other applicable rules, must be shown for
each new or replacement emergency BUG.

4.	For each new emergency BUG, compliance with Rule 1200 must be shown.
However, a replacement engine is not subject to Rule 1200 if it does not result in an
emission increase. This will be assumed to be the case for a replacement diesel
emergency BUG if the PMio hourly mass emission rate (lbs/hr) of the replacement
engine is less than that of the engine it is replacing. For replacement natural gas
fueled engines, the test will be whether estimated hourly acrolein emissions are
equal to or less than that of the natural gas fueled engine being replaced. If hourly
diesel PMio or acrolein emissions are less, a health risk assessment will not be
required. A diesel engine replacing a natural gas engine (and vice versa) will
increase emissions of a TAC (diesel PMio or acrolein) and must be evaluated under
Rule 1200.

5.	In July 2001, District policy was developed that specified that HRAs for emergency
standby engines be conducted based on a total of 200 hours per year of emergency
and non-emergency (maintenance and testing) operation. Additionally, TBACT
was considered to be a PM emission rate of 0.15 g/BHP-hr or less. Due to advances
in diesel engine particulate control technology, and considering historical data on
emergency engine operation, the following procedures will be used to evaluate
diesel IC engines for compliance with District Rule 1200 until further notice.

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Electrical utility estimates of hours of emergency use in 2001 ranged from zero to
more than 200 hours. However, historical information to date has shown that actual
emergency operations are negligible. Therefore, it is not appropriate, at this time,
to assume 200 hours per year operation when evaluating these engines. Future Rule
1200 HRAs should be conducted using the allowable permitted maintenance and
testing duration. For new emergency engines this will generally be 50 to 100 hours
per year in accordance with ATCM section (e)(2)(A).

TBACT is defined as the most effective emission limitation or emission control
device or control technique which: 1) has been achieved in practice for a source or
category of source; or 2) is found by the Air Pollution Control Officer to be
technologically feasible. The July 2001, policy established an engine emission rate
of 0.15 g/bhp-hr as TBACT for emergency engines. Since that time, the diesel
engine Air Toxics Control Measure (ATCM) was adopted and the use of diesel
particulate filters (DPFs) has been proven to be technologically feasible and has
been achieved in practice in numerous applications. Therefore, DPFs shall be
considered to be TBACT for emergency stationary compression ignition engines.
TBACT should not be required for any project based on the results of a screening
HRA. Engines that fail a screening HRA will require a refined HRA unless the
applicant chooses a lower allowable maintenance and testing duration that complies
with Rule 1200 risk criteria.

Permitting engineers are reminded that AQIA and Rule 1200 requirements apply to a
project defined as an aggregation of emission units at a stationary source for which one
or more applications for Authority to Construct and/or Permit to Operate are under
District review. Thus, if application(s) have been received for multiple BUG's at the
same stationary source, the aggregate air quality and public health impacts of all engines
(and any other pending permit applications that would increase emissions at the
stationary source) must be evaluated. For purposes of screening, the estimated risk of
each new engine should be determined, then added for all new engines.

The above procedures are intended to allow expedited processing of applications for the
majority of relatively clean new/replacement emergency backup generators while still
ensuring compliance with District rules. Please bring any questions or problems that
arise to the immediate attention of your supervisor or the chief of engineering.

13.10 Rule 69.4.1 Requirements - New Natural Gas-Fueled
Emergency Standby Engines (February 7, 2002)

A problem has come up with how Rule 69.4.1 treats natural gas (NG)-fueled emergency
standby engines. Rule 69.4.1 requires new and replacement emergency standby engines
comply with the Section (d) emission standards. Those standards, which were developed
with high use NG-fueled engines in mind, require add-on controls to comply with the
NOx emission limits. Without add-on controls, NG engines also have CO emission rates
very close to the limits of Section (d). These controls are expensive and may not be
particularly effective or cost-effective for an engine operated 1-2 hours per week or less.

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Certified diesel engines that comply with the Rule 69.4.1(d) standards without add-on
controls are readily available and less expensive than NG-fueled engines with add-on
controls. Rather than install a NG-fueled engine with controls, a facility will choose to
put in a readily available, less expensive diesel-fueled engine.

The effect of this is that a diesel-fueled emergency standby engine that emits more NOx
[-6.9 gms NOx/bhp-hr vs -3.8 gms NOx/bhp-hr (uncontrolled)] and emits a potent toxic
air contaminant (diesel exhaust particulate) is installed in order to comply with Rule
69.4.1. The Rule Development Section is working on revisions to Rule 69.4.1 to correct
this.

Until Rule 69.4.1 can be revised, the Engineering Division will not apply the NOx and
CO emission standards of Rule 69.4.1(d)(1) and (d)(2) to new or replacement natural gas-
fueled emergency standby engines provided the NOx emission rate of the engine is less
than 6.9 gms/bhp-hr (the allowable rate for a new emergency standby diesel engine). CO
emissions will be subject to the AQIA thresholds of Rules 20.2 and 20.3.

The remaining rule requirements will continue to apply, in particular the VOC limit in
Subsection (d)(3) and the maintenance and recordkeeping requirements of the rule. Note
that Subsection (b)(3) exempts new and replacement emergency standby engines from
Subsections (e)(1), (e)(2), (f)(1), (g)(3), (g)(4), (g)(5) and (i)(l) of the rule. These
exemptions continue to apply.

13.11 Startup/Commissioning Periods for Turbines and Engines
(February 11, 2003)

Often it is impractical for a new (or replacement) turbine or engine to comply with the
applicable emission standards of District Rules 69.3.1 or 69.4.1 from first fuel firing and
during the initial startup/commissioning period, especially when the project includes add-
on emission control equipment. Running time is needed to debug and adjust the turbine
or engine. During this period, it is necessary to operate units without the required add-on
control equipment fully installed and/or fully functional to protect the control equipment.

These startup/commissioning periods are typically limited to from a few hours to a few
weeks, depending on the size and complexity of the turbines or engines and control
equipment, and operational problems encountered. Total running time during these
periods is usually very limited. Such shakedown operations can be accommodated under
New Source Review but Rules 69.3.1 and 69.4.1 do not address this need.

The District is working on a new rule to provide for these initial startup/commissioning
periods. Until the rule has been adopted, and to avoid an excessive number of variance
requests, the District will use its enforcement discretion to implement the following
procedure:

1. The District will not require compliance with the emission standards of Rules

69.3.1 or 69.4.1, ortheBACT or LAER emission limits of New Source Review as

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applicable, for a new or replacement gas turbine or engine that requires a
startup/commissioning period for the unit or add-on controls, for up to the first 200
operating hours for each turbine or engine, starting with first fuel firing. All other
requirements of applicable District rules will continue to apply during the initial
startup/commissioning period.

2.	The operator must notify the District when first fuel firing occurs. A First Fuel Fire
Notice form will be provided to the applicant (with the Authority to Construct) for
this purpose. Once the operator has submitted a First Fuel Fire Notice form to the
District, the operator may commence the startup/commissioning period in
accordance with the Authority to Construct.

3.	The operator must maintain a log of the dates, times and cumulative unit operating
hours when fuel is being combusted in each turbine or engine during the initial
startup/commissioning period.

4.	The startup/commissioning period for a unit ends when the total 200 unit operating
hours have elapsed, or when emission controls are installed and fully functional,
and the owner/operator has provided the District with a Notice of Completion of
Construction, whichever is sooner. If the unit will not be in compliance after 200
operating hours, the operator must discontinue operating or petition the Hearing
Board for a variance to allow continued operations. If the unit is in compliance
within the 200 hours and the operator has provided the Notice of Completion of
Construction, operations may be allowed thereafter pursuant to Rule 24 or a District
Startup Authorization.

5.	The above requirements are to be reflected in Authorities to Construct for such
projects.

6.	The Authority to Construct conditions regarding scheduling initial compliance
source testing are to be reworded as follows:

•	Within 60 days from the date that construction of the above equipment is
complete in accordance with this Authority to Construct and a Notice of
Completion of Construction is submitted to the District, an initial source test
shall be conducted by an independent ARB approved tester or the District, at the
applicant's expense, to determine initial compliance with the emission standards
of this Authority to Construct and applicable District rules.

•	A source test protocol shall be submitted to the District for review and approval
at least 30 days prior to the initial source test. The source test protocol shall
comply with the following requirements:

a. Measurement of NOx, CO and oxygen content of the exhaust gas shall
be determined in accordance with San Diego APCD Test Method 100.

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b.	Measurement of VOC emissions shall be determined in accordance with
EPA Test Methods 25A and/or 18. (if VOC testing is required).

c.	NOx, VOC (if applicable) and CO emission concentrations shall be
calculated as an average of three subtests. The averaging period to
calculate emission concentrations and to determine compliance from the
results of source testing shall be at least 30 minutes and not more than
60 minutes unless otherwise specified in writing by the Air Pollution
Control Officer.

d.	Source testing shall be performed at no less than 80% of maximum
sustainable power output or brake horsepower rating, as applicable.

• Within 30 days after the completion of source testing, a final test report shall
be submitted to the District for review and approval. The testing contractor
shall include as part of the test report a certification that to the best of their
knowledge the report is a true and accurate representation of the test
conducted and the results.

This procedure takes effect immediately. If you have any questions, please see your
supervisor or one of us. A copy of a First Fuel Fire Form is attached for your use.

13.12	Evaluation of 40 Hour Testing and Maintenance Allowance
for Hospital Facilities (July 7, 2007 - Tom Weeks)

The May 26, 2005 amendments to the Diesel Engine ATCM allow districts to approve
operation of emergency engines at hospitals up to 40 hours in order to comply with the
Joint Accreditation Manual for Healthcare Organizations requirements for more
extensive and frequent testing of emergency standby engines.

On August 8, 2005 the Diesel ATCM Implementation Committee discussed the criteria
that would be applied when determining if the 40 hours would be allowed. The
committee determined that health risk assessments should be performed. Furthermore
research indicated that a cancer risk of 10 in a million was used as a basis for the control
levels specified in the ATCM (see the ARB staff report Appendix F, pages F-4 and F-7).

Therefore it was determined that 10 in a million would be the appropriate standard to
apply so that these sources would be held to the same standard used for other similar
sources. This standard will be applied to all hospitals requesting the 40 hour testing and
maintenance allowance.

13.13	Mobile/Portable vs. Stationary Engines - Rules 69.4 and
69.4.1 Applicability (May 17, 2001 - M. Lake/T. Morris)

The question has come up regarding the applicability of District Rules 69.4 and 69.4.1 to
mobile internal combustion engines that are associated with ancillary facility equipment

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such as fork lifts, tow motors or small mobile cranes that may be permanently located at a
stationary source. These rules were intended to apply only to stationary internal
combustion engines that, by definition, exclude portable emission units. They were not
intended to apply to engines used to propel equipment such as forklifts, tow motors and
small mobile cranes.

Section 40000 of the California Health and Safety Code distinguishes the authorities of
the air districts and ARB regarding stationary and mobile sources. Section 40000
preempts air districts from regulating emissions from motor vehicles except in specified
circumstances. Controlling emissions from motor vehicles is the responsibility of the
ARB. Section 39039 of the Health and Safety Code defines "motor vehicle" as having
the same meaning as defined in Section 415 of the Vehicle Code. Section 415 defines
motor vehicle as a vehicle that is self-propelled. Section 670 of the Vehicle Code defines
(in relevant part) a vehicle as a device by which a person or property may be propelled,
moved or drawn upon a highway except devices used exclusively on stationary rails or
tracks.

District Rule 2 defines a motor vehicle as a vehicle that is self-propelled, but does not
define vehicle. However, Rule 11(d)(1) and (d)(2) provide further clarification of what
types of engines used in conjunction with mobile sources are exempt from permits -
typically if an engine is used solely for propulsion. If an engine is used on or within a
vehicle to provide propulsion and other useful work, the test is whether the engine is used
primarily for propulsion. The District has interpreted vehicles to include items that are
capable of being propelled, moved or drawn on a highway (public or private road or
right-of-way) even if they may not typically do that and even if they are not required to
be licensed for movement on a highway.

Although Rules 69.4 and 69.4.1 may not explicitly exempt engines used solely or
primarily to propel motor vehicles, the District is preempted from regulating emissions
from such engines by the Health and Safety Code.

Therefore, the provisions of Rules 69.4 and 69.4.1 should not be applied to engines used
solely or primarily to propel a vehicle such as a forklift, tow cart or small crane. The
provisions of Rule 11(d)(1) and (d)(2) should be used as guidance, in particular where an
engine is used in conjunction with specified types of mobile sources or for multiple
purposes.

Moreover, since these rules were not intended to apply to these common types of mobile
sources, the District will not routinely require facilities to make a demonstration that such
engines are used primarily for propulsion. Requiring such a demonstration is
burdensome and should be reserved for those cases where there is a demonstrable
expectation that propulsion is the minority use, where there is a supportable opinion that
an engine operator may be circumventing the requirements of the rules, or when an
operator requests a written opinion from the District regarding rule applicability.

Requests for such demonstrations must be pre-approved, in writing, by the Chief of
Engineering, Chief of Compliance, or Assistant Director.

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13.14 Procedure for Review of Applications and Issuance of Certificates
of Registration

This procedure has been developed to provide guidance when issuing Rule 12 or 12.1
registrations. Two options are available to applicants as shown on the attached process
flow diagrams and the following procedure.

Option 1 - Application received electronically or via mail

10.	Application Submittal - Applicant submits the application forms (Appl 16 and the
appropriate supplemented form) with appropriate fees.

11.	Permit Processing Review - Permit Processing (PP) reviews the application to verify
that correct fees and forms were submitted, creates the permit file, logs the application
into the permit database and forwards the file to the Engineering Division (ED) after
scanning out the application. If correct forms or fees have not been submitted, PP will
notify the applicant and hold the application until sufficient fees are received to process
the application. The PP review step should be completed within one working day of
receipt of the application.

12.	Engineering Review - The ED representative will pick up the file and scan it in. The
ED representative will normally be an Engineering Technician but can be the assigned
duty engineering as necessary to address staff availability issues. A completeness review
will be performed and an incomplete letter in the form of a standardized incomplete
letter/checklist will be issued, if necessary, within three working days of application
receipt. If the application is compete, the ED representative will perform emission
calculations, complete the engineering evaluation and draft the registration certificate.

13.	Consultation Meeting - The ED representative will contact the applicant and offer to
meet with them to review and issue the initial registration certificate. If the applicant
declines the consultation meeting, the ED representative will issue the initial registration
certificate via mail or email. Issuance of the initial registration for complete applications
shall be within 10 working days of receipt.

14.	New BEC Creation - If a new BEC is required to incorporate hours of use limitations the
ED representative will request the new BEC using a standardized BEC template and
forward the request to PP. Senior Engineer and Compliance Division approval is not
required for these limited BEC changes.

15.	Permit Database Entry - The ED representative will enter the permit information into
the permit database system and forward the file to the Senior Engineer. Permit database
entry shall be with in 30 days of application receipt.

16.	Senior Engineer Review - The Senior Engineer will review the file and approve it in the
permit database system or return it to the ED representative for revision. After approval
the Senior Engineer will forward the permit file to the Accounting Section for fee
reconciliation.

17.	Fee Reconciliation - Following fee reconciliation, the Accounting Section will forward
the file to PP.

18.	Application Cancellation - Incomplete applications for equipment subject to Rule 12
will be cancelled if the requested information is not supplied within 90 day of such

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request. Incomplete applications for equipment subject to Rule 12.1 will be cancelled if
the necessary information is not supplied within 30 day of application receipt. Proposed
cancellations must be approved by the Senior Engineer.

Option 2 - Walk-in Customer

JaM. Application Receipt - Applicant arrives at the front desk with and application. All

applications will first go to Permit Processing (PP) for verification that the correct forms
and fees are available. If correct forms and fees are available, PP will copy the Appl 16
form and contact the ED representative (the ED representative will normally be an
Engineering Technician but can be the assigned duty engineer as necessary to address
staff availability). If correct forms and fees are not available, PP will inform the
applicant and provide them with information on how to complete the application. PP and
the ED representative will work in parallel, where necessary from this point forward (see
process flow diagram).

9.	Engineering Review - The ED representative will escort the applicant to a meeting
room. A completeness review will be performed and an incomplete letter in the form of a
standardized incomplete letter/checklist will be issued if necessary. If the application is
compete, the ED representative will perform emission calculations, complete the
engineering evaluation, issue the initial registration certificate and explain the registration
conditions to the applicant.

10.	New BEC Creation - If a new BEC is required to incorporate hours of use limitations the
ED representative will request the new BEC using a standardized BEC template and
forward the request to PP. Senior Engineer and Compliance Division approval is not
required for these limited BEC changes.

11.	Permit Database Entry - The ED representative will enter the permit information into
the permit database system and forward the file to the Senior Engineer. Permit database
entry shall be within 30 days of application receipt.

12.	Senior Engineer Review - The Senior Engineer will review the file and approve it in the
permit database system or return it to the ED representative for revision. After approval
the Senior Engineer will forward the permit file to the Accounting Section for fee
reconciliation.

13.	Fee Reconciliation - Following fee reconciliation, the Accounting Section will forward
the file to PP.

14.	Application Cancellation - Incomplete applications for equipment subject to Rule 12
will be cancelled if the requested information is not supplied within 90 day of such
request. Incomplete applications for equipment subject to Rule 12.1 will be cancelled if
the necessary information is not supplied within 30 day of application receipt. Proposed
cancellations must be approved by the Senior Engineer.

14. Vapor Recovery Section Procedures

14.1 Rule 61.3 Enforcement Policy (May 25, 2000 - Rosa Salcedo)

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A Notice of Violation for Rule 61.3 will be issued whenever a submerged fill pipe is
more than 6 1/2 inches from the bottom of the tank. The extra one-half inch will ensure
that the fill pipe is, in fact, less than six inches from the bottom of the tank as required by
Rule 61.3. A Notice of Violation for Rule 61.3 will be issued whenever a dry break that
is inoperative is observed and there is gasoline in the tank.

14.2	Rule 61.2 Transfer of Volatile Organic Compounds (VOCs) into
Mobile Transport Tanks (December 10,1979)

There will be no fugitive vapor leaks along the vapor transfer path—that combination of
piping, hoses, valves, fittings, storage tanks, saturator tanks, vapor processors and other
devices—through which hydrocarbon vapors are transferred, stored or processed to meet
the requirements of this rule. The vapor transfer path will include the interface between a
mobile transport tank having a capacity greater than 550 gallons and the stationary
storage tank facility vapor control fittings. The vapor transfer path will not include any
mobile transport tank, vapor control processor exhaust or designated vapor control
system vents.

14.3	Issuance of A/Cs and P/Os to Vapor Recovery (VR) Systems
Certified by Air Resources Board (October 24, 2000 - Rosa Salcedo)

A.	All A/Cs will be issued citing Rule 20 and Section 41960 of the health and safety
code.

B.	Concerns regarding the pressure drop criteria used for the certification of systems
will be documented and presented to the ARB under the signature of the APCO in a
timely manner.

C.	An application for a system certified by ARB at the efficiency required by the rule
will be approved if an engineering analysis indicates the proposed installation is
consistent with the ARB certified system.

D.	If a system is installed as specified in the A/C and ARB Executive Order, and all
appropriate tests are passed, and maintained in proper working order, a P/O will be
issued.

E.	Full scale efficiency testing will not be required as a condition for an A/C or P/O.

F.	Annual testing of specific parameters may be required as a condition for an A/C or
P/O.

14.4	Documenting VR Violations by Engineers (August 20,1979)

The vapor recovery engineers will document violations they observe during their field
inspections. The documentation will be used to ensure that a Notice of Violation is
prepared properly and presented to the responsible person.

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The violations will be sufficient to hold up in a criminal proceeding. When an engineer
observes a violation, the engineer will call Compliance staff and request the assistance of
an inspector. The inspector will observe the violation and document it. Then the
inspector will issue the notice and prepare the report. The engineer will observe all of
these actions in order to understand what will be required when a future violation is
observed. The engineer will ask the inspector any questions that are raised during the
inspection and documentation of the violation.

14.5	Vapor Recovery Station Rebuilds (July 28,1994)

Applications for vapor recovery station rebuilds will be assigned fee code MAL instead
of 26A or 26F. The fee will be calculated from fee schedule 26A or 26F, column 1 minus
column 2. The initial fee cannot exceed this amount nor can any additional labor charges
be recovered except re-inspections.

All labor charges will be charged to MAL except re-inspections. When a re-inspection is
performed this labor will be charged to REF and will be invoiced separately upon
completion of the application process.

The station's current permit must be active with all fees paid prior to accepting the
application. Renewal fees must be paid each year until the application process has been
completed and the District issues a revised permit using the existing permit number.

14.6	Inspection/Maintenance Manuals at Service Stations (December
4, 2001)

Vacuum-assist executive orders require manufacturers' installation and maintenance
manuals be maintained on site. However, ARB has not formalized any approval process
for these manuals and subsequent revisions. As a result, there has been confusion as to
what manual(s) are to be maintained on site. Accordingly and effective immediately,
vapor recovery facilities will no longer be required to maintain manufacturers'
installation and maintenance manuals on site. This policy will remain in effect until ARB
establishes a formal review process regarding these manuals.

14.7	Test Cancellation Fee (July 5, 2000 - Rosa Salcedo)

The revisions to District Rule 40 went into effect July 1, 2000. Fee schedule 26 now
includes a test cancellation fee for any test scheduled to be witnessed by the District
which is cancelled less than 2 working days prior to the test date. A site substitution
within 2 days of the scheduled test date is considered a test cancellation. The fee should
be charged to the original site.

To implement this new fee, it is imperative that we generate the invoices immediately
after receiving notification of a test cancellation or substitution. All invoices should
include the same standard language for "reason for invoice". A copy of this standard

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language is attached. Accounting has been consulted and they agree to automatically
include the appropriate language if the invoices are clearly labeled as "Test
Cancellation".

Therefore, when receiving notice of a test cancellation or substitution you will need to
take the following steps:

1)	Obtain a "Request for Invoice" form. There are forms in the form boxes by Joe's
office.

2)	Complete the Application No., ID #, P/O #, amount due, and Equipment Address
blanks.

3)	In the spaces allowed for "Reason to be typed on invoice" write:

•	"Test Cancellation"

•	Tester - name of testing company

•	Original test date - enter test date as per our testing calendar

•	Cancellation date - date cancellation or substitution call received (if message

left on VM over weekend, date received is first District working day after )

4)	Submit invoice to accounting immediately.

This fee applies to "no-shows" for a scheduled test.

It is important that we are all diligent about generating these invoices in a timely
fashion and that we follow these steps. It is also necessary that we are careful to
avoid misunderstandings in scheduling tests to avoid challenges of test dates.

14.8 Invoicing for Reinspection (July 5, 2000)

It is time to put an end to outstanding fees on applications due to reinspections that do not
get invoiced until the application closes.

Therefore, the Vapor Recovery Section must now follow the District-wide procedure of
invoicing as the project progresses rather than at the bitter end.

Standard language has been generated for "reason for invoice" and all invoices should
include this language. A copy of this standard language is attached. Accounting has
been consulted and they agree to automatically include the appropriate language if the
invoices are clearly labeled as "Reinspection Required".

Effective immediately the following policy is in effect for Vapor Recovery:

1) When returning from a field test that will require a reinspection, obtain a "Request
for Invoice" form. (Available in the form boxes next to Joe's office.)

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2)	Complete the Application No., ID #, P/O #, and Equipment Address blanks.

3)	Complete amount due blank. If you know the re-test will require a full day, enter
amount equivalent to 13 hours of your time. If the re-test will require a brief visit,
say for 2 or 3 nozzles, enter amount equivalent to 5 hours of your time. (These time
estimates include 2 to 3 hours of REF office work.) Note that a re-test due to a no-
show requires this invoice in addition to the test cancellation invoice. (Please be
aware that the Schedule 94 has been revised when calculating your charges.)

4)	In the spaces allowed for "Reason to be typed on invoice" write:

•	"Reinspection required"

•	Test date - enter date you were at the site

•	Reason - no show or test/inspection failed

•	Tester - name of testing company

5)	Submit invoice to accounting immediately.

If the site fails on the second visit, a third visit should not be conducted until
payment on the second visit (first reinspection) is verified. Regardless, a third visit
should not be scheduled prior to discussing with me the circumstances under which
the facility failed for possible application denial action.

It is important that we are all diligent about generating these invoices in a timely
fashion and that we follow these steps. I expect these invoices to be submitted to
accounting within two working days (based on each individual's work schedule) of
the original site visit.

Reinspection Invoice Language

The following language is to be used for requests for invoices generated by the Vapor
Recovery Group when a reinspection is required.

When "reason" is noted as a no-show.

A District witnessed test was scheduled for your facility for	(insert

date)	L Your tester, (insert name of testing company), was not present at the

scheduled time. Therefore, a District witnessed test will have to be rescheduled.

Pursuant to District rule 40(a)(7), the applicant is required to pay the cost of a
reinspection.

OR

When "reason" is noted as test/inspection failed.

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A District witnessed test and/or inspection was conducted at your facility on (insert date).
Your facility failed to successfully complete all required testing and/or failed inspection.
Therefore, a reinspection of your facility will be required. Pursuant to District Rule
40(a)(7), the applicant is required to pay the cost of a reinspection.

14.9 Applicability of Rule 1200 to Gasoline Dispensing Facilities
(October 2, 2003)

Rule 1200 exempts gasoline service station emission units equipped with T-BACT if the
increase in estimated cancer risk is less than 100 in one million and the total acute and
chronic noncancer risks are less than 10. For the past 6 months the District has been
evaluating Rule 1200 compliance for new and modified gas stations relative to the 10 in
one million risk criteria of Rule 1200. The purpose of this was to gain information about
gas station risks and determine the feasibility of eliminating the Rule 1200 exemption or
otherwise limiting risk to 10 in one million.

After review and discussion of the results of this effort, the following policy has been
developed:

1)	Only new (not modified) emission units shall be reviewed for compliance
with the 10 in one million criteria in Rule 1200. Evaluation of new facilities has value in
that it may indicate stations that have elevated risks and may provide opportunities for
risk reduction prior to construction. Rule 1200 only applies to an emission increase and
therefore it is highly unlikely that a modification would not qualify for the eexemption.
Additionally, evaluation of modifications, which can be frequent, does little to
characterize or manage the total risk from the station. Total risk for existing facilities
will be better characterized and managed through the "Hot Spots" process.

2)	If estimated risk from new emission units exceeds 10 in one million, the
permit engineer should discuss the results of the risk assessment with the Sr. Engineer
and/or the Chief of Engineering and evaluate potential voluntary risk reduction efforts
that may be proposed to the applicant. If the facility agrees to voluntary risk reduction
measures, permit conditions should be included in the facility permit to ensure the
reductions are permanent and enforceable. If the facility does not agree to voluntary risk
reduction measures, recordkeeping conditions should be included on the permit to
facilitate compliance with AB2588.

3)	All new and modified emission units will continue to be evaluated for
compliance with the 100 in one million criteria in Rule 1200. This analysis will be
conducted using the October 2002 screening procedure or a refined HRA if necessary.
Permit conditions limiting throughput will only be applied if the requested throughput
levels specified in the application indicate that the risk may exceed 100 in one million
and it is therefore necessary to limit throughput.

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15. Emissions Inventory Procedures (M Luther, January 2021, J Lofgren
December 2021)

The work related to Emissions Inventories and the prioritization scores for the AB2588
Air Toxics "Hot Spots" Program is performed within the EIS system with the labor
recorded within Time Accounting in BCMS (see procedure 2.4.12), unless otherwise
specified.

I. Types of Emission Inventories (El's)

There are multiple types of inventories the District conducts, each with its own facility
list and timelines:

•	Criteria Pollutants (District Rule 19.3, annual inventory)

•	Toxic Pollutants for specific facilities (AB2588 "Hot Spots" Program (H&SC
44300 et. Seq.), Emissions Inventory Criteria and Guidelines Regulation (17CCR
93300.5), while the District processes these inventories every year, each facility is
only included once every 4 years)

•	Toxic Pollutants for Industry-wide sources (AB2588 "Hot Spot" Program,(H&SC
44300 et. Seq.), Emissions Inventory Criteria and Guidelines Regulation (17CCR
93300.5), once every 4 years inventory). Industry-wide sources as defined below.

•	Criteria and Toxic Pollutants for the Criteria and Toxic Reporting Regulation
(CTR, 17CCR 93400 et. Seq., annual inventory)

•	Community Air Protection Program (for facilities within a designated community,
per the Community Monitoring Plan or the Community Emission Reduction Plan,
as needed)

Industry-wide sources, for toxic pollutants, are defined by CARET s "Hot Spots'

Program as a source that:

(1)	Qualifies to be included in an industrywide emission inventory prepared by an air
pollution control or air quality management district pursuant to Health and Safety
Code Section 44323

(2)	Releases, or has the potential to release, less than ten tons per year of each criteria
pollutant, and

(3)	Is either of the following:

o The facility falls in one of the following 4 classes of facilities: a. Autobody
shops, as described by SIC Codes 5511- 5521 or 7532; b. Gasoline stations, as
described by SIC Code 5541; c. Dry cleaners, as described by SIC Code 7216;
d. Printing and publishing, as described by SIC Codes 2711-2771 or 2782; or
o The facility that has not prepared an Individual Plan and Report in accordance
with Sections 44340, 44341, and 44344 of the Health and Safety Code. This
also includes Combustion-Diesel Engines.

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The District identifies these sources as being listed in BCMS under specific types of Fee
Schedules, as follows:

o Combustion - Diesel Engines: All 34-except 34X, which includes [34C]

Emergency Standby Engine, [34A] Cogeneration Engine, [34B] Cogeneration
Engine w/ Emission Controls, [34C] Emergency Standby Engine, [34D]
Engine for Non-Emergency & Non-Cogeneration, [34E] Dredging or Crane
Engines, [34G] Engine for Non-Emergency and Non-Cogeneration Operation,
[34H] California Certified Emergency Standby Engine, [341] Engine Test Cell
and Test Stand, [34L] Diesel Particulate Filter Cleaning Process, and [34W]
Registered Engine (Rule 12).
o Gasoline - General Storage and Dispensing: [26A] Initial Installations and

Renovations and [26C] Phase I.
o Autobody Shop Coating Operations: [27R] Vehicle Refinishing Operations,
o Dry Cleaning Operations: [31 A] Facility using Halogenated Hydrocarbon
Solvents.

II. Setting Up and Mailing Out the Inventory Requests - EI Team Members,
Aide

Prior to January 1 of each year, data requests must be set up within EIS for the facilities
that will be included in that year's inventories. Data requests are to be mailed out in early
January to meet the required reporting deadlines.

A. Determining Facilities Subject to Inventory

At the end of each data year, the EI team should compile a list of facilities which
will be subject to reporting emission inventories for that data year, including what
type of program each facility should report to. The following guidelines are used
to determine which programs are applicable:

a.	Criteria Emission Inventories - Facilities are categorized as criteria
emission inventories if the facility emits more than 5 tons per year of VOC
or NOx, as outlined in Rule 19.3

b.	AB2588 Hot Spots Toxic Emission Inventories (TEI) - TEI facilities are
inventories on a four-year cycle. A facility may be inventoried at a higher
frequency as part of another program, although prioritization scores and
subsequent HRA requirements should follow only the TEI cycle.

c.	CTR - CTR facilities are inventoried on an annual basis and must meet
one of the following criteria to be considered a CTR inventory:

i.	GHG MRR - Facilities which are required to report GHG
emissions according to CARB's Mandatory Reporting Regulation.
If requested, CARB will provide a list of active GHG facilities to
compare against active facilities for determination.

ii.	Criteria - Facilities are designated as criteria for CTR if the facility
emits greater than 250 tons per year of any nonattainment pollutant

iii.	Elevated Risk - Facilities are categorized as elevated risk if the
facility has:

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1.	Facilities with cancer, chronic or acute Category A
prioritization scores

2.	Facilities expected, or resulted, in risks above Rule 1210
notification or risk reduction thresholds

B. New Facilities Subject to Inventory

Updated Permit to Operate data is pulled from BCMS and uploaded into EIS, to
ensure all permits that were active during that year are included, then the devices
(emission points) from each permit are determined and calculation methods are
assigned to each device. Determination of inventory type should follow the
procedure described above.

III. Deadlines for Facilities to Submit Their Information and Tracking the
Status - EI Team Members, Aide

The different types of inventories have different deadlines for facilities to submit their
information. Until a tracking ability is available in EIS, tracking the status of each
facility will need to be done manually (spreadsheets, etc.). The statutory deadlines for
facilities to submit their information are as below, however the data requests will be sent
with a 60 day deadline for all inventories that can be extended (if needed and allowed for
the type of inventory they are subject to):

Type of Inventory

Deadline to Submit

Extension Allowed?

Criteria

60 days after request
(R19.3(c)(6)(i))

Yes, 60 days (R19.3(c)(8))

AB2588

(including

Industry-wide)

180 days after request (H&SC
44341)

No

CTR

By May 1 (17CCR 93403(c)(1))

At District discretion but
must process and submit
inventory to CARB by
August 1.

CAPP

As determined by the District

As determined by the
District

Additionally, facilities that must submit an Emission Statement Form per Rule 19.3(c)(3),
must submit that within 60 days of when the Form is sent to the facility, per Rule
19.3(c)(6)(i).

IV. Reviewing and Processing the Facilities' Information - EI Team
Members, Aide and Senior Engineer

For instructions in how to navigate and use EIS, please see the Guide to EIS in
SharePoint.

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Once the facility submits their information (through online EIS Portalthe Aide will record
this in EIS workflow. Then, if any data needs to be entered or uploaded into EIS, this
will be done by the Aide or a EI Team Member, as appropriate.

Once the data submitted in EIS, the EI Team Member assigned will Quality Assure the
data to ensure it is complete and makes sense (based on past inventories and type of
source, i.e., a small metal coating operation probably would not use 10,000 gallons of
paint, but might use 100 gallons), and ensure the correct calculation method is assigned to
each device and material.

After the data is entered and reviewed, the EI Team Member will process the inventory
by running the calculations and reports, then reviewing the resulting emissions, based on
the reported usages. At this point, for facilities that are subject to the Air Toxics "Hot
Spots" Program (AB2588), prioritization scores should be calculated (see section V of
this procedure for more details).

Once the work has been reviewed and approved by the Senior Engineer, the EI Team
Member will send the draft inventory (and draft prioritization scores if appropriate) to the
facility for a 30-day review, using the template letters in SharePoint. If the facility
provides additional information to revise the inventory or prioritization scores, the
information should be reviewed, and if approved, the EI Team Member will do the
appropriate revisions. This review and should be completed within 30 days of when the
facility provides the additional information.

The deadlines to process the inventory are as follows:

Type of Inventory

Deadline to Process Inventory

Criteria

No deadline per Rule 19.3

AB2588 (including Industry-wide)

90 days after receiving the data (H&SC 44343)

CTR

Completed inventory must be submitted to
CARB by August 1 (17CCR 93403(c)(1))

CAPP

As determined by the District

Once the approved revisions to the inventory are made, or if the facility has not provided
any comments within 30 days, the inventory will be approved, and the facility notified of
this approval in writing. AB2588 approved inventory must include a notification to
inform the facility whether or not a HRA is required and the prioritization score if a HRA
is required under the Hot Spots Program (please see section V of this procedure for more
details).

V. Prioritization Scores and Health Risk Assessment Requirements for
AB2588 Facilities- EI Team Members, Senior Engineer, Aide

For facilities being inventoried under the AB2588 "Hot Spots" program (the once every 4
years inventory), prioritization scores will be calculated based on the District's Air
Toxics "Hot Spots" Prioritization Procedure, using the tools within EIS (see Section 15.2
Subsection 7 for how to do this). The EI Team Member will calculate the prioritization
scores when the draft inventory created and include the scores in the Draft Report to the
facility.

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If the prioritization scores are below the thresholds for requiring a AB2588 Health Risk
Assessment (HRA), the inventory approval letter will indicate that a HRA is not required.
If the prioritization scores are above the threshold for requiring a AB2588 HRA, the Aide
will create a HRA record in BCMS for the facility (see Section 16 for the procedure for
doing this). The EI Team Member will include the prioritization scores in the inventory
approval letter and will attach the HRA required letter, using the template letters in
SharePoint.

Per the Health and Safety Code 44360(a) the prioritization scores must be finalized
within 90 days of the emission inventory being approved.

VI.	Inventory and/or Prioritization Revision Requests After they are
Approved - Aide, EI Team Members, Senior Engineer

Once the emission inventory is approved, the facility may request additional changes to
either the inventory or to the prioritization scores if they are under AB2588. If the
facility is not subject to a AB2588 HRA, then the proposed revisions will be reviewed,
and the time spent logged into Time Accounting (using the Emission Inventory labor
codes).

However, if the facility is required to conduct a AB2588 HRA, the time spent reviewing
the proposed revisions must be logged into the HRA Record. The EI Team Member
will notify the HRA Team Member of the request for revisions, who will determine if an
invoice is needed for the amount of time reviewing the revisions is expected to take.

VII.	Posting records in documentum - EI Team Members & Senior Engineer

All relevant documents (i.e. documents associated with the inventory request, facility
submittal and approved inventories) must be posted in BCMS under the SITE record.
Except for invoices, all documents posted under the SITE records related to the Emission
Inventory program must be posted in documentum using the "APCD-ENG-EI" or
"APCD-ENG-HOTSPOTS" group and appropriate category as shown below. Please note
that any confidential information such as "attorney-client" communication must be
posted using the "trade secret" categories listed below. All documents that are not
designated as "trade secret" will be disclosed to the public. Draft documents, zipped
files, and internal communication should NOT be posted in documentum.
For documents associated with a criteria. CTR or CAPP inventory, the group APCD-
ENG-EI should be used:

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Go To ~ I

Document permissions are based on the document type and your role at APCD.
Document Group/Category [Required] »

APCD-EIMG-Ei

-Select-

Division Current Division

APC D-EI-Correspondence
APC D-EI-Correspondence-Tra de-Secret
APCD-EI-Data Request
APCD-EI-Data Submittal
APCD-EI-Data-Submittal-Trade-Secret
APCD-EI-Emission Statement
APCD-EI-lnventory Tracking
APC D-EI-Prioritization
APCD-EI-Report

APC D-EI-Supportin g-Documentati on

APC D-EI-Supportin g-Docurnentati o n-Tra de-Secret

APCD Engineering

Description



check soellina

Please use the fields at the bottom of the screen to
You can add multiple documents via the [Add] butt

jIT

For documents associated with a AB2588 Hot Spots inventory, the group A PCD-EN G-
HOTSPOTS should be used:

APCD202Q-HRA-0003 - Miramar Energy Facility, SDGS.E AB258S Toxic Hot Spots HRA
Save	Add	Delete Cancel	Help

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Document permissions are based on the document type and your role at APCD.
Document Group-Category [Required] •

IAPCD-ENG-HOTSPOTS	s

Division Current Division

I APCD Engineering

Description

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Please use the fields at the bottom of the screen to
You can add multiple documents via the [Add] butt

Apply Definitions to Selected

APCD-EI Supp docs
APCD-EI Supp docs Trade Secret
APCD-EI-Correspondences
APCD-EI-Correspondences Trade Secret
APCO-El-Data Req
APCD-EI-Data Submittal
APCD-EI-Data Submittal Trade Secret
APCD-EI-Emission Statement
APCD-EI-HRA Submittal
APCD-EI-inv T racking
APCD-EI-Prioritization
APCD-El-Public Notification Approved
APCD-El-Public Notification Submittal
AP CD-El-Report
APCD-EI-Risk Red Approved
APCD-EI-Risk Red Submittal

The following table list some critical documents that must be posted in BCMS with the
specified document group/category .

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The name of the document should follow the following format:

__

The Type of Document should follow the Document column below (Data Request,
Inventory Submittal, Approved Inventory Report, etc.

As an example, for a data request for the 2020 inventory year for a facility with EID 350,
the file name would be 2020_Data Request EID 350.









Team









Member







Documentum

Responsible
for Posting
the

Document

BCMS Records

Documentum Group

Category

Document

Data Request NOT
related to





APCD-EI-Data
Request



AB2588(when facility
is notified an inventory
is needed)

SITE

APCD-ENG-EI

Aide

Data Request related
to AB2588 (when

SITE

APCD-ENG-

APCD-EI-Data

Aide

facility is notified an

HOTSPOTS

Req

inventory is needed)









Inventory submittal
from facility NOT
related to AB2588

SITE

APCD-ENG-EI

APCD-EI-Data
Submittal

Aide

Inventory submittal
from facility related to
AB2588

SITE

APCD- ENG -
HOTSPOTS

APCD-EI-Data
Submittal

Aide

Submitted Emission
Statement Form as
required by Rule
19.3(c)(3)





APCD-EI-



SITE

APCD-ENG-EI

Emission
Statement

Aide

Draft inventory sent to
the facility including
the 30-day comment

SITE

APCD-ENG-EI

APCD-EI-
Report

Aide

letter NOT related to









AB2588









Draft inventory sent to
the facility including
the 30-day comment

SITE

APCD- ENG -
HOTSPOTS

APCD-EI-
Report

Aide

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letter related to
AB2588









Draft or Approved
Prioritization scores

SITE

APCD- ENG -
HOTSPOTS

APCD-EI-
Prioritization

Aide

Request to revise
inventory scores from

facility, with the
proposed revision(s)
NOT related to
AB2588

SITE

APCD-ENG-EI

APCD-EI-Data
Submittal

Aide

Request to revise
inventory/ pri oritizati on
scores from facility,
with the proposed
revision(s)- related to
AB2588

SITE

APCD- ENG -
HOTSPOTS

APCD-EI-Data
Submittal

Aide

Approved Inventory
Report sent to facility
NOT related to
AB2588

SITE

APCD-ENG-EI

APCD-EI-
Report

Aide

Approved Inventory
Report sent to facility
related to AB2588

SITE

APCD- ENG -
HOTSPOTS

APCD-EI-
Report

Aide

HRA Request (when
facility is notified a
HRA is needed under
the Hot Spots
program)

HRA

APCD-ENG-
HOTSPOTS

APCD-EI-
Correspondences

Aide

Notification rescinding
the HRA request

HRA

APCD-ENG-
HOTSPOTS

APCD-EI-
Correspondences

Aide

In addition to the documents listed above, which should be posted in documentum,
the following records related to Emission Inventories should be maintained in
SharePoint:

Emission Inventory supporting documents (e.g. calculation sheets). Please
note that all facility submittals must be maintained in SharePoint.

Tracking sheets
Templates

Guidance/reference documents

Internal communication and draft document should NOT be maintained in
SharePoint or BCMS.

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15.1 Emission Inventory Fees

The District collects fees from facilities which are applicable to District Rule 40.d.4.ii
and AB2588 "Hot Spots" State Fees Regulation. The purpose of collecting fees is to
recover District and State costs associated with implementing regulatory programs. Fees
are determined and collected monthly as described below.

I. 5 Ton per Year (tpy) Criteria Pollutant Fee, District Rule 40.d.4.ii

Monthly, permits processing supplied emission inventory a list of sites which have permit
renewal fees within that month. 5 tpy fees are calculated for those sites listed on the
monthly renewal list and proposed to permit processing for inclusion in the renewal
invoices. There are two alternatives to calculate 5 tpy fees, as described in Rule 40.d.4.ii:

•	Actual Emissions - Fees are suggested based on the actual emissions of the
facility, as determined by the latest approved emissions inventory report. Per Rule
40.d.4.ii.A, if the actual expected annual emissions of carbon monoxide (CO),
oxides of nitrogen (NOx), oxides of sulfur, particulate matter (PM10) or volatile
organic compounds (VOC) equal or exceed five tons, then the Air Contaminant
Emissions Fee shall be based on the total expected emissions of all these
contaminants for that calendar year, multiplied by an air contaminant emissions
fee rate of $ 116 per ton).

For example, if a facility has the following criteria emissions:

CO - 1 tpy
NOx - 2 tpy
PM10 - 6 tpy
SOx - 1 tpy
VOC - 2 tpy
Total =12 tpy

This facility would be applicable because PM10 is over 5 tpy, and the fee would
be the sum multiplied by the fee rate - 12 tpy x $ 116/ton = $1,392 proposed fee.
A template has been created to aide in the creation of these fees and it is found on
SharePoint under Emission Inventory - 9 - Emission Fees (Permit Processing) - 1
- Procedures4. This template should be updated as indicated in the instructions on
an annual basis.

•	Special Fee Schedule - Fees determined based on special fees schedules, in the
absence of actual approved emissions inventory by the District. For these a single
Air Contaminant Emissions Fee would be charged based on the nature of the
activities at the stationary source. The Rule specifies the following fee schedules -

4https://sdcountycagov.sharepoint.com/ :x:/s/apcd/Engineermg/EY0KSHAcsd5Hh3tgkU62KU
cBipe2UJIY8ZfZ-ooFqJY7Zw?e=h351G6

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26(a), 28 (k and 1), 28(f), 27(e), 27(k), 27(v) and Various- for all other stationary
sources, to be subject to this type of fees.

In general, the following procedure is used to estimate and propose emission fees for
facilities:

A.	Identify whether the sites on the list have been inventoried. If the site has not been
inventoried, we don't make any recommendations for emissions fees.

B.	For the sites which have been inventoried:

1.	Identify the facility emissions inventory facility ID (EID or EIF ID), under
which each site was inventoried.

2.	For some of the large facilities, multiple sites may exist, were inventoried
as one entity that has one EID and one site designated as a Parent Site. If
one of the sites in Permits Processing List is part of a facility with multiple
sites, identify the EID and if that site is a Parent Site.

3.	For each EID, identify the latest year of approved emissions inventory.
Utilize the facility's latest approved emissions report to collect annual
emissions of the five criteria pollutants: carbon monoxide (CO), oxides of
nitrogen (NOx), oxides of sulfur, particulate matter (PM10) and volatile
organic compounds (VOC).

4.	If any criteria pollutant is greater than 5tpy, the summation of the yearly
emissions of all five criteria pollutant will be calculated in Tons then
multiplied by $116/Tons. The resulting value will be presented to permits
processing as recommended fees.

5.	If each one of the five criteria pollutants < 5 tpy, no recommendation will
be made, and we leave it to permits processing to choose between standard
or special schedule fees.

6.	If a Site is a part of multi-site facility, emissions fees will be calculated
and recommended only when that site under review is the Parent Site of
the facility. No recommendation will be made for the rest of the sites
under this Facility as all the sites are inventoried together (one inventory =
one fee). For the rest of the sites under that facility, zero fees are
recommended.

II. AB25 88 "Hot Spot" Emission Fees

As described in CARB's AB2588 "Hot Spots" Fees Regulation5, the District must charge
facility's fees for participating in the AB2588 program. The district utilized the following
resources to aide in the development of these fees:

5 https://ww2.arb.ca.gov/ our-work/programs/ab-2588-air-toxics-hot-spots/ab-2588-hot-spots-
state-fees

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Engineering Division Manual of Procedures

1.	Chart and Graph as provided on CARB's Website "Hot Spots" State Fees
Categories & Costs6

2.	CARB's Annual Status Reports - Core and IW Fees

Fees are developed for both production and industry-wide facilities as described below:

Industry-wide Facilities:

•	Industry-wide facilities should be charges an annual flat fee of $35 according to
CARB's website and Annual Status Reports as mentioned above

•	Although industry-wide facilities are inventoried once every four years, as is
required, fees are charged on an annual basis.

Production Facilities:

•	Compared to industry-wide facilities, production facilities are larger and more
complex. While the District may inventory the facility on an annual basis for
reporting programs other than "Hot Spots", prioritization scores, and subsequent
HRA requirements, are only created once every 4 years.

•	Fees for production facilities are estimated based on two elements, each described
below:

o Category:

¦	Fees categories are risk-based, as determined by a district approved
Health Risk Assessment (HRA) or prioritization scores, and
aligned with the categories described in ARB- "Hot Spots" State
Fees Categories & Costs. The categories are based on cancer risk
or a combination of both cancer and non-cancer (Acute/Chronic)
risk, as reflected in categories ,B, C, D, F, and G.

¦	Categories are determined by the most recent approved HRA
results. If the facility does not have an approved HRA, then the
most recent prioritization scores should be used. If a facility has a
prioritization completed that triggered conducting a HRA, the
prioritization cancer scores will be used for assessing its Hot Spots
Fees, pending the approval of the HRA. The Prioritization Cancer
Scores will also be used to determine Fees for the facilities that
didn't trigger a HRA requirement. In both cases, the Cancer score
will be compared to the Categories (A) of ARB- "Hot Spots" State
Fees Categories & Costs7 and the (Update Facility or Low-Level
Facility) Categories of CARB-"Hot Spots" Fee Categories
Flowchart, to specify the Fees.

6 https://ww2.arb.ca.gov/hot-spots-state-fees-categories-costs

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Engineering Division Manual of Procedures

o Complexity

¦	Site complexity is based on the number of site processes as
determined by six-digit Source Classification Codes (SCC). ARB-
Air Toxics "Hot Spots" Fee Regulation- Title 17 CCR 907017,
defines the facility as being:

•	Complex Facility: has more than five processes.

•	Medium Facility: has three to five processes.

•	Simple Facility: has one or two processes.

¦	The Calculation method in EIS captures the SCC of the facility
processes and the number of unique captured SCC in the facility
Emissions evaluation is used to specify its complexity.

15.2 Guide to EIS

Please follow the Step-by-Step instructions in this general guidance document for
emissions inventory data entry, reporting, calculating prioritization scores, and tracking
status (workflow). For details regarding particular operations, please use the District
Toxics page for reference. Any specific questions that arise during the inventory process
can be addressed to any of the engineers in the Toxics group.

https://www.sandiegocountv.gov/content/sdc/apcd/en/engineering/Permits/Engineering
Emissions Inventory.html

1) How to Log in to your EIS account

1.	Go the following address: http://cosd-

www.cloudapp.net/COSD/Account/LogOn?ReturnUrl=%2fCOSD%2f.

2.	Log in using your District email address and the password you created when you set up
your EIS account.

3.	If you have difficulties with logging in, you may try re-setting your password by
clicking on "Forgot Password". After providing a new password, try logging in with the
new password.

7 https://ww3.arb.ca.gov/regs/titlel7/90701.pdf

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Engineering Division Manual of Procedures

San Diego APCD - Emissions Inventory System (EIS)

APCD

AIR POLLUTION CONTROL DISTRICT

COUNTV OF SAN DIEGO

EIS Login Page

EIS is Only Available from Monday to Friday,
7:00am to 7:00pm, Pacific Time

A Usemame

A Password
D Remember me

Forgot Password?

HS Version 2.1.2 en-US - Q5-Apr-2019
© 2012-2019 Lakes Environments! Software

2) How to enter data into EIS

There are two options for data entry in EIS:

a.	PRDCOSD (Production) - this is where all facility data should be
entered and stored if the facility did NOT enter data themselves into the
Portal (below) meaning the facility provided data request via hardcopy or
electronic copy.

b.	APCD Portal (Portal) - this is where the Facility directly entered data
themselves with their own EIS account. If the Facility entered data in the
Portal, this should be QA'd for completeness. Click on PRD COSD.

Data Entry Via Production -
. Per District Rule 19.3, data submitted by the facility will be submitted using the data
request forms till data year 2021 and then use of the EIS portal will be required The Aide
or EI Team Member may should download the data submitted by the facility and upload
to the appropriate Everything placed in the SharePoint will be found using the following
link:

https://sdcountvcagov.sharepoint.com/sites/apcd/Engineering/SitePages/Home.aspx7Root
Folder=%2Fsites%2Fapcd%2FEngineering%2FShared%20Documents%2FEmissions%2
0Inventorv%2F2%20%2D%20Emissions%20Inventorv&FolderCTID=0x012000EE39B
A8F198AD74CB4B836087AAE73F3&View=%7BC34333F3%2DE384%2D44A8%2D
860B%2DA667D 1 DB7A7F%7D

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Engineering Division Manual of Procedures

1. Click on the Production link (PRDCOSD) which will take you to the Data Request
Dashboard.

Select EIS Project



[Enler search tags fi | ^

<



# Project Name

Project Description

z: i pro cost)

PRD_COSD



2 APCD - PORTAL

PRD - Public Portal





2. Select the Inventory year you want to enter data for by clicking on the "Inventory:
Year - Year Inventory Production" towards the upper right part of the screen.

Inventory Configuration

Please select an emissions inventory to work with from the list, by clicking on the Inventory Name.

P

#

Inventory Name v

Created By



Creation Date

n





~



i

2016 - 2016 Test

Mar/ Vasquez



06-Apr-2016

2

2015 - 2015 Mary's new inventory

Mary Vasquez



15-Mar-2016

3

2015 - 2015 Inventory New (spare)

Mary Vasquez



08-Apr-2016

4

2015 - 2015 Inventory (Production Spare)

Mary Vasquez



03-Jun-2016

5

2015 - 2015 (2nd Spare)

Mary Vasquez



12-Apr-2016

6

2071 - EASIER Import Production

Mike Johnson



03-May-2018

7

2018 - 2018 Inventory Production

Russell K. Yanagihara



19-Sep-2018

8

2017-2017 Inventory Production

Russell K, Yanagihara



18-Apr-2018

9

2016 - IW Import Test

Elizabeth Davis



16-May-2017

10

2016 - 2016 Inventory Production

Mary Vasquez



22-Feb-2017

3. Click on the Emissions link towards the top of the screen.

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Engineering Division Manual of Procedures

4. Here you can select from two different formats for entering data (Data Entry Direct or
EI Questionnaire). For this example, select Data Entry Direct.

Oathboardt FnUwiom, Rid Ticketing Document* Map R*$orci Svctvigf Admin

Emissions Emissions Data

Morrtv If n^r.vcrv^ frnu.tianx OmLb

Entry Direct

El Questionnaire

5. Here is where you can search for your facility to enter data in the search box using the
Facility name or EIF ID. When you find your facility, click Select.

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Engineering Division Manual of Procedures

Dashboards Emissions Risk Ticketing Documents

Map

Reports

Settings

Admin

Calculation Configuration

Home Emissions Emissions Data Data Entry Direct









Calculation Configuration











Facility









<

* jjs*











# Facility Name







Elf 10



1 General Dynamics NAS5C0





19





2 Canyon Rock





27





3 CEMEX Construction Materials Pacific LLC





56





4 Cabrillo Power I LLC





73



6. This is the Calculation Configuration page where all Sites, Permits, Devices, and
Materials are listed. All data entries are to he done for under Materials. To begin
entering data, select the device and click on one of the materials listed for a listed
device. A note about device numbers - within a facility, no 2 devices can have the
identical device number. New device numbers should follow the following format:
use the permit number if there is only one device associated with the permit, but if
there are 2 or more devices, use the last 4 numbers of the permit plus 2 sequential
numbers (i.e., PTO-971234, the device number would ready 123401, 123402, etc.).
The default number of permits /pages that appear in the platform is 5 permits, this can
be increased up to 80 permits.

7. Select the appropriate Calc Method corresponding to the Permitted operation. This
will be reflected in the title of the Facilities Data Request and the permit description.
Click Select Calculator, then select from the listed calc methods.

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Engineering Division Manual of Procedures

Clear Selectio,

Description:

A01-B18-Boiler-I\latura;l Gas Fired-0.3-100 mmBTU/hr-Flue Gas Recirculation



?. Scroll down to Calculator Parameters & Requests. There are 4 sections listed where
you will enter raw facility data:

a.	Data Requests - complete all sections according to facility provided data
request. Ensure that annual and hourly usages have been provided by facility.

b.	Control Requests - Several facilities will already have this data pre-entered
however a QA should be done versus submitted data requests to ensure this is
correct. If blank, fill in all control parameters according to data request and
ensure that the sum of the capture efficiencies equals 100%.

c.	Emission Factors - For each selected calculation method, default Emission
Factors will auto-populate. For those facilities that have devices with specific
emission factors based on source test data or for specific paints, those will
require to be manually updated and the origin of the source test data should be
chosen. See Source Test tip in later section of this guidance document.

d.	Surrogate Pollutants (if needed) - For some pollutants, surrogate pollutants
must be specified. One example is hex chrome. While the Welding and
Thermal Spraying calculation methods have this built in, if there are other
calculation methods or other pollutants that need this, the procedure is as
follows (using chromium as an example). Press the Add button and under the
Pollutant column, add Chromium, Total and the corresponding Surrogate
Pollutant should be Chromium, Non-Hexavalent. Add one more line and again
add Chromium, Total and the corresponding Surrogate Pollutant should be
Chromium, Hexavalent.

Calculator Parameters & Requests

EMHcrlpUons

Aoi-Bia-Bolliw-Natural Ga% ftieil-0.3~100	Gas RmeirrtiUlIwi



Maximum Uiqt (U/iMnn i d?6 q	Rut Car R«?c»n

Sulfur Content llbaftniwon t3fc n	-waMrii

SCR tyM/DO)c	NO

Hum Opur^don (ymvnof	No

RHti Sum Operation {yB/no|;	NO
Other Control! <0laasc dascrlbaK

Daily Operation |t»ours/OayK
Annual Operation {dayyyeatk

9. Scroll back up towards the Materials section and click Save.

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Engineering Division Manual of Procedures

10. Repeat steps 7 through 9 for ALL listed Materials for the Facility. Ensure that all data
entries for each material are saved prior to moving to the next material, to avoid data
losses.

Data Entry Via Portal -
If the Facility provided data online via the EIS Portal, there should be an email by the
Facility stating that their data was submitted online in the appropriate SharePoint folder
for that inventory year. Use the same link

(https://sdcountvcagov.sharepoint.com/sites/apcd/Engineering/SitePages/Flome.aspx7Roo

tFolder=%2Fsites%2Fapcd%2FEngineering%2FShared%20Documents%2FEmissions%

20Inventorv%2F2%20%2D%20Emissions%20Inventory&FolderCTID=0x012000EE39

BA8F198AD74CB4B836087AAE73F3&View=%7BC34333F3%2DE384%2D44A8%2

D860B%2DA667D1DB7A7F%7D)

to check how the Facility data was provided to the District. Use the following procedures
for Portal entries.

1. Click on link next to "Project:" in upper right-hand corner of page if currently in
Production (PRDCOSD) which will take you to the Data Request Dashboard.

Select EIS Project

Project Description

PRD_COSD
PRD - Public Portal

2. Select Facility you want to enter data for by clicking on the "Inventory: Year -
Year Inventory (Facility)" towards the upper right part of the screen. Then search
for the Facility

3. Click on the Emissions link towards the top of the screen.

PI v

Project Name

d ? APCD - PORTA) U

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Engineering Division Manual of Procedures

APCD

AIR POUUTION C0NTR8L DISTRICT

COUNTY Of IAN OIFBO

Dashboards w Emissions Risk Ticketing Documents Map Reports Settings Admin

Data Request Dashboard

Home Data Request Dashboard

Permits

1424

From 128 Facility Records

Data Entered Progress

250

Linked to 1424 Permit Records

Entries Remaining:

Status	Facility

4. Here you can select from two different formats for entering data (Data Entry
Direct or EI Questionnaire). For this example, select Data Entry Direct.

Cukthboardi FmlMiom Rivit Tickttog DocumMiK Map fteportc	Admin

Emissions ¦ Emissions Date

Hani* frr -.' ;-*ii f muviefli Dili

Data Entry Direct

El Questionnaire

5. Check to ensure all data entered by Facility is completed for each material in the
Calculator Parameters & Request section. As in Production, ensure that the
Control Request tab is also complete and correct and that the capture efficiencies
equal 100%. If there is any required data missing (e.g. annual usage, hourly usage,
or operating schedule) contact Facility to acquire that information.

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Engineering Division Manual of Procedures

Calculator Parameters & Requests

Calculator Name;

A01-B18

ftiel Type

Annual Fuel Osage wmllten ftayesrK
Maxv.rcsum Fu«l Wugfl fft3/Vm«l:
Fuel Sulfur Content |?&si,rrWIHoa ft3):
R»jwifff|y SoOrue T«sWH (yrt/fwj;

*JATVRA1 GfiS

2293

1026.9

~ear Selection

Description:

AOi -018-Boiler-Naturftl Gas F*red-Q,3-1QQ mmETru/tir-Fiue 6« Reatcuiation

• Low HO* Burners (yesftKtf:
- riueGas Recirculation (yec/noj:

-	Wster »n)etlion (yes/not

-	Steam »njeeflw» ^yes/rtoj:

-SCRoi (djyifyoar'i:

6. Once data has been confirmed to be entered by the facility. The user will generate
a PDF copy of the data submi tted using the "Data Entry Forms"

Accel a Automation®	X ^ EIS | Emissions - Data Entry Forr- X l3 Enqineer.ig -

G £ftl A Not secure I cosd-www.cloudapp.net/COSD/Nav/IV

Dashboards C Emissions J Risk Ticketing Documents Map Reports

APCD

br ftMtulion Conlrol Dittnci

Emissions - Data Entry Forms

Home Emissions Data Entry Forms

II Emissions Data

Upload EIQ Spreadsheet

impoT EIQ data fro1^ an Excel nil

Inventory Setup

!S Calculators

^ II Data Entry Forms

SS Tools

M

Download EIQ Spreadsheet

Excort EIQ data to ar Exce f 
-------
Engineering Division Manual of Procedures

To print out the completed data forms deselect the following options which are
defaulted as active: "Export Required Fields as Blank" and "Include Blank
Forms"

••'J. > Accel a Automation®	x	EIS | Download EIQ PDF Forms X & Engineering - Home	x | & Engineenrvq - Home	X -f-

G IaI 4 Not secure ! cosd-www.cloudapp.net/COSD/EIQPDFExport/Step

Emissions Risk Ticketing Documents Map Reports Settings Admin

APCD

Download EIQ PDF Forms

Home Emssicos Data Entry Forms Download EIQ PDF Forms

This will prompt the user to the Queue where you can download the completed
Data Requests for the Facility. Once finished, click View Files and then click
Download. Save pdf file to SharePoint to have a copy of the facility submittal.

7. Once the data has been saved the data can be migrated back into the Production
inventory from Portal. While in Production inventory for the particular inventory
year you want to import data back into go to the Admin menu on the top and
Portal Admin function on the left menu. Select "Inventory Synchronization".

I fc, US | • Band	K Of

O & A -"-iurr CWd wwXk:KjdiffMWLO

APCD

Once selected the user will be taken to a screen to start selections on importing
the data back into Production. Select "Update Production Projects from Public
Portal"

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Engineering Division Manual of Procedures

*'1B i&jcfU Aufnn!.»!r:in 1	X	FfS | Irt*rtg - hhm:*	X f^i F.- t;» H;j'i

f	G fiS A New secure fosd-www.clc-iJttapp.nW' OSl;/WL*v,rrtmentory/S1eri

Mr| bunara Uro *uuh

ARCD

l.t IU«1

fefc r«j»

O Upfaw fi whwUin f i ijitta fcww ftwfcfa. Nrid

9. The user is then able to select which Portal inventory to migrate back into the
Production Inventory

APCD

iwawcteuddppjirt

A <§ t

10.	Once the data is migrated into Production the user can now verify data and hook
up calculation methods for the inventory.

11.	Select the appropriate Calc Method corresponding to the Permitted operation.
This will be reflected in the title of the Facilities Data Request and the permit
description. Click Select Calculator, the select from listed calc methods.

Clear Selection

Description:

A01 -B18-Boiler-Natural Gas Fired-0,3-100 mmBTU/hr-Flue Gas Recirculation

^ Select Calculator ^

12.	Scroll back up towards the Materials section and click Save.

13.	Repeat steps 11 through 12 for each Material listed for the Facility.

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Engineering Division Manual of Procedures

3) How to RUN FACILITY EMISSION CALCULATIONS

Basic knowledge of what the appropriate calculation(s) for each equipment / material is
not discussed here. If you have any questions regarding this, please don't hesitate to get
help from more experienced EI group members. All Calc Method information and
equations are located in the District's Toxics page and can be found using the following
link

https://www.sdapcd.org/content/sdc/apcd/en/engineering/Permits/Engineering Emissions

Inventory/Engineering Phase 3 Toxics Procedures.html. This will be required for
having to QA the EIS batch calculation reports and Facility Emission Reports discussed
below.

1. From the Emissions menu, click on Calculators icon on the left side of the menu.

APCD

AIR POLLUTION CONTROL DISTMCT

COUNTY Of 8 R N 01(60

Dashboards

Risk Ticketing

Map

Reports Settings

Emissions - Emissions Data

Home Emissions Emissions Data

Admin

Emissions Data

S3 Inventory Setup

S3 Calculators

S3 Data Entry Forms

Data Entry Direct

Manage device and material data for the permits

2. From the selection of menu items, click on the Batch Emissions Calculation icon.

WIS •wentory S

Us«r Calculators - {raatc/f drt

_J	Enrnwom Intimation Paramatan • Unport/f xport

Batch Emission, Results Output

*

Job Quew Batdh taintana Cakulitw (BEC)

Cakulai&rs Reports

3. On Step 1/3, select the specific Facility you want to quantify emissions and run
batch calculation and click Next.

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Engineering Division Manual of Procedures

Select

4. On Step 2/3, add a "notes" name:

a. Notes - Enter the Facility Name, followed by the Inventory Year and

include the EID for the Facility so you can identify the batch calculation in
Queue.

Click Next when done.

Step 2/3: Batch Emissions Calculator (BEC)

Unit of Measure - Criteria Pollutants:

TONS

BEC Output Settings

Unit of Measure - Non-Criteria Pollutants:

POUNDS

The Batc» Emissions Calculator jfBEC)
allows you to calculate emissions for
multiple facilities and for muttipie
processes in one easy step.

5. On Step 3/3, review summary of criteria selected for Facility and click Finish.
This will run the batch calculation for the Facility where you will be able to view
the quantified emissions for the entire Facility in the Queue.

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Engineering Division Manual of Procedures

Stcfi 3/3: GdSth Emiwlom Calculation







SuteniCMl On:

'IPnits of Mmun:

J

2019.1*0*08



tpir-:t Summary

Sufe«nit[*d By:

Crit *n» Until «f Mejvure:

M Ovt» « CCTeifSf frwRPiw

Errvwitary Yur.

f million Citfjerf.



Cakutato* mod*:

fKftty:



Hotw





Mtnnt&cto Wl«ehv>*_201 i ft»D 04224)



6. Once the Facility has finished running the batch calculation, click on View Files
for that Facility.

7. Here you will be able to view the Annual and Ftourly Emissions for each Material
listed for the Facility in an excel spreadsheet. To view Annual and Ftourly
Emissions, download the "Batch Emissions Calculations Excel file". From these
spreadsheets, you can filter and sort emissions based on Permit #, Device,
Material, or Pollutant.

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Engineering Division Manual of Procedures

Job Files

Enter search tags...	LP

#

Download

Description

File Name

Added On

1 <

^ Download J

Spreadsheet

Sharp Cororado hospital &
Healthcare Center,xlsx

16-Mar-2Q21, 17:10:41



Point Location

Facility Device

Material

Emission Period

Pollutant Equation Term

Equation Expression

Term Value

Unit of Measure

Note Calculation Method

San Diego County

Minnesota Methane LLC North '*960022

1-LANDFILL GAS

ANNUAL

Nitrogen cANNUALUSAGE



165.7

million ft3/year

A01-E11 - vl

San Diego County

Minnesota Methane LLC North >'960022

1-LANDFILL GAS

ANNUAL

Nitrogen t EF



58.15



AQl-Ell-Vl

San Diego County

Minnesota Methane LLC North 1*960022

1-LANDFILL GAS

ANNUAL

Nitrogen (MAX_HOURLY_USAGE



425

ft3/min

A01-E11- vl

San Diego County

Minnesota Methane LLC North '*960022

1-LANDFILL GAS

ANNUAL

Nitrogen 0.0, ANNUAL,

0



A01-E11 - vl

San Diego County

Minnesota Methane LLC North 1*960022

1-LANDFILL GAS

ANNUAL

Nitrogen 0.0, MAX_HO

0



A01-E11 - vl

San Diego County

Minnesota Methane LLC North '*960022

1- LANDFILL GAS

ANNUAL

Nitrogen (AED

IF(EF >0.0, ANNUAL_

9635.455



A01-E11 - vl

San Diego County

Minnesota Methane LLC North '^60022

1-LANDFILL GAS

ANNUAL

Nitrogen (HED

IF(EF >0.0, MAX_HO

1.482825



A01-E11 - vl

San Diego County

Minnesota Methane LLC North '*960022

1-LANDFILL GAS

ANNUAL

Nitrogen (AED_AND_AEF

AED+AEF

9635.455



A01-E11 - vl

San Diego County

Minnesota Methane LLC North '*960022

1- LANDFILL GAS

ANNUAL

Nitrogen t_FinalValue_

AEDANDAEF

9635.455

LB

A01-E11 - vl

San Diego County

Minnesota Methane LLC North '*960022

1-LANDFILL GAS

ANNUAL

Nitrogen (Total Emissions

Total Emissions

4.8177275 TON

A01-E11 - vl

4) How to QA EMISSIONS

Both Annual and Hourly Emissions from the Facility batch calculations will require QA
versus the District approved calculation methods listed in the Toxics page using the
following link:

https://www.sdapcd.org/content/sdc/apcd/en/engineering/Permits/Engineering Emissions
Inventory/Engineering Phase 3 Toxics Procedures.html

1.	To QA Annual and Hourly Emissions in the batch calculations, download the
"Batch Emissions Calculations Excel file" spreadsheet located in the Job Files as
shown above. This is called the Batch Emission Calculation (BEC) Report where
all emissions are quantified for the given Facility.

2.	Filter out by Calculation Method selecting one calc method at a time to QA to
ensure that the emissions are quantified correctly in EIS. Then filter out by
Equation Term column to view the Total Emissions. You will also be able to view
all input parameters in the Equation Term column which should also be checked
to ensure the data entries into the data request forms match what was entered into
EIS.

Pollutant



Equation Term -t





Equation Expression



Term Vali^ -

t of Me *

Note -

Calculation M

Nitrogen Oxides (NOx)

Tota

Emissions

Tota

Emissions





4.8177275

TON



A01-E11 - vl

Carbon Monoxide (CO)

Tota

Emissions

Tota

Emissions





26.455662

TON



A01-E11 - vl

Sulfur Oxides (SOx)

Tota

Emissions

Tota

Emissions





0.608119

TON



A01-E11 - vl

Total Organic Gases (TOG)

Tota

Emissions

Tota

Emissions





1.5584085

TON



A01-E11 - vl

Total Particulates (TSP)

Tota

Emissions

Tota

Emissions





1.90555

TON



A01-E11 - vl

Particulate Matter (PM10)

Tota

Emissions

Tota

Emissions





1.90555

TON



A01-E11 - vl

Acetone

Tota

Emissions

Tota

Emissions





3.51284

LB



A01-E11 - vl

Acrylonitrile

Tota

Emissions

Tota

Emissions





2.88318

LB



A01-E11 - vl

Ammonia

Tota

Emissions

Tota

Emissions





0

LB



A01-E11 - vl

Benzene

Tota

Emissions

Tota

Emissions





1.29246

LB



A01-E11 - vl

Carbon Disulfide

Tota

Emissions

Tota

Emissions





0.38111

LB



A01-E11 - vl

Carbonyl Sulfide

Tota

Emissions

Tota

Emissions





0.24855

LB



A01-E11 - vl

Chlorobenzene

Tota

Emissions

Tota

Emissions





0.24855

LB



A01-E11 - vl

Chloroform

Tota

Emissions

Tota

Emissions





0.03314

LB



A01-E11 - vl

Chlorofluorocarbons

Tota

Emissions

Tota

Emissions





1.22618

LB



A01-E11 - vl

Dimethyl Sulfide

Tota

Emissions

Tota

Emissions





4.17564

LB



A01-E11 - vl

Ethyl Benzene

Tota

Emissions

Tota

Emissions





4.20878

LB



A01-E11 - vl

Ethylene Dichloride

Tota

Emissions

Tota

Emissions





0.34797

LB



A01-E11 - vl

Formaldehyde

Tota

Emissions

Tota

Emissions





22.3695

LB



A01-E11 - vl

Hexane

Tota

Emissions

Tota

Emissions





4.87158

LB



A01-E11 - vl

Hydrogen Chloride

Tota

Emissions

Tota

Emissions





1231.151

LB



A01-E11 - vl

Hydrogen Sulfide

Tota

Emissions

Tota

Emissions





10.40596

LB



A01-E11 - vl

Methylene Chloride

Tota

Emissions

Tota

Emissions





10.45567

LB



A01-E11 - vl

Methyl Ethyl Ketone

Tota

Emissions

Tota

Emissions





4.40762

LB



A01-E11 - vl

-312-

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Engineering Division Manual of Procedures

3.	To QA emission calculations, you can either use the District Toxics website (link
above) and its calculation procedures or SharePoint QA Calc Spreadsheets using
the following link

https://sdcountycagov.sharepoint.com/sites/apcd/Engineering/SitePages/Home.as
px?RootFolder=%2Fsites%2Fapcd%2FEngineering%2FShared%20Documents%
2FEmissions%20Inventory%2FCalculations&FolderCTID=0x012000EE39BA8F
198AD74CB4B836087AAE73F3&View=%7BC34333F3%2DE384%2D44A8%
2D860B%2DA667D1DB7A7F%7D. The Districts Toxics website provides all
reference information for each calculation method, so it is recommended that this
be used in addition to the SharePoint Spreadsheets to gain a better understanding
of all input parameters.

4.	When QA'ing the BEC Report, its best to filter out each calculation method and
spot QA its corresponding pollutant emissions. Once the calc method has been
determined to be correct in calculating emissions, you can then filter out to the
next calculation method on the batch emission spreadsheet until all emission
calculations have been QA'd and are determined to be correct.

5) How to GENERATE A FACILITY WIDE EMISSIONS REPORT

Once all the emission calculations from the Facility have been determined to be correct
after the QA process, you will then be required to submit a Facility Wide Summary
Emissions Report to the Facility, for their review and approval. This Report will include
the following:

A.	Facility Wide Emission report with quantified Annual and Max Hourly
emissions for both Criteria Pollutants (NOx, SOx, VOC, TOG, PM10,
TSP, and CO) and speciated Toxic Air Contaminants (TACs).

B.	Completed Data Request Forms which has the data that is entered into EIS
for the Facility and compiled into one pdf document.

C.	Cover Letter (to be generated by APC Aide)

D.	Emission Statement if NOx and/or VOC emissions are >25 tons/year.

Step A. - Facility Wide Emissions Report -

1. Click on the Reports link towards the top of the screen then click on All Reports.

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Engineering Division Manual of Procedures

C.a«htxufd% Imnuom Risk Txkvlmf Pc
-------
Engineering Division Manual of Procedures

Reports

3 G«*ral
It Com Utter
EI I IS Rrpcrt*

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Mult> Vtjif

3. Enter the Facility Name or EID in the search box and then check the Selected box.
Then Click Finish.

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Engineering Division Manual of Procedures

Step 1/1: facility Emissions - Scientific Wizard

select facilities
95165 •

C^Vi

* p .r

Cobtom Advanced tlectronw: soluoww lnc

lii^l

4.	Once the report is generated, you can download and save in multiple formats
(word, pdf, or excel). After downloading Report, QA the Annual and Max Hourly
emissions versus what is in the BEC report. If there are any errors in the Facility
Wide Report, follow the procedures in Section 6, Emissions Inventory Tracking.

5.	If the Facility Wide Emissions Report is correct, save a copy onto SharePoint.

Step B. - Generating Completed Data Request Forms-

1. Click on Emissions, then click on Data Entry Forms on the left-hand side of the
screen.

ARCD

AIR PDtLUTION CONTROL DISTRICT

C0U1IV OF 81N DKCO

Dashboard^! Emissions Risk Ticketing Documents Map Reports

Settings

Emissions - Data Entry Forms

Home Emissions Data Entry Forms

Emissions Data

Upload EiQ Spreadsheet

import EIQ data from an Excel file

Inventory Setup

¦2 Calculators

Data Entry Forms

Download EIQ Spreadsheet

Export EIQ data to an Excel file

Download EIQ PDF Forms

Generate a PDF of completed ant	a forms

2. Select Facility by typing in name or EIF ID into the search box, then click Next.

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Engineering Division Manual of Procedures

Slep 1/2. Download EtQ 5prtru |

3. Uncheck the box Export Required Fields as Blank and check the box Export
File(s) as ZIP. Then check off all permits in the Air Permit Number column, then
click Finish.



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-------
Engineering Division Manual of Procedures

Job Files

II

0

>>

1

#	Download	Description	File Name	Added On	Added By

. u-	EIQ_PDF Cobham Advanced Electronic	„ __	___ . .

C Download* Zip Archive	- , .	03-Apr-2019, 17:14:22	Travis Arciaga

^Solutions Inc.zip

5. After completing Steps A and B, email the Toxics Senior Engineer (or their
delegate) with either the two documents attached, or an indication where in
SharePoint the documents are saved, for their review prior to moving to Step C.
For facilities subject to a toxic emission inventory, also attach the prioritization
scores (See Section 7).

Step C. - Cover Letter -

1.	After the Facility Wide Report and Completed Data Requests have been reviewed
and approved by the Senior Engineer (or their delegate), email both documents to
the Toxics Section Aide with a short message stating that the Report is ready to be
finalized and provided to the Facility. The Aide will prepare the draft Emissions
Inventory Report letter for you to sign which will be mailed out and emailed (if an
email address is available) to the Facility for their review. The letter will use the
approved report letter template and list the attachment at the bottom. If a facility
requires an Emission Statement, the letter will list it in the attachment and the full
report must be mailed via certified mail. The template letter for TEI will include
the draft prioritization scores, if any of the scores are above the threshold to
require a Hot Spots health risk assessment. The letter will indicate that it is a draft
for the facility's 30-day review.

2.	Once the facility's comments (if any) are addressed, or if 30 days has past and the
facility did not provide any comments, an approved Emissions Inventory Report
letter will be created and sent to the facility indicating the inventory has been
approved. If this is for a TEI and the prioritization scores are above the threshold
to require a Hot Spots health risk assessment, the Aide will also prepare and send
the Health Risk Assessment Required letter.

This will conclude the Emissions Inventory for that Facility.

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Engineering Division Manual of Procedures

6) WORKFLOW TICKETING

Tracking inventory Progress should be completed by utilizing the Ticketing module in
EIS.

1.	During the Emissions Inventory process, it is important to update the tasks
assigned to each facility's workflow.

2.	To access the Ticketing module click on "Ticketing" on the top menu of EIS.

Dashboards Emissions Risk Ticketing Documents	Map Reports Settings Admin

San Diego .County

I Air Pollution	,	, „

' Control District I icketing - Workflow

Home Ticketing Workflow

il

Project Workflows

View project workflows

3. Click on the Project Workflows to choose a specific inventory, within an
inventory year

tony*to
-------
Engineering Division Manual of Procedures

related to specific tickets, click on the ticket ID.

CW4o<>rdt fninJ-m lUift fcknlni D«um«na M*p ftavom Vidnji	a£J ^any*ioip«->OnUp
-------
Engineering Division Manual of Procedures

4. Use the dropdown boxes to select the appropriate details regarding the type of
error you are experiencing. For example, for reporting errors (EIS Reporting
feature), select the following:

a.	Category - Reports

b.	Reproducibility - if this is a consistent problem, select Always, otherwise
choose a different option

c.	Severity - if there a significant issue in EIS, mark this area as Major,
otherwise choose from the other options as appropriate.

d.	Priority - Choose Normal unless it needs urgent attention

e.	Select Profile - Select based on the internet platform you are using or skip
this section.

f.	Product Version - ignore this section

g.	Assign To - All EIS errors should be assigned to "lakes_mike" (Mike
Johnson).

h.	Target Version - ignore this section

i.	Summary - provide a brief summaiy title of the error

j. Description - Provide a detailed but brief description of the error
k. Steps to Reproduce - ignore this section
1. Additional Information - ignore this section

m. Attach Tags - its HIGHLY recommended you attach what errors you are
experiencing whether it's with reporting or calculations. For the tag, give
the attached error document a brief name. Its best to identify the inventory
year, Facility name, and EID so it can be quickly resolved by Lakes,
n. Requires documentation - select Yes
o. Upload Files - drop attached error file in the drop section

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Engineering Division Manual of Procedures

14 Enter Gssue Details

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V



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5. Click Submit Issue and monitor the progress of the issue by Lakes. Lakes will

send out an email to the user that submitted the error via Bug Tracker with
information on the status of the error.

-322-

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Engineering Division Manual of Procedures

7) HOW TO CALCULATE FACILITY WIDE PRIORITZATION
SCORES

For facilities subject to a Toxic Emission Inventory (tagged "tei" and subject to the Air
Toxics "Hot Spots" Program, AB2588), and other facilities the District wants to
determine if they would impact their communities for which their toxic emissions have
been calculated (such as facilities within the Portside Environmental Justice Area),
prioritization scores will be calculated, while compiling the Report for the Facility, to
determine whether a Health Risk Assessment (HRA) will be required for the Facility.
Prioritization scores do NOT take into account Criteria Pollutants (NOx, VOC, TOG,
SOx, TSP, PM10), therefore only Toxic Air Contaminants will be quantified for
Prioritization.

A. Development & Updating EIS Pollutant Table and Health Data

Per AB2588, Emission Inventory Criteria and Guidelines (EICG) for the "Hot
Spots" Program, the District is required to prepare emission inventories for
facilities which emit TACs. Appendix A of the EICG and the District's Rule 1200
establish which pollutants need to be inventoried. To be included in creation of
prioritization scores, pollutants must be assigned health values including type and
rate of toxicity. Health data has been established from several different
organization and sources, including California's Office of Environmental Health
Hazard Assessment (OEHHA). CARB and OEHHA regularly adopt new
pollutants to be inventories and new health values when data becomes available.
The EIS pollutant table should be updated to include newly adopted pollutants
and health values after regulatory amendments are final or advised by CARB
and/or OEHHA. ARB continually updates and presents the adopted pollutants and
health values on the Consolidated Table of OEHHA/ARB Approved Risk
Assessment Health Values8

a. Pollutant Flags - Each pollutant within EIS is assigned pollutant flags in
order to calculate emissions and prioritization scores accurately. Each
pollutant is assigned a True (T) or False (F) tag for each of the following
categories. Note a 'NULL' or blank flag will result in a calculation error
for the selected calculation method.

i.	VOLATILE_FLAG - assigned to a pollutant if it is a volatile organic
compound (VOC)

ii.	ROG_FLAG - assigned to a pollutant if it is a reactive organic
compound

iii.	EXEMPT_SOLVENT_FLAG - assigned to a pollutant if it is an
exempt solvent per District Rule 2, Rule 11 and Rule 66.1

iv.	TOXIC_COMPOUND - assigned to a pollutant if it is a toxic
compound

v.	PARTICULATE_FLAG - assigned to a pollutant if it, or its
byproduct, is a particulate emission and not a VOC

8 https://ww2.arb.ca.gov/resources/documents/consolidated-table-oehha-carb-approved-risk-
assessment-health-values

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Engineering Division Manual of Procedures

Use the following District guideline as a reference for understanding Prioritization
procedures for the Air Toxics Hot Spots Program (AB2588):

https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Toxics Program/APCD Air Toxics
Hot Spots Prioritization Procedures.pdf

A. Initial Prioritization Run

For purposes of determining the prioritization scores at the time of the draft inventory
(per Section 5. Step c.l, above).If the results from the initial run indicate a HRA is
needed, facilities may provide additional information that could affect the scores, then
the additional information should be added in the appropriate run to see if a FIRA is
still indicated or not. These adjustments are typically in the form of a revised
emission inventory called a refined acute scenario.

1. Click on the Risk link towards the top of the screen.

APCD

Dashboards Emissions

Ticketing

Main Dashboard

Air Pollution control District Home Main Dashboard

Inventory Year

s jim.swaney@sdcounry.ca.gov - O
Inventory: 2019 - 2019 Inventory Test

2019

*019 4019 «nvenio»y S Change

T«l

Facilities

28S

Located -n San Diego i= List
tnunry

Release Points

3,758

witfWn 33S f

Emissions by Facility

Emissions reported In Tons, unless staled In grid below

t ntra SH»ch lags

Y,

215

fcn»tted from 288 B Reports

facriiriK

2. Select Prioritization Scores

-324-

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Engineering Division Manual of Procedures

&

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Q Prior rtu«l ion

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; IKLil *r»d Urwi^sfc t'ftcien

Exctuti«4 Pollutants Management

On the next screen, is a field to name the prioritization scenario. Use the format
"Inventory Year, E1D ####, Facility Name" to name prioritization runs. There is
also a check box to indicate if you want to include criteri a emissions in the HHRP
(Prioritization) Report - typically this is not needed, except in a specific
situation9. Select Compute baseline prioritization scores.

Ak Pollution
Control CMftrfcl

4.

5.

©<-

Receptor Distances

One of the factors considered when prioritizing facilities is the receptor
distance.

Receptor Distances equal to or Great Than 50 Conservative receptor distances
will be applied, as described per the District's Prioritization Procedures. Distance

9 Facilities that report zero usage for all devices within an inventory year, criteria pollutants must
be included in the prioritization run in order to indicate the facility's scores were reviewed. This
will require that emissions have been calculated for at least one device/material for the facility
for the criteria pollutants (they will show as zero emissions).

-325-

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Engineering Division Manual of Procedures

should be estimated on Google Earth, from faiclity to closest receptor. KMZ files
showing the distances should be saved in the facility's respective SharePoint
folder. Facilities can request to adjust distances by providing more detailed
information, such as PFDs and site-maps. A HHRP Specific Distance report
should be provided with every Draft TEI report so the facility can review the
conservative distances that were applied.

Air Poilirtion
Sjgf Control District



Map

RcperU

S*«Uhijs

Pripntraartit** Rcpc«rfc»

6. On the next screen,, select the facility either by scrolling and highlighting it, or
by using the search box using either the Facility Name or EIF ID. Check the box
next to the facility and click Next.

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Engineering Division Manual of Procedures

APCD

Dashboards Emissions Risk Ticketing Documents More...

Prioritization Run

I tome Risk Prioritization Prioritization Run

25 jim.5waney@sdcounty.ca.gov »

Inventory: 2019 - 2019 Inventory Test

Step 2/3: Prioritization Run

Facility Selection

«usq i htr faciinio \0 0'
included in the
priacmwuon fun.

All Facilities
Q Specific Facilities'

Cnler search tags

* rr

a

facility Name

EIF ID

sic | NJUC5 street Address

city

Tags jj

i

Dd General Dynamics NASSCO

19

^ 336611 2798 East Haibor Di

San
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< Previous I New >

7. After selecting the facility, click 'Next', to input receptor distances. Choose 'Auto
Fill Distances' to autofill or override previous distances entered. A facility, with
any receptor type, less than 50 meters away should choose 'Has Receptors that are
<50m' and default to 50 meters for that receptor type.

a

PflDjCOSO

-327-

-------
Engineering Division Manual of Procedures

8. The next screen, will show your selections. If any selections need to be changed,
click Previous to change them, or click Finish to run the prioritization scores.

APCD

Air Pollirtion Control District

Ticketing

Prioritization Run

Home Risk. Prioritization Prioritization Run

jim.5waney@5dcounty.ca.gov -
Inventory: 2019 - 2019 Inventory Test

Step 3/3: Prioritization Run

Summary

seistini «irsvi pres* lbs
Finish hunon

Scenario Name:

2019. EID 19, NASSCO Prioritization Score - Q9-Mar-2021
Toxicity Table:

Master Exposure Table - Z02D*12-If«

Facility Selection;

Ail Facilities

Receptor Distance - Standard [mj:

SO

Receptor Distance - Acute i[m]:

50

Use Refined Distances:

Yes

Plot Scores:

Yes

Evaluate Criteria Pollutants:

No

< Previa <5 I Finish

The Job Queue - Prioritization Run screen will appear (you can also access this
screen from the main Risk screen). Here you can see the progress of the run.
Once the ran is finished, you can see the HHRP spreadsheet by clicking on files,
then Download the HHRP log.

-328-

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Engineering Division Manual of Procedures

APCD

Dashboards	Emissions	Risk Ticketing	Documents	Mare..

¦II

Prioritization Run

Mr Pollution Control District Home Risk Pri
-------
Engineering Division Manual of Procedures

ABCDE	FGH	I	J

1	E!F ID Facility Na Workshee" Cancer Chronic 8-Hour Acute Default Di: Default Acute Distance

2	19	General 1 - Refinec 3799.594 123.2345 124.1 258.4645

3	1

4	Project: 2019 - 2019 Inventory 3799,594 123.2345 124.1 258.4645

10. District guidelines require facilities perform an HRA with an A prioritization
grade (cancer score > 100, chronic or acute score >10 (HRA currently not
required if the only score > 10 is for 8-hour)). B graded facilities (cancer score
between 1 and 100, chronic or acute score between 1 and 10) may be required to
perform an HRA on a case-by-case basis. C graded Facilities (scores below 1)
will not be required to perform an HRA. After completion, include the scores and
the HHRP file in the email to the Toxics Senior Engineer (as described in Section
5, Step B.5.).

B. Acute Scenarios

1. For facilities that trigger HRA requirements for acute scores based on the initial
or distance refinement prioritization run, there is the possibility for additional
refinements to the score (for cancer and chronic scores, there is no further
refinement that can be done once the emissions are finalized and distances are
included). Acute scenarios take into account which devices and materials actually
operate within the same hour. This will require the facility to provide information
about which devices operate at the same time, and any limitation on which
materials are used. This proposed scenario needs to be reviewed to ensure it
makes sense. For example, if a source has multiple emergency IC engines, the
scenario will include all engines that run (for non-emergency purposes) in the
same hour and will exclude engines that don't run in that same hour. If they have
different hours where multiple engines run, then the scenario should use the hour
that results in the highest score (the HHRP spreadsheet can be used to determine

-330-

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Engineering Division Manual of Procedures

2.

this). For a coating operation within a booth where only one coating is applied at
one time, select the coating that gives the highest score, and exclude the other
coatings. For facility-wide devices (such as welding or solvent usage), care must
be taken to ensure the facility's proposed scenario includes all the activities that
can be done within the same hour. For example, it is not enough to select the one
welding rod that yields the highest score unless it can be demonstrated that the
hourly usage for that rod is the total hourly welding usage for the entire facility.
Note that if an acute device distance will be used, a Distance Refinement nan
using that distance must be run before the acute scenario is run.

Once the acute scenario is determined, then select the Prioritization Run
Refinement option from the main Risk screen.

APCD

Dashboards Emissions Risk Ticketing Documents More,,.

Risk Prioritization

Home Risk Prioritization

8 jim.swaney@sdcounty.ca.gov »

inventory: 2019 - 2019 inventory Test

~

Prioritization Run

Create a new prioritization modeling run

Prioritization Run Refinement

Refine and rerun a previously calculated priortUwtton
scenario

Job Queue - Prioritization Run

Manage the processing of prioritization runs and track
their status

Toxicity Tables

View References Exposure Level* (RED arid Unit Risk
Factors (URF) for air contaminants

Prioritization Device Distance Refinement

Refine Prtorttotlon scores with devices specific distances

^ii i

Prioritization Results

View and eKpon calculated prioritization scores

: ; Facilities, Devices, and Distances

V*. Manage facilities, devkes. and risk specific distances

V i Prioritization Management

^ J Manage Priotl/alion

Prioritization Reports

3. A list of past prioritization runs will appear - select the am that will be used as
the base run (whether it be an initial run or a distance refined run) and select Next.

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Engineering Division Manual of Procedures

APCD

Dashboards	Emissions	Risk Ticketing	Documents	More—

Prioritization Run Refinement

sai iitii canal*

Air Pollution Control District Hump If- I- Prior Ittyalluu Prioritization Run Refinement

& jim,swaney@sdcounty.ca.gov - O
Inventory; 2019 - 2019 Inventory Test

Step 1/4: Prioritization Run Refinement

Select a Prioritization Run:

Enter search lags

Prioritization Run
Selection

Select * Prioritization low
tfut you wont to tofWvr

9

scenario Name

created By

Created
On

Toxicity Tabic

standard Acute
Distance Distance
(m] [m]

1

2019 EID 19 NASSCO Dtetunw '
fteflrwmwtt Rwtt&atlan Sowe - !
Ion M«ir 2021

Jsni SwaneyWsdaiunly.ca.gov
Jwn Swanoy

09 Mar
2021

Mastc* t*posure
Table-2020-12-16



2019	EID 19 NASSCO

2	Prioritization Score 09Mar
2021

2019, EID 19, NASSCO

3	Prioritization Store - 09-Ma«-
3021

Prionti7Bt»on Score - ?fl-r>ec-
" 3020

Prifwiti7nrwn Score - 2S-0ec-

2020

PrtexnrfcUJon Scare - 02-Det-
2020

TITI 2019 Eternal Hills Cemetery
7 (£IF IP 131) Prtontlzatiort Score
- 07-06C-3020

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Cancel Q

On the next screen, a list of all the facility's devices is shown. Select a device
that has materials to be excluded (engines, coatings, welding rods, etc.), and the
list of materials for that device will appear. Check all the materials that will be
excluded, ensuring the material to be included is not checked. Go through all the
devices that have an exclusion, then select Next.

For devices which will be excluded (like diesel engines):

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Engineering Division Manual of Procedures

APCD

Dashboards	Emissions

Ticketing Documents

Prioritization Run Refinement

lai ohm comiii

Air Pollution Control District Home Risk Prioritization Prioritization Run Refinement

jirn.swaney@sdcounty.ca.gov » C*
Inventory: 2019 - 2019 Inventory Test

Step 2/3: Prioritization Run Refinement

Materials Exclusion

3«ctnl the moler i»l> tlirt
thould be excluded Irwn
the wWfHijjiwn Run
Refinement.

EIF ID: 19

Company Name: Genera] Dynamics NA55CO

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site

m Recur
tl>

Air Permit

Permit

Devk;

Device

Niimlwr

Description

IO

Dearriptfor

Excluded Materials.
Q 1 DIESEL
Reasons to Exclude:

- ?0 at48 Pag* 1	of 5 

APCD

Prioritization Run Refinement

(II Hid CiMII

Air Pollution Control District Home Risk Prioritization Prioritization Run Refinement

a 3 jim.swaneytSsdcounty.ca.gov - O
Inventory: 2019 - 2019 Inventory Test

Step 2J3\ Prioritization Run Refinement

Materials Exclusion

Select the TWtcriuls unit
ihe Prlnrtllraiinn Run

EIF ID: 19

Company Name: General Dynamics NASSCQ

l.ntof search isfjs

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Engineering Division Manual of Procedures

5. There is not an option to name the scenario, so on the next screen select Finish to
run the scenario.

APCD

Dashboards Emissions Risk Ticketing Documents More,..

Prioritization Run Refinement

Home Risk Prioritization Prioritization Run Refinement

I. jim.swaney@sdcounty.ca.gov -r

inventory: 2019 - 2019 inventory Test

Step 3/3: Prioritization Run Refinement

Summary

Review [MS opUtJiti. you
selectand press flr«e
nruih button.

Prioritization Run:

?019 FID 19 NA55CO Distance Refinement Pnorlti/aiion Score - 09-Mar-2QJ1
Facility;

EIFIO 19 General Dynamics NASSCO

Excluded Materials:

9

< Previous I Finish

6.

7.

Once Finish is clicked, you will be sent to the Job Queue - Prioritization Run
screen as di scussed in step A6 above.

District guidelines require facilities perform an HRA with an A prioritization
grade (cancer score > 100, chronic or acute score > 10 (HRA currently not
required if the only score > 10 is for 8-hour)). B graded facilities (cancer score
between 1 and 100, chronic or acute score between 1 and 10) may be required to
perform an HRA on a case-by-case basis. C graded Facilities (scores below 1)
will not be required to perform an HRA. After completion, include the scores and
the HITRP file in the email to the Toxics Senior Engineer (as described in Section
5, Step B.5.).

C. Specifying the final prioritization scores

Once all refinements have been applied and the scores finalized, go to the
Prioritization Management option from the main Risk screen to indicate which
prioritization run shows the final scores. All scores should be finalized or 'locked'
before sending Draft emission inventories to Senior for review and before
resolved the Prioritization Score task in workflow.

L

-334-

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Engineering Division Manual of Procedures

ARCD

Dashboards Emissions Risk Ticketing Documents More.,.

Risk Prioritization

Home Risk Prrorimntion

r* jjm.swaney@sdcounty.ca.gov -*

inventory: 2019 - 2019 inventory Test

Prioritization Run

Create a new prioritization modeling run

Prioritization Run Refinement

Refine and rerun a pieviousiy calculated prioritization
scenario

Job Queue * Prioritization Run

Manage the processing of prioritization runs and facit
their status

1 Prioritization Device Distance Refinement

2 Refmo Prkortlzation scores with devices specific distances

Prioritization Results

View and eKport calculated prioritization scores

: ; Facilities, Devices, and Distances

. Manage facilities, devkes. and risk specific distances

Toxicity Tables

View References Exposure Levels (RED and Unit Risk
Factors (URF) for air contaminants

U

Prioritization Management

Manage Priotl/ation

*

Prioritization Reports

2. Select the facility (by clicking Select in the Action column) and scroll down to see
the various prioritization runs that have been done for that facility.

APCD

Dashboards Emissions Risk Ticketing Documents More..

Prioritization Management

Home Risk Prioritization Prioritization Management

jim.swaney@sdcounty.ca.gov - O
Inventory: 2019 -2019 Inventory Test

Total Facilities

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-335-

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Engineering Division Manual of Procedures

3. Select the exact prioritization run and select if this is from uniform or refined
distances in the drop-down box, then click Select.

APCD

Dashboards Emissions Risk Ticketing Documents More...

Prioritization Management

Home RJ'*k PriOfHIvallOM Prioritization Management

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Run Details

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r jim.5waney@sdcounty.ca.gov " O
Inventory: 2019 - 2019 Inventory Test

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08 Ma» 2021, 22:2S:0ir
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4. After you have clicked Select you will see a check mark next to the selected run.
The selected run will be used by the various prioritization reports in EIS and will
be used to determine if a HR A is required or not.

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Engineering Division Manual of Procedures

APCD

Air Pollution Control District

Dashboards Emissions Risk Ticketing Documents More...

Prioritization Management

Hom« Risk PriOflUZatton Prioritization Management

u iy wwi-si UyNWhU nawmju

jim.swaney@isdcounty.ca.gov -
Inventory: 2019 - 2019 Inventory Test

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Jo8 Mar 2021. 22:25:0?
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oa Mar 2021. 23:06:11

& & A

16. Toxics "Hot Spots" Procedures (December 2020-M Luther, Rev. Jan
2021-M Luther, Rev. March 5, 2021, Rev. May 2021, Rev. October 2021,
Rev. December 2021, Rev. March 2022)

The work related to the Hot Spots Health Risk Assessment and associated public
notification and risk reduction requirements must be captured under a HRA Record in
BCMS.

I. Creating a HRA Record - Emission Inventory Aide

Once the Emission Inventory is approved and the prioritization score indicates a Health
Risk Assessment (HRA) is required under AB2588, the aide assigned to the Emission
Inventory team will create a HRA record in BCMS as follows:

1. Select the SITE record for the facility that is subject to the HRA requirement,
click on the "related record" tab, and then "clone mult".

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Engineering Division Manual of Procedures

] ARCD1998-SITE-10382 County of San Diego Air Pollution Control District

Page
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of 1

APCQ1998-SFTE-10382 - San Diego APCD Site for APCD's backup Engine

Menu ^ List View Clone Sgl Clone Mult Update Related Records

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AFCC1898-JQB-97t4B9 —> fLUEG-AFCD Aoministrafo/e. Legacy Pata.UncategQrizedl; Status C

2. Please select the HRA record under the highlighted dropdown list, click in the
highlighted arrow to move the record to the box shown on the right, then click
submit.

New Set Existing Set Cancel

Help

Go To "

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C3o*ve To Set:

# of Clones per Record Type

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Please select the Record Type
LUES-APCD/HRA/NAWi

3. Please select the contact checkbox to copy the contact information to the HRA
record and click submit. The HR A record will be available under the site record
(see related record configuration in BCMS)

-338-

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Engineering Division Manual of Procedures

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4. Please update the following fields

APCD2021 -HRA-0001
Save	Reset

Help

Record Specific Info Record Specific Info Tables (0) Record Status History (2) Related Records!

FACILITY NOTIFICATION

Facility Notification

Date the facility is notified
that a HRA is required under
the Hot Spots program

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Facility deadline for the HRA
submittal -per the Health and

Safety code section 44360
facilities have up to 180 days

HRA Submittal Due Date

10

II. Updating the fields in BCMS - Hot Spot Team Members & Senior
Engineer

The fields in BCMS must be updated by the team member who has been assigned the
record. It is critical to update these fields on a timely manner (upon completion of the
tasks). The information in these fields must be accurate as it must be used to verify
compliance with the applicable deadlines under the Health and Safety code and Rule
1210.

The Hot Spot team members and senior engineer must run the "Health Risk Assessment
Report" from BCMS on a regular basis to track the deadlines. If a facility fails to meet a
deadline the Chief and/or Deputy Director should be informed immediately.
The following fields must be completed by the team member who is assigned the record
as follows:

L

Date a reminder is sent to the facility (template in
no later than 120 days after facility
notification

SharePoint

FACILITY NOTIFICATION
Facility Notification •

HRA Submittal Due Date

| 01/05/2021

3

Reminder Sent

L



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Engineering Division Manual of Procedures

Date the HRA is
received from the
facility

Date APCD sends
HRA to OEHHA

HRA REVIEW

HRA Received



OEHHA Comments Due Date

HRA Review Completion



n

Date the OEHHA
Comments are due. Per
section 44361 of the H&S
code OEHHA has 180
days to comment

Date the APCD completes its
review of the HRA

Date OEHHA Comments
are received

HRA Sent to OEHHA

OEHHA Comments Received

1/^

APCD HRA Comment

~

Date APCD submits comments on the
HRA to the facility. Per section
44362 facilities have 60 days to
respond to comments

HRA REVISION
Revised HRA Due Date

APCD Response

HRA APPROVAL

Public Notification Require^
O Yes O No
HRA Approval Date

60 days from the "APCD HRA
Comment" date

Date APCD responds to comments

Indicate if a public notification is
required per Rule 1210

Date the HRA is approved. This
happens after the 60 day period

Date facilities submits revised
HRA (should be within 60 days)

Revised HRA Received

Date APCD submits a letter requiring a
public notification package

Indicate if a risk reduction is
required per Rule 1210

Risk Reduction Required

O Yes O No

Date the public notification
package is due. Per rule 1210 it
is due 45 days from the date we
notify

PUBLIC NOTIFICATION

Public Notification Requirement Mailed

I	ia

Public Notification Plan Received

I	^

Public Notification Plan Approved

i	i	ira

When the public
notification package is
received

Date APCD approves the public
notification package. Per rule 1210 we
need to approve it or revise it within
30 days

Date the public notification
package approval is due. Per rule
1210 we need to approve it or
revise it within 30 davs

Public Notification Plan Due Date

I	_ 	!¦

Public Notification Plan Approval Due Date

	|B

Public Notification Deadline

Date the public
notification is due. Per
rule 1210 facilities have
30 days to notify

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Engineering Division Manual of Procedures

Public Notification Completed

3

Is a Public Meeting Requii

O Yes O No
Public Meeting Deadline

Date the facility notifies the public.
Per rule 1210 it should be within 30
days from when the APCD approves it

For the initial notification a
meeting is required. For annual
notifications, consult with your

supervisor and Chief to
determine if a meeting will be
required.

If a public meeting is needed it must be
conducted within 30 days from the
public notification date (Rule
1210(d)(10))

This date is 30 days from when
the public notification is sent

jblic Comment Deadline

3

APCD Public Meeting Notification Date

	!~

Date the APCD notifies the

facility that a public
meeting is required (Rule
1210(d)(10))

The following fields should also be updated with the health risk information from the
approved HRA.

HEALTH RISKS

Maximum Individual Excess Lifetime Cancer Risk

| (Number)

Maximum Occupational Excess Lifetime Cancer Risk

| (Number)

Maximum Residential Chronic Non-Cancer Health Hazard Index

(Number)

Maximum 8-Hour Occupational Non-Cancer Health Hazard Index

| (Number)

Maximum Residential Acute Health Hazard Index

| (Number)

Maximum Residential Excess Lifetime Cancer Risk
|	| (Number)

Maximum Chronic Non-Cancer Health Hazard Index

|	| (Number)

Maximum Occupational Chronic Non-Cancer Health Hazard Index
|	| (Number)

Maximum Acute Health Hazard Index
|	| (Number)

Maximum Occupational Acute Health Hazard Index
|	| (Number)

Population Excess Cancer Burden

| (Number)

III. APCD HRA Comments - Hot Spots Team Members & Senior Engineer

The HRA must be reviewed in accordance with the Health and Safety code, sections
44360-62.

Please be aware that section 44262(a) states " Taking the comments of the Office of
Environmental Health Hazard Assessment into account, the district shall approve or
return for revision and resubmission and then approve, the health risk assessment
within one year of receipt. If the health risk assessment has not been revised and
resubmitted within 60 days of the district's request of the operator to do so, the district
may modify the health risk assessment and approve it as modified.

Therefore, if the District cannot approve the HRA the District must provide comments to
the facility and give it an opportunity to revise and resubmit the HRA within 60 days
before the District revises the HRA. If the facility resubmits a revised HRA within 60

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Engineering Division Manual of Procedures

days that cannot be approved, then the team member should inform the senior engineer
for specific guidance.

When providing comments to the facility, APCD should clearly state that section
44362(a) of the Health & Safety code states "If the health risk assessment has not been
revised and resubmitted within 60 days of the district's request of the operator to do so,
the district may modify the health risk assessment and approve it as modified
The Health and Safety Code does not require an endless circle of reviews, revisions,
comments, and resubmittals of HRAs.

IV.	HRA Approval -Notifying facilities of public notification and risk
reduction requirements - Hot Spots Team Members & Senior Engineer

After considering the comments received by facilities within the 60-day period, the HRA
should be approved by the APCD per Health and Safety code, sections 44360-62. The
team member that is assigned the HRA record should prepare a notification to the facility
informing of the approved HRA results, applicable public notification and/or risk
reduction requirements (including template notification letters for each type of
notification required (residential cancer, residential cancer plus acute, etc.), the fact sheet
and survey response card), and a response to the comments provided by the facility. This
notification must be approved by the Senior Engineer.

The team member assigned the HRA record and the senior are responsible for tracking
the submittal of the public notification package and the risk reduction plan. This can be
done by adding reminders in outlook and monitoring the HRA records by running the
report.

The HRA record should not be approved until any required public notification is
completed and the risk reduction plan is submitted and approved (if applicable).

V.	Reviewing the public notification package - Hot Spots Team Members &
Senior Engineer

The team member who is assigned the HRA record is responsible for reviewing the
public notification and ensure compliance with all applicable requirements under Rule
1210 including:

Deadline for submittal (per Rule 1210(d)(2) they have 45 days)

Compliance with Rule 1210(d)(2) and Rule 1210(d)(3)(iv), which is an optional
informational letter, as decided by the stationary source

A list of the primary languages spoken by non-English speaking persons in the area to
receive notification where such language is the primary language of five percent (5%)
or more of the total persons to be notified in any census tract in the area to receive
notification. Multilingual notifications shall be provided by the owner or operator of a
stationary source if five percent (5%) or more of the recipients within any census tract
in the area to receive notification are non-English speaking. In such case, the

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Engineering Division Manual of Procedures

notifications shall be provided in those languages which are the primary language of

five percent (5%) or more of the total persons to be notified in that census tract.

A proposed method for responding to public comments and requests.

The "Air Toxics Hot Spots Fact Sheet" and a "Public Response Survey Card"

provided by the APCD. Template is available in SharePoint.

Ensure the proposed optional stationary source informational letter complies with

Rule 1210(d)(3)(iv)

If any of the above requirements is not met the team member who is assigned the HRA
record should send a written notification to the facility providing comments as soon as
possible but at least one week from when the APCD must approve the notification
package. The notification should use the wording in the template available in SharePoint.

VI.	Providing envelopes to the facility - Hot Spots Team Members

Per Rule 1210(d)(6) each public notification shall be mailed in an envelope supplied by
the APCD. The envelope shall be marked with the name and address of the Air Pollution
Control District and addressed to "Current Resident" of private residences, business or
sensitive receptors. Please make sure to coordinate with the Support Services team to
give them sufficient time to prepare these envelopes.

VII.	Approving or Cancelling HRA Records - Senior Engineer

Cancelling HRA Records

When the Emission Inventory team can enhance the prioritization scores and the facility
is no longer subject to the HRA requirements under AB2588, the senior engineer should
cancel the HRA record in BCMS following the steps below:

1.	Ensure all relevant documents are available in BCMS (see documentum section of
this procedure), including:

a.	The HRA request

b.	Documentation of the revised prioritization scores explaining why the HRA is
no longer required

c.	Documentation informing the facility the HRA is no longer required

2.	Ensure the trust account has sufficient funds to cover the pending charges and
request an invoice accordingly

3.	Close the workflow tasks, except for the accounting reconciliation task, which
should be assigned to accounting



Task Details - Accounting Reconciliation



Workflow Tasks



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Action Bv Division * Current Division

Action Bv * Current User

|j]-r*3 HRA Review

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| Mahiany Luther v

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Current Status



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Cnpnt (Alt + m * Status nate *

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APCD Accounting

Assigned to

Zenaida Samaniego

4. Change the record status to cancel

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Engineering Division Manual of Procedures

APCD2021-HRA-00D1
Save	Reset

Help

Go To » ¦; status Trust Accounts (0) Workflow Workflow History (0)

Use this form to change overall Record Stetus. Please include comments.

Action By Division * Current Division

Action By * Current User

Comments Ebstantlard Comment

check spelling

Approving HRA Records

The HRA records should be closed when the entire public notification process is
completed (i.e. after the APCD determines a public meeting is not needed or after a
public meeting is conducted per Rule 1210(d)(10)) and/or the risk reduction plan is
submitted and approved (if applicable).

L Ensure all relevant documents are available in BCMS (see documentum section of
this policy)

2.	Ensure the trust account has sufficient funds to cover the pending charges and
request an invoice accordingly

3.	Close the workflow tasks, except for the accounting reconciliation task, which
should be assigned to accounting

^ Workflow Tasks

6"Ov Facility Notificaiton
Ej3-Q HRA Review
i-Q HRARevison

Public Notification
iS-Os Accounting Reconciliation

Task Details - Accounting Reconciliation

Action By Division * Current Division

| APCD Compliance Supervisor s/ |

Current Status

Action By 1 Current User

| Mahiany Luther

Assigned to Division

APCD Accounting

Assigned to

Zenaida Samaniego

Maui Ctntuc /Aft +

Hnnrc ^rwmt (Alt + H) ;

Status Date ¦

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Engineering Division Manual of Procedures

4. Change the record status to "approved'1

A PCD2021 -H RA-0001

Save	Reset	Help

bo To *	status Trust Accounts (0) Workflow Workflow History I

Use this form to change overall Record Status. Please include comments.

Action By Division - Current Division	Action By * Current User

Comments ^Standard Comment

check spelling

VIII.	Invoices- Hot Spots Team Members & Senior Engineer

All of the labor associated with the Hot Spots program must be logged under the HRA
record. The Hot Spots team member assigned the HRA record and the senior engineer are
responsible for monitoring the trust account of the HRA record and request invoices
accordingly. The HRA record is NOT associated with Real Time Accounting so the trust
account must be monitored. The trust account is part of the HRA report.

An invoice must be requested by the Hot Spots team member and approved by the senior
when the HRA is submitted by the facility or when the work will exceed about $500. All
the other tasks can be performed and the invoice can be generated when the record is
closed (cancelled/approved).

IX.	Annual Notifications- Hot Spots Team Members & Senior Engineer

At the beginning of the year the Senior Engineer must run the HRA record report and
review the Annual Air Toxics "Hot Spot" Program Report to determine the facilities
subject to annual or biennial notifications in accordance with Rule 1210 (d)(8).

The senior should request new HRA BCMS records, which can be created by the aide
assigned to the toxic team, and assign the record to a team member.

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Engineering Division Manual of Procedures

The senior and team member must consult with the Chief to determine if a public
meeting will be required for the annual notification in accordance with Rule 1210 (d)(10).

The team member should notify the facility of the annual notification requirement and
public meeting (if required for annual notifications). Under this notification facilities
should be reminded of the 45-day requirement to submit the notification package (per
Rule 1210).

All sections of this policy and Rule 1210, as applicable, should be followed for annual
notifications.

X. Addressing inquires from the public regarding the public notification

When addressing comments from members of the public, it is important to be available to
assist them in understanding the health risk exceedances. HRAs are very complex and the
terminology used to convey the health risk exceedances can also be confusing.

Please put yourself in their shoes and consider what information you would need as a
member of the public if you received a notification reporting health risks. Some
suggestions to consider include:

•	Explain why the facility notified. We can say: "Facility Name was required to
conduct a Health Risk Assessment in accordance with the California Air Toxics
"Hot Spots" Program (Program), which addresses public concerns over toxic air
contaminant emissions. Toxic air contaminants are chemicals in gases, liquids, or
particles that are emitted into the atmosphere and may cause adverse health
effects. Adverse health effects can range from relatively mild temporary
conditions, such as minor eye or throat irritation, to serious conditions such as
cancer or damage to organs.

•	Explain what a HRA is: "A health risk assessment estimates the risk of adverse
health effects from exposures to emissions of toxic air contaminants. The estimated
risks are based on computer models that calculate risks based on a variety of
conservative assumptions and emission calculations. Facility Name was required
to notify all community members in the area where there is a potential health risk
above thresholds established by the APCD Rule 1210. As an example, APCD Rule
1210 requires public notification when the estimated increased risk of contracting
cancer (above normal background levels) is above 10 in one million. To help put
the risk into perspective, consider that the American Cancer Society estimates the
total lifetime cancer risk for people living in the United States to be 400,000 in one
million "

Additionally, when responding to the public please ensure the following requirements are
met:

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Engineering Division Manual of Procedures

1.	You must contact every member of the public that contacts you regarding the Hot
Spots HRA, even if you are not contacted via the survey

2.	If the inquiry if not specific, you should call the person (or send an e-mail) to find
out more details and address the question accordingly

3.	If you obtain multiple inquires requesting more information regarding the HRA
(more than 5) please contact your supervisor

4.	If the member of the public asks for a copy of the official record (e.g. isopleth)
please provide it to them. Official records include anything that we would
disclose under the PRA

XI. Posting records in documentum - Hot Spots Team Members & Senior
Engineer

All relevant documents (i.e. documents associated with the HRA review, public
notification, and risk reduction) must be posted in BCMS under the HRA record. Except
for invoices, all documents posted under the HRA records related to the Hot Spots
program must be posted in documentum using the "APCD-ENG-HOTSPOTS" group and
appropriate category as shown below. Please note that any confidential information such
as "attorney-client" communication must be posted using the "trade secret" categories
listed below. All documents that are not designated as "trade secret" will be
disclosed to the public. Draft documents, zipped files, and internal communication
should NOT be posted in documentum.

All data files should be maintained in SharePoint and available to the public upon
request.

The name of the document should follow the following format:

__

The Type of Document should follow the Document column below (HRA Request,
OEHHA Submittal, Public Notification Plan, etc.

-347-

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Engineering Division Manual of Procedures

Document permissions ore based on the document type and your role at APCD.
Document Group-'Cateoory (Required] »

[ AFCP-eNG'HOTSFOTS	~

Division Current P'V«?K»n

APCD Compt Lance Supervisor

Description

rty Tasks

, My Task Searching

Menu * Assign	Claim Release

Workflow tasks (O) Inspections (0| D

CAP Reference

0 rccorcK*) fownt

Status

APCOAiiTo/icsCorresponaenc^s	/\

APCOAtfToxJCS-CofresponcJerices-TracJe-Secfe!

APCO-AH TOJ-ICS-HRA-Approved

APCO-Ak-Toxrcs-HRA-Gomments

APCD-Aif-To:TicS-HRA-Re£|ueSt

APCO-Am Toxics-HRA-Resarul-Letter

APCD-Air- Toxrcs-HRA-Submlttal

APCDAjrTo*iCS-lriVOtC6

APCO-Ah-Tojics-OE HHA-Commerrts

APCO-Air- Topics-Prioritization

APCO-At( TOtiCS-PuEiUC-NotiflCSttan -Approved

APCD-Aw-ToxHS-iPublic-Notrticatior-Comments

APCO-Aif-Tox.ics-Prjt3lic-Motihcatiofl-&ubmitt3l

APCD-Atf-TtWiCS-ReUOrt

APCD-Air-Towcs-Rlsk-Red- Approved

APCO-Atr-Toxies-fttsK-Red-Submittal

APCD-All-T OWCS-Supp-dOCS

APCO-Air-Toacs-Supp-docs-Trade-Secret

APCO-El Supp docs

APCD-EI Supp docs Trade Secret

APCD-EI-CooesponiJences

APCQ-Ei-CwrespomJences Trade Secret

APCO-EI-Oata Req

APCO-EI-Oata Submittal

APCD Ei-Divta submittal Trade Secret

APCO-Ei-EmisstOfi Statement

APCD-EIHRA Submittal

APCD-Ei-lnv Tracking	v

APCD-EI-Pnontizatson

Duralic
(Days)

The following table list some critical documents that must be available under the HRA
records with the specified document group/category.

Document

Documentum
Group

Documentum
Category

Team Member
Responsible for Posting
the Document

HRA Request (when
facility is notified a HRA
is needed under the Hot
Spots program)

APCD-ENG-
HotSpots

APCD-Air-
Toxic-HRA
Request

Aide

Documentation of the
revised prioritization
scores explaining why the
HRA is no longer
required

APCD-ENG-
HotSpots

APCD-Air-
Toxic-Supp-
docs

Aide

Documentation informing
the facility the HRA is no
longer required

APCD-ENG-
HotSpots

APCD- Air-
Toxics-APCD
HRA Rescind
Letter

Aide

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Engineering Division Manual of Procedures

HRA Received by the
Facility

APCD-ENG-
HotSpots

APCD- Air-
Toxic -HRA
Submittal

Hot Spots Team member
(who has been assigned
the HRA record)

Record showing when the
APCD sent HRA to
OEHHA

APCD-ENG-
HotSpots

APCD- Air-
Toxics-
Correspondences

Hot Spots Team member
(who has been assigned
the HRA record)

OEHHA Comments on
the HRA

APCD-ENG-
HotSpots

APCD- Air-
Toxics-OEHHA
Comments

Hot Spots Team member
(who has been assigned
the HRA record)

APCD Comments on the
HRA submitted to
Facility

APCD-ENG-
HotSpots

APCD- Air-
Toxics-APCD
HRA Comments

Hot Spots Team member
(who has been assigned
the HRA record)

Facility Response to
APCD Comments on the
HRA

APCD-ENG-
HotSpots

APCD- Air-
Toxics
Correspondences

Hot Spots Team member
(who has been assigned
the HRA record)

APCD HRA Approval

APCD-ENG-
HotSpots

APCD- Air-
Toxics -HRA
Approved

Hot Spots Team member
(who has been assigned
the HRA record)

Public Notification Plan
submitted by the facility

APCD-ENG-
HotSpots

APCD- Air-
Toxics -Public
Notification
Submittal

Hot Spots Team member
(who has been assigned
the HRA record)

Public Notification Plan
Approved by the APCD

APCD-ENG-
HotSpots

APCD- Air-
Toxics -Public
Notification
Approved

Hot Spots Team member
(who has been assigned
the HRA record)

APCD Public Meeting
Notification sent to the
facility

APCD-ENG-
HotSpots

APCD -Air-
Toxics
Correspondences

Hot Spots Team member
(who has been assigned
the HRA record)

APCD Public Meeting
Presentation (Adobe
Acrobat version)

APCD-ENG-
HotSpots

APCD - Air
Toxics
Correspondences

Senior Engineer

Risk Reduction Plan
proposed by Facility

APCD-ENG-
HotSpots

APCD-Air-
Toxics -Risk
Reduction
Submittal

Hot Spots Team member
(who has been assigned
the HRA record)

Approved Risk Reduction
Plan

APCD-ENG-
HotSpots

APCD- Air-
Toxics -Risk
Reduction
Approved

Hot Spots Team member
(who has been assigned
the HRA record)

Public Comments

APCD-ENG-
HotSpots

APCD-Air-
Toxics
Correspondences

Hot Spots Team member
(who has been assigned
the HRA record

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Engineering Division Manual of Procedures

Public Comment
Responses

APCD-ENG-
HotSpots

APCD-Air-
Toxics-
Correspondences

Hot Spots Team member
(who has been assigned
the HRA record

XII. Clarifications related to Rule 1210
School Notification

Rule 1210(d)(3)(vi) specifies the notification requirements applicable to
parents or legal guardians of students attending schools with potential
exposure to risks above the significant risk thresholds as required by
Subsection (d)(1), which are:

•	Maximum incremental cancer risks equal to or greater than 10 in one
million, or

•	Cancer burden equal to or greater than 1.0, or

•	Total acute noncancer health hazard index equal to or greater than 1.0,
or

•	Total chronic noncancer health hazard index equal to or greater than
1.0.

After consulting with counsel, this notification requirement applies to all
schools located in an area for which any of the significant risk thresholds are
exceeded.

Sensitive Receptors

For the purposes of Rule 1210, sensitive receptors include schools, hospitals,
day care centers, and convalescent homes.

Sensitive Receptor Notification requirements

All sensitive receptors must be notified for that type of exceedance if they are
within any isopleth. Specifically:

•	If the sensitive receptor is contained within one of the isopleth above
the limits stated in Rule 1210 that facility (i.e. sensitive receptor) is
required to be notified. For schools Rule 1210 also requires the parents
to be notified if they are within one of the notification isopleths.

•	Every contour or isopleth should be used to identify sensitive receptors
that are required to be notified.

•	While cancer burden is calculated at the centroid of the census tract,
notification requirements apply to all residential addresses and
sensitive receptors within the one in one million isopleth for cancer
burden.

Notification Letters

The APCD notification letter signed by the APCO discusses the type of health
risk exceedance the receptors are subject to. For some facilities there might be

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Engineering Division Manual of Procedures

multiple areas subject to different health risk exceedances. If this is the case,
the receptors should only be notified of the health risk exceedance they are
subject to. Consequently, the APCD might have to provide multiple versions
of the notification letters to the facility but the receptors should only be
receiving one letter.

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Appendix I. EPA's Response to Comments

Page 57 of 59

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EPA Region 9 Responses to the SDAPCD Comments on the
Draft Title V Program Evaluation Report
September 30, 2022

Responses to Comments

Thank you for providing comments on the draft title V program evaluation report.1 On August 30,
2022, the District provided its comments via a "marked up" version of the draft. Below, we summarize
the significant comments and provide our response. Note: use of the word "we" or "our" refers to the
EPA.

1. Executive Summary

SDAPCD Comment: The SDAPCD suggested some changes in tone and corrected some
organizational information. The SDAPCD also requested a clarification that new title V sources
resulting from any non-attainment redesignation have one year from the date of EPA's final
approval of the SDAPCD's revised title V rules to submit their title V application.

EPA Response: The EPA appreciates the SDAPCD's correction and suggestions. We changed some
wording in the Executive Summary and modified the SDAPCD organization description based on the
comments. We recommend the SDAPCD update its organization chart and website to reflect these
changes.

Regarding when new title V sources need to submit an application for a title V permit due to
reclassification, we added a footnote to the final report for more context. Generally, new title V
sources would have had one year from the effective date of a reclassification to submit their initial
title V application. However, the EPA should have been clearer in our ozone reclassification action
for San Diego County on the timing for SDAPCD to submit an updated title V program to the EPA.
We should have specifically identified that the SDAPCD's title V program was deficient pursuant to
CAA section 502(i) and 40 CFR 70.10 for not having a program that adequately implements the
CAA's required major source thresholds, and then required the SDAPCD to submit a program
revision pursuant to 40 CFR 70.4. Because our reclassification action was not specific in this regard,
we believe that our action was not an official notice of deficiency and has not triggered sanctions
under CAA section 502(i). Also, because the SDAPCD has submitted revisions to EPA to correct the
deficiency, and EPA is processing the program revision, we are not planning to issue a formal notice
of deficiency. Thus, upon the effective date of the EPA's approval of regulations that includes the
required 25 ton per year major source threshold in San Diego County, sources newly subject to the
program will have 12 months to submit initial title V applications. The EPA is taking steps to ensure
any future reclassification actions specifically cite to the authorities in the title V program.

1 The EPA's responses to comments, along with the SDAPCD's comments, are included as Appendix I and J, respectively, in
the final report.

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2. Finding 2.1

SDAPCD Comment: The SDAPCD stated that the Standard Operating Procedure (SOP) revisions
were already provided previously and explained the District's review process. In general, because
the SDAPCD first issues local Authorities to Construct (ATCs) to modifications to all facilities,
including both title V and non-title V facilities, those ATCs undergo review by Senior Engineers
before being sent to Compliance Division for review. For title V facilities, those local permits, which
have already undergone review by both Engineering and Compliance, are then incorporated into
title V facility permits either with the next title V revision or at the time of renewal. The SDAPCD
stated that the EPA received inconsistent answers because of the limited experience of some staff.
The SDAPCD agreed that additional training is helpful, especially for new staff.

EPA Response: The EPA appreciates the SDAPCD's feedback and modified the finding to
acknowledge that there is an SOP for processing title V permits. Nevertheless, as the SDAPCD
stated, more training is necessary to ensure the written process is being followed. We emphasize
that for ATCs relating to title V sources, there should be an evaluation documented by the District
identifying the type of title V revision that is required for the action. In the documents we have
reviewed, the local permit engineering evaluations only focused on the NSR aspects of a change
while title V related determinations were not documented, and therefore likely not reviewed by
the review chain.

3. Finding 2.2

SDAPCD Comment: The SDAPCD stated that the engineering evaluations of the local permits
includes the detailed and site-specific items mentioned in the EPA's discussion of what needs to be
included in a statement of basis. The SDAPCD has consistently provided statements of basis as part
of all permitting actions submitted for EPA comment, and had not received comments about lack of
content, or any significant deficiency. As indicated the type of analysis is contained in the
engineering evaluations for the underlying equipment or in previous statements of basis if the
underlying rationale has not changed. The SDAPCD would be happy to further discuss this with the
EPA.

EPA Response: The EPA acknowledges permits are sent to the EPA for review during the regular
reviewing cycles; however, the program evaluation is our opportunity to do a deep dive and review
multiple permits at once to have a better understanding of the full program and provide broader
feedback as a whole. If the information included in the engineering evaluations is applicable to the
source's title V actions, then these evaluations should be submitted to the EPA as part of the title V
permit review—currently they are not. The EPA appreciates the SDAPCD's efforts in addressing
these issues and the EPA will continue to work with the SDAPCD in tracking the recommendations
via a workplan and analytical review as noted in the report. This finding and recommendation
remain as drafted; language on submitting any relevant supporting documents during EPA permit
review was added.

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4. Findings 2.4/7.2 - 502(b)(10)

SDAPCD Comment: The SDAPCD agreed that all 502(b)(10) changes submitted must be reviewed
and determined whether or not they qualify as such. However, the SDAPCD did not agree with the
EPA's conclusion that the SDAPCD did not make a determination of the appropriate type of permit
action. It appeared that this finding should have been more focused on the lack of clear
information to document a determination, rather than concluding that there was a lack of making
correct determinations, unless the EPA has identified any changes which were improperly
classified.

The SDAPCD noted that they provided some of these supporting engineering evaluations to the
EPA staff as part of the document request and has included a spreadsheet listing all title V
applications either received or approved within the previously requested timeline, including an
annotation regarding the type of application and a brief description of the proposed change. This
list shows that the SDAPCD processes each different type of application, not just 502(b)(10)
changes. The SDAPCD processes very few significant modifications, but this is due to the types of
modifications being proposed, not lack of reviewing requirements. The District mentioned one
example that contained analysis of minor/significant projects.

EPA Response: The EPA acknowledges that the draft findings on this issue appeared somewhat
conclusive and has make minor revisions to Findings 2.4 and 7.2 to clarify that the focus on the
finding is lack of information for title V modification determinations. The EPA reviewed engineering
evaluations for local permits and the list provided by SDAPCD in making this determination. Please
note that the example mentioned in the comments was not provided by the time of the issuance of
this report. In most of the files reviewed, there was no supporting documentation explaining
whether a proposed modification was subject to a title V modification or what type. For this
reason, if a determination is made, even if it is prior to submittal of an application, we recommend
that it be documented.

5. Findings 2.4/5.3 - Enhanced NSR

SDAPCD Comment: The SDAPCD disagreed with the EPA's contention that the EPA and public
review somehow does not occur for NSR changes. District Rule 20.3 requires that an EPA comment
period and public notice is conducted equivalent to the same level required for significant
modifications or new permits prior to an authority to construct being issued. Additionally, if such a
notice was required, the title V application would be treated as a significant modification or an
initial permit, as appropriate, and a separate EPA comment period would occur prior to issuance of
the title V permit, as required by SDAPCD rules. Alternatively, at the discretion of the SDAPCD and
the permit applicant, the project can be processed under "enhanced ATC" provisions, which would
combine the two notice/comment periods. The SDAPCD also stated that it appears that the EPA
may be inferring that the SDAPCD is not implementing this correctly while also stating that there
are no examples of the SDAPCD using this program (if EPA would like to see an example, the
SDAPCD would be happy to provide an example of a permit where an A/C was issued using
enhanced procedures and an administrative amendment was filed, but not acted on yet). Also, the

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SDAPCD did not agree with the EPA's implication of using 502(b)(10) changes instead of
documenting enhanced NSR.

EPA Response: Please note the revision that was made to finding 2.4, as well as some clarifications
to the discussion in finding 5.3. Also note that while the EPA requested examples of enhanced NSR
actions, we did not receive any examples by the time of the issuance of this report. The EPA
appreciates the SDAPCD's efforts in addressing these issues and the EPA will continue to work with
the SDAPCD in tracking the recommendations via a workplan and analytical review as noted in the
report.

6.	Findings 2.4 - PSD

SDAPCD Comment: The SDAPCD agreed to coordinate with EPA on whether or not new sources or
modifications to existing sources trigger prevention of significant deterioration (PSD) requirements.
The District also stated that the EPA specifically identifies PSD and title I modifications as concerns.
However, these requirements would be addressed during the local permitting review which would
include notification to the EPA if a project constituted a federal major modification or triggered PSD
requirements. In recent years, none of the projects that would have potentially required PSD
permits were approved (or were modified to no longer trigger PSD requirements).

EPA Response: The EPA appreciates the SDAPCD's coordination with the EPA on whether or not
new sources or modifications to existing sources trigger PSD requirements. From our review of
some of the District's PSD analyses, it is unclear what methodology the District is using to
determine whether a project is a federal PSD major modification. The analyses we reviewed did not
use or cite 40 CFR 52.21, the federally applicable PSD regulation in San Diego County. We are
making some additional clarification to the finding to state that we would like to be involved in the
evaluation of whether PSD applies and not only when the SDAPCD believes that it applies. It may be
appropriate to include this issue in your workplan, where we can mutually agree on the method for
EPA involvement.

7.	Finding 2.5

SDAPCD Comment: The SDAPCD would like to clarify that when the SDAPCD cites "NSR" as the
basis for a condition, it simply cites Rule 20.2 or 20.3 (depending on whether the source is major or
non-major for criteria pollutants). This is no different than any other rule citation. The SDAPCD
would like to point out that the EPA has not previously raised this concern during the review of title
V permits as a comment or an objection.

The SDAPCD clarified with an example: if an ATC condition has already been fulfilled prior to
issuance of a title V permit (such as requirements for initial source testing) the SDAPCD may not
place that condition in the title V permit because the initial source testing will be completed prior
to issuance of the title V permit.

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EPA Response: The EPA acknowledges title V permits are sent to the EPA for our review; however,
the program evaluation is our opportunity to do a deep dive and review multiple permits at once to
have a better understanding of the full program instead of commenting through regular renewal
cycles to avoid delays for the District. As we stated in the finding, each title V permit is required to
specify and reference the origin and authority for each term or condition and identify any
difference in form as compared to the applicable requirement upon which the term or condition is
based.2 If the condition is incorporated from an NSR permit, then the permit number should be
cited in the title V permit as the origin. NSR conditions that are not appropriate for inclusion in the
title V permit should be documented in the statement of basis. This finding and recommendation
remain as drafted.

8.	Findings 2.6

SDAPCD Comment: The SDAPCD noted that streamlining typically occurs during the local permit
review stage, not as a separate analysis in the title V statement of basis. The SDAPCD typically
conducts an equivalent streamlining analysis as part of the local permit review and these
conditions are later incorporated into the title V permit through the appropriate modification
application. The District's normal practice is to review requirements rule by rule in the engineering
evaluation and then any similar requirements will be automatically streamlined into the permit
conditions. This approach ensures all requirements of all rules are reviewed to ensure the permit is
enforceable.

EPA Response: While we reviewed a sample of local permit engineering evaluations, we did not
find examples streamlining analysis documented. Nevertheless, if the SDAPCD does have
engineering evaluations that include these analyses, then they should also be submitted as part of
the statement of basis. This finding and recommendation remain as drafted.

9.	Finding 2.7

SDAPCD Comment: The SDAPCD stated that it is important to note that not all requirements in
local permits, such as some state or local toxics rules, are federally enforceable.

EPA Response: We agree with the SDAPCD and made a clarification to Finding 2.7 to reflect that
not all requirements are federally enforceable.

10.	Finding 3.1

SDAPCD Comment: The SDAPCD stated that it has no sources which require CAM and impose all
monitoring requirements through permit conditions directly requiring periodic monitoring. The
SDAPCD does evaluate for CAM applicability. In order to be subject to CAM, the source has to have
a pollutant specific emissions unit (PSEU) with an applicable emissions limit and control device, and
the pre-control emissions must exceed major source thresholds (40 CFR Part 64.2). As mentioned

2 See 40 CFR 70.6(a)(l)(i).

5

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earlier, some of the staff interviewed have not had much title V experience, but the Senior
Engineers ensure CAM applicability is evaluated. The SDAPCD is open to further training on CAM.

EPA Response: The EPA appreciates the SDAPCD's comment; however, the EPA reaffirms that a
title V renewal permit is a new, standalone permit and, to the extent the District wants to rely on
prior CAM determinations, those determinations need to be included in the renewal action. It is
not uncommon to find errors in prior determinations and the District is obligated to fix such errors
in title V renewal permits. The EPA will work with the SDAPCD to ensure its staff receive CAM
training. This finding and recommendation remain as drafted.

11.	Finding 3.2

SDAPCD Comment: The SDAPCD stated that the District conducts most of its review as part of the
local permit evaluation and considers both Engineering and Compliance input prior to a permit
being issued. The SDAPCD believes that, as the EPA's review has also confirmed, appropriate
monitoring provisions have been incorporated into title V permits. Further, the EPA has not
previously commented or raised objections due to lack of monitoring requirements during the
EPA's past review of title V permits. The SDAPCD will continue to ensure daily emission limits have
adequate monitoring requirements, and believes that reviewing all title V permits again at renewal
for periodic monitoring would be redundant and resource intensive.

EPA Response: First, please note that while the EPA strives to provide feedback on proposed title V
permits, our not providing comments or objecting on a specific topic does not mean that the issue
does not exist. In addition, the intent of the title V program is to have a comprehensive review of
the title V permit every five years, and resources should be allocated to ensure this happens. Thus,
the EPA disagrees with the SDAPCD's comment that reviewing all title V permits at renewal to
determine whether periodic monitoring is needed would not be a fruitful exercise. As noted in our
finding, during our file review, we found examples of emissions limits that did not have adequate
monitoring. This finding and recommendation remain as drafted.

12.	Finding 3.3

SDAPCD Comment: The District stated that because Compliance does not usually use the
statement of basis and rather enforces the permit requirements and permit conditions, the District
does not believe there is an enforceability issue related to incorporating all applicable monitoring
and recordkeeping requirements.

With respect to diesel fuel, the SDAPCD includes fuel records in engine permits which are
incorporated into title V permits. Diesel fuel requirements are typically specified in the emissions
unit specific permit conditions. The District views this as sufficient to ensure only EPA/CARB diesel
is used in any diesel powered permitted equipment. For example, the SDAPCD has used the
following requirements for a facility which operates an emergency engine which also include
streamlined NSPS requirements related to fuel:

6

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(1)	This engine shall only use CARB diesel fuel. (Rule 12, Rule 69.4.1, 17 CCR 93115, 40 CFR 60
Subpart Nil)

(2)	The owner or operator of the engine shall maintain the following records on site for at least
the same period of time as the engine to which the records apply is located at the site:

(a)	documentation shall be maintained identifying the fuel as CARB diesel, and

(b)	manual of recommended maintenance provided by the manufacturer.

(Rule 12, Rule 69.4.1, 17 CCR 93115, 40 CFR 60 Subpart Nil)

EPA Response: We revised the report in response to this comment. We are clarifying that the EPA,
not SDAPCD compliance staff, found it challenging to determine that the permit contained all
monitoring and recordkeeping because of the lack of details in the statement of basis. Additionally,
the EPA appreciates the example provided related to recordkeeping and updated the report to
state that this example was provided.

13.	Section 4

SDAPCD Comment: The SDAPCD pointed out in the EPA's description of the public notice process, a
public notice may include the time and place of any hearing that may be held. The SDAPCD stated
that a public hearing is normally not scheduled in advance before sending out the public notice. A
public hearing will only be scheduled if requested during the public comment period and
determined that it is justified. The SDAPCD suggested to change the language to indicate that if it
has been determined in advance that a public hearing will be held.

EPA Response: Many permitting authorities in EPA Region 9 do not wait to receive a request to
hold public hearings as part of their community outreach and Environmental Justice (EJ) efforts and
thus include the public hearing information at the time the public comment period begins. Because
the statement says to include any public hearing that "may" be held, the description remains as
drafted.

14.	Finding 4.1

SDAPCD Comment: The SDAPCD considers EJ a high priority and is the first district in California
which has an EJ representative on its Governing Board. Also as noted earlier, the SDAPCD has
created an Office of EJ and has added significant resources to address public outreach and EJ
issues. The SDAPCD posts all title V public notices to our website and is open to discuss further
translation of the notices with the EPA. However, please note that the map provided by the EPA
has too large of a resolution to be useful for identifying whether projects need translation. Also,
the map only identifies the percentile of linguistic isolation, it does not provide actual percentages
of people who are linguistically isolated nor what language they speak. This may lead to somewhat
misleading data because of the non-linear nature of percentiles. The SDACPD agrees with the EPA
that providing assistance to environmentally disadvantaged communities is a critical issue and is
actively taking steps to improve in these areas.

7

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EPA Response: The EPA commends the SDAPCD for making EJ a high priority. We note that the
map provided was not meant to be used as guidance for permit outreach but to highlight the
existence of linguistically isolated communities in San Diego County. EJScreen can easily be tailored
to individual permit actions to generate a report that includes the percentages of people who are
linguistically isolated and the languages they speak. The SDAPCD should use the tool they find most
helpful for their public outreach process. This finding and recommendation remain as drafted.

15.	Finding 4.4

SDAPCD Comment: The SDAPCD agreed that if the SDAPCD receives comments from the public
during the 30-day public review period, the 45-day EPA review would be restarted as a result of a
comment. The SDAPCD further commented that it would be the case if the District modifies the
permit, or the comment raises substantive issues that need to be addressed.

EPA Response: When a comment is received, the comment should be provided to the EPA with any
responses to comments as part of the permit review package. If the SDAPCD does not believe the
comment is significant, we are happy to work with the SDAPCD to determine the correct path,
including providing an expedited 45-day review period when appropriate. Given the number of
comments the SDAPCD historically receives on draft permits, this should not cause routine delay in
the permit issuance process. This finding and recommendation remain as drafted.

16.	Finding 5.2

SDAPCD Comment: The SDAPCD previously did not have a policy that specifically required a
statement of basis for minor modifications (although all relevant information would have been
contained in the related local permit engineering evaluation), so in some previous cases where the
SDAPCD thought it would be self-evident that a change qualified as a minor modification, a
statement of basis may not have been included. However, the SDAPCD has already instituted a
policy which requires documentation through a statement of basis for both minor modifications
and 502(b)(10) changes. The SDAPCD appreciates the EPA's recognition that the SDAPCD routinely
submits copies of both proposed and final title V permit actions to the EPA. The SDAPCD has also
revised its rule procedures to require a statement of basis for minor modifications. The SDAPCD's
revised title V rules are presently under review by the EPA.

EPA Response: As part of our review, the EPA requested supporting documents for minor
modifications, and we did not find all the relevant information in the local permit engineering
evaluations. As previously stated, if the SDAPCD believes the local permit engineering evaluations
support the title V permit action, then the evaluations should be included as part of the title V
permit package. The EPA commends the SDAPCD for taking steps in making these changes and
documenting its permitting decisions. This finding and recommendation remain as drafted.

17.	Finding 5.4

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SDAPCD Comment: The SDAPCD did not agree that it does not calculate or track the facility's
potential to emit (PTE) on a facility-wide basis or may not be properly implementing permitting for
sources which take synthetic limits to stay out of title V. While the SDAPCD does not maintain a
tabulated list of PTE for all stationary sources, it instead conducts this review at the time a change
occurs at a facility.

For existing sources, the SDAPCD utilizes the actual emissions that Rule 60.1 allows for sources to
be exempt from title V requirements based on having actual emissions one half the major source
threshold (a list of such facilities was provided to the EPA). This means that by tracking actual
emissions and identifying those facilities with emissions above half the threshold, the District has to
only assess PTE for those facilities with actual emissions between 50 and 100% of the major source
threshold to determine if their PTE is below, at, or above 100% of the major source threshold,
significantly reducing the resources necessary to identify major sources. Also please note that the
SDAPCD evaluates any requirements dependent on facility PTE for NSR during review of the
application associated with new or modification of a source.

So to summarize, the SDAPCD does use PTE to determine requirements. However, in lieu of
maintaining a tabulated list of facility PTE, the District instead assesses facility PTE at the time each
modification occurs and for existing facilities not being modified, tracks actual emissions and
compares to the thresholds in SDAPCD Rule 60.1 which means the SDAPCD is using a more
stringent screening method to detect title V facilities than required by the underlying rules. Then
for any facility with actual emissions above the thresholds of 60.1 the SDAPCD can conduct an
assessment of PTE to determine whether the facility is actually exempt based on PTE.

The second point of this finding refers to synthetic minor permits. SDAPCD would like to provide
some clarification as to how the local permitting program ties into title V permitting. Rule 60.2 is
the SDAPCD's synthetic minor source rule and was intended to be used by existing sources that do
not have their emissions limited through NSR. However, for the vast majority of facilities, emissions
are limited mainly through permit restrictions imposed through NSR Rules 20.2 or 20.3, including
appropriate monitoring and recordkeeping, and included in ATCs and PTOs that are therefore
federally enforceable limits.

EPA Response: We disagree that the SDAPCD's approach to determining title V applicability, as
described above, is consistent with the title V program. The characterization of Rule 60.1 is not
consistent with the rule's own language, as the rule is not applicable to all sources but only those
that would otherwise be a major source. One would first need to know the PTE of a facility to
determine whether Rule 60.1 is applicable because PTE is the determining factor of major source
status. Because the SDAPCD does not determine PTE, it is relying on facilities to determine whether
they are otherwise a major source. It appears the SDAPCD would like to generally assume that any
source with actual emissions below 50% of the major source thresholds is not a title V source.

There is nothing in the part 70 program, or the SDAPCD's approved title V program, that supports
this approach. Reviewing actual emissions is neither equivalent to nor more stringent than
determining PTE.

9

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It was clear during our site visit that the SDAPCD had a difficult time determining which sources
would be subject to title V because of the reclassification, as the District does not calculate facility-
wide PTE as defined by the title V program. The SDAPCD must develop a plan for ensuring the
District can determine title V applicability according to the definitions for "potential to emit" and
"major source" in 40 CFR 70.2. The EPA looks forward to working with the District on a workplan at
the conclusion of this program evaluation. This finding and recommendation remain as drafted.

18.	Finding 6.1

SDAPCD Comment: The processing of open applications should not interfere with the schedule for
conducting effective inspections, because the outcome of inspections should be based on existing
permits and not applications requesting changes to the permits. The SDAPCD appreciates the EPA's
recognition that the SDAPCD performs Full Compliance Evaluations (FCEs) for all title V sources
annually.

EPA Response: From our interviews, the concern expressed to us related to scenarios where open
applications delayed completing title V inspections because processing the application would avoid
the need to issue a violation. It is possible Engineering and Compliance disagree on the need and
urgency of such permit revisions. We continue to recommend increased communication between
Permitting and Compliance so that these issues can be addressed and there is a common
understanding of what should happen in these scenarios.

19.	Finding 6.6

SDAPCD Comment: The District noted that the SDAPCD does not presently have a Permit
Streamlining Committee. The SDAPCD also does not believe that permit condition change requests
have stopped being made. The SDAPCD appreciates the EPA's recognition that there is a formal
process in place for Compliance to request changes to permit conditions and agrees that a realistic
expectation with appropriate timeframe be established. Please note that the SDAPCD had already
begun work on addressing this issue. One point to consider is that in order to change permit
conditions, the SDAPCD has to follow the formal process which makes it clear that some condition
changes to title V permits would require an EPA comment period and, in some cases, public notice
and public review. This means that the title V permits can't just be simply revised without going
through title V permits revision requirements. For this reason, some of the requested condition
changes in the past have been scheduled to be included with the next permit modification or
renewal to avoid multiple permit revisions and EPA or public noticing and reviews.

EPA Response: The Permit Streamlining Committee is included in the SOP we were provided. We
recommend the SDAPCD modify its SOP to reflect the current process. The EPA commends the
SDAPCD for already working on addressing permit change request issues. We encourage the
SDAPCD to provide responses to change requests even when the District does not believe the
changes can be made. Having documentation that requestors can refer to will help everyone
understand why certain determinations were made.

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20. Finding 7.1

SDAPCD Comment: The SDAPCD appreciates the EPA's recognition that the SDAPCD staff receives
effective support from the SDAPCD's Counsel. The SDAPCD has a new District Counsel, Veera Tyagi,
who has extensive experience in air quality programs. Prior to joining the SDAPCD, Ms. Tyagi
worked as a Principal Deputy District Counsel at South Coast Air Quality Management District. We
are very happy and excited to have Veera working as our Counsel and she can provide expert legal
support on all title V and other air quality matters.

EPA Response: The EPA commends the SDAPCD for finding counsel with extensive experience in air
quality programs. This finding has been updated to include this updated information.

21.	Finding 7.6

SDAPCD Comment: The SDAPCD stated that a compensation analysis was recently conducted for
the Service Employees International Union (SEIU). This analysis, conducted for all represented
SDAPCD employees, considered several other local air pollution control districts, such as San Luis
Obispo County APCD, Bay Area AQMD, Imperial County APCD, Sacramento Metro AQMD and South
Coast AQMD. Also the County Contract for SEIU compensation package was approved by the San
Diego County Board of Supervisors in June 2022.

The SDAPCD, like other entities, experienced a high turnover after the COVID-19 pandemic,
increasing the number of vacancies. The SDAPCD is committed to continuing to monitor the
workload and explore opportunities to provide adequate resources and fill vacancies with the best
candidates to address any potential retention issues.

EPA Response: The EPA has modified its finding to reflect the new information that the SDAPCD
provided. As a result, our finding is more focused on the need for a review of the District's existing
staffing in light of its current permitting backlog as well as a review of the additional staffing that
will likely be needed as the number of facilities subject to title V permitting requirements increase
under the SDAPCD's new nonattainment reclassification.

22.	Finding 8.3

SDAPCD Comment: The SDAPCD noted that the draft report stated that it took three weeks to get a
report query. The SDAPCD would like to clarify that it is due to other priorities that the District
could not run the query sooner and not that it took three weeks to run one query.

EPA Response: The EPA made minor revisions to this finding to clarify this issue. This issue was
flagged in our report because it was a longer than expected timeframe compared to other
permitting authorities.

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23. Other General Comments

In addition to the significant comments summarized in this document, the SDAPCD provided
additional recommendations and commentary related to style, minor edits, and formatting. The
EPA reviewed these comments as well and incorporated minor edits into the final report as
appropriate.

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Appendix J. SDAPCD's Draft Report Response

Page 58 of 59

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San Diego County

~g| Air Pollution
Control District

August 30, 2022

Gerardo C. Rios, P.E.

Manager, Permits Office
Air and Radiation Division
U.S. EPA, Region IX
75 Hawthorne Street
San Francisco, CA 94105

RE: Draft San Diego County Air Pollution Control District Title V Program Evaluation

Dear Mr. Rios:

Thank you for the opportunity to review and provide comments on the Draft Program Evaluation for the
San Diego County Air Pollution Control District's (SDAPCD's) Title V Operating Permit Program
Evaluation. I appreciate you and your staff s time, cooperation, support and follow up meetings and
correspondence with my staff in conducting the evaluation of the SDAPCD's Title V program. We have
reviewed the draft report, and would like to provide you with some additional information and
clarification in order to ensure that it more accurately reflects SDAPCD's Title V program.

Therefore, attached please find a copy of the draft report with SDAPCD's comments and responses to
each finding and the associated recommendations. Staff provided our response to each finding after each
recommendation, along with additional comments related to the finding and the discussion.

Please feel free to contact me at (858)586-2706, Mahiany Luther, Deputy Director, at (858)586-2725, or
Mohsen Nazemi, Chief of Engineering Division at (858)922-1182, if you have any questions. I look
forward to assisting EPA to finalize the report and to our continued collaboration to ensure the
SDAPCD's Title V program is implemented in an effective manner to improve air quality and public
health in San Diego County.

Sincerely,

Paula Forbis

Air Pollution Control Officer

10124 Old Grove Rd. San Diego California 92131-1649
(858) 586-2600 Fax (858) 586-2601
www.sdapcd.org

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San Diego County Air Pollution Control District
Title V Operating Permit Program Evaluation

Draft Report

July 28, 2022

Conducted by the

U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, California 94105

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Table of Contents

Acknowledgments	5

Glossary of Acronyms and Abbreviations	6

Executive Summary	7

1.	Introduction	10

Background	10

Title V Program Evaluation at the San Diego County Air Pollution Control District	11

Description of the SDAPCD	12

EPA's Findings and Recommendations	1

2.	Permit Preparation and Content	15

2.1	Finding: The SDAPCD has an internal quality assurance process for reviewing draft versions of
permits before they are made available for review by the public and the EPA; however, the
understanding of the review process is inconsistent between various groups and varies with level of
experience	15

2.2	Finding: The SDAPCD's statement of basis does not consistently describe regulatory and policy
decisions the District has made in the permitting process	17

2.3	Finding: The SDAPCD uses template permit documents and maintains template conditions in its
database to provide consistency in its permits	19

2.4	Finding: The SDAPCD does not evaluate whether a requested title V permit modification meets
the criteria under which it is submitted, including confirming whether a change is a modification under
title I of the CAA	20

2.6	Finding: The SDAPCD generally references the underlying origin and authority for permit
conditions, but often does not reference the origin of New Source Review (NSR)
requirements	22

2.7	Finding: While the SDAPCD appears to streamline applicable requirements in its title V permits,
the District generally does not provide the necessary streamlining analysis in the statement of
basis	23

2.8	Finding: The SDAPCD clearly identifies locally enforceable conditions in title V permits	25

3.	Monitoring	25

3.1 Finding: While the SDAPCD generally reviews CAM applicability, internal guidance needs to be
updated and staff need training	26

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3.2	Finding: The SDAPCD's title V permits generally contain monitoring that is sufficient to
determine compliance with emissions limits. However, the SDAPCD's statement of basis does not
consistently address periodic monitoring	27

3.3	Finding: The SDAPCD generally includes sufficient recordkeeping requirements as required by
the NSPS and NESHAP regulations	28

4.	Public Participation and Affected State Review	29

4.1	Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services as required by 40 CFR Part
7.35(a)	30

4.2	Finding: The SDAPCD provides public notices of its draft title V permitting actions on its
website	31

4.3	Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit	32

4.4	Finding: The SDAPCD's general practice is to conduct a concurrent public and EPA review. If
comments are received during the 30-day public review period, the permit package is re-proposed to
the EPA for a new 45-day review period	33

4.5	Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application
meetings with potential sources to help identify the scope of potential permitting projects and the
applicability of regulatory requirements	34

4.6	Finding: The SDAPCD notifies tribes of title V permitting actions	35

5.	Permit Issuance / Revision / Renewal	36

5.1	Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog	36

5.2	Finding: The SDAPCD routinely submits proposed and final permit actions to the EPA	37

5.3	Finding: The SDAPCD has authority to use parallel processing to streamline the issuance of
modified NSR and title V permits. However, it is not clear that this processing method is correctly
utilized	38

5.4	Finding: The District does not evaluate the potential emissions from sources without title V
permits to determine if they are major sources or whether such sources need synthetic limits to avoid
title V applicability or other CAA requirements	39

6.	Compliance	41

6.1 Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS)	42

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6.2	Finding: The District's Compliance Division reviews all title V deviation reports, annual
compliance certifications, and semiannual monitoring reports submitted by Part 70 sources	42

6.3	Finding: When potential compliance issues are discovered, the District addresses them prior to
permit issuance. However, the District's statement of basis could be improved to include compliance
history	43

6.4	Finding: The District uses title V compliance certifications and semiannual monitoring reports
to prioritize inspections and initiate enforcement actions	44

6.5	Finding: Compliance staff have the necessary equipment to perform their job duties but find
the procurement process for new equipment to be slow	45

6.6	Finding: While the SDAPCD has a process in their internal database for compliance staff to
request changes to title V permits, it is unclear if it is being used consistently	45

7.	Resources and Internal Management	46

7.1	Finding: The SDAPCD staff report that they receive effective legal support from the District
Counsel's office	47

7.2	Finding: The District tracks title V program expenses and revenue and those funds are spent
solely to support the title V program	47

7.3	Finding: The District permitting and compliance management communicate well and meet
routinely to discuss programmatic issues. However, the results of these discussions are not clearly and
consistently communicated to compliance staff and has resulted in uncertainty regarding outcomes of
issue resolution among compliance staff	48

7.4	Finding: The District lacks a training plan for its permitting and compliance staff. 49

7.5	Finding: Permitting staff demonstrated a general lack of knowledge on environmental justice
(EJ) and would like the EPA to provide training on this issue	50

7.6	Finding: The SDAPCD is having difficulty retaining permitting and compliance staff. 51

8.	Records Management	53

8.1	Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center	53

8.2	Finding: The SDAPCD has improved its written file retention policy. However, most staff are not
aware of the District's record retention schedules	53

8.3 Finding: The SDAPCD uses an electronic database to track title V permits and continues to make
database improvements	54

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Acknowledgments

The EPA Region 9 acknowledges the cooperation of the staff and management of the San Diego County
Air Pollution Control District (SDAPCD). We appreciate their willingness to respond to information
requests and share their experiences regarding the implementation of the SDAPCD's title V program
under the Clean Air Act.

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Glossary of Acronyms and Abbreviations

AB

Assembly Bill

Act

Clean Air Act [42 USC Section 7401 et seq.]

ATC

Authority to Construct

CAA

Clean Air Act [42 USC Section 7401 et seq.]

CAM

Compliance Assurance Monitoring

CARB

California Air Resources Board

CFR

Code of Federal Regulations

CMS

Compliance Monitoring Strategy

District

San Diego County Air Pollution Control District

EJ

Environmental Justice

EPA

U.S. Environmental Protection Agency

EPS

Electronic Permit System

FCE

Full Compliance Evaluation

HAP

hazardous air pollutants

NESHAP

National Emission Standards for Hazardous Air Pollutants, 40 CFR Parts 61 & 63

NOV

Notice of Violation

NOx

Nitrogen Oxides

NSPS

New Source Performance Standards, 40 CFR Part 60

NSR

New Source Review

NTC

Notice to Comply

OEJ

Office of Environmental Justice

OIG

EPA Office of Inspector General

PSD

Prevention of Significant Deterioration

PTE

Potential to Emit

PTO

Permit to Operate

Region

U.S. Environmental Protection Agency Region 9

BAP

Business Assistance Program

SDAPCD

San Diego County Airy Pollution Control District

SIP

State Implementation Plan

SOP

Standard Operating Procedure

Team

EPA Region 9 Program Evaluation Team

we

U.S. Environmental Protection Agency

Page of 55

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Executive Summary

In response to the recommendations of a 2002 Office of Inspector General (OIG) audit, the U.S.
Environmental Protection Agency (EPA or "we") re-examined the ways it can improve state and local
operating permit programs under title V of the Clean Air Act ("title V programs") and expedite permit
issuance. Specifically, the EPA developed an action plan for performing program evaluations of title V
programs for each air pollution control agency beginning in fiscal year 2003. The purpose of these
program evaluations is to identify good practices, document areas needing improvement, and learn
how the EPA can help the permitting agencies improve their performance.

The EPA's Region 9 (the "Region") oversees 47 air permitting authorities with title V programs in the
Pacific Southwest. Of these, 43 are state or local authorities approved pursuant to 40 CFR part 70 (35 in
California, three in Nevada, four in Arizona, and one in Hawaii), referred to as "Part 70" programs. The
terms "title V" and "Part 70" are used interchangeably in this report. The Region also oversees a
delegated title V permitting program in Navajo Nation under 40 CFR part 71 and title V programs in
Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands under 40 CFR part
69, referred to, respectively, as "Part 71" and "Part 69" programs. Because of the significant number of
permitting authorities, the Region has committed to performing, on an annual basis, one
comprehensive title V program evaluation of a permitting authority with 20 or more title V sources.
This approach covers at least 85% of the title V sources within the Region 9 jurisdiction.

The Region initially conducted a title V program evaluation of the San Diego County Air Pollution
Control District (SDAPCD or "District") in 2008 ("2008 Evaluation").1 This is the second title V program
evaluation the EPA has conducted for the SDAPCD. The EPA Region 9 program evaluation team
("Team") for this evaluation consisted of the following EPA personnel: Meredith Kurpius, Air and
Radiation Division Assistant Director; Gerardo Rios, Manager of the Air Permits Office; Noah Smith,
Attorney Advisor; Ken Israels, Program Evaluation Advisor; Sheila Tsai, Program Evaluation
Coordinator; Mario Zuniga, SDAPCD Oversight Team Lead; Lisa Beckham, Program Evaluation Team
Member; Amber Batchelder, Program Evaluation Team Member; Tina Su, Program Evaluation Team
Member; Po-Chieh Ting, Program Evaluation Team Member; Catherine Valladolid, Program Evaluation
Team Member; and Camille Cassar, Program Evaluation Team Member.

The program evaluation was conducted in four stages. During the first stage, the Region sent the
SDAPCD a questionnaire focusing on title V program implementation in preparation for the interviews
(see Appendix B, Title V Questionnaire and SDAPCD Responses). During the second stage, the Team
conducted an internal review of the EPA's own set of SDAPCD permit files. The third stage of the
program evaluation was a hybrid site visit, which consisted of Region 9 representatives visiting the
SDAPCD office in San Diego, California to conduct interviews of the SDAPCD staff and managers in
person and virtually. Because this was a hybrid site visit, some of the interviews were conducted
virtually through video conferencing. The site visit took place March 28-30, 2022. Finally, the fourth
stage involved follow-up and clarification of issues for completion of the draft report.

1 San Diego County Air Pollution Control District; Title V Operating Permit Program Evaluation, dated September 30, 2008.
See https://www.epa.gov/sites/default/files/2015-07/documents/sd-finalreport-93020Q8.pdf.

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We recognize that the District is going through many changes: brand new governance structure, new
governing board and leadership, as well as the recent reclassification for ozone from serious to severe.
" rs;> Region's 2022 evaluation of the SDAPCD's implementation of the Part 70 program concludes that
the SDAPCD has areas for improvements but is already taking steps to improve its implementation of
the program. For example, title V permitting workload will be distributed more evenly amongst
permitting staff and the District is focusing on a more comprehensive outreach process for its
programs, he uding through the creation of the Office of Environmental Justice (OEJ) under the
Monitoring and Technical Services Division. A framework for the new Office of Environmental Justice2
and Public Participation Plan3 was developed and approved by the new governing board. The SDAPCD
is making positive changes and we hope our findings and recommendations will further assist the
District in improving its implementation of the program.

Overall, the District's title V permits generally contain sufficient monitoring, recordkeeping, and
reporting requirements to determine compliance with emissions limits The District could use some
overall improvement in standardizing and documenting its work processes and permitting decisions in
its supporting documents. This would resolve most of the findings we have related to the support
document that explains the legal and factual basis for permit conditions (referred to as the "statement
of basis"). We also want to emphasize the need for the SDAPCD to evaluate the potential emissions
from each facility to accurately determine a source's major source and/or synthetic minor status. We
recognize the District is actively working on its backlog and currently lacks sufficient resources, but we
also note that the SDAPCD continues to perform full compliance evaluations of all title V sources and
reviews all title V deviation, annual, and semiannual reports submitted by Part 70 sources.

f;orne major findings we want to highlight from our report are listed below:

1.	Finding: The SDAPCD's statement of basis does not consistently describe regulatory and policy
decisions the District has made in the permitting process. (Finding 2.2)

2.	Finding: The SDAPCD does not evaluate whether a requested title V permit modification meets
the criteria under which it is submitted, including confirming whether a change is a modification
under title I of the CAA. (Finding 2.4)

3.	Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit. (Finding 4.2)

4.	Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services. (Finding 4.3)

5.	Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application
meetings with potential sources to help identify the scope of potential permitting projects and

2	See https://www.sdapcd.org/content/dam/sdapcd/documents/communitv/environmental-iustice-
/APCD%200ffice%20of%20Environmental%20Justice Draft%20Framework.pdf.

3	See https://www.participatesdapcd.org/About%20the%20Plan/.

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the applicability of regulatory requirements. (Finding 4.5)

6.	Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog. (Finding 5.1)

7.	Finding: The District does not evaluate the potential emissions from sources without title V
permits to determine if they are major sources or whether such sources need synthetic limits to
avoid title V applicability or other CAA requirements. (Finding 5.4)

8.	Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS). (Finding 6.1)

9.	Finding: The District tracks title V program expenses and revenue to ensure that funding is
sufficient, and those funds are spent solely to support the title V program. (Finding 7.2)

10.	Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center. (Finding 8.1)

Our report provides a series of findings (in addition to those listed above) and recommendations that
should be considered in addressing our findings. As part of the program evaluation process, the
SDAPCD has been given an opportunity to review these findings and consider our recommendations.

In addition, our evaluation also considered whether issues found during our 2008 Evaluation have since
been addressed. As discussed in Findings 2.3, 4.1, and 4.6, the District has corrected issues related to
ensuring permits are signed, publishing public notices in a newspaper of general circulation, and
notifying tribal governments of title V permitting actions. discussed in Findings, 2.4, 6.6, 7.3, and
7.5, the District has not fully addressed issues related to streamlining NSR and title V actions consistent
with the title V program, ensuring recommendations from compliance staff to improve permit
enforceability are considered in a timely manner, improving communication between permitting and
compliance staff, and improving permitting staffs knowledge of environmental justice.

To better communicate our recommendations and work together on the recommended
improvements,request an initial kick-off meeting within 90 days of the SDAPCD's receipt of the
final report to discuss developing a workplan. A workplan typically includes specific goals and
milestones that can be used to demonstrate progress. We commit to meet with the SDAPCD regularly
to discuss progress until both the SDAPCD and the EPA mutually agree the workplan items are
sufficiently complete.

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1. Introduction

Background

In 2000, the EPA's Office of Inspector General (OIG) initiated an evaluation on the progress that the
EPA and state and local agencies were making in issuing title V permits under the Clean Air Act (CAA or
the "Act"). The purpose of OIG's evaluation was to identify factors delaying the issuance of title V
permits by selected state and local agencies and to identify practices contributing to timely issuance of
permits by those same agencies.

After reviewing several selected state and local air pollution control agencies, the OIG issued a report
on the progress of title V permit issuance by the EPA and states.1 In the report, the OIG concluded that

(1)	a lack of resources, complex EPA regulations, and conflicting priorities contributed to permit delays;

(2)	EPA oversight and technical assistance had little impact on issuing title V permits; and (3) state
agency management support for the title V program, state agency and industry partnering, and permit
writer site visits to facilities contributed to the progress that agencies made in issuing title V operating
permits.

The OIG's report provided several recommendations for the EPA to improve title V programs and
increase the issuance of title V permits. In response to the OIG's recommendations, the EPA made a
commitment in July 2002 to carry out comprehensive title V program evaluations nationwide. The
goals of these evaluations are to identify where the EPA's oversight role can be improved, where air
pollution control agencies are taking unique approaches that may benefit other agencies, and where
local programs need improvement. The EPA's effort to perform title V program evaluations for each air
pollution control agency began in fiscal year 2003.

On October 20, 2014, the OIG issued a report, "Enhanced EPA Oversight Needed to Address Risks From
Declining Clean Air Act Title V Revenues," that recommended, in part, that the EPA: establish a fee
oversight strategy to ensure consistent and timely actions to identify and address violations of 40 CFR
part 70; emphasize and require periodic reviews of title V fee revenue and accounting practices in title
V program evaluations; and pursue corrective actions, as necessary.5

The Region oversees 47 air permitting authorities with title V programs in the Pacific Southwest. Of
these, 43 are state or local authorities approved pursuant to 40 CFR part 70 (35 in California, three in
Nevada, four in Arizona, and one in Hawaii), referred to as "Part 70" programs. The terms "title V' and
"Part 70" are used interchangeably in this report. The Region also oversees a delegated title V
permitting program in Navajo Nation under 40 CFR part 71 and title V programs in Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands under 40 CFR part 69, referred to,

4	Report No. 2002-P-00008, Office of Inspector General Evaluation Report, "EPA and State Progress In Issuing title V
Permits", dated March 29, 2002. See https://www.epa.gov/sites/production/files/2015-12/documents/titlev.pdf.

5	Report No. 15-P-0006, Office of Inspector General Evaluation Report, "Enhanced EPA Oversight Needed to Address Risks
From Declining Clean Air Act Title V Revenues", dated October 20, 2014. See
https://www.epa.gov/sites/production/files/2015-09/documents/20141020-15-p-00Q6.pdf.

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respectively, as "Part 71" and "Part 69" programs. Because of the significant number of permitting
authorities, the Region has committed to performing, on an annual basis, one comprehensive title V
program evaluation of a permitting authority with 20 or more title V sources. This approach covers at
least 85% of the title V sources within the Region 9 jurisdiction.

Title V Program Evaluation at the San Diego County Air Pollution Control District

This is the second title V program evaluation the EPA has conducted for the SDAPCD. The first title V
program evaluation was conducted in 2008. Thus, this evaluation is a follow-up to SDAPCD's 2008
Evaluation. The EPA Region 9 Team for this evaluation consisted of the following EPA personnel:
Meredith Kurpius, Air and Radiation Division Assistant Director; Gerardo Rios, Manager of the Air
Permits Office; Noah Smith, Attorney Advisor; Ken Israels, Program Evaluation Advisor; Sheila Tsai,
Program Evaluation Coordinator; Mario Zuniga, SDAPCD Oversight Team Lead; Lisa Beckham, Program
Evaluation Team Member; Amber Batchelder, Program Evaluation Team Member; Tina Su, Program
Evaluation Team Member; Po-Chieh Ting, Program Evaluation Team Member; Catherine Valladolid,
Program Evaluation Team Member; and Camille Cassar, Program Evaluation Team Member.

The objectives of the evaluation were to assess how the SDAPCD implements its title V permitting
program, evaluate the overall effectiveness of the SDAPCD's title V program, identify areas of the
SDAPCD's title V program that need improvement, identify areas where the EPA's oversight role can be
improved, and highlight the unique and innovative aspects of the SDAPCD's program that may be
beneficial to transfer to other permitting authorities. The program evaluation was conducted in four
stages. In the first stage, the EPA sent the SDAPCD a questionnaire focusing on title V program
implementation in preparation for the interviews. (See Appendix B, Title V Questionnaire and SDAPCD
Responses.) The Title V Questionnaire was developed by the EPA nationally and covers the following
program areas: (1) Title V Permit Preparation and Content; (2) General Permits; (3) Monitoring; (4)
Public Participation and Affected State Review; (5) Permit Issuance/Revision/Renewal Processes; (6)
Compliance; (7) Resources & Internal Management Support; and (8) Title V Benefits.

During the second stage of the program evaluation, the Region conducted an internal review of the
EPA's SDAPCD title V permit files. The SDAPCD submits title V permits to the Region in accordance with
its EPA-approved title V program and the Part 70 regulations.

The third stage of the program evaluation was a hybrid site visit, which consisted of Region 9
representatives visiting the SDAPCD office in San Diego, California to conduct interviews of the SDAPCD
staff and managers in person. Because this was a hybrid site visit, some of the interviews were
conducted virtually through video conferencing. The purpose of the interviews was to confirm the
responses in the completed questionnaire and to ask clarifying questions. The site visit took place
March 28-30, 2022.

The fourth stage of the program evaluation was follow-up and clarification of issues for completion of
the draft report. The Region compiled and summarized interview notes and asked follow-up questions
to clarify the Region's understanding of various aspects of the SDAPCD's title V program.

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Description of the SDAPCD

The SDAPCD's mission is to "improve air quality to protect public health and the environment." The
SDAPCD is currently organized into five divisions: (1) Engineering, (2) Compliance, (3) Monitoring and
Technical Services, (4) Rule Development, and (5) Grants and Incentives. Stationary source operating
permits, including title V permits, are issued by the Engineering Division. Compliance and enforcement
activities, such as facility inspections and preparing enforcement cases are handled by the Compliance
Division. Source testing is conducted by the Monitoring and Technical Services Division. The Rule
Development Division develops and implements air quality rules and attainment plans. The Grants &
Incentives Division administers a number of state and local funding programs to reduce emissions,
primarily from mobile sources. 6 The SDAPCD's office is located in San Diego, California.

Since 1955, the 5-member County of San Diego Board of Supervisors served as the District's governing
board, known as the Air Pollution Control Board. As of March 1, 2021, California Assembly Bill (AB) 423
(Gloria, 2019) amended State law to restructure and expand the governing board of the SDAPCD. AB
423 adds specified duties to the District, requires the California Air Resources Board (CARB) to conduct
a program audit of the District7, separates the SDAPCD from the County governance structure, and
requires the appointment of a new 11-member governing board." With AB 423, the SDAPCD is focusing
on a more comprehensive outreach process for its permitting actions and has created the Office of
Environmental Justice (OEJ) under the Monitoring and Technical Services Division. A framework for the
new Office of Environmental Justice9 and Public Participation Planwas developed and approved by
the new governing board on April 14, 2022. In addition to governing board changes, the SDAPCD
recently had several experienced staff retire and selected new senior leadership and a new Air
Pollution Control Officer.

In addition to changes in structure and leadership, the workload associated with the SDAPCD's
implementation of the title V program is expected to increase. Effective July 2, 2021, the EPA
reclassified the San Diego County ozone nonattainment area from "Serious" to "Severe" for the 2008
ozone National Ambient Air Quality Standards (NAAQS) and from "Moderate" to "Severe" for the 2015
ozone NAAQS.11 Upon reclassification, the threshold at which a source is considered a major source
under the Part 70 program for emissions of nitrogen oxides (NOx) and volatile organic compounds
(VOC) dropped in San Diego County from 50 tons per year to 25 tons per year. All major stationary
sources under part D of the CAA are required to obtain a title V permit and have year from
becoming subject to the title V program to submit an initial title V permit application. Thus, an influx of
initial title V applications is expected for those sources newly subject to the title V program in San
Diego County.

6	See https://www.sdapcd.org/content/sdapcd/about.html.

7	See https://ww2.arb.ca.gov/our-work/programs/san-diego-program-review.

8	See https://www.sdapcd.org/content/sdapcd/about/district-boards/governing-board.html.

9	See https://www.sdapcd.org/content/dam/sdapcd/documents/community/environmental-iustice-
/APCD%200ffice%20of%20Environmental%20Justice Draft%20Framework.pdf.

10	See https://www.participatesdapcd.org/About%20the%20Plan/ .

11	See 86 FR 29522 (June 2, 2021).

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The EPA granted the SDAPCD's title V program interim approval effective December 7,1995, and full
approval effective November 30, 2001. The EPA also later granted approval of program revisions that
were effective on February 27, 2004.12 On October 21, 2021, the District submitted additional updates
to its title V program that the EPA is currently processing.13

The Part 70 program generally requires that a permitting authority take final action on each permit
application within 18 months after receipt of a complete permit application. Additionally, a permitting
authority must take action on an application for a minor modification within 90 days of receipt of an
application (or 15 days after the EPA's 45-day review period, whichever is later) and the permitting
authority has 60 days to act on requests for administrative permit amendments.14 The SDAPCD's local
rules regarding title V permit issuance contain the same or more stringent timeframes as the Part 70
program.15

Currently, there are 28 sources in the SDAPCD jurisdiction that are subject to the title V permit
program, with the San Diego County's ozone nonattainment area reclassification, the SDAPCD is
expecting at least 12 more title V sources.16 Unlike the conclusion from our 2008 Evaluation, the
District does not currently have sufficient permitting resources'' and is unable to process title V permit
applications in a timely manner that results in a title V permit application backlog.

SDAPCD's Approach to the Title V Program

Consistent with the other permitting authorities in California, when the EPA approved the SDAPCD's
title V operating permit program, the District had already been implementing an operating permit
program locally for many years. As a result, the title V program was implemented as an overlay to the
District's local permitting program. The existing program requires permits to be issued for individual
pieces of equipment. Each Authority to Construct (ATC) permit is issued prior to the construction of the
emissions unit and typically contains conditions required for the construction and initial operation. The
ATC permit is then converted to a Permit to Operate (PTO) after construction is completed and
operation of the emissions unit has commenced. During the conversion from ATC to PTO, certain ATC
permit conditions are not retained in the PTO if the ATC conditions are determined to be obsolete or
irrelevant because they were construction related. Furthermore, because these operating permits are

12	See Appendix A, 40 CFR part 70.

13	This revision includes updates to the District's definition for major stationary source. Although the District has revised its
NSR rules to include the correct major source thresholds, the definition in the District's title V rules still contains an error
where the major source threshold for all criteria pollutants is identified as 100 tons per year. Although this error exists, the
SDAPCD implemented its approved title V program at the prior 50 tpy threshold for NOx and VOC consistent with the
requirements of title V of the CAA and the Part 70 program. The revisions we are currently processing will clarify which
sources must obtain title V permits. If the EPA determines a permitting authority is not adequately administering an
approved Part 70 program, we will provide notification of the deficiency and, when related to a pollutant in a
nonattainment area, apply sanctions as appropriate until the deficiency is resolved. See CAA section 502(i).

14	See 40 CFR 70.7(a)(2) and 70.7(e)(2)(iv).

15	See the SDAPCD Rule 1410.

16	See Finding 5.4 of this report for more discussion on the District's title V source determination.

17	See Section 7 of this report for more discussion on the SDAPCD's resource management.

18	See Finding 5.1 of this report for more discussion on the District's title V backlog.

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linked to fee payment and renewed annually, new permit conditions can be added or revised each year
as applicable. However, these local PTOs do not meet all the requirements for an operating permit
required by title V of the CAA.

To implement the title V program, the SDAPCD's title V permits are created by including all the local
PTOs and then adding additional sections for facility-wide applicable requirements and title V program
-specific conditions such as semi-annual monitoring, annual compliance certifications, deviation
reporting, and additional monitoring to assure compliance. The result is that title V sources in SDAPCD
have two sets of operating permits with overlapping requirements.

Historically, the SDAPCD only had one title V permit engineer that was assigned all title V permits, and
most of the SDAPCD title V permit actions are performed under the conditions of section 502(b)(10) of
the CAA (known as a "502(b)(10) change"). When a modification is needed, the general process is that
the applicant would submit both an ATC application and a 502(b)(10) change. The ATC/PTO would be
issued first, and the 502(b)(10) change would be incorporated later into the title V permit, typically
during the renewal.

In our view, to evaluate the SDAPCD's title V program, we must also consider the District's ATC/PTO
actions for title V sources because these permit decisions are relied upon to create the District's title V
permits and would typically represent title V permit modifications.|q Throughout this report, when we
refer to the District's title V program, we are also generally considering the local ATC/PTO actions for
title V sources. However, because the SDAPCD uses separate processes for what it considers to be
ATC/PTO and title V permit actions, we will refer to the ATC/PTO permit as the "local permit" to make
the distinction when necessary/"

During our site visit, we learned that the SDAPCD is planning to change how the title V program is
being implemented. Title V permits will no longer be written and revised by a single engineer, instead
the workload will be distributed across permitting staff and more training will be provided. We
acknowledge that the SDAPCD has experienced and is still experiencing many changes; we are
conducting our evaluation based on what we learned, and we hope to assist the District in its title V
program implementation going forward.

Sections 2 through 8 of this report contain the EPA's findings regarding implementation of the title V
permit program by SDAPCD.

19	See Finding 2.4 of this report for more discussion on how the SDAPCD categorize its title V permitting actions.

20	This approach also necessarily affects how title V fees are gathered and spent as the title V fees are viewed as being in
addition to the fees collected for the pre-title V permitting program. See our fee-related finding in Chapter 7 of this
evaluation report.

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The EPA's Findings and Recommendations

The following sections include a brief introduction, and a series of findings, discussions, and
recommendations. The findings are grouped in the order of the program areas as they appear in the
Title V Questionnaire.

The findings and recommendations in this report are based on the District's responses to the Title V
Questionnaire, the EPA's internal file reviews, interviews conducted during the March 28-30, 2022 site
visit, and follow-up emails and phone calls subsequent to the site visit.

2. Permit Preparation and Content

The purpose of this section is to evaluate the permitting authority's procedures for preparing title V
permits. Part 70 outlines the necessary elements of a title V permit application under 40 CFR 70.5, and
it specifies the requirements that must be included in each title V permit under 40 CFR 70.6. Title V
permits must address all applicable requirements, as well as necessary testing, monitoring,
recordkeeping, and reporting requirements sufficient to assure compliance with the terms and
conditions of the permit.

2.1 Finding: The SDAPCD has an internal quality assurance process for reviewing draft versions of
permits before they are made available for review by the public and the EPA; however, the
understanding of the review process is inconsistent between various groups and varies with
level of experience.

Discussion: Based on the interviews, we found that all SDAPCD issued permits undergo an
internal review process; however, we received inconsistent answers as to who is involved in the
review process for local and title V permits. This is mostly likely caused by the separate
procedures used for issuing title V and local permits, where, historically, only one staff person
processed title V permits.' "¦ • SDAPCD does not maintain a clear Standard Operating Procedure
(SOP) on the process for issuing local or title V permits. Our overall understanding is that draft
local permits go through a more extensive review process than the draft title V permits. I.ocal
draft permits are sent to the Compliance Division for review. Then, the draft local permit is sent
to the senior engineer in the appropriate Engineering Division section for review. Senior
management does not typically get involved in this review unless an unresolved issue requires
attention, or a cursory review is needed. After the internal review is complete, the draft local
permit is sent to the permittee for review and comment before it is public noticed. In contrast,
the permit review process was less clear when discussing title V permits. At a minimum, draft
title V permits go to the title V permit manager for review. We received inconsistent responses
about whether the Compliance Division reviews them or not.

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Many pointed out that there has been extensive turnover within the District,21 and
communications have not been as effective due to lack of training. There was an even split in
response between interviewees regarding whether the Compliance Division reviews the title V
permits. Some compliance staff also mentioned they have stopped sending comments to the
Engineering Division after repeatedly not seeing feedback being incorporated into permits.22

Recommendation: The EPA acknowledges that the SDAPCD recently changed how it processes
title V permits, and many processes and responsibilities are still in transition. As part of the
transition, the SDAPCD should document the procedure of its quality assurance process and
provide staff training so the process can be implemented consistently. The EPA suggests that
the comprehensive process used for local permits should serve as a starting point for title V
permits and that the process address how feedback generated in the internal and permittee
review processes are to be considered.

Response: The SDAPCD appreciates EPA's recommendation and agrees that additional training
is helpful, especially for new staff The SDAPCD would like to point out that it maintains a
manual of procedures (MOP) that describes the permit issuance process in detail. The SDAPCD
has already revised portions of the TV procedures for the MOP and implemented them in a
draft format and intends to officially modify the MOP as well as train staff on the procedures.
This MOP and the MOP revisions were provided to EPA and is contained as a reference in this
document. In general since the SDAPCD first issues local Authorities to Construct (ATCs) to
modifications to all facilities, including both TV and Non-TV facilities, those ATCs undergo
review by Senior Engineers first and then are also sent to Compliance Division for review. Then
for TV facilities those local permits, which have already undergone review by both Engineering
and Compliance, are then incorporated into TV facility permits either at the time of renewal or
revisions. However, some of the engineers who were selected for interview by EPA either had
not processed any TV permits or had only processed very few TV permits. As a result, they may
have had some differences in their understanding of the TV permitting processes by level of
experience, and would not be expected to know all aspects of the TV program. This also
explains the differences in understanding of Compliance review since only physical
modifications, or modifications involving changes to conditions would need such review (e.g. a
502(b)(10) change would not require review by Compliance).

21	See Finding 7.6 of this report for more discussion on employee retention.

22	See Finding 6.6 of this report for more discussion on compliance permit feedback process.

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2.2 Finding: The SDAPCD's statement of basis does not consistently describe regulatory and policy
decisions the District has made in the permitting process.

Discussion: 40 CFR part 70.7(a)(5) requires the District to provide "a statement that sets forth
the legal and factual basis for the draft permit conditions" and is commonly referred to as the
"statement of basis". The purpose of this requirement is to provide the public and the EPA with
the District's rationale on applicability determinations and technical issues supporting the
issuance of proposed title V permits. A statement of basis documents the regulatory and policy
issues applicable to the source and is an essential tool for conducting meaningful permit
review.

The EPA has issued guidance on the required content of statement of basis on several
occasions, most recently in 2014.23 This guidance has consistently explained the need for
permitting authorities to develop a statement of basis with sufficient detail to document the
decisions made in the permitting process. The EPA provided an overview of this guidance in a
2006 title V petition order, In the Matter of Onyx Environmental Services, Order on Petition No.
V-2005-1 (February 1, 2006) (Onyx Order). In the Onyx Order, in the context of a general
overview statement on the statement of basis, the EPA explained:

A statement of basis must describe the origin or basis of each permit condition or
exemption. However, it is more than just a short form of the permit. It should highlight
elements that U.S. EPA and the public would find important to review. Rather than
restating the permit, it should list anything that deviates from simply a straight
recitation of applicable requirements. The statement of basis should highlight items such
as the permit shield, streamlined conditions, or any monitoring that is required under 40
C.F.R. § 70.6(a)(3)(i)(B). Thus, it should include a discussion of the decision-making that
went into the development of the title V permit and provide the permitting authority, the
public, and U.S. EPA a record of the applicability and technical issues surrounding the
issuance of the permit. (Footnotes omitted.) See, e.g., In RePort Hudson Operations,
Georgia Pacific, Petition No. 6-03-01, at pages 37-40 (May 9, 2003) ("Georgia Pacific");
In Re Doe Run Company Buick Mill and Mine, Petition No. VII-1999-001, at pages 24-25
(July 31, 2002) ("Doe Run"); In Re Fort James Camas Mill, Petition No. X-1999-1, at page
8 (December 22, 2000) ("Ft. James").

Onyx Order at 13-14. Appendix C of this report contains a summary of the EPA guidance to date
on the suggested elements to be included in a statement of basis.

23 Memorandum from Stephen D. Page, Director of the Office of Air Qualtiy Planning and Standards, "Implementation
Guidance on Annual Compliance Certification Reporting and Statement of Basis Requirements for Title V Permits," April 30,
2014. See https://www.epa.gov/sites/production/files/2015-08/documents/2014043Q.pdf.

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In our review, we found that the statement of basis prepared by the District often does not
adequately describe the regulatory and policy issues or document the decisions the District
made in the permitting process. Though there is variation, the District's statement of basis
generally includes: Introduction/Description; Title V Applicability; Applicable Requirements;
Monitoring, Record-keeping, and Reporting; Public Notice and EPA Review; and
Conclusions/Recommendations. While these are the types of categories often found in the
statement of basis for a title V permit, the District does not consistently include the type of
detailed, site-specific information needed in these sections that would allow the reader to
understand the District's legal and factual basis for the terms and conditions in the permit.

For example, the District often includes a list of applicable requirements but does not always
explain why the source is subject to the requirements or whether an otherwise potentially
applicable requirement is not applicable in a particular case. The District could improve this
section by consistently explaining why the source meets the appropriate applicability criteria.
The section should also not be limited to New Source Performance Standards (NSPS) or
National Emission Standards for Hazardous Air Pollutants (NESHAP) but should also include the
applicability of all federal applicable requirements, including Compliance Assurance Monitoring
(CAM), the Prevention of Significant Deterioration (PSD) permit program at 40 CFR 52.2124, the
title IV Acid Rain Program, and State Implementation Plan (SlP)-approved rules.

In addition, the sections dedicated to background and introductory information could be
improved by including a description of the various processes and operations at the source,
relevant historical information, and the current type of permitting action. While the statement
of basis generically describes the changes being made to the permit, the District could improve
by providing more context. It should be clear to the reader why the permit needs to be revised
and that the revisions the District is making are appropriate for the situation. The District could
also consider including a redline/strikethrough version of the permit revisions as part of the
permit record provided during the public participation process to facilitate permit review.
I :::thermore, when streamlining multiple applicable requirements, the statement of basis must
explain the requirements being streamlined and how the permit conditions assure
compliance/1'

24	While the SDAPCD does not have an EPA-approved PSD program, PSD remains a potential applicable requirement to title
V sources in SDAPCD. Any EPA-issued PSD permits must be incorporated into the District's title V permits.

25	See Finding 2.7 of this report for more discussion on the SDAPCD streamlining evaluation.

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Recommendation: As required by the Part 70 program, he SDAPCD must consistently produce a
statement of basis for each title V permit action (initial permits, renewals, and significant and
minor revisions) and should commit to improving the content of this document for future
permitting actions. We encourage the SDAPCD to work in close coordination with the EPA to
ensure that the statement of basis is adequate for explaining the legal and factual basis of each
action as required by 40 CFR 70.7(a)(5).

Response: The District appreciates EPA's recognition that the SDAPCD's Statement of Basis
includes the types of categories typically found in TV permits and the recommendations on
further enhancement of the Statement of Basis. Please note that the engineering evaluations of
the local permits includes a lot of the detailed and site-specific items mentioned in the EPA's
discussion section above, including the streamlining of conditions (also please see response to
Finding 2.7). The SDAPCD has consistently provided statements of basis as part of all permitting
actions submitted for EPA comment, and had not received comments about lack of content, or
any significant deficiency. As indicated the type of analysis is contained in the engineering
evaluations for the underlying equipment or in previous statements of basis if the underlying
rationale has not changed. The SDAPCD would be happy to further discuss this with EPA.

2.3 Finding: The SDAPCD uses template permit documents and maintains template conditions in its
database to provide consistency in its permits.

Discussion: From staff interviews, most permit engineers refer to previous permitting actions to
ensure consistency between permitting documents, especially for the statement of basis.26 The
SDAPCD also maintains a list of template permit conditions within its permitting database to
assist in permit language consistency.27

The SDAPCD's template title V permit includes a cover page with the Source's general
information, responsible official, and signature from an appropriate District official. The
template title V permit is divided into six sections: Preamble, Regulation XIV Permit
Requirements, Facility-Wide Requirements, Emission Unit Requirements, District-Only
Provisions, and Appendices. During the 2008 Evaluation, the SDAPCD's title V permits were not
signed by an appropriate District official. The District's title V permit template now includes a
District official signature, and the District appears to have resolved its signature issue.

Recommendation: We commend the SDAPCD for promoting consistency between its permit
documents using templates. We encourage the SDAPCD to continue improving the statement
of basis as discussed in Finding 2.2.

Response: The SDAPCD appreciates EPA's finding.

26	See Finding 2.2 of this report for more discussion of the SDACPD's statement of basis.

27	See Finding 8.3 of this report for more discussion of the SDAPCD permitting database.

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Finding: The SDAPCD does not evaluate whether a requested title V permit modification meets
the criteria under which it is submitted, including confirming whether a change is a modification
under title I of the CAA.

Discussion: When changes are made to a Part 70 source, there are several options for the
method that must be used to incorporate the change into the title V permit under the Part 70
and District regulations. The District has developed an internal guidance document that defines
the criteria to classify the different title V permit revision types and specifies the steps to follow
to determine the appropriate revision track. The guidance also describes the type of supporting
documentation that should accompany each type of permit revision. This guidance document
was provided to the EPA during the file review and should serve as a good resource for the
SDAPCD staff to understand the criteria for classifying title V revisions and to provide consistent
processing of title V permit changes.

During our file review, we requested 5 years of permit files for the various types of permit
modifications (significant modifications, minor permit modifications, administrative
amendments, and off-permit changes/502(b)(10) changes). In reviewing these files, we
discovered the District consistently does not evaluate whether the type of permit modification
requested is correct. Importantly, the District does not document whether 502(b)(10) changes
and minor permit modifications are not modifications under title I of the Act, a minimum
requirement for using these options. Further, such determinations should include
consideration of the PSD program at 40 CFR 52.21 that is implemented by the EPA within San
Diego County." no District's rule that references "PSD" requirements, Rule 20.3, is not an EPA-
approved PSD program and does not use the correct PSD applicability criteria.

Permitting authorities are not required to produce a statement of basis when processing a
502(b)(10) change; however, we believe it would be beneficial for the SDAPCD to document its
analysis verifying that a requested operational change qualifies as a 502(b)(10) change.
Otherwise, the regulated community is encouraged to avoid title V program requirements, and
potentially title I requirements, by submitting every action as a 502(b)(10) change. We also note
that files pertaining to 502(b)(10) changes did not document that the requested changes were
eventually incorporated into the title V permit at the time of the next renewal, nor did the
District respond when title V sources requested notification whether their changes qualified as
502(b)(10) changes.

Due to the lack of documentation, the EPA was unable to fully assess the SDAPCD staff's
understanding of the various permit revision tracks and could not verify whether applications
for permit modifications were categorized and processed correctly pursuant to District and
federal regulations. When these types of decisions are not consistently documented it can lead
to inconsistent implementation of the title V program.

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Further, during our 2008 Evaluation we found that the District "streamlines" its NSR and title V
actions but did not consistently follow its own rules in doing so by ensuring adequate EPA and
public review of NSR actions added to the title V permit.28 It is unclear whether in lieu of using
the appropriate procedures in its rules, the District is now instead determining all changes at
title V sources qualify as 502(b)(10) changes. See Finding 5.3.

Recommendation: To ensure permitting staff accurately categorize title V permit actions, the
SDAPCD should document its actions, rationale, and justification for each title V permit action.
The EPA strongly recommends that the SDAPCD consistently review and document whether
submitted 502(b)(10) changes qualify for this option, including whether such changes are title I
modifications. Since the District is not the PSD permitting authority in San Diego County, the
District should also be coordinating with the EPA on whether new sources or modifications at
existing major sources are subject to the PSD program.

Response: The SDAPCD appreciates EPA's comments and agrees with EPA's recommendations
that all 502(b)(10) changes submitted must be reviewed and determined whether or not they
qualify as such. The SDAPCD also agrees with EPA's recommendation to coordinate with EPA on
whether or not new sources or modifications to existing sources trigger PSD requirements.
However, the SDAPCD does not agree with EPAs conclusion that the SDAPCD does not make a
determination of the appropriate type of permit action. Under the SDAPCD's permit program,
all Title V applications require that prior to applying for a change to the Title V permit, they
must apply for a new or revised permit under the SDAPCD's local permitting program. The
SDAPCD typically discusses all modifications with facilities prior to submittal of an application
when preparing the estimate for fees associated with the application. Since fees are heavily
dependent on the type of modification, we ask questions to determine whether we think the
application will best fit criteria for 502(b)(10), minor or significant modifications. Additionally,
502(b)(10), minor and significant modifications require that the facility also submit an
application under the local permitting program to obtain an authority to construct or modified
local permit before they can apply for a Title V modification (in practice many facilities submit
simultaneously, but we do not process the Title V modification until after the local application
has been approved). This means that by the time the Title V application is reviewed, the
SDAPCD has already made determinations regarding whether major source NSR requirements
applied, any impacts on federally applicable requirements, and monitoring requirements. The
engineering evaluation prepared as part of this application review will document these
decisions and analysis.

28 See Finding 5.2 in the 2008 Evaluation

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The SDAPCD also disagrees with EPAs contention that EPA and public review somehow does not
occur for NSR changes. District Rule 20.3 requires that an EPA comment period and public
notice is conducted equivalent to the same level required for significant modifications or new
permits prior to an authority to construct being issued. Additionally, if such a notice was
required, the Title V application would be treated as a significant modification or an initial
permit, as appropriate, and a separate EPA comment period would occur prior to issuance of
the Title V permit, as required by SDAPCD rules. Alternatively, at the discretion of SDAPCD and
the permit applicant, the project can be processed under "enhanced ATC" provisions, which
would combine the two notice/comment periods.

Furthermore, EPA specifically identifies PSD and Title I modifications as concerns. However,
these requirements would be addressed during the local permitting review which would include
notification to EPA if a project constituted a federal major modification or triggered PSD
requirements. In recent years, none of the projects that would have potentially required PSD
permits were approved (or were modified to no longer trigger PSD requirements).

It appears that this finding should have been more focused on the lack of clear information to
document a determination, rather than concluding that there was a lack of making correct
determinations, unless EPA has identified any changes which were improperly classified.

Please note that the SDAPCD provided some of these supporting engineering evaluations to EPA
staff as part of the document request, and has included a spreadsheet listing all Title V
applications either received or approved within the previously requested timeline, including an
annotation regarding the type of application and a brief description of the proposed change.
This list shows that the SDAPCD processes each different type of application, not just 502(b)(10)
changes. The SDAPCD processes very few significant modifications, but this is due to the types
of modifications being proposed, not lack of reviewing requirements. Finally, the District is
including/highlighting some additional examples of how it has reviewed the difference between
minor/significant changes (Chula Vista Energy Center, APCD2021-APP-006597) as well as an
example of a project evaluated as an enhanced A/C in lieu of being processed as a Title V
change (Palomar Energy Center, APCD2015-APP-003970 and APCD2015-APP-003971).

2.6 Finding: The SDAPCD generally references the underlying origin and authority for permit

conditions, but often does not reference the origin of New Source Review (NSR) requirements.

Discussion: Each title V permit is required to specify and reference the origin and authority for
each term or condition and identify any difference in form as compared to the applicable
requirement upon which the term or condition is based.29 In most cases, the origin and
authority for a permit condition can be referenced by citing to the particular rule or regulation.

29 See 40 CFR 70.6(a)(l)(i).

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The District consistently cites a basis for each permit condition; however, its practice of
only citing to "NSR" for NSR requirements is insufficient. It is also unclear whether the
District incorporates requirements from the District's ATC's into the title V permit.
Conditions from ATCs remain federal applicable requirements under the California SIP
regardless of their inclusion in the PTO.30

For NSR requirements, the authority for the permit condition stems from the SIP-approved
NSR rule. But, because NSR rules likely do not specify the emissions limits and associated
monitoring, recordkeeping, and reporting requirements to which the source is subject to
under the NSR determination, the origin of the title V permit condition is the actual NSR
permit issued to the source. Thus, requirements stemming from NSR rules, or the PSD
program at 40 CFR 52.21, should generally cite the underlying rule or regulation as the
authority and the specific NSR permit action as the origin.

Recommendation: To address this finding, the District must develop a plan to revise its title

V	permits to assure that each permit cites the appropriate NSR/PSD permits as part of the
origin and authority for a permit term or condition as required by 40 CFR 70.6(a)(l)(i).

Response: The SDAPCD appreciates EPA's comments and recommendations. However, the
SDAPCD would like to clarify that when SDAPCD cites "NSR " as the basis for a condition, it
simply cites Rule 20.2 or 20.3 (depending on whether the source is major or non-major for
criteria pollutants). This is no different than any other rule citation. The SDAPCD would like
to point out that EPA has not previously raised this concern during the review of Title V
permits as a comment or an objection.

Also please note that the SDAPCD would like to make a clarification that for example if an
ATC condition has already been fulfilled prior to issuance of a Title V permit (such as
requirements for initial source testing) the SDAPCD may not place that condition in the Title

V	permit, since the initial source testing will be completed prior to issuance of the Title V
permit.

2.7 Finding: While the SDAPCD appears to streamline applicable requirements in its title V

permits, the District generally does not provide the necessary streamlining analysis in the
statement of basis.

Discussion: The SDAPCD's title V permits appear to contain streamlined requirements in
which one or more federal/local requirements are subsumed under the most stringent
requirement that applies to an emissions unit. For example, the requirements from the
NSPS and the same or more stringent District rule requirements are sometimes
streamlined into a single permit condition. The District's statement of basis will sometimes
state that the streamlined permit condition is at least as stringent as the subsumed
requirements. However, such a blanket statement does not actually demonstrate that the
requirement was accurately streamlined.

30 While some ATC requirements not included in the PTO may also not be appropriate for inclusion in the title V permit, this
determination should be documented in the statement of basis.

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Streamlining applicable requirements is an acceptable practice but must be appropriately
documented to assure compliance with all requirements. The EPA most recently provided
guidance on streamlining in 2014 in the EPA's April 30, 2014 memorandum,
"Implementation Guidance on Annual Compliance Certification Reporting and Statement of
Basis Requirements for Title V Operating Permits." The EPA initially provided guidance in
our March 5,1996 guidance document, "White Paper Number 2 for Improved
Implementation of The Part 70 Operating Permit Program." 31

The permit condition should cite to the requirement included in the permit and any
subsumed requirements. In addition, the statement of basis should document how the
permit condition assures compliance with all subsumed requirements.

Recommendation: As required by 40 CFR 70.7(a)(5), if the District wishes to continue its
practice of creating streamlined title V permit conditions, the District must revise its
practice by ensuring the statement of basis provides the legal and factual basis for the
permit conditions by demonstrating that the permit conditions assure compliance with all
subsumed requirements. We further recommend that the District follow the EPA guidance
provided above in developing a process to appropriately streamline applicable
requirements.

Response: The SDAPCD appreciates EPA's comment and recommendation. Please note
that, as previously discussed, streamlining typically occurs during the local permit review
stage, not as a separate analysis in the Title V Statement of Basis. The SDAPCD typically
conducts an equivalent streamlining analysis as part of the local permit review and these
conditions are later incorporated into the Title Vpermit through the appropriate
modification application. The District's normal practice is to review requirements rule by
rule in the engineering evaluation and then any similar requirements will be automatically
streamlined into the permit conditions. This approach ensures all requirements of all rules
are reviewed to ensure the permit is enforceable.

31 See Appendix C of this report.

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2.8 Finding: The SDAPCD clearly identifies locally enforceable conditions in title V permits.

Discussion: Permit conditions based on state or local rules are only federal applicable
requirements if the rule has been approved by the EPA into the California SIP. Some state and
local rules are only adopted at the local level and have not been, or will not be, approved into
the SIP. State or local rules not approved into the SIP are not federal applicable requirements
under the title V program and are only enforceable at the State or District level. During the file
review, we found that the District's equipment-specific permits to operate were divided into
two main sections: "Federally-Enforceable and District-Enforceable Conditions" and "District-
Only Enforceable Conditions." In creating these sections, the District clearly indicates the
enforceability of all permit conditions.

However, we note that the District's local permits program is part of the California SIP and
permits issued pursuant to these rules are federal applicable requirements.

Recommendation: The EPA commends the SDAPCD for identifying which conditions are
federally and locally enforceable in their title V permits. The District should continue this
labelling practice and ensure ATC and PTO requirements remain federal applicable
requirements.

Response: The SDAPCD appreciates EPA's recognition that SDAPCD identifies federally vs.
locally enforceable requirements in the Title Vpermits and believes that it is important to note
that not all requirements, such as some state or local toxics rules, are federally enforceable.

3. Monitoring

The purpose of this section is to evaluate the permitting authority's procedures for meeting title V
monitoring requirements. Part 70 requires title V permits to include monitoring and related
recordkeeping and reporting requirements. See 40 CFR 70.6(a)(3). Each permit must contain
monitoring and analytical procedures or test methods as required by applicable monitoring and testing
requirements. Where the applicable requirement itself does not require periodic testing or monitoring,
the permitting authority must supplement the permit with periodic monitoring sufficient to yield
reliable data from the relevant time period that is representative of the source's compliance with the
permit. As necessary, permitting authorities must also include in title V permits requirements
concerning the use, maintenance, and, where appropriate, installation of monitoring equipment or
methods.

Title V permits must also contain recordkeeping for required monitoring and must require that each
title V source record all required monitoring data and supporting information and retain such records
for a period of at least five years from the date the monitoring sample, measurement, report, or
application was made. With respect to reporting, permits must include all applicable reporting
requirements and require (1) submittal of reports of any required monitoring at least every six months
and (2) prompt reporting of any deviations from permit requirements. All required reports must be

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certified by a responsible official consistent with the requirements of 40 CFR 70.5(d).

In addition to periodic monitoring, permitting authorities are required to evaluate the applicability of
Compliance Assurance Monitoring (CAM), and include CAM provisions and a CAM plan into a title V
permit when applicable. CAM applicability determinations are required either at permit renewal, or
upon the submittal of an application for a significant title V permit modification. CAM regulations
require a source to develop parametric monitoring for certain emissions units with control devices,
which may be required in addition to any periodic monitoring, to assure compliance with applicable
requirements.

3.1 Finding: While the SDAPCD generally reviews CAM applicability, internal guidance needs to be
updated and staff need training.

Discussion: CAM regulations, found at 40 CFR part 64, apply to title V sources with large
emissions units that rely on add-on control devices to comply with applicable requirements.
The underlying principle, as stated in the preamble to our 1997 rulemaking, is "to assure that
the control measures, once installed or otherwise employed, are properly operated and
maintained so that they do not deteriorate to the point where the owner or operator fails to
remain in compliance with applicable requirements."32 Per CAM regulations, sources are
responsible for proposing a CAM plan to the permitting authority that provides a reasonable
assurance of compliance with applicable requirements for pollutant-specific emissions units
with add-on control devices.

The District reported that there are currently no facilities in its jurisdiction that are subject to
the CAM rule. In the permits we reviewed, we found that the District generally explains CAM
applicability in its statement of basis, however, CAM applicability can evolve over time as a
source makes changes, and thus its applicability should be confirmed during title V renewals
and significant modifications to ensure ongoing compliance. During our interviews, we found
that permitting staff do not have experience determining CAM applicability. In addition,
internal guidance documents may not interpret CAM applicability requirements correctly, as
the guidance is too generalized to ensure criteria in the CAM rule is followed. For example,
internal guidance appears to incorrectly imply that emissions limits with existing monitoring are
not subject to CAM or that being subject to an emissions standard exempt from CAM means
that other standards for the same pollutant/unit are also exempt from CAM.

32 62 FR 54902, October 22,1997.

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Recommendation: The SDAPCD should continue to review CAM requirements as it processes
permit renewals and significant modifications and ensure CAM applicability is consistently
reviewed and discussed in the statement of basis. Additionally, CAM training should be
provided for permitting staff, and the District's internal guidance should be updated to provide
more detailed information for determining applicability based on the criteria in the CAM rule.

Response: The SDAPCD appreciates EPA's comments and recommendation and welcomes
further training on CAM.

3.2 Finding: The SDAPCD's title V permits generally contain monitoring that is sufficient to

determine compliance with emissions limits. However, the SDAPCD's statement of basis does
not consistently address periodic monitoring.

Discussion: Our file review confirmed that the SDAPCD's title V permits generally contain
appropriate monitoring provisions. Many of the applicable requirements incorporated into the
District's title V permits already contain sufficient monitoring (such as, NSR permit conditions,
SIP-approved rules, NSPS/NESHAP and use of CEMS for large combustion sources). Source
testing, parametric monitoring of control device operation, and associated recordkeeping are
used to assure compliance with emissions limits. During our file review, we discovered some
permits contained daily emissions limits, but did not appear to contain corresponding daily
monitoring/recordkeeping requirements to assure compliance, or the wording of such limits
was too vague to determine whether the emissions limits were daily limits or a monthly
average.

The SDAPCD does not specifically address in the statement of basis whether additional periodic
monitoring is needed. While many applicable requirements may already contain sufficient
monitoring, the District does not document whether additional periodic monitoring is, or is not,
needed to assure compliance. The EPA has issued guidance that reinforces the need to address
periodic monitoring in the statement of basis. Additionally, an Order responding to a petition to
the EPA to object to the proposed title V permit for the Chevron Products Company in
Richmond, California, dated March 15, 2005, directed the permitting authority to reopen the
permit to include either periodic monitoring requirements to assure compliance with
regulations or to provide adequate justification in the statement of basis explaining why no
periodic monitoring is required.33

Recommendation: The SDAPCD should continue to ensure that all title V permits have
monitoring sufficient to determine compliance, including ensuring daily emissions limits have
monitoring conducted on at least a daily basis. Additionally, the statement of basis should
evaluate the need for adding periodic monitoring when sufficient monitoring is not specified by
an underlying applicable requirement. We recommend the District develop a plan to
incorporate review of periodic monitoring for each title V facility at the next permit renewal.

33 This document is available in the Title V petition database on the EPA website at

https://www.epa.gov/sites/default/files/2015-08/documents/conoco Phillips cbe decision2004.pdf.

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Response: The SDAPCD appreciates EPA's recognition that SDAPCD generally contain
appropriate monitoring provisions. As previously mentioned, because the District conducts most
review as part of the local permit evaluation, and considers both Engineering and Compliance
input prior to a permit being issued. SDAPCD believes that, as EPA's review has also confirmed,
appropriate monitoring provisions have been incorporated into Title Vpermits. Further, during
EPA's review of Title Vpermits, EPA has not previously commented or raised objections due to
lack of monitoring requirements. The SDAPCD will continue to ensure daily emission limits have
adequate monitoring requirements, and believes that reviewing all Title Vpermits again at
renewal for periodic monitoring would be redundant and resource intensive.

3.3 Finding: The SDAPCD generally includes sufficient recordkeeping requirements as required by
the NSPS and NESHAP regulations.

Discussion: During the EPA's review, we found the SDAPCD generally includes sufficient
recordkeeping requirements as required by the NSPS and NESHAP regulations. A specific and
prevalent exception pertains to recordkeeping for determining compliance with diesel fuel
standards in NSPS Subpart Nil and NESHAP Subpart ZZZZ. The SDAPCD generally does not
include a recordkeeping requirement in its title V permits to ensure sources only purchase EPA-
compliant diesel fuel as required by these standards. Maintaining fuel purchase records is a
standard practice to ensure non-compliant fuels are not entering the market.34

However, as discussed in Finding 2.2, because the statement of basis does not consistently
document permitting decisions, it can be challenging to determine whether a permit has
incorporated all the applicable monitoring and recordkeeping requirements.35 During our
interviews, compliance staff also mentioned they sometimes see enforceability issues in
permits while conducting inspections. See Finding 6.6.

Recommendation: The EPA commends the SDAPCD for including sufficient recordkeeping
requirements as required by the NSPS and NESHAP regulations. During permit renewals, the
District should update their title V permits to require records to assure that only EPA-compliant
diesel fuel has been purchased.

34	Records that EPA-compliant diesel fuel was purchased ensures that the fuel meets the sulfur content, cetane index, or
aromatic content of 40 CFR 80.510, as required by NSPS Nil and NESHAP ZZZZ.

35	We did, however, find an example where the District incorrectly used the concept of a "replacement unit" to determine
NSPS/NESHAP applicability. The District incorrectly determined that replacement of an existing engine with a new engine
meant that, despite being a new engine, the NSPS did not apply. While the NSR program may have special provisions for
replacement units, those provisions cannot be used to determine NSPS/NESHAP applicability.

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Response: The SDAPCD appreciates EPA's recognition that SDAPCD generally includes sufficient
recordkeeping requirements. With respect to dieselfuel, please note that the SDAPCD includes fuel
records in engine permits which are incorporated into Title V permits. Diesel fuel requirements are
typically specified in the emission unit specific permit conditions. The District views this as sufficient
to ensure only EPA/CARB diesel is used in any diesel powered permitted equipment. For example, the
SDAPCD has used the following requirements for a facility which operates an emergency engine
which also include streamlined NSPS requirements related to fuel:

This engine shall only use CARB dieselfuel. (Rule 12, Rule 69.4.1,17 CCR 93115, 40 CFR 60 Subpart
llll)

The owner or operator of the engine shall maintain the following records on site for at least the
same period of time as the engine to which the records apply is located at the site:

(a)	documentation shall be maintained identifying the fuel as CARB diesel, and

(b)	manual of recommended maintenance provided by the manufacturer.

(Rule 12, Rule 69.4.1, 17 CCR 93115, 40 CFR 60 Subpart llll)

4. Public Participation and Affected State Review

This section examines the SDAPCD procedures used to meet public participation requirements for title
V permit issuance. The federal title V public participation requirements are found in 40 CFR 70.7(h).

Title V public participation procedures apply to initial permit issuance, significant permit modifications,
and permit renewals. The SDAPCD public participation procedures must provide for public notice,
including an opportunity for public comment and public hearing on the draft initial permit, permit
modification, or permit renewal. Draft permit actions must be noticed in a newspaper of general
circulation or a state publication designed to give general public notice; sent to affected states; sent to
persons on a mailing list developed by the permitting authority; sent to those persons that have
requested in writing to be on the mailing list; and provided by other means as necessary to assure
adequate notice to the affected public.

The public notice must, at a minimum: identify the affected source; the name and address of the
permitting authority processing the permit; the activity or activities involved in the permit action; the
emissions change involved in any permit modification; the name, address, and telephone number of a
person from whom interested persons may obtain additional information, including copies of the draft
permit, the application, all relevant supporting materials, and all other materials available to the
permitting authority that are relevant to the permit decision; a brief description of the required
comment procedures; and the time and place of any hearing that may be held, including procedures to
request a hearing. See 40 CFR 70.7(h)(2).

The permitting authority must keep a record of the public comments and of the issues raised during
the public participation process so that the EPA may fulfill its obligation under section 505(b)(2) of the
Act to determine whether a citizen petition may be granted. The public petition process, 40 CFR

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70.8(d), allows any person who has objected to permit issuance during the public comment period to
petition the EPA to object to a title V permit if the EPA does not object to the permit in writing as
provided under 40 CFR 70.8(c). Public petitions to object to a title V permit must be submitted to the
EPA within 60 days after the expiration of the EPA 45-day review period. Any petition submitted to the
EPA must be based only on objections that were raised with reasonable specificity during the public
comment period, unless the petitioner demonstrates that it was impracticable to raise such objections
within such period, or unless the grounds for such objection arose after such period.

4.1 Finding: San Diego County contains a significant number of linguistically isolated communities
for which the SDAPCD does not consistently provide translation services as required by 40 CFR
Part 7.35(a).

Discussion: The SDAPCD's jurisdiction includes sources located throughout San Diego County.
In response to California's AB 617 legislation, the District has increased its use of translations
and public outreach in certain communities.36 In addition, the District has created an EJ
outreach position that is designed to carry out the outreach effort to EJ communities. The EPA
prepared a map of linguistically isolated communities within the SDAPCD's jurisdiction in which
title V permits have been or may be issued (see Appendix D). The EPA's map indicates that
there are numerous populations that are linguistically isolated. These linguistically isolated
communities have a significant population density, and thus the SDAPCD should provide
translation services in those communities during the title V permitting process. Section
502(b)(3)(C)(6) of the Act and 40 CFR 70.7(h) require a Part 70 program to have adequate
procedures for public notice. Using a map like that found in Appendix D may provide additional
opportunities to direct the SDAPCD's translation efforts.

Further, please see 40 CFR Part 7.35(a) for additional detail regarding federal grantee
obligations in demonstrating compliance with title 6 of the Civil Rights Act of 1964. In addition,
see Appendix D of this report that includes a copy of a recent preliminary decision regarding
this topic dated March 30, 2021 from the EPA's External Civil Rights Compliance Office to Carol
S. Cromer, Director, Missouri Department of Natural Resources.

Recommendation: The EPA recommends that the SDAPCD provide translation services for
linguistically isolated communities within its jurisdiction. The SDAPCD should consider directing
translation efforts by using mapping tools as appropriate to assure updated information.

36	This effort is known as the Community Air Protection Program. For a description of the District's response to AB 617,
please see https://www.sdapcd.org/content/sdapcd/communitv/communitv-air-protection-program.html.

37	The use of the State of California's environmental justice tool CalEnviroScreen may also assist in learning where best to
deploy translation resources.

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Response: The SDAPCD appreciates EPA's comment and would like to point out that SDAPCD
considers environmental justice (EJ) a high priority and is the first district in California which has an
EJ representative on its Governing Board. Also as noted earlier, the SDAPCD has created an Office of
EJ and has added significant resources to address public outreach and EJ issues. The SDAPCD posts all
Title V public notices to our website and is open to discuss further translation of the notices with EPA.
However, please note that the map provided by EPA has too large of resolution to be useful for
identifying whether projects need translation. Also, the map only identifies the percentile of linguistic
isolation, it does not provide actual percentages of people who are linguistically isolated nor what
language they speak. This may lead to somewhat misleading data because of the non-linear nature
of percentiles. The SDACPD agrees with EPA that providing assistance to environmentally
disadvantaged communities is a critical issue and is actively taking steps to improve in these areas.

4.2 Finding: The SDAPCD provides public notices of its draft title V permitting actions on its
website.

Discussion: A permitting authority's website is a powerful tool to make title V information
available to the general public. Easy access to information that is useful for the public review
process can result in a more informed public and, consequently, provide more meaningful
comments during title V permit public comment periods.

Currently, the SDAPCD posts relevant title V permit information on its website including, but
not limited to, proposed title V permits, statement of basis, public notices, permit appeal
procedures, and general title V information and guidance.

The District website provides general information to the public and regulated community
regarding the SDAPCD permitting program.38 The public can find information regarding the
permitting process, whether a permit is needed for an operation, how to obtain a permit,
application forms, and information about related programs that inform the District's permitting
program.

The SDAPCD's website also provides a list of active projects that are in the public comment
period along with the corresponding draft permit, statement of basis, and public notice that
includes information on how to comment electronically or by mail.39

38	See https://www.sdapcd.org/content/sdapcd/permits.html and
https://www.sdapcd.org/content/sdapcd/permits/equipment-types/titlev.html

39	https://www.sdapcd.org/content/sdapcd/permits/public-notices.html

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The SDAPCD maintains electronic mailing lists for title V public notices and for notification of
affected states. Members of the public may sign up for the title V public notice mailing list on
the District's website. However, as discussed in Finding 4.1, the District does not currently
translate notices of proposed title V permit actions in languages other than English as required
by 40 CFR Part 7.35(a). As stated in the introduction, the SDAPCD is developing strategies to
enhance public engagement as part of its AB423 commitment.

Finally, in our 2008 Evaluation, we found that the District had been publishing notices of its
proposed permits in a newspaper, of which circulation was almost solely among the business
community. The District has addressed this issue by publishing its notices of proposed permits
in the San Diego Union-Tribune, a newspaper of general circulation.

Recommendation: We encourage the SDAPCD to continue providing information related to
title V permits to the public via their website and notifying affected states and interested
parties of relevant title V permitting actions via District electronic mailing lists. The District
should also provide all final title V permits to the public on its website and must provide
translations of notices as discussed further in Finding 4.3.

Response: The SDAPCD appreciates EPA's recognition that SDAPCD maintains an electronic
mailing list and publishes the public notices on our website and makes the necessary
information related to Title V permits available for public review and comments. The SDAPCD
considers public engagement and transparency a priority and will be open to further
accessibility of public notices via translating the notices.

4.3 Finding: The SDAPCD provides notification regarding the public's right to petition the EPA
Administrator to object to a title V permit.

Discussion: 40 CFR 70.8(d) provides that any person may petition the EPA Administrator, within
60 days of the expiration of the EPA's 45-day review period, to object to the issuance of a title V
permit. The petition must be based only on objections that were raised with reasonable
specificity during the public comment period.40

40 An exception applies when the petitioner demonstrates that it was impracticable to raise those objections during the
public comment period or that the grounds for objection arose after that period.

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San Diego County Rule 1425 contains the required information about the public's right to
petition the EPA Administrator to object to a title V permit. In 2008, we made a finding that the
District was not informing the public of their right to petition when public noticing title V
permitting actions.41 In our review of the District's draft permit packages for the last five years,
including the public notice for the permit action, we found that the District did not inform the
public of the right to petition the EPA Administrator to object to a title V permit at the time of
the site visit in March. However, the District has recently updated its practice and in the latest
public notice, from April 21, 2022, there is new language that incorporates the public petition
details.

Recommendation: The EPA commends the SDAPCD for revising its public notice templates to
inform the public of the right to petition the EPA Administrator to object to the issuance of a
title V permit. The District should have written internal procedures that ensure this remains an
ongoing practice.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD provides the public
with the appropriate information on how to petition the EPA Administrator to object to the
issuance of a Title V permit.

4.4 Finding: The SDAPCD's general practice is to conduct a concurrent public and EPA review. If
comments are received during the 30-day public review period, the permit package is re-
proposed to the EPA for a new 45-day review period.

Discussion: Per section 505(b) of the CAA and 40 CFR 70.8, state and local permitting agencies
are required to provide proposed title V permits to the EPA for a 45-day period during which
the EPA may object to permit issuance. The EPA regulations allow the 45-day EPA review period
to occur either following the 30-day public comment period (i.e., sequentially), or at the same
time as the public comment period (i.e., concurrently).

41 See 2008 Evaluation, Finding 4.5.

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When the public and the EPA review periods occur sequentially, permitting agencies will make
the draft permit available for public comment, and following the close of public comment,
provide the proposed permit and supporting documents to the EPA.42 When the public and
the EPA review periods occur concurrently, a state or local agency will provide the EPA with
the draft permit and supporting documents at the beginning of the public comment period. As
specified in 40 CFR 70.8 and per SDAPCD's internal guidance, r t ie SDAPCD receives
comments from the public during the 30- day public review period, the 45-day EPA review
would be restarted to allow the SDAPCD to prepare responses to the public comments, and an
updated permit and Statement of Basis, if applicable, to the EPA. As the permit actions
reviewed did not contain public comments, the EPA was unable to confirm this process is
being consistently followed at the District. However, the procedures for concurrent public
comment and response to comments are well documented in internal District guidance and
SOPs.

Recommendation: The SDAPCD's internal guidance appears consistent with the requirements
of the title V program and we recommend the District follow its guidance when public
comments are received.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD's guidance is
consistent with the requirements of Title V.

4.5 Finding: The SDAPCD has a Business Assistance Program (BAP) to conduct pre-application

meetings with potential sources to help identify the scope of potential permitting projects and
the applicability of regulatory requirements.

Discussion: Under section 507 of the CAA, permitting authorities are required to implement a
small business assistance program to assist small businesses that need title V permits.

During this evaluation, we found that the District has a full BAP to provide assistance to
business owners and operators, small and large, in determining which county, state, and
federal requirements are applicable. The assistance includes coverage of title V small
businesses.

42 Per 40 CFR 70.2, "draft permit" is the version of a permit for which the permitting authority offers public participation or
affected State review. Per 40 CFR 70.2, "proposed permit" is the version of a permit that the permitting authority proposes
to issue and forwards to the EPA for review. In many cases these versions will be identical; however, in instances where the
permitting agency makes edits or modifications as a result of public comments, there may be material differences between
the draft and proposed permit.

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During the interviews, the BAP staff stated that they help small businesses draft permit
applications and review permits to ensure permit records adequately represent the source. This
helps the Permitting staff process permit applications in a timely fashion. The BAP staff also
assist small businesses with compliance demonstrations by conducting mock on-site inspections
and by reviewing the source's draft Annual Emissions Reports to ensure they are adequate
before the reports are submitted to the Compliance and Enforcement Section.

Additionally, the BAP staff helps small businesses with pollution prevention by providing
guidance on control technologies. For example, they help gas stations understand the benefits
of Stage II vapor controls. The District has a BAP website where they describe who they are and
provide forms, calculation sheets, and other information to aid businesses developing permit
applications. Furthermore, the website has a notification feature available for small businesses
in case they want to be made aware when new content is posted on the BAP website.43

Discussions with the BAP staff also indicated that work related to title V sources is tracked so
that time spent working with these sources is appropriately accounted for in tracking title V
fees and revenue.

Recommendation: The EPA commends the District for its efforts to provide assistance to small
businesses and recommends the District continue supporting small businesses by providing
these services through its BAP.

Response: The SDAPCD appreciates EPA's recognition of the SDAPCD's small business
assistance program.

4.6 Finding: The SDAPCD notifies tribes of title V permitting actions.

Discussion: During our 2008 Evaluation, we did not find evidence that the District notified any
tribes in San Diego County regarding title V permit actions. During this evaluation, we found
that this issue has been resolved as the District provides notifications to all tribes in San Diego
County. Of the 18 Indian reservations in San Diego County, two tribes have been approved by
the EPA to be treated in the same manner as a neighboring state for the purpose of "affected
state" notification under section 505(a)(2) of the CAA. 44 Regardless of the affected state
status, the EPA believes that state and local air agencies should notify tribal governments when
taking significant actions that may affect their air quality.

Recommendation: We commend the SDAPCD for notifying tribes and affected states.

Response: The SDAPCD appreciates EPA's recognition that SDAPCD notifies tribes in
San Diego County regarding Title V permit actions.

43	See https://www.sdapcd.org/content/sdapcd/compliance/business-assistance.html

44	Additionally, the EPA maintains a map on its website of tribes in Region 9 that have received treatment as a state status for
purposes of section 505(a)(2) of the CAA: https://www.epa.gov/caa-permitting/affected-states-notifications-region-9.

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5. Permit Issuance / Revision / Renewal

This section focuses on the permitting authority's progress in issuing initial title V permits and the
District's ability to issue timely permit renewals and revisions consistent with the regulatory
requirements for permit processing and issuance. Part 70 sets deadlines for permitting authorities to
issue each type of title V permit. The EPA, as an oversight agency, is charged with ensuring that these
deadlines are met as well as ensuring that permits are issued consistent with title V requirements. Part
70 describes the required title V program procedures for permit issuance, revision, and renewal of title
V permits. Specifically, 40 CFR 70.7 requires that a permitting authority take final action on each permit
application within 18 months after receipt of a complete permit application, except that action must
be taken on an application for a minor modification within 90 days after receipt of a complete permit
application.45

5.1 Finding: The SDAPCD does not consistently process title V actions in a timely manner, resulting
in a permitting backlog.

Discussion: The District does not consistently process permitting applications in a timely
manner, mainly due to resource constraints and competing priorities. At the time of our
evaluation, the SDAPCD had 28 title V sources and two synthetic minor sources.46 Of these 28
sources, the District indicated 75% of sources have a pending renewal application. During the
interviews, many expressed time constraints on permit issuance for both local permits and title
V permits. Based on the documentation the District provided, there were several permit
applications that have not been processed before the 18-month deadline as required by 40 CFR
70.7. In the last 5 years, about 40% of the title V applications received by the SDAPCD have had
processing times in excess of 18 months. In addition to exceeding statutory permitting
deadlines, delays create issues for the Compliance Division. See Finding 6.1. During interviews,
District staff were confident that once the resources issue is addressed, the permitting backlog
will no longer be an issue.

Recommendation: The EPA acknowledges that the SDAPCD is currently in transition and more
engineers are now being trained and assigned to process title V permit actions. The District
should develop a plan of action for reducing its title V renewal application backlog, as well as to
process the new title V applications that the District will expect to receive as a result of their
new Ozone Non-attainment area classification (See Section 7 of this report for additional
discussion on the District's resources).

Response: The SDAPCD appreciates EPA's comment and recommendation. The SDAPCD would
also like to work with EPA to ensure that measures recommended by this Title Vprogram
evaluation are implemented in the most efficient way to avoid additional resource constraints
and delays in permit reviews.

45	See 40 CFR 70.7(a)(2) and 70.7(e)(2)(iv).

46	See Finding 2.4 of this report for more discussion on the SDPACD's major source determination and Finding 5.4 for more
discussion on the SDAPCD's synthetic minor sources.

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5.2	Finding: The SDAPCD routinely submits proposed and final permit actions to the EPA.

Discussion: 40 CFR 70.8(a)(1) and the SDAPCD's EPA-approved title V program require that
proposed and final permits be sent to the EPA. During our review of recent actions, the EPA
found that the SDAPCD routinely submits copies of both proposed and final title V permit
actions to the EPA via the EPA Central Data Exchange's Electronic Permit System (EPS). The EPA
oversight team receives the SDAPCD's permitting notices. These notices generally include the
notice of proposed action, the proposed permit, and the proposed technical support
document. However, during our internal file review, we found several instances where a copy
of the statement of basis or technical support document for minor permit modifications was
not included in the submitted permit package (see Finding 2.4).

Additionally, we could not find a requirement in the SDAPCD's title V rules (District Regulation
XIV) that ensures a statement of basis is developed and provided during the public comment
period and the EPA's 45-day review period. In 2020, the EPA revised the Part 70 program at 40
CFR 70.7 and 70.8 to make clear that the statement of basis must be made available to the
public and the EPA.47

Recommendation: The EPA commends the District for submitting its proposed and final permit
actions to the EPA for review. The District should also ensure its proposed permits include a
statement of basis, consistent with 40 CFR 70.7 and 70.8, and should update its title V rules for
consistency with these requirements.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD routinely submits copies of
both proposed and final Title V permit actions to EPA. As mentioned in the comment above, the
SDAPCD has also revised its procedures to require statement of basis for minor modifications. The
SDAPCD's revised Title V rules are presently under review by EPA.

5.3	Finding: The SDAPCD has authority to use parallel processing to streamline the issuance of
modified NSR and title V permits. However, it is not clear that this processing method is
correctly utilized.

47 See https://www.federalregister.gov/documents/2020/02/05/2020-01099/revisions-to-the-petition-provisions-of-the-
title-v-permitting-program.

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Discussion: EPA guidance and regulations allows sources to simultaneously apply for, and
permitting authorities to process, revisions to NSR and title V permits.48 Under this option,
often referred to as "enhanced NSR," NSR permit modifications are subject to the procedural
requirements of the Part 70 program, including a 45-day EPA review period and a 60-day
petition period that allows citizens to petition the Administrator to object to permit issuance.
After the NSR permit has been issued, and the project has been completed, the permitting
authority revises the title V permit to add (or delete) the new or revised NSR conditions via an
administrative amendment. The benefits of consolidating the NSR and title V permitting
processes include reduced permit processing time and the opportunity for the EPA to review
NSR permit actions.

The District appears to understand the enhanced NSR process, dedicating a section to Enhanced
Authority to Construct in the Engineering Division Manual of Operating Procedures (Appendix
H). The EPA supports this practice; however, our file review did not find evidence that SDAPCD
was implementing enhanced NSR. In our file reviews, we did not find an example of an
administrative amendment that incorporated NSR permit conditions into a title V permit.
However, the District routinely does not incorporate new or revised NSR permit requirements
into the title V permit until a title V renewal is issued. Instead, the District may incorrectly be
allowing 502(b)(10) changes to be used instead of documenting enhanced NSR practices. See
Finding 2.4.

Recommendation: To address this finding, the District must ensure that the applicable
permitting procedures required by the Part 70 program are followed. We recommend the
District review the Part 70 program requirements related to enhanced NSR and 502(b)(10)
changes and develop a plan to address this finding.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD has included the
Enhanced NSR process in the SDAPCD's MOP. However, it appears that EPA maybe inferring
that the SDAPCD is not implementing this correctly while also stating that there are no
examples of the SDAPCD using this program (if EPA would like to see an example, the SDAPCD
would be happy to provide an example of a permit where an A/C was issued using enhanced
procedures and an administrative amendment was filed, but not acted on yet). Also, the
SDAPCD does not agree with the EPA's implication of using 502(b)(10) changes instead of
documenting enhanced NSR. Also please refer to response to Finding 2.4.

48

See 40 CFR 70.7(d)(l)(v) and Appendix C: White Paper for Streamlined Development of Part 70 Permit Applications, July
10, 1995; 11/7/95 letter from Lydia Wegman, OAQPS, to William Becker, STAPPA/ALAPCO; Title V Implementation Q & A,
Region 9, December 1995

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5.4 Finding: The District does not evaluate the potential emissions from sources without title V

permits to determine if they are major sources or whether such sources need synthetic limits to
avoid title V applicability or other CAA requirements.

Discussion: A source may accept a voluntary limit (also known as a "synthetic minor" limit) to
maintain its Potential to Emit (PTE) below an applicable major source threshold and thereby
avoid major NSR permit requirements and/or the need for a title V permit. Sources establish
such a limit by obtaining a synthetic minor permit containing practically enforceable emissions
limitations from the permitting authority.

According to EPA guidance, synthetic minor limits must be enforceable as a practical matter,
meaning they are both legally and practicably enforceable. Additionally, for emissions limits in a
permit to be practicably enforceable, the permit provisions must specify: 1) technically-
accurate limitations and the portions of the source subject to such limitations; 2) the time
period for the limitations (emissions limit averaging period); and 3) the method to determine
compliance, including appropriate and practically enforceable monitoring, recordkeeping, and
reporting requirements.49

In response to a petition regarding the Hu Honua Bioenergy Facility in Hawaii, the EPA stated
that synthetic minor permits must specify: 1) that all actual emissions at the source are
considered in determining compliance with its synthetic minor limits, including emissions
during startup, shutdown, malfunction or upset; 2) that emissions during startup and shutdown
(as well as emissions during other non-startup/shutdown operating conditions) must be
included in the semi-annual reports or in determining compliance with the emissions limits; and
3) how the source's emissions shall be determined or measured for assessing compliance with
the emissions limits.50

The District does not have a policy for setting synthetic minor limits but has two local rules,
Rules 60.1 and 60.2, that can be used to limit a source's PTE. These rules are available to

49	Options for Limiting the Potential to Emit (PTE) of a Stationary Source Under Section 112 and Title V of the Clean Air Act
(Act), John S. Seitz, Director, Office of Air Quality Planning and Standards (January 25,1995).

50	Order Responding to Petitioner's Request that the Administrator Object to Issuance of State Operating Permit Petition No.
IX-2011-1, Gina McCarthy, Administrator (February 7, 2014).

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sources seeking to avoid major source status through voluntary requirements. However, the
use of these rules appears limited, and the District does not independently determine the
facility-wide PTE of the sources it regulates. Instead, the District determines major source
status based on actual emissions. While using actual emissions was acceptable for avoiding title
V permitting as part of the EPA's 1995 transition policy, that policy expired in 2000.51

Determining whether a stationary source is a major source and subject to the title V program is
based on potential, not actual, emissions.52 We found during the evaluation that District
permitting staff are generally familiar with calculating the PTE of impacted emissions units
when issuing local permits. And the District closely tracks the actual annual emissions of each
facility. However, the District does not calculate or track a facility's PTE on a facility-wide basis.
Because major source status is based on facility-wide potential emissions, it is challenging for
the District to know when an existing minor source becomes a major source or whether a
source's claim of being a minor source is accurate. This is particularly problematic for the
current situation where the District was recently reclassified as Severe nonattainment for the
ozone NAAQS causing the major source threshold in San Diego County for NOx and VOC to drop
to 25 tons per year. Beyond title V applicability, this issue can also have implications in
determining NSR program requirements and requirements for major sources of HAPs. This also
creates potential enforcement risk for any facility relying on actual emissions to not obtain a
title V permit or a major NSR permit.

Recommendation: The SDAPCD must develop a plan for ensuring the District can determine
title V applicability according to the definition for "major source" under 40 CFR 70.2 by
evaluating the facility-wide PTE. For those facilities with a PTE above the major source
threshold that wish to avoid title V permitting, we recommend the District develop internal
guidance for permitting synthetic minor sources consistent with EPA policy, and that permitting
staff take the EPA's online training for Setting Enforceable Potential to Emit Limits in NSR
Permits.1';

Response: The SDAPCD appreciates EPA's comment and recommendation. However, the SDAPCD
does not agree that it does not calculate or track the facility's PTE on a facility-wide basis or may not
be properly implementing permitting for sources which take synthetic limits to stay out of Title V.
The SDAPCD always uses PTE of sources for determining applicability of Title V and NSR
requirements. This evaluation is done each time the District reviews an application that is potentially
subject to new source review and includes all provisions described in Rule 20.1 including when a
calculation requires use of projected actual emissions as potential emissions (such as determining the
emission increase associated with a modified emission unit at a major source). While the SDAPCD
does not maintain a tabulated list of PTE for all stationary sources, it instead conducts this review at
the time a change occurs at a facility.

51	See the EPA's December 20,1999 guidance memorandum 'Third Extension of January 25,1995 Potential to Emit
Transition Policy." https://www.epa.gov/sites/default/files/2015-08/documents/4thext.pdf

52	See definition of "Potential to emit" at 40 CFR 70.2.

53	https://airknowledge.gov/SI/PERM203-SI.html

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For existing sources, the SDACPD utilizes the actual emissions which are required to be calculated
and tracked through our emission inventory program and that Rule 60.1 allows for sources to be
exempt from Title V requirements based on having actual emissions one half the major source
threshold (a list of such facilities was provided to EPA). This means that by tracking actual emissions
and identifying those facilities with emissions above half the threshold, the District has to only assess
PTE for those facilities with actual emissions between 50 and 100% of the major source threshold to
determine if their PTE is below or at or above 100% of the major source threshold, significantly
reducing the resource necessary to identify major sources. Also please note that the SDAPCD
evaluates any requirements dependent on facility PTE for NSR during review of the application
associated with new or modification of a source.

So to summarize, the SDAPCD does use PTE to determine requirements. However, in lieu of
maintaining a tabulated list of facility PTE, the District instead assesses facility PTE at the time each
modification occurs and for existing facilities not being modified, tracks actual emissions and
compares to the thresholds in SDAPCD Rule 60.1 which means the SDAPCD is using a more stringent
screening method to detect Title Vfacilities than required by the underlying rules. Then for any
facility with actual emissions above the thresholds of 60.1 the SDAPCD can conduct an assessment of
PTE to determine whether the facility is actually exempt based on PTE.

The second point of this finding refers to synthetic minor permits. SDAPCD would like to provide
some clarification as to how the local permitting program ties into Title V permitting. Rule 60.2
is the SDAPCD's synthetic minor source rule and was intended to be used by existing sources
that do not have their emissions limited through NSR. However, for the vast majority of
facilities, emissions are limited mainly through permit restrictions imposed through NSR Rules
20.2 or 20.3, including appropriate monitoring and recordkeeping, and included in ATCs and
PTOs that are therefore federally enforceable limits.

Lastly SDAPCD appreciates EPA's efforts to provide training and will ensure that staff, in
particular new staff who may not be familiar with writing enforceable permit conditions, take
advantage of such training.

6. Compliance

This section addresses the SDAPCD practices and procedures for issuing title V permits that ensure
compliance with all applicable requirements. Title V permits must contain sufficient requirements to
allow the permitting authority, the EPA, and the general public to adequately determine whether the
permittee is in compliance with all applicable requirements.

Compliance is a central priority for the title V permit program. Compliance assures a level playing field
and prevents a permittee from gaining an unfair economic advantage over its competitors who comply
with the law. Adequate conditions in a title V permit that assure compliance with all applicable
requirements also result in greater confidence in the permitting authority's title V program within both
the general public and the regulated community.

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6.1	Finding: The District performs Full Compliance Evaluations (FCEs) of all title V sources on a
schedule consistent with its negotiated compliance monitoring strategy (CMS).

Discussion: The EPA's 2016 Clean Air Act Stationary Source Compliance Monitoring Strategy54
recommends that permitting authorities perform FCEs for most title V sources at least every
other year. For the vast majority of title V sources, the EPA expects that the permitting
authority will perform an on-site inspection to determine the source's compliance status as part
of the FCE. In addition to weekly routine inspections, the SDAPCD has established its inspection
priority, giving emphasis to sources receiving ongoing public complaints, sources with issues of
continued non-compliance, and sources that need follow-up due to a Notice of Violation
(NOV).55 During interviews, District inspectors indicated that quarterly compliance evaluations
and annual full inspections are conducted for all permitted equipment. I lowever, District
inspectors also indicated that the effectiveness of the inspection schedule may be
compromised due to delays in processing open permit applications.

Recommendation: The EPA commends the District's ongoing efforts to perform FCEs of all title
V sources annually.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD performs FCEs for all
Title V sources annually.

6.2	Finding: The District's Compliance Division reviews all title V deviation reports, annual
compliance certifications, and semiannual monitoring reports submitted by Part 70 sources.

Discussion: During interviews, the District's compliance staff indicated that all deviation
reports, quarterly monitoring reports, and compliance certifications that sources submit to the
agency are reviewed by inspectors. Supervisors and the Chief of Compliance Division review
reports as necessary. The SDAPCD tracks these reports through their internal database and
reviews these records through their compliance staff and supervisors. If NOVs are warranted
after reviewing a report, the inspectors are required to discuss the documented deficiency with
the facility prior to issuing the NOV, to explain the nature of the violation, and advise the site to
respond to NOVs timely with the actions needed to return to compliance or prevent future
violations prior. Compliance supervisors will review the violation and associated report and are
responsible for approving NOVs.

54This document is available at: https://www.epa.gov/compliance/clean-air-act-stationarv-source-compliance-monitoring-
strategy.

55 See Inspection Practices and Priorities, SDAPCD Compliance Division Policy and Procedures Manual, Policy number 2.1,
effective date September 1,1998, revised on July 25, 2016.

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In addition, engineering staff indicated that deviation reports and compliance certifications are
typically not routinely reviewed during permit processing. For example, reviewing these
documents as part of the title V permit renewal process could indicate a need to increase
testing frequency or require different monitoring that would ensure compliance.

Recommendation: The EPA commends the SDAPCD's efforts in reviewing and tracking all
deviation reports, quarterly monitoring reports, and compliance certifications. We encourage
the SDAPCD to coordinate the outcomes of compliance issues with permitting staff. See Finding
6.6.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD reviews and tracks all
deviation reports, quarterly monitoring reports and compliance certifications and agrees with
coordinated effort between compliance and permitting staff.

6.3 Finding: When potential compliance issues are discovered, the District addresses them prior to
permit issuance. However, the District's statement of basis could be improved to include
compliance history.

Discussion: The Part 70 program requires that each title V permit contain a schedule of
compliance if necessary.-0 This includes ensuring title V permits contain requirements that
ensure sources comply with requirements that have future compliance dates and ensure that
title V permits contain enforceable milestones leading to compliance for those requirements for
which the source is not in compliance. Based on interview responses, the District has not
recently issued permits with compliance schedules. Instead, compliance staff will generate a
citation report, which is sent to the District's Civil Actions Investigator to determine the
corresponding penalty. Pending permit applications are not processed until a facility comes
back into compliance. This practice does not appear to significantly affect or delay the issuance
of permits.

Recommendation: We recommend the compliance section in the District's statement of basis
be improved to include the source's compliance history and the actions being taken to address
compliance issues, as applicable.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD does not issue a permit
until compliance issues are addressed. Please refer to earlier responses related to the
information provided in the local permit engineering evaluations vs statement of basis.

56 See 40 CFR 70.6(c)(3) and 70.5(c)(8).

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6.4 Finding: The District uses title V compliance certifications and semiannual monitoring reports to
prioritize inspections and initiate enforcement actions.

Discussion: Similar to our 2008 Evaluation, the District continues to prioritize inspections and
initiate enforcement actions by using title V compliance certifications and semiannual
monitoring reports.57 The District's Compliance Division has a policy for reviewing annual
compliance certifications and semiannual monitoring reports (which include deviation
reports).58The District uses these title V compliance reports as well as past violations, recent
applications and activities to prioritize and target inspections. Interviewees stated that they
review these reports for compliance issues. They also review the facility's compliance history,
including recent inspections, breakdowns, exceedances, or violations, if any. The District uses
this information to prioritize inspections.

The District has also initiated enforcement actions at title V facilities based on information from
compliance certifications and semiannual monitoring reports. In one example, the District
issued an NOV for a violation identified in a title V report. The violations were related to time
periods when the facility failed to maintain NOx and O2 CEMS per Appendix B of 40 CFR Part 75.
Since the violations were short-term (i.e., not ongoing) and the facility was not out of
compliance at the time of permit issuance, a schedule of compliance was not required.59

Interviewees were generally knowledgeable about the procedures for reviewing title V
compliance reports and were aware of the District's policy for title V report reviewing process,
for issuing a NOV and/or a Notice to Comply (NTC).

Recommendation: The EPA encourages the District to maintain its practice of using title V
compliance reports to prioritize and target inspections and to continue implementing its policy
for reviewing these reports.

Response: The SDAPCD appreciates EPA's recognition of the SDAPCD's practice to use
compliance certification reports to prioritize and target inspections.

57	See 2008 Evaluation, Finding 6.1.

58	See Review of Title VSemiannual and Annual Reports, SDAPCD Compliance Division Policy and Procedures Manual, Policy
number 3.13, effective date April 4, 2002, revised in August 2018.

59	A schedule of compliance is required for Title V sources that are not in compliance with all applicable requirements at the
time of permit issuance. (See 40 CFR 70.5(c)(8)(iii)(C).)

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6.5	Finding: Compliance staff have the necessary equipment to perform their job duties but find
the procurement process for new equipment to be slow.

Discussion: During interviews, members of the Compliance Division stated that they have
sufficient tools and safety equipment to perform inspections, including hard hats, safety
glasses, safety vests, and an annual voucher for safety shoes. At the same time, employees also
expressed the need for new monitoring equipment as existing equipment, including Thermo
Fisher Scientific analyzers, are experiencing a loss in functionality due to age. Though the
process for equipment repairs and purchases have been initiated, they have been slow.
Compliance staff also mentioned that they could have been supplied with better personal
protective equipment during the COVID-19 pandemic.

Recommendation: The EPA recommends that the District review its equipment needs and plan
in advance for the replacement of old and outdated equipment to expedite the procurement
process.

Response: The SDAPCD appreciates EPA's recognition that SDAPCD Compliance has sufficient
tools and safety equipment to perform inspections and will continue to explore opportunities
to expedite the procurement process for such equipment.

6.6	Finding: While the SDAPCD has a process in their internal database for compliance staff to
request changes to title V permits, it is unclear if it is being used consistently.

Discussion: In our 2008 Evaluation, we found that the SDAPCD did not have a clear track record
of utilizing the District's internal Request for Change of Permit Conditions form to make
corrections to title V permits, and that the decisions made by the Engineering Division on such
requests were seldom communicated back to the Compliance Division. The District has since
developed a policy for the use of such request forms. Under the Division policy, compliance
staff are expected to review all permit conditions during the annual inspection and submit a
Request for Change of Permit Conditions form to the Division Chief if a site-specific permit
condition is found to not be clear, enforceable, or consistent with existing rules and/or other
applicable requirements. The Division Chief is responsible for keeping the inspector and their
supervisor informed of any decision.60 For issues identified across multiple permits, the policy
states these issues should be forwarded to the District's Permit Streamlining Committee for
evaluation.

60 See How to Submit Permit Change Requests, SDAPCD Compliance Division Policy and Procedures Manual, Policy number
2.18, effective date February 17, 2016, revised in July 2017.

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During interviews, inspectors said they have used the request change forms in the District's
database system to request changes to the title V permits. Interviewees expressed concern
about the length of time it takes for changes identified to be made and about the Engineering
Division's lack of action on some requests. Compliance staff noted that some permits were not
updated in a timely manner to make the permit conditions enforceable. In some cases, this
resulted in NOVs being issued that compliance staff believe would have been unnecessary if the
permit had included monitoring and recordkeeping that facilitated compliance with the
requirements in the permit.

While the Permit Change Request process appears to be a good mechanism for inspectors to
request correction of obvious errors, or minor administrative changes, compliance staff may
have stopped using the process based on historical lack of response from the Engineering
Division.

Recommendation: Engineering and Compliance Divisions should agree on a realistic Permit
Change Request process, including the types of changes that should be made and the
appropriate timeframe for doing so, so that both Divisions can work together to ensure
enforceable permits.

Response: The SDAPCD appreciates EPA's recognition that there is a formal process in place for
Compliance to request changes to permit conditions and agrees that a realistic expectation
with appropriate timeframe be established. Please note that the SDAPCD had already begun
work on addressing this issue. One point to consider is that in order to change permit
conditions, the SDAPCD has to follow the formal process which makes it clear that some
condition changes to Title V permits would require an EPA comment period and, in some cases,
public notice and public review. This means that the Title Vpermits can't just be simply revised
without going through Title Vpermits revision requirements. For this reason, some of the
requested condition changes in the past have been scheduled to be included with the next
permit modification or renewal to avoid multiple permit revisions and EPA or public noticing
and reviews.

7. Resources and Internal Management

The purpose of this section is to evaluate how the permitting authority is administering its title V
program. With respect to title V administration, the EPA's program evaluation: (1) focused on the
permitting authority's progress toward issuing all initial title V permits and the permitting authority's
goals for issuing timely title V permit modifications and renewals; (2) identified organizational i"Nes
and problems; (3) examined the permitting authority's fee structure, how fees are tracked, and how
fee revenue is used; and (4) looked at the permitting authority's capability of having sufficient staff and
resources to implement its title V program.

An important part of each permitting authority's title V prop to ensure that the permit program
has the resources necessary to develop and administer th jgrc. effectively. A key requirement of
the Part 70 program is that the permitting authority e.c' i^libn an adei., le fee program to ensure that
(1) title V fees are adequate to cover title V permit r jm costs, and (*. used solely to cover the

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permit program costs. Regulations concerning the fee program and the appropriate criteria for
determining the adequacy of such programs are set forth in 40 CFR 70.9.

7.1	Finding: The SDAPCD staff report that they receive effective legal support from the District
Counsel's office.

Discussion: In our 2008 Evaluation,61 we stated that the SDAPCD staff receive expert,
knowledgeable, and experienced legal support. Since then, the District Counsel in place during
our 2008 Evaluation retired and another District Counsel was hired with equally effective
results. However, as a result of the recent change in leadership, the District, at the time of our
site visit, was in the process of hiring a new District Counsel. The District's legal support is
currently in transition but given the record of effective legal support for the title V program and
District management's understanding of the importance of this function, the EPA expects that
District staff will continue to receive effective legal support for the District's title V program.

Recommendation: The SDAPCD should continue to ensure that it receives effective legal
support for the Part 70 program.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD staff receives effective
support from the SDAPCD's Counsel. The SDAPCD has a new District Counsel, Veera Tyagi, who
has extensive experience in air quality programs. Prior to joining SDAPCD, Ms. Tyagi worked as
a Principal Deputy District Counsel at South Coast Air Quality Management District. We are
very happy and excited to have Veera working as our Counsel and she can provide expert legal
support on all Title V and other air quality matters.

7.2	Finding: The District tracks title V program expenses and revenue and those funds are spent
solely to support the title V program.

Discussion: The Part 70 regulations require that permit programs ensure that the collected title
V fees are adequate to cover title V permit program costs and are used solely to cover the
permit program's costs.62 In our 2008 Evaluation, the EPA did not closely review title V fee
accounting as the District's program at the time was not experiencing any staff shortages, nor
delays in its permit processing times. In this more recent effort, the SDAPCD provided
accounting data for the prior 3 years. As noted elsewhere in this report, prior to the title V

612008 Evaluation, Finding 7.2.
62 See 40 CFR 70.9(a).

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program, the SDAPCD was already implementing its own permitting program. When the Part 70
requirements took effect, the SDAPCD treated the Part 70 requirements as an overlay to the
existing SDAPCD permitting program. As a result of this approach, the SDAPCD treated the
revenue and expenses associated with the Part 70 program as supplemental to the revenue and
expenses associated with the existing local permitting program. Thus, the combination of their
base permitting program and the additional Part 70 requirements that apply to title V sources
result in the full program as implemented by the SDAPCD. Using an approach based on full cost
recovery, the SDAPCD ensures that it collects fees for its base permitting program and the
supplemental title V costs (including overhead, compliance costs, etc.) that match the expenses
used for implementing the supplemental title V program requirements. See Appendix F for
details regarding their accounting approach.

As discussed in Findings 5.1 and 7.6, the District has a title V permitting backlog and is
experiencing difficulty retaining permitting and compliance staff, urther, Finding 2.4 discusses
that the District may be processing all changes at title V sources as S02(b)(10) changes instead
of expending resources to process changes according to the correct permit revision type. While
the District's accounting approach is consistent with the Part 70 program requirements, it is not
clear whether those fees will be sufficient going forward to fully administer the program.

Recommendation: The EPA commends the SDAPCD for their approach to accounting for both
revenue and expenses for the implementation of the title V program. During the evaluation, the
EPA provided the SDAPCD with the most recent EPA policy on title V funding (see appendix E).
We recommend the SDAPCD review the policy to assure their fee program continues to be
consistent with EPA title V fee policy and that fees will be sufficient going forward.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD tracks Title V revenues
and expenses and spends such funds solely to support the Title V program. Also the SDAPCD
appreciates EPA's additional Tile Vfunding information and guidance provided to us.

7.3 Finding: The District permitting and compliance management communicate well and meet
routinely to discuss programmatic issues. However, the results of these discussions are not
clearly and consistently communicated to compliance staff and has resulted in uncertainty
regarding outcomes of issue resolution among compliance staff.

Discussion: In our 2008 Evaluation, we found that permitting decisions were not always clearly
communicated among the SDAPCD's engineering and compliance staff.63 During this evaluation,
we found the lack of communication and coordination at the staff level persists. The SDAPCD's
compliance and engineering management continue to hold routine meetings to discuss
permitting and compliance issues; however, such meetings are not held regularly at the staff
level. Although the District's permitting staff indicated that draft permits for unique sources are
sent to Compliance for review, the District's compliance staff indicated that draft permits are
rarely sent to the Compliance Division for review prior to the public comment period.64

63	See 2008 Evaluation, Finding 7.1.

64	See Finding 6.6 of this report for more discussion on compliance permit feedback process.

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Permitting staff, as a practical matter, should be accessible to the compliance staff for
consultation on practical enforceability, applicability determinations, and compliance
determinations. Having a systematic process, especially in cases that involve more than one
group within the District, would reduce the time necessary to resolve complex issues and
minimize potential delays in permit issuance or in appropriate enforcement action.

Recommendation: The EPA commends the SDAPCD's effort to maintain good communication
between permitting and compliance management. However, we encourage the SDAPCD to
promote increased communication and cooperation between permitting and compliance staff,
and to explore ways to improve permitting decisions among SDAPCD's engineering and
compliance staff.

Response: The SDAPCD appreciates EPA's comment and recommendation and will continue to
identify opportunities to promote effective communications.

7.4 Finding: The District lacks a training plan for its permitting and compliance staff.

Discussion: As noted elsewhere in this report, ¦ District's title V permitting program is
experiencing staff retention challenges. In addition, we identified several s^nstantive issues
related to permit preparation and content indicating a need for further title V training in order
to prepare more effective permits (See Section 2). In interviews, staff identified title V training,
primarily focusing on permit writing and inspections, as something that would improve the
District's title V program. District staff specifically suggested training on federal regulations
(NESHAPs and NSPS), would improve staff's familiarity with regulatory requirements and help
permit writers identify how best to incorporate these requirements into title V permits. The
EPA has separately identified training needs related to CAM and other critical program
elements and policies.

For Compliance, it appears that the amount and content of trainings for inspectors varies from
supervisorto supervisor, and that the Compliance Division has no formal training plan, training
material, or standardized procedure. Training is heavily focused on shadowing experienced
inspectors in the field. Staff and managers acknowledged that they would likely benefit from
standardized training.

Recommendation: The District should identify core training needs and develop a curriculum
that title V program staff, both permitting and compliance, should complete to enhance title V
program understanding and improve permit writing and compliance determinations.65

65 In other title V program evaluations, the EPA has found good examples of the type of training and curriculum that the District
may find most useful. For example, see Finding 7.4 on pages 33 and 34 of the EPA's "Bay Area Air Quality Management District
title V Operating Permit Program Evaluation Final Report September 29, 2009", which is available on the EPA's website at
https://www.epa.gov/sites/default/files/2015-07/documents/bavarea-final-report9-29-09.pdf.

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Regulatory updates sent by EPA Region 9 can also be shared with staff as it contains relevant
updates to NSPS and NESHAP requirements and can be used as reference material for finding
relevant information on the EPA's website.66 Additionally, the District should encourage staff to
network with staff from other agencies by allowing them to participate in other learning
opportunities such as conferences, workshops and online trainings/webinars.

Response: The SDAPCD appreciates EPA's recommendations and looks forward to partnering
with EPA to identify additional training opportunities.

7.5 Finding: Permitting staff demonstrated a general lack of knowledge on environmental justice
(EJ) and would like the EPA to provide training on this issue.

Discussion: As noted in the 2008 Evaluation, the District's permitting staff is generally not
familiar with EJ issues and how these issues may arise in a permitting context.67 As a result,
there is uncertainty about tools that may help them address EJ issues and inform the public
more effectively of permitting actions. In the EPA's prior evaluation, the EPA committed to
providing EJ training but was unable to do so given resource constraints at the time. However,
in January 2022, the EPA held a two-day training for Region 9 permit writers on EPA's EJScreen
tool and provided case studies from across Region 9 for implementing EJ in permitting.

One of the tools available to help anticipate where EJ issues may arise with permitting actions is
the EPA's EJScreen tool. This tool can be used to prepare maps that highlight specific
demographic data for use in focusing outreach, for example. The EPA suggests that the District
examine the maps provided in the appendices to this report (including the linguistic isolation
map - see Appendix D) to familiarize staff with the EJScreen tool and its capabilities in
identifying communities where additional outreach on permitting actions may be warranted.68

Recommendation: We recommend the District permitting and compliance staff coordinate
with the District's new OEJ to assist with EJ considerations in permitting. The EPA will continue
to share new information related to EJ in permitting as it becomes available.

Response: The SDAPCD appreciates EPA's recommendation and believes that EJ is a top
priority and EJ considerations must be integrated into all programs.

66	For example, recent updates provide a link to the federal government's new "eCFR" website that can be used to compare
versions of federal regulations to see what has recently changed. This feature can be helpful when working on a title V
renewal action.

67	See, e.g, https://www.epa.gov/sites/production/files/2015-07/documents/ei-permitting-faqs-4.29.pdf

68	For an overview of the EJScreen tool, please see https://www.epa.gov/eiscreen . For learning resources on EJScreen,
please see https://www.epa.gov/eiscreen/learn-use-eiscreen . CalEnviroScreen, a similar tool available in California, would
provide similar information.

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7.6 Finding: The SDAPCD is having difficulty retaining permitting and compliance staff.

Discussion: During interviews staff noted that the District compliance and permitting staff are
compensated in accordance with the San Diego County compensation structure as opposed to
the District having its own compensation structure tailored to the unique knowledge, skills and
abilities of the District's air quality professionals.69 It is unclear to EPA whether or not the
District has the ability to set its own compensation structure separate from the County's
compensation structure. Interviewees noted that though recent open positions have been
advertised as open to those with no experience as well as to those candidates who may have
more experience, the District has typically hired less experienced candidates for whom
permitting and compliance positions may be more challenging and will require a
comprehensive training program in order for less experienced staff to reach a level of
competence necessary to confidently prepare for participation in the title V program (both
permit preparation and permit compliance determinations). The results of our interviews
suggest that the District should focus on succession planning to better prepare for the event
that staff leave the District. Finally, staff noted that because the career ladder seems limited in
terms of advancement opportunity, some employees leave for other County departments
where career ladders provide more advancement opportunity and therefore higher
compensation.

Impacts of high staff turnover rate include: (1) a workload situation in which certain key title V
program tasks are or may not be completed in the timeframe required by District rules and the
Part 70 program and (2) a lack of institutional knowledge at the staff level within the District's
permitting and compliance programs.

69 The District has a performance and recognition program that typically provides a $100 to $150 monetary award and
certificate for high performers.

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Recommendation: Staff turnover can erode an agency's institutional knowledge, which can
create delays in the issuance of title V permits and lead to inconsistent permitting
determinations.70 Based upon discussions with the District's permitting and compliance staff,
the EPA believes that a compensation analysis is needed and may lead to a system in which
staff can demonstrate growth through their careers in a way that is comparable to what other
County departments offer, reduce the frequency of staff turnover, and lead to additional
opportunities for qualified candidates for senior positions within the permitting and compliance
groups. The District should also consider conducting a workload assessment to determine the
number of additional staff persons needed to implement its title V program taking into
consideration the new ozone area classification and the expected additional title V work that
will result. As noted in the discussion above, in the event that the District has the ability to
independently set a compensation structure that can be better tailored to the unique
knowledge, skills and abilities of the District's air quality professionals, the District may want to
take the opportunity to do so to address this finding. In the alternative, the District should work
with the County administration to act on the results of the analyses identified in this
recommendation.

Response: The SDAPCD appreciates EPA's comments and recommendations. A compensation
analysis was recently conducted for the Service Employees International Union (SEIU) (Titled Base
Salary Compensation Study, by Koff & Associates, dated September 29, 2021, independently from
SEIU and the County of San Diego, San Diego Final Comp Report 09 29 21.pdf - Google Drive ). This
analysis, conducted for all represented SDAPCD employees, considered several other local air
pollution control districts, such as San Luis Obispo County APCD, Bay Area AQMD, Imperial County
APCD, Sacramento Metro AQMD and South Coast AQMD. Also the County Contract for SEIU
compensation package was approved by the San Diego County Board of Supervisors in June 2022
(County Contract (seiu221.org)).

The SDAPCD, like other entities, experienced a high turnover after the COVID-19 pandemic,
increasing the number of vacancies. The SDAPCD is committed to continuing to monitor the
workload and explore opportunities to provide adequate resources and fill vacancies with the best
candidates to address any potential retention issues.

70 In the EPA's 2008 Evaluation, we noted that the District had considerable experience in its title V program (see findings
2.2 and 7.3 of our 2008 Evaluation).

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8. Records Management

This section examines the system the SDAPCD has in place for storing, maintaining, and managing title
V permit files. The CAA provides that certain documents created pursuant to the title V permitting
program, including the permit application, be made available to the public but also allows some
protections for confidential information.71 The SDAPCD has a responsibility to the public in ensuring
that title V public records are complete and accessible.

In addition, the SDAPCD must keep title V records for the purposes of having the information available
upon the EPA's request. 40 CFR 70.4(j)(l) states that any information obtained or used in the
administration of a State program shall be available to the EPA upon request without restriction and in
a form specified by the Administrator.

The minimum Part 70 record retention period for permit applications, proposed permits, and final
permits is five years in accordance with 40 CFR 70.8(a)(1) and (a)(3). However, in practical application,
permitting authorities have often found that discarding title V files after five years is problematic in the
long term.

8.1	Finding: The SDAPCD has successfully converted all permitting hard copy files to electronic files
and stores historical physical title V permit files in a central records center.

Discussion: According to the SDAPCD, they have digitized all their files and any physical files are
archived in a separate records center. During our site visit, most interviewees stated that they
do not normally use any hard copies, and if they do, it is due to personal preference. This
conversion helped greatly during the COVID-19 pandemic.

Recommendation: The EPA commends the SDAPCD on its conversion to all electronic files.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD has successfully converted
all permitting documents into electronic files.

8.2	Finding: The SDAPCD has improved its written file retention policy. However, most staff are not
aware of the District's record retention schedules.

71 This protection, however, is not absolute as the types of information that may be treated as confidential, and therefore
withheld from the public, is limited. Specifically, "[t]he contents of a permit shall not be entitled to [confidential] protection
under section 7414(c) of this title." CAA section 503(e), referring to section 114(c) of the CAA which provides protection of
certain confidential trade secret information - but not emissions data - from disclosure. In addition to the title V program
requirements, confidentiality is also addressed in the EPA's regulations governing the disclosure of records under the
Freedom of Information Act (FOIA). Pursuant to those requirements, information which is considered emissions data,
standards or limitations are also not entitled to confidential treatment. See In the Matter of ExxonMobil Corporation,
Baytown Refinery, Order on Petition No. VI-2016-14 (April 2, 2018) (Baytown Order)

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Discussion: Similar to our 2008 Evaluation, the SDAPCD has a written file retention policy for
retaining, managing, and disposing of official records; however, most staff are not aware of the
District's record retention schedules.72 Previously, for permit-related records, the District's
records retention schedule required that permit files, including title V permit files, be retained
for a total of nine years—two years after completion of a project at the District's office (onsite)
and seven years off-site. The schedule did not specifically address the retention time for title V-
related compliance records, which include compliance certifications, deviation reports and
semiannual monitoring reports. While the District's record retention schedule contained a
general section on compliance and enforcement documents, the schedule only required that
the District retain these documents for up to three years. With the current file retention
policy,73 title V documents are maintained while a permit is still active and then an additional
five years after the permit is terminated. The title V compliance files are also now explicitly
listed with a retention time frame of five years.

Recommendation: The EPA commends the SDAPCD on having a written file retention policy
that complies with the federal regulation. We recommend that the District provide training to
staff on its records management policies.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD has a written file or
records retention policy and agrees to provide further training in this area.

8.3 Finding: The SDAPCD uses an electronic database to track title V permits and continues to make
database improvements.

Since our 2008 Evaluation, the SDAPCD has replaced its previous permitting database, VAX, to a
web-based Business Case Management System (BCMS). Generally, most District staff believe it
is an improvement from VAX and that it is good at both storing electronic communications and
tracking information. For example, final permitting documents, public comments, and email
exchanges relating to the permit are captured in the database. The BCMS can track compliance
reports and violations, generate site history and productivity reports for inspectors, and create
a priority list of inspections each quarter. The system also currently stores annual/semi-annual
reports, generates site history report, and generates priority list of inspection on quarterly
basis. The system can also generate a report of pending applications and track application
deadlines.

72	2008 Evaluation, Finding 9.2.

73	Appendix G - Record Retention Schedule.

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The BCMS was not originally designed for the title V program. For instance, BCMS can generate
a report of all title V applications but cannot distinguish between different types of title V
applications. Further, the BCMS does not currently track synthetic minor74 and title V sources
explicitly. When the EPA requested data on the processing times for the District's title V
permits, the SDAPCD had to work with the developers for about three weeks to get that query
created. However, after the query was created, the turnaround time for similar processing time
requests was significantly shortened. The District continues to work with developers to upgrade
the permit and compliance report generation capabilities.

As mentioned in Finding 2.3, the BCMS stores permit conditions used in permits to help with
consistency from permit to permit. However, if modifications are made to a condition stored in
the database, a new template condition is generated in the database and sometimes it is
difficult to track which template condition to use. When the template permit condition is
updated, it also does not universally update all the permit conditions where the template was
used, the District has to manually update each permit that contains that template condition.

Generally, District staff suggested that even though the BCMS is workable, it is generally slow,
not very effective, and information can be difficult to retrieve sometimes. The BCMS has limited
workflow tracking capabilities and ability to track fees and calculations. There's currently no
streamlined process that moves a permit application through different stages of review within
the system.

Recommendation: The EPA encourages the SDAPCD to continue to improve BCMS or explore
other database options to help manage and track its permitting and compliance tasks.

Response: The SDAPCD appreciates EPA's recognition that the SDAPCD uses an electronic data
base to track Title V permits and the SDAPCD is actively working on BCMS enhancements.

74 See Finding 5.4 of this report. Actual emissions of individual equipment are recorded as the PTE, and facility-wide PTE is
not tracked

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Appendix K. Titled Base Salary Compensation Study

Page 59 of 59

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Koff & Associates

A Gallagher Company

September 29,2021

Base Salary Compensation Study
Final Report

County of San Diego

KOFF & ASSOCIATES

KATIE KANEKO

Managing Director

2835 Seventh Street
Berkeley, CA 94710
www.KoffAssociates.com

kkaneko@koffassociates.com

Tel: 510.658.5633
Fax: 510.652.5633

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Koff & Associates

A Gallagher Company

September 29, 2021

County of San Diego
Attention: Human Resources
1600 Pacific Highway
San Diego, CA 92101

To Whom It May Concern:

Koff & Associates is pleased to present the Total Compensation Study Final Report to the County
of San Diego. This report documents the market compensation survey methodology, findings,
and recommendations for implementation.

We would like to thank the County and SEIU for the regular meetings, interest, assistance, and
cooperation without which this study could not have been brought to its successful completion.

We will be glad to answerany questions or clarify any points as you are implementing the findings
and recommendations. It was a pleasure working with the County and we look forward to future
opportunities to provide you with professional assistance.

Very truly yours,

Katie Kaneko
Managing Director

2835 Seventh Street, Berkeley, California 94710 | 510.658.5633 | www.KoffAssociates.com

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Base Salary Compensation Study - Final Report

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TABLE OF CONTENTS

EXECUTIVE SUMMARY	

Background	

Summary of Findings	

STUDY PROCESS	

Classifications Survyed	

Comparator Agencies	2

Salary Data	4

Cost of Labor Differential	4

Data Collection	6

Matching Methodology	6

Data Spreadsheets	7

INTERNALSALARY RELATIONSHIPS	7

MARKET COMPENSATION FINDINGS	9

Base Salary	9

Cost	10

RECOMMENDATIONS	20

Pay Philosophy	20

Options for Implementation	20

PAY PREMIUMS	22

USING THE MARKET DATA AS A TOOL	22

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LIST OF TABLES

Table 1. Comparator Agencies	2

Table 2. Additional Comparator Agencies - Air Quality/Air Pollution	3

Table 3. Additional Comparator Agencies - Housing	4

Table 4. Cost of Labor Differentials	5

Table 5. Classifications 0% to 5% Below the Market Median	10

Table 6. Classifications 5% to 10% Below the Market Median	12

Table 7. Classifications 10% to 20% below the Market Median	14

Table 8. Classifications Greater than 20% below the Market Median	17

Table 9. Three-Year Implementation Proposal	20

LIST OF FIGURES

Figure 1: Distribution of Classifications Above and Below Market Median	9

Figure 2: Distribution of Classifications Below the Market Median	9

APPENDICES

Appendix I: Results Summary

Appendix II: Market Compensation Findings

Appendix III: ERI Methodology for Cost of Labor

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EXECUTIVE SUMMARY

Background

Between May-August 2021, Koff & Associates ("K&A") conducted a Base Salary compensation
study for the County of San Diego ("County"). All survey findings as requested are presented in
this report.

The goal of the compensation study is to assist the County in developing a competitive pay plan,
which is based upon market data, and to ensure that the plan is fiscally responsible and meets
the needs of the County with regards to recruitment and retention of qualified staff.

This report summarizes the study methodology, analytical tools, and the base salary survey
findings. The results of the compensation study showed:

>	467 classes were submitted to be studied; 459 SEIU classifications were surveyed since 8
classifications submitted were found to be terminated by the County and had no salary
associated.

>	The County's base salaries, overall, in comparison to the adjusted median are 7.3% below
the market.

>	323 classifications are below the median by an overall average of 13.1%.

>	136 classifications meet or exceed the median.

>	11 classifications had no comparator data. For these classifications and the 90
classifications that had insufficient data with fewer than four matches, we made internal
alignment recommendations based on the market data framework.

>	An additional breakdown of those below the market median reveals:

•	77 classifications are between 0% to 5% below the median

•	71 classifications are between 5% to 10% below the median

•	104 classifications are between 10% to 20% below the median

•	71 classifications are below market by more than 20% of the median

>	K&A considers a classification falling within 5% of the median to be competitive.

The County worked with SEIU to determine the study elements related to survey classifications,
comparator agencies, and data to be collected. The study initially included all 467 SEIU
classifications. They fall into the following Bargaining Units:

> Appraisal, EDP, Fiscal, and Purchasing = AE

Summary of Findings

STUDY PROCESS

Classifications Surveyed

i

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>	Clerical = CL

>	Food Services = FS

>	Health Services = HS

>	Mid Management = MM

>	Professional = PR

>	Public Services = PS

>	Registered Nurses = RN

>	Social Services Supervisors = SS

>	Social Workers = SW

Subsequently it was found that 8 of the classes were terminated by the County and had no
salaries associated with them. Consequently, data was collected on 459 classifications.

The classifications surveyed are listed alphabetically in Appendix I as part of the Market Results
Summary.

Comparator Agencies

Another important step in conducting a market salary study is the determination of appropriate
agencies for comparison. The County had provided a predetermined comparator group of 13
counties listed at Table 5. Additionally, Air Quality/Air Pollution Control Districts/Agencies (5
agencies) listed at Table 6 and Housing Agencies (4 agencies) at listed at Table 7 were identified
as additional comparators for select Air Quality or Housing benchmarks also listed below.

Table 1. Comparator Agencies

13 Comparator Agencies

1. County of Alameda

2. County of Contra Costa

3. County of Fresno

4. County of Kern

5. County of Los Angeles

6. County of Orange

7. County of Riverside

8. County of Sacramento

9. County of San Bernardino

10. City & County of San Francisco

11. County of San Mateo

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13 Comparator Agencies

12.	County of Santa Clara

13.	County of Ventura

Table 2. Additional Comparator Agencies-Air Quality/Air Pollution

5 Air Quality/Air Pollution Agencies

1.

Air Pollution Control District San Luis Obispo County

2.

Bay Area Air Quality Management District

3.

Imperial County

4.

Sacramento Metropolitan AirQuality Management District

5.

South Coast Air Quality Management District

These air quality/air pollution agencies were used as additional comparators for the following
classifications:

>	Air Pollution Control Aide

>	Air Pollution Control Civil Actions Investigator

>	Air Pollution Control Small Business Assistant Program Specialist

>	AirPollutionTestTechnician (T)

>	Air Quality Inspector I

>	AirQuality Inspector II

>	AirQuality Specialist

>	Assistant Air Pollution Chemist

>	Assistant Air Resources Specialist

>	Assistant APC Engineer

>	Assistant Meteorologist

>	Associate Air Pollution Chemist

>	Associate Air Pollution Control Engineer

>	Associate Air Resources Specialist

>	Associate Meteorologist

>	Electronic Instrument Technician I

>	Electronic Instrument Technician II

>	Junior Air Pollution Chemist

>	Junior Air Pollution Control Engineer

>	Senior Air Pollution Chemist

>	Senior Air Pollution Control Engineer

>	Senior Meteorologist

>	Supervising AirQuality Inspector

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>	Supervising Air Resources Specialist

>	Supervising Electronic Instrument Technician

Table 3. Additional Comparator Agencies - Housing

9 Housing Authority Agencies

1.

Housing Authority of the County of Contra Costa

2.

Fresno Housing Authority

3.

Housing Authority of the County of Kern

4.

LA County Development Authority

5.

Sacramento Housing & Redevelopment Agency

6.

Housing Authority of the County of San Bernardino

7.

San Francisco Housing Authority

8.

Housing Authority Santa Clara County

9.

Area Housing Authority of the County of Ventura

These housing agencies were used as additional comparators forthe following classifications:

>	Housing Aide

>	Housing Program Analyst I

>	Housing Program Analyst II

>	Housing Program Analyst III

>	Housing Program Analyst IV

>	Housing Specialist I

>	Housing Specialist II

>	Housing Specialist III

Salary Data

The minimum and top step of the salary range was collected for each benchmark classification.
All figures are represented on an annual basis.

Cost of Labor Differential

Use of a broader geographic survey group, as was done in this study, generally raises questions
on the impact of regional differences in wages. Cost of Labor measures regional differences in
wage trends and is an effective measure in drawing a comparison between salaries. To
accomplish this, we used databases from the Economic Research Institute (ERI), a nationally
recognized provider of data with respect to differences in the costs of living and cost of labor in
counties with a population of over 10,000. The Cost of Labor percentages reflect regional

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differences in wages and are relevant to making compensation decisions because the focus is on
what other employers are paying within the region rather than the differences in the cost of
consumer goods. Cost of Living focuses on the difference in the cost of consumer goods including
housing and therefore can fluctuate more dramatically between locations. Information
regarding ERI's methodology can be found in Appendix III.

Cost of Labor differentials were applied to the top step salary of each of the comparator agencies
to ensure that wages reflect the regional pay levels of San Diego County. For example, counties
located in the San Francisco Bay Area experience the highest Cost of Labor and accordingly, in
order to reflect the Cost of Labor for the San Diego region, the top step salary of a match in
Alameda County would have to be adjusted downward by 11.4% to represent the regional pay of
San Diego. Alternatively, there were some comparators that had a lower Cost of Labor than San
Diego County such as Kern County. The salaries of Kern County matches would have to be
adjusted upward by 1.2% to reflect the regional pay levels of San Diego County.

K&A lists the Cost of Labor differentials to be utilized by the County to provide more accurate
wage comparisons. The cost of labor percentages are as follows:

Table 4. Cost of Labor Differentials

Agency

Location of County
Seat/Main Office

Salary
Differentials
to Apply

City and County of San Francisco

San Francisco, CA

-17.4%

County of Alameda

Oakland, CA

-11.4%

County of Contra Costa

Martinez, CA

-11.1%

County of Fresno

Fresno, CA

4.7%

County of Kern

Bakersfield, CA

1.2%

County of Los Angeles

Los Angeles, CA

-3.8%

County of Orange

Santa Ana, CA

-2.0%

County of Riverside

Riverside, CA

1.9%

County of Sacramento

Sacramento, CA

0.1%

County of San Bernardino

San Bernardino, CA

1.9%

County of San Mateo

Redwood City, CA

-17.5%

County of Santa Clara

San Jose, CA

-16.8%

County of Ventura

Ventura, CA

-0.7%

Air Quality Agencies

Bay Area Air Quality Management District

San Francisco, CA

-17.4%

Imperial County Air Pollution Control District

El Centro, CA

5.6%

Sacramento Metropolitan Air Quality Management District

Sacramento, CA

0.1%

San Luis Obispo County Air Pollution Control District

San Luis Obispo, CA

2.9%

South Coast Air Quality Management District

Diamond Bar, CA

-2.8%

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Agency

Location of County
Seat/Main Office

Salary
Differentials
to Apply

Housing Authorities

Area Housing Authority of the County of Ventura

Newbury Park, CA

-1.1%

Fresno Housing Authority

Fresno, CA

4.7%

Housing Authority Contra Costa County

Martinez, CA

-11.1%

Housing Authority County of Kern

Bakersfield, CA

1.2%

Housing Authority County of San Bernardino

San Bernardino, CA

1.9%

Housing Authority County of Santa Clara

San Jose, CA

-16.8%

Los Angeles County Development Authority

Alhambra, CA

-2.7%

Sacramento Housing and Redevelopment Agency

Sacramento, CA

0.1%

San Francisco Housing Authority

San Francisco, CA

-17.4%

Data Collection

Data was collected during the months of May through August 2021, through comparator agency
websites, conversations with human resources, accounting, and/or finance personnel, and
careful review of agency documentation such as classification descriptions, memoranda of
understanding, organization charts, and other documents. Regular check in meetings occurred
with the County's Human Resources team and SEIU representation.

Matching Methodology

K&A believes that the data collection step is the most critical for maintaining the overall
credibility of any study and relied on the County's classification descriptions as the foundation
for comparison.

When K&A researches and collects data from the comparator agencies to identify possible
matches for each of the benchmark classifications, there is an assumption that comparable
matches may not be made that are 100% equivalent to the classifications at the County.
Therefore, K&A does not match based upon job titles, which can often be misleading, but rather
analyze class descriptions before a comparable match is determined.

K&A's methodology is to analyze each class description and the whole position by evaluating
factors such as:

>	Definition and typical job functions;

>	Distinguishing characteristics;

>	Level within a class series (i.e., entry, experienced, journey, specialist, lead, etc.);

>	Reporting relationship structure (for example, manages through lower-level staff);

>	Education and experience requirements;

>	Knowledge, abilities, and skills required to perform the work;

>	The scope and complexity of the work;

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>	Independence of action/responsibility;

>	The authority delegated to make decisions and take action;

>	The responsibility for the work of others, program administration, and for budget dollars;

>	Problem solving/ingenuity;

>	Contacts with others (both inside and outside of the organization);

>	Consequences of action and decisions; and

>	Working conditions.

In order for a match to be included, K&A requires that a classification's "likeness" be at
approximately 70% of the matched classification.

When an appropriate match is not identified for one classification, K&A often uses "hybrids"
which can be functional or represent a span in scope of responsibility. A functional hybrid means
that the job of one classification at the County is performed by two or more classifications at a
comparator agency. A "hybrid" representing a span in scope means that the comparator agency
has one class that is "bigger" in scope and responsibility and one class that is "smaller," where
the County's class falls in the middle.

If an appropriate match could not be found, then no match was reported as a non-comparable

For each benchmark classification, there is one information page with the Minimum and the Top
Annual Base Salary Data.

The medians (midpoint) of the comparator agencies are reported on the Top Annual salary data
spreadsheets. The % above or below that the County is compared to the median is also reported.
The median is the midpoint of all data with 50% of data points below and 50% of data points
above.

K&A typically requires that there be a minimum of four (4) comparator agencies with matching
classifications to the benchmark classification. The reason for requiring a minimum of four
matches is so that no one classification has undue influence on the calculations. However, the
County requested that the median be calculated on all classifications regardless of meeting the
four match minimum. We have flagged those benchmarks with fewer than four matches as
having insufficient data. Sufficient data was collected from the comparator agencies for 352 of
the originally designated 467 benchmark classifications.

For some classifications we were unable to find any comparable matches with the survey
agencies. For those classifications, with insufficient data, building from the salary levels
established for identified benchmark classes, internal salary relationships were developed and
consistently applied in order to develop specific salary recommendations for all classifications.

(N/C).

Data Spreadsheets

INTERNAL SALARY RELATIONSHIPS

7

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Base Salary Compensation Study - Final Report

County of San Diego

While analyzing internal relationships, the same factors analyzed when comparing the County's
classifications to the labor market are used when making internal salary alignment
recommendations.

In addition, the following are standard human resources practices that are commonly applied
when making salary recommendations based upon internal relationships:

>	A salary within 5% of the market average or median is considered to be competitive in
the labor market for salary survey purposes because of the differences in compensation
policy and actual scope of the position and its requirements. However, the County can
adopt a different standard.

>	Certain internal percentages are often applied. Those that are the most common are:

•	The differential between a trainee and experienced (or journey) class in a series
(l/ll orTrainee/Experienced) is generally 10% to 15%.

•	A lead or advanced journey-level (III or Senior-level) class is generally placed 10%
to 15% above the journey-level.

•	A full supervisory class is normally placed at least 10% to 25% above the highest
level supervised, depending upon the breadth and scope of supervision.

>	When a market or internal equity adjustment is granted to one class in a series, the other
classes in the series are also adjusted accordingly to maintain internal equity.

Internal equity between certain levels of classifications is a fundamental factor to be considered
when making salary decisions. When conducting a market compensation survey, results can
often show that certain classifications that are aligned with each other are not the same in the
outside labor market. However, as an organization, careful consideration should be given to
these alignments because they represent internal value of classifications within job families, as
well as across the organization.

For the classifications that had insufficient data, zero matches or fewer than four matches,
internal alignments with other classifications will need to be considered, either within the same
class series or with those classifications that have similar scope of work, level of responsibility,
and "worth" to the County. Where it is difficult to ascertain internal relationships due to unique
qualifications and responsibilities, reliance can be placed on past internal relationships. It is
important for County management to carefully review these internal relationships and determine
if they are still appropriate given the current market data.

It is also important to analyze market data and internal relationships within class series as well
as across the organization, and make adjustments to salary range placements, as necessary,
based on the needs of the organization.

The County may want to make internal equity adjustments or alignments, as it implements the
compensation strategy. This market survey is only a tool to be used by the County to determine
market indexing and salary determination.

8

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Base Salary Compensation Study - Final Report

County of San Diego

MARKET COMPENSATION FINDINGS

Appendix I represents a summary of the market top annual (base) salary. For each benchmark
classification, the number of matches (agencies with a comparable position) and percent above
or below the top annual salary market median is listed. The Appendix is sorted alphabetically.

Base Salary

Base salary market results show that 361 classifications are paid below the market median, and
98 classifications are paid above the market median.

Above

Belowthe Market Median 136	77	71	104	71	459

Figure 1: Distribution of Classifications Above and Below Market Median

350
S 300

V)

(/)

j£2 250

2 200

0

•5 150

0)

-Q 100

E

1	50

0

Figure 2: Distribution of Classifications Below the Market Median

160
8! 140
ro 120
- 100

(0

3 80

\Z	60
o

t	40

¦|	20

= 0
Z

Above 0-5% 5-10% 10-20% >20%

Median

Percent Below Market Median

Above Median	Below Median

9

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Base Salary Compensation Study - Final Report

County of San Diego

Generally, a classification falling within 5% of the median is considered to be competitive in the
labor market for salary survey purposes because of the differences in compensation policy, actual
scope of work, and position requirements. However, the County can adopt a different standard.

Cost

The total cost to bring all incumbents to the annual median salary for the 13 counties is
$50,361,190. The total cost to bring all budgeted positions to the annual median salary is
$54,826,506. (Approximately 11,185 positions). This amount includes internal alignment
recommendations for those classification with no market data or fewer than four matches.

Additional Information

The following tables display the classifications 0% to 5% below, 5% to 10% below, 10% to 20%
below, and greater than 20% below the median, respectfully:

Table 5. Classifications 0% to 5% Below the Market Median

77 Classifications
0% to 5% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Account Clerk Specialist

CL

63

$90,399

Admissions Clerk

CL

12

$10,152

Air Quality Specialist

PR

5

$1,683

Alcohol & Drug Program Specialist

PR

10

$18,140

Animal Care Attendant

PS

11

$6,704

Appraiser II

AE

48

$42,358

Assistant Health Physicist*

PR

0

$0

Assistant Procurement Specialist

AE

4

$9,241

Associate Accountant

AE

59

$9,331

Associate Air Pollution Control Engineer

PR

6

$14,506

Associate Meteorologist*

PR

3

$5,261

Broadcast Engineer

PS

1

$3,262

Cadastral Technician

AE

7

$17,139

Community Health Program Specialist

PR

26

$84,974

Community Health Promotion Specialist 1

PR

6

$10,453

Emergency Services Coordinator

MM

3

$11,701

EngineeringTechnician 1

PS

2

$1,338

EngineeringTechnician III

PS

16

$14,552

Environmental Health Specialist Trainee

PR

14

$24,680

Estate Assistant*

PS

3

$5,280

Estate Property Manager

MM

1

$3,336

Fleet Standards Technician*

AE

4

$8,407

10

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Base Salary Compensation Study - Final Report

County of San Diego

77 Classifications
0% to 5% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Fleet Support Specialist*

PR

l

$1,467

Graphic Artist

PS

2

$1,107

Human Services Specialist

SW

1656

$1,232,020

Industrial Hygienist 1*

PR

1

$644

Industrial Hygienist II

PR

3

$2,332

Jr Land Use/Environmental Planner

PR

7

$18,469

Land Surveyor

PR

5

$7,327

Land Use Aide*

PS

5

$6,386

Land Use Technician 1

PS

7

$17,699

Land Use Technician III

PS

6

$19,076

Land Use/Environmental Planner 1

PR

12

$17,826

Land Use/Environmental Planner III

PR

43

$74,702

Library Associate*

PR

3

$6,842

Mail Systems Supervisor

MM

1

$95

Medical Consultant*

PR

3

$11,404

Occupational/Physical Therapist

PR

32

$105,485

Paralegal Supervisor*

MM

13

$14,728

Patient Services Specialist III (T)

SW

1

$394

Property Assessment Specialist 1*

AE

15

$17,344

Protective Services Worker

SW

557

$294,884

Public Health Microbiologist

PR

5

$18,012

Records Clerk*

CL

77

$140,405

Recycling Specialist 1*

PR

0

$0

Residential Childcare Specialist*

HS

9

$3,361

Section Chief, Revenue & Recovery

MM

5

$21,647

Senior Admissions Clerk*

CL

1

$1,697

Senior Airport Technician

MM

2

$2,086

Senior Health Physicist*

MM

1

$246

Senior HHSA Contract Auditor

MM

4

$9,361

Senior Meteorologist*

PR

1

$1,171

Senior Park Ranger

MM

17

$53,013

Senior Public Health Microbiologist

PR

5

$10,867

Senior Real Property Agent

PR

10

$24,608

Senior Structural Engineer

MM

0

$0

Senior Tax Payment Enforcement Officer

PS

1

$1,387

Senior Tax Payment Processor*

CL

0

$0

Senior Vector Control Technician

PS

8

$17,099

11

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Base Salary Compensation Study - Final Report

County of San Diego

77 Classifications
0% to 5% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Sheriff's Detentions Nurse

RN

168

$120,280

Sheriff's Licensing Clerk 1*

CL

7

$5,874

Sheriff's Licensing Clerk II*

CL

2

$349

Sheriff's Licensing Specialist*

CL

2

$3,267

Statistician

PR

0

$0

Supervising Air Resources Specialist*

MM

2

$6,070

Supervising Community Health Promotion Specialist

MM

1

$2,760

Supervising Pest Management Technician

MM

1

$1,387

Supervising Sheriff's Emergency Services Dispatcher

MM

15

$7,719

Supervising Vector Ecologist*

MM

1

$992

Tax Payment Enforcement Officer

PS

1

$2,152

Tax Payment Processor

CL

0

$0

Telecommunications Technician III

MM

8

$9,083

Telecommunications Technician IV

MM

3

$10,283

Toxicologist II

PR

4

$10,320

Toxicologist III*

MM

1

$3,908

Vector Ecologist*

PR

2

$4,716

Watershed Manager*

MM

0

$0



Total

3,041

$2,737,251

* 1 nsufficient data. Used internal alignmentto make a salary recommendation.





Table 6. Classifications 5% to 10% Below the Market Median



71 Classifications
5% to 10% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Account Clerk

CL

37

$148,033

Adult Protective Services Specialist

PS

62

$452,727

Adult Protective Services Supervisor

MM

14

$99,442

Air Pollution Test Technician (T)*

PS

1

$6,293

Animal Control Officer

PS

9

$27,176

Appraiser Trainee

AE

0

$0

Assistant Airport Manager

MM

2

$11,245

Assistant APC Engineer

PR

11

$77,342

Assistant Meteorologist*

PR

0

$0

Assistant Weapons Coordinator*

PS

2

$9,178

Civil Engineer

PR

32

$276,843

12

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Base Salary Compensation Study - Final Report

County of San Diego

71 Classifications
5% to 10% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Code Enforcement Officer

PS

10

$68,326

Community Health Promotion Assistant

PR

0

$0

Community Health Promotion Specialist II

PR

18

$110,672

Deputy Public Admin-Guardian

PS

15

$78,562

Environmental Health Specialist II

PR

61

$336,253

Environmental Health Specialist III

PR

32

$196,227

Fleet Parts Specialist

AE

3

$11,667

Food Services Supervisor

MM

14

$57,253

Housing Program Analyst III

PR

2

$10,577

Industrial Hygienist III*

PR

0

$0

Insect Detection Specialist 1

PS

0

$0

Investigative Specialist

PS

11

$41,903

Jr Surveyor (T)

PR

3

$12,509

Legal Support Supervisor 1

MM

33

$113,197

Legal Support Supervisor II

MM

24

$101,212

Librarian III

PR

17

$84,607

Library Technician IV*

PS

14

$51,563

Mail Carrier

PS

15

$51,967

Medical Transcriber

CL

1

$4,013

Mental Health Case Management Clinician

PR

25

$168,660

Mental Health Specialist

HS

6

$27,166

Office Assistant

CL

788

$2,515,896

Office Support Specialist

CL

97

$386,599

Paralegal 1

PS

21

$112,720

Park Ranger

PS

49

$214,900

Parks Recreational Supervisor

MM

8

$29,239

Pharmacist

MM

10

$85,531

Probation Aide

PS

19

$84,406

Protective Services Assistant

SW

1

$2,869

Protective Services Supervisor

SS

129

$999,326

Psychiatric Nurse

RN

104

$881,067

Purchasing Clerk

AE

3

$15,050

Recreational Therapist

PR

7

$43,175

Residential Care Worker Supervisor*

MM

20

$104,397

Road Crew Supervisor

MM

18

$127,493

Senior Civil Engineer

MM

29

$238,985

Senior Clinical Psychologist

PR

14

$77,708

13

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Base Salary Compensation Study - Final Report

County of San Diego

71 Classifications
5% to 10% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Senior Construction Inspector

MM

l

$6,701

Senior Electronic Security & Systems Technician

MM

l

$8,018

Senior Laboratory Assistant

HS

3

$13,713

Senior Mail Carrier*

PS

1

$3,567

Senior Medical Transcriber*

CL

1

$4,442

Senior Occupational/Physical Therapist

PR

19

$134,792

Senior Revenue & Recovery Officer

PS

9

$37,625

Senior Storekeeper

MM

9

$46,767

Senior Vector Ecologist*

PR

1

$7,339

Sheriff's Detentions, Chief Mental Health Clinician*

MM

2

$15,430

Sheriff's Operations Supervisor*

MM

6

$38,623

Supervising Animal Care Attendant

MM

4

$13,468

Supervising Child Support Officer

MM

17

$75,229

Supervising Deputy Public Administrator-Guardian

MM

2

$14,362

Supervising Environmental Health Specialist

MM

22

$128,017

Supervising Industrial Hygienist

MM

1

$9,793

Supervising Occupational/Physical Therapist

MM

11

$102,825

Supervising, Vector Control Technician*

MM

5

$27,076

Toxicologist 1*

PR

0

$0

Vector Control Technician

PS

16

$82,793

Veterinarian

PR

1

$12,201

Wastewater Facilities Supervisor

MM

1

$8,242

Wastewater Plant Operator III

MM

4

$26,040

Total

1,928

$9,371,040

* I nsufficient data. Used internal alignmentto make a salary recommendation.

Table 7. Classifications 10% to 20% below the Market Median

104 Classifications
10% to 20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Accounting Technician

AE

82

$665,837

Administrative Secretary II

CL

91

$723,907

Aging Program Specialist II

PS

42

$571,194

Animal Medical Operations Manager*

MM

1

$18,766

Animal Services Dispatcher*

CL

5

$27,715

Animal Services Representative

CL

6

$30,290

14

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Base Salary Compensation Study - Final Report

County of San Diego

104 Classifications
10% to 20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Assessment Clerk

CL

29

$130,132

Assistant Child Support Officer

PS

8

$72,831

Assistant Real Property Agent

PR

0

$0

Assistant Surveyor

PR

3

$30,731

Associate Air Pollution Chemist*

PR

15

$286,849

Associate Air Resources Specialist

PR

4

$56,391

Associate Real Property Agent

PR

3

$25,953

Building Maintenance Supervisor

MM

14

$178,745

Building/Enforcement Supervisor

MM

3

$31,697

Cashier

CL

10

$52,740

Certified Nurse Practitioner

RN

4

$82,345

Community Services Officer

PS

50

$470,375

Cook

FS

15

$116,786

Crime Prevention Specialist

PS

19

$118,126

Departmental Clerk

CL

0

$0

Detentions Processing Supervisor*

MM

28

$226,300

Detentions Processing Technician

CL

147

$1,128,252

Drafting Technician

PS

0

$0

Electronic InstrumentTechnician 1

PS

2

$15,611

Electronic InstrumentTechnician II

PS

7

$57,887

Food Services Worker

FS

50

$253,556

Health Information Management Clerk*

CL

6

$42,491

Health Information Management Technician

HS

33

$275,605

Health Services Social Worker

SW

3

$30,420

Histology Technician

HS

0

$0

Historian

PR

0

$0

Housing Aide

PS

6

$53,539

Housing Program Analyst IV

PR

3

$34,496

Housing Specialist III

PS

7

$59,187

Jr Air Pollution Chemist*

PR

0

$0

Jr Air Pollution Control Engineer*

PR

1

$9,488

Jr Public Health Microbiologist

PR

3

$25,266

Laboratory Assistant

HS

6

$31,055

Legal Support Assistant II

CL

148

$1,350,019

Library Technician 1

PS

69

$523,765

Library Technician II

PS

46

$277,468

Library Technician III

PS

37

$239,502

15

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Base Salary Compensation Study - Final Report

County of San Diego

104 Classifications
10% to 20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Licensed Vocational Nurse

HS

38

$235,523

Litigation Investigator

PS

0

$0

Mail Processor

PS

0

$0

Medical Examiner Invest II

PS

11

$168,804

Mental Health Aide*

HS

15

$119,552

Mental Health Case Management Assistant

HS

7

$58,481

Nutritionist

PR

4

$36,083

Occupational/Physical Therapist Assistant

HS

1

$10,980

Patient Services Specialist IV (T)

SS

1

$10,689

Pharmacy Stock Clerk

AE

0

$0

Principal Treasurer-Tax Collector Specialist

MM

2

$22,732

Process Server

PS

1

$6,139

Process Server Supervisor*

MM

1

$9,979

Psychiatric Technician

HS

0

$0

Public Assistance Investigator 1*

PS

8

$61,536

Public Assistance Investigator II

PS

19

$209,196

Public Assistance Investigator Supervisor

MM

8

$95,879

Public Assistance Investigator Trainee*

PS

3

$22,953

Public Defender Investigator 1

PS

16

$217,693

Public Defender Investigator II

PS

34

$538,603

Public Health Nurse

RN

110

$1,092,584

Public Health Nurse Supervisor

MM

33

$553,994

Public Health Nutrition Manager

MM

1

$11,598

Quality Assurance Specialist (Registered Nurse)

PR

14

$217,164

Recreation Therapy Supervisor

MM

2

$18,980

Registered Veterinary Technician

PS

5

$47,378

Revenue & Recovery Officer Trainee

PS

1

$4,869

Senior Account Clerk

MM

4

$36,409

Senior Adult Protective Services Specialist

PS

10

$94,830

Senior Air Pollution Chemist*

MM

3

$61,420

Senior Animal Services Representative*

CL

2

$11,686

Senior Cashier*

MM

0

$0

Senior Cook

FS

58

$440,167

Senior Forensic Evidence Technician

PS

1

$9,018

Senior Histology Technician*

HS

0

$0

Senior Litigation Investigator*

PS

4

$55,036

Senior Office Assistant

MM

118

$866,557

16

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Base Salary Compensation Study - Final Report

County of San Diego

104 Classifications
10% to 20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Senior Precinct Planning Technician*

PS

2

$18,364

Senior Protective Services Worker

sw

145

$1,381,054

Senior Public Health Nurse

RN

52

$648,983

SeniorTreasurer-Tax Collector Specialist

CL

27

$211,490

Sewing Room Supervisor*

MM

1

$7,037

Sheriff's Commissary Stores Supervisor*

MM

1

$8,597

Sheriff's Communications Dispatcher

PS

3

$17,488

Sheriff's Emergency Services Dispatcher

PS

92

$797,933

Sheriff's Property & Evidence Manager*

MM

1

$13,205

Sheriff's Property Investigator*

PS

3

$29,512

Sheriff's Records & Identification Clerk 1

CL

1

$6,680

Sheriff's Records & Identification Clerk II

CL

55

$423,856

Social Work Supervisor

SS

25

$281,845

Social Worker 1

SW

33

$314,584

Staff Nurse

RN

47

$672,740

Stock Clerk

AE

47

$362,508

Storekeeper II (T)

MM

1

$6,561

Supervising Animal Control Officer

MM

4

$33,244

Supervising Electronic InstrumentTechnician

MM

2

$33,002

Supervising Nurse

MM

20

$310,670

Supervising Park Ranger

MM

19

$202,578

Technical Writer

PR

1

$14,157

Treasurer-Tax Collector Specialist

CL

30

$222,981

Victim/Witness Assist Program Manager

MM

1

$17,353

Total

2,154

$19,708,253

* I nsufficient data. Used internal alignmentto make a salary recommendation.

Table 8. Classifications Greater than 20% below the Market Median

71 Classifications
>20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Administrative Secretary 1

CL

40

$464,004

Aging Program Specialist 1*

PS

1

$13,533

Aging Program Specialist III*

MM

7

$113,723

Air Pollution Control Aide*

PS

14

$275,140

Assistant Air Pollution Chemist*

PR

0

$0

17

-------
Base Salary Compensation Study - Final Report

County of San Diego

71 Classifications
>20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Assistant Air Resources Specialist

PR

0

$0

Assistant Division Chief, Assessor/Recorder/County Clerk

MM

8

$331,802

Chaplain-Coordinator

PR

0

$0

Clinical Psychologist

PR

3

$59,593

Departmental Payroll Technician

CL

1

$13,123

Deputy Medical Examiner 1*

PR

0

$0

Deputy Medical Examiner II

PR

5

$240,183

Deputy Sheriff Cadet-Detentions/Court Services

PS

45

$1,026,573

Deputy Sheriff's Cadet

PS

58

$841,616

Detentions Information Assistant

CL

53

$503,579

Dietitian

PR

1

$17,717

Disease Research Scientist

PR

1

$22,982

Environmental Health Technician

PS

18

$249,846

Geographic Information Systems Analyst

PR

6

$130,062

Geographic Information Systems Technician

PS

4

$48,738

Human Services Control Specialist

SW

29

$512,106

Insect Detection Specialist II

PS

31

$376,216

Inservice Education Coordinator*

RN

3

$87,603

Jr Real Property Agent

PR

0

$0

Landscape Architect

PR

1

$24,012

Legal Support Assistant 1

CL

55

$614,889

Legal Support Assistant III

CL

52

$572,842

Library Technician Substitute*

PS

0

$0

Medical Claims Specialist

CL

14

$146,898

Medical Examiner Invest 1

PS

3

$52,133

Medical Examiner Invest III

MM

3

$68,205

Payroll Clerk

CL

2

$29,357

Pediatrician

PR

0

$0

Pharmacy Storekeeper*

MM

0

$0

Physician Assistant

PR

0

$0

Precinct Planning Technician*

PS

1

$10,664

Psychiatric Clinical Nurse Specialist

RN

0

$0

Psychiatric Resident*

PR

0

$0

Psychiatrist

PR

2

$88,440

Psychiatrist - Specialist

PR

5

$352,130

Public Defender Investigator III

PS

12

$308,251

Radiologic Technologist

HS

2

$58,184

18

-------
n

Base Salary Compensation Study - Final Report

County of San Diego

71 Classifications
>20% Below Median

Bargaining
Unit

# of
Incumbents
per Class

Cost per
Actual
Incumbents

Radiologist*

PR

l

$58,615

Records Management Coordinator

MM

3

$52,884

Recreation Therapy Aide*

HS

6

$90,957

Senior Assessment Clerk

CL

5

$70,212

Senior Geographic Information Systems Analyst

PR

10

$198,725

Senior Health Information Management Technician*

HS

8

$89,124

Senior Insect Detection Specialist*

PS

6

$74,925

Senior Payroll Clerk*

CL

0

$0

Sheriff's Emergency Services Dispatcher Trainee

PS

27

$624,859

Sheriff's Fingerprint Examiner

PS

8

$175,665

Sheriff's Licensing Supervisor*

MM

3

$40,087

Sheriff's Property & Evidence Custodian*

PS

2

$27,414

Sheriff's Property & Evidence Specialist 1

CL

9

$144,708

Sheriff's Property & Evidence Specialist II

CL

0

$0

Sheriff's Range Guard*

PS

3

$65,817

Sheriff's Records & Identification Supervisor

MM

10

$118,622

Sheriff's Senior Fingerprint Examiner

PS

1

$25,830

Social Services Aide

SW

20

$170,385

Social Worker II

SW

14

$204,391

Social Worker III

SW

202

$3,734,007

Storekeeper

AE

16

$165,405

Supervising Assessment Clerk

MM

4

$62,382

Supervising Human Services Control Specialist

SS

6

$109,837

Supervising Human Services Specialist

SS

220

$3,413,259

Supervising Office Assistant

MM

43

$592,333

Supervising Treasurer-Tax Collector Specialist

MM

6

$91,198

Utilization Review Quality Improvement Specialist

PR

20

$403,921

Utilization Review Quality Improvement Supervisor

MM

4

$84,940

Vector Control Technician Aide

PS

0

$0

Total

1,137

$18,544,646

* I nsufficient data. Used internal alignmentto make a salary recommendation.

19

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Base Salary Compensation Study - Final Report

County of San Diego

RECOMMENDATIONS

Pay Philosophy

The County has many options regarding what type of compensation plan it wants to implement.
This decision will be based on fiscal considerations, what the County's pay philosophy is, at which
level it desires to pay its employees compared to the market, whether it is going to consider
additional alternative compensation programs, and how great the competition is with other
agencies over recruitment of a highly qualified workforce. The initial recommendations have
been made utilizing a philosophy of market median adjusted for Cost of Labor differentials.

Options for Implementation

While the County may be interested in bringing all salaries to the market median, in most cases
this goal may not be reached with a single adjustment. In this case, one option is to move
employees into the salary range that is recommended for each class based on this market study
and to the step within the new range that is closest to their current compensation. If employees'
current salaries are significantly below market so that their current compensation falls below the
bottom of the newly recommended range, then larger adjustments would be needed to move
those employees at least to the bottom of the new salary range.

Another option is to use a phased implementation approach. Normally, if the compensation
implementation program must be carried over months or years, the classes that are farthest from
the market median should receive the greatest equity increase (separate from any cost of living
increase). If a class falls within 5% of the market median, it would be logical to make no equity
adjustment in the first round of changes. However, if a class is more than 5% (or in this case,
more than 20%) below the market median, a higher percentage change may be initially
warranted to reduce the disparity.

For example, if the County decided to implement the recommendations over a three-year period,
then the following guidelines could be applied for the initial increase of the three-year
implementation plan:

Table 9. Three-Year Implementation Proposal

Market Disparity

% Increase

0 to 4.99%

0 to 2.49%

5.0% to 9.99%

2.5% to 4.99%

10.0% to 14.99%

5.0% to 7.49%

15.0% to 19.99%

7.5% to 9.99%

20.0% and above

10.0%

20

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Base Salary Compensation Study - Final Report

County of San Diego

The initial first year adjustment would provide a portion of the equity increase and place the class
into the closest step (but not below) where they are now. Subsequent increases would be spaced
on a similar schedule (at annual intervals) based upon the remaining disparity after each
adjustment.

Please note that typically, for those classes that had a market disparity of 0 to 4.99%, we
recommend a 0% increase in the first year and an adjustment in the second year. Depending
upon the County's financial situation, which will have to be reviewed before each further
adjustment is made, all market disparity adjustments are intended to be completed by the third
year. The County may also consider a similar implementation plan over a longer period of time,
like a five-year implementation plan.

The County may spend additional time to go through a process of deliberation and decision-
making as to what compensation philosophy it should implement to attract, motivate, and retain
a high-quality workforce. However, the County may want to consider adjusting those
classifications' salaries that are currently below the market median as soon as possible, assuming
that incumbents' performance meets the County's level of expectation.

When classifications are over market, K&A typically recommends Y-rating employees whose
current pay exceeds the maximum of the recommended range until the market numbers "catch
up" with their current salary. To Y-rate an employee means to keep the employee's salary frozen
and to provide no salary increases (including no cost of living adjustments) until the employee's
current salary is within the recommended salary range. This will result in no immediate loss of
income but will delay any future increases until the incumbent's salary is within the salary range.

Other options to "freezing" a classification's salary in place until the market catches up are:

>	"Grandfathering" of salary ranges: This means that the salary range for the classification
is adjusted down to what the market numbers are. However, current incumbents would
continue being paid at the current rate of pay (which would put them outside of the new
and adjusted salary range for the class) until they separate from employment with the
County. Any new hires would be paid within the newly established salary range.

>	Single-incumbent classes: If a class only has one incumbent, an option would be to wait
until the person separates from employment with the County and then adjust the salary
range for the class according to the market.

>	Recent hires: Some employees who have recently been hired may still be at one of the
lower steps within their current salary range. So, even if the top of their current salary
range is above market, the incumbents are currently still paid belowthe market maximum
because they are not at the top of their current salary range. In this case, an immediate
salary range adjustment could be made to bring the salary range within the market. This
would bring the affected incumbents either to the top of the market range or very close
to it, but they would not technically be Y-rated or lose any pay.

21

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Base Salary Compensation Study - Final Report

County of San Diego

Another option, of course, is to actually reduce salaries down to the market. However, from an
employee relations perspective this may not be a viable option.

Another consideration when making salary decisions is to evaluate pay premiums, or
differentials, that have historically been paid to attract talent for difficult to recruit for
classifications. Often these differentials are necessary when the supply of workers is low or
compensation is not competitive to attract those capable of performing the work. The County
should evaluate those classifications where these premiums have historically been applied, and
determine whether they are necessary once equity adjustments have been made setting
compensation at a competitive level.

K&A would like to reiterate that this report and the findings are meant to be a tool for the County
to create and implement an equitable compensation plan. Compensation strategies are designed
to attract and retain excellent staff; however, financial realities and the County's expectations
may also come into play when determining appropriate compensation philosophies and
strategies. The collected data presented herein represents a market survey that will give the
County an instrument to make future compensation decisions.

It has been a pleasure working with County on this critical project. Please do not hesitate to
contact us if we can provide any additional information or clarification regarding this report.

Respectfully submitted by,

Koff & Associates

PAY PREMIUMS

USING THE MARKET DATA AS A TOOL

Katie Kaneko
Managing Director

22

-------
lose Salary Compensation Study - final Report

County of San Diego

Results Summary

-------
County of San Diego
Appendix I: Results Summary
August 2021

Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



||















PR

$ 114,317

$ 85,904



$ 85,493

$ 85,493



$ -28,824

1

$0

1

$0

2

Above Market N/A

Account Clerk

CL

$ 43,243

$ 48,758

-12.8%

$ 47,244

$ 47,244

-9.3%

$ 4,001

37

$148,033

37

$148,033

13



Account Clerk Specialist

CL

$49,816

$ 50,746

-1.9%

$ 51,251

$ 51,251

-2.9%

$ 1,435

85

$121,967

63

$90,399

10



Accounting Technician

AE

$ 53,144

$ 65,020

-22.3%

$ 61,264

$ 61,264

-15.3%

$ 8,120

87

$706,437

82

$665,837

13



Administrative Secretary I

CL

$ 44,616

$ 59,248

-32.8%

$ 56,216

$ 56,216

-26.0%

$ 11,600

50

$580,005

40

$464,004

8



Administrative Secretary II

CL

$ 51,542

$ 67,039

-30.1%

$ 59,497

$ 59,497

-15.4%

$ 7,955

105

$835,277

91

$723,907

10



AdmissionsClerk

CL

$44,179

$ 44,687

-1.1%

$ 45,025

$ 45,025

-1.9%

$ 846

14

$11,844

12

$10,152

5



Adult Protective Services Specialist

PS

$ 75,317

$ 85,613

-13.7%

$ 82,619

$ 82,619

-9.7%

$ 7,302

74

$540,352

62

$452,727

9



Adult Protective Services Supervisor

MM

$ 92,602

$ 105,184

-13.6%

$ 99,705

$ 99,705

-7.7%

$ 7,103

16

$113,648

14

$99,442

8



Aging Program Specialist I

PS

$ 57,450

$ 80,313

-39.8%

$ 72,891



-23.6%

$ 13,533

0

$0

1

$13,533

2

Internal Alignment: 15% below the Aging Program Specialist II

Aging Program Specialist II

PS

$ 69,909

$ 95,484

-36.6%

$ 83,509

$ 83,509

-19.5%

$ 13,600

42

$571,194

42

$571,194

4



Aging Program Specialist III

MM

$ 79,789

$ 93,032

-16.6%

$ 86,601

$ 96,035

-20.4%

$ 16,246

8

$129,969

7

$113,723

2

Internal Alignment: 15% above Aging Program Specialist II

Agricultural Civil Actions Investigator

PR

$ 100,610







$ 99,327

1.3%

$ -1,283

0

$0

0

$0

0

Internal Alignment: 10% below Litigation Investigator

Agricultural Scientist

MM

$ 109,907

$ 94,426

14.1%

$ 85,373

$ 85,373

22.3%

$ -24,535

4

$0

3

$0

2

Above Market N/A

Agricultural Standards Inspector

PR

$ 74,693

$ 76,040

-1.8%

$ 67,599

$ 67,599

9.5%

$ -7,093

3

$0

30

$0

13



Air Pollution Control Aide*

PS

$ 55,203

$ 59,004

-6.9%

$ 56,911

$ 74,856

-35.6%

$ 19,653

15

$294,793

14

$275,140

3

Internal Alignment: 15% below Jr. Air Pollution Chemist

Air Pollution Control Civil Actions Investigator*

PS

$ 100,797

$ 105,790

-5.0%

$ 94,861

$ 99,327

1.5%

$ -1,470

4

$0

4

$0

2

Internal Alignment: 10% below Litigation Investigator

Air Pollution Control Small Business Assistant Program Specialist*

PR

$ 98,197







$ 97,340

0.9%

$ -857

1

$0

1

$0

0

Internal Alignment: Anchor to Environmental Health Specialist III

Air Pollution Test Technician (T)*

PS

$ 72,966

$ 75,693

-3.7%

$ 67,629

$ 79,259

-8.6%

$ 6,293

1

$6,293

1

$6,293

2

Internal Alignment: 10% below Jr. Air Pollution Chemist

Air Quality inspector I*

PS

$ 77,397

$ 76,802

0.8%

$ 75,149

$ 75,149

2.9%

$ -2,247

0

$0

11

$0

6



Air Quality Inspector II*

PS

$ 89,731

$ 90,115

-0.4%

$ 85,565

$ 85,565

4.6%

$ -4,167

26

$0

15

$0

6



Air Quality Specialist*

PR

$ 99,050

$ 108,780

-9.8%

$ 99,386

$ 99,386

-0.3%

$337

6

$2,020

5

$1,683

5



Alcohol & Drug Program Specialist

PR

$ 81,890

$ 92,922

-13.5%

$ 83,704

$ 83,704

-2.2%

$ 1,814

13

$23,582

10

$18,140

6



Animal Care Attendant

PS

$48,318

$ 53,554

-10.8%

$ 48,928

$ 48,928

-1.3%

$ 609

11

$6,704

11

$6,704

10



Animal Control Officer

PS

$ 59,925

$ 66,264

-10.6%

$ 62,944

$ 62,944

-5.0%

$ 3,020

12

$36,235

9

$27,176

11



Animal Medical Operations Manager

MM

$ 101,587

$ 120,034

-18.2%

$ 106,710

$ 120,353

-18.5%

$ 18,766

1

$18,766

1

$18,766

1

Internal Alignment: 80% above Registered Veterinary Technician

Animal Services Dispatcher

CL

$47,715

$ 50,082

-5.0%

$ 51,034

$ 53,258

-11.6%

$ 5,543

5

$27,715

5

$27,715

3

Internal Alignment: 5% below Sheriff's Communications Dispatcher

Animal Services Representative

CL

$ 46,010

$ 55,304

-20.2%

$ 51,058

$ 51,058

-11.0%

$ 5,048

7

$35,338

6

$30,290

6



Appraiser I

AE

$ 70,450

$ 76,500

-8.6%

$ 70,213

$ 70,213

0.3%

$-237

0

$0

5

$0

10



Appraiser II

AE

$ 80,454

$ 87,174

-8.4%

$ 81,337

$ 81,337

-1.1%

$ 882

54

$47,653

48

$42,358

13



Appraiser III

AE

$ 90,792

$ 97,533

-7.4%

$ 89,181

$ 89,181

1.8%

$ -1,611

29

$0

27

$0

10



Appraiser IV

AE

$ 99,882

$ 99,492

0.4%

$ 93,885

$ 93,885

6.0%

$ -5,997

9

$0

8

$0

8



Appraiser Trainee

AE

$ 57,949

$ 67,338

-16.2%

$ 63,428

$ 63,428

-9.5%

$ 5,479

0

$0

0

$0

8



Assessment Clerk

CL

$ 44,054

$ 48,573

-10.3%

$ 48,542

$ 48,542

-10.2%

$ 4,487

29

$130,132

29

$130,132

8



Assistant Air Pollution Chemist*

PR

$ 84,053

$ 93,461

-11.2%

$ 83,439

$ 101,276

-20.5%

$ 17,223

0

$0

0

$0

2

Internal Alignment: 15% above Jr. Air Pollution Chemist

Assistant Air Resources Specialist*

PR

$ 78,042

$ 102,427

-31.2%

$ 94,978

$ 94,978

-21.7%

$ 16,936

0

$0

0

$0

4



Assistant Airport Manager

MM

$ 86,736

$ 103,890

-19.8%

$ 92,359

$ 92,359

-6.5%

$ 5,623

2

$11,245

2

$11,245

9



Assistant APC Engineer*

PR

$ 88,421

$ 97,854

-10.7%

$ 95,452

$ 95,452

-8.0%

$ 7,031

0

$0

11

$77,342

6



Assistant Child Support Officer

PS

$47,216

$ 57,962

-22.8%

$ 56,320

$ 56,320

-19.3%

$ 9,104

0

$0

8

$72,831

12



Assistant Division Chief, Assessor/Recorder/County Clerk

MM

$ 83,200

$ 125,520

-50.9%

$ 124,675

$ 124,675

-49.9%

$ 41,475

8

$331,802

8

$331,802

4



Assistant Engineer

PR

$ 92,893

$ 94,456

-1.7%

$ 89,247

$ 89,247

3.9%

$ -3,645

0

$0

43

$0

13



Assistant Health Physicist

PR

$ 94,037







$ 97,851

^.1%

$ 3,814

0

$0

0

$0

0

Internal Alignment: Anchor to Industrial Hygienist II

Assistant Manager, Sheriff's Food Services

MM

$ 96,013

$ 93,746

2.4%

$ 92,475

$ 92,475

3.7%

$ -3,538

2

$0

2

$0

9



Assistant Meteorologist

PR

$ 85,259

$ 109,499

-28.4%

$ 98,270

$ 91,394

-7.2%

$ 6,135

0

$0

0

$0

2

Internal Alignment: 20% above Hydrographic Instrument Technician

Assistant Procurement Specialist

AE

$ 60,237

$ 66,649

-10.6%

$ 62,547

$ 62,547

-3.8%

$ 2,310

0

$0

4

$9,241

11



Page 1 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of

oiassmcauon

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

euageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Assistant Real Property Agent

PR

$ 67,226

$ 79,834

-18.8%

$ 74,838

$ 74,838

-11.3%

$ 7,612

0

$0

0

$0

8



Assistant Surveyor

PR

$ 92,893

$ 110,847

-19.3%

$ 103,137

$ 103,137

-11.0%

$ 10,244

3

$30,731

3

$30,731

6



Assistant Transportation Specialist

PR

$ 91,832

$ 82,326

10.4%

$ 79,256

$ 79,256

13.7%

$ -12,576

0

$0

0

$0

5



Assistant Weapons Coordinator

PS

$ 71,573

$ 73,403

-2.6%

$ 71,935

$ 76,162

-6.4%

$ 4,589

3

$13,768

2

$9,178

3

Internal Alignment: Anchor to Hydrographic Instrument Technician

Associate Accountant

AE

$ 74,110

$ 82,085

-10.8%

$ 74,269

$ 74,269

-0.2%

$ 158

95

$15,025

59

$9,331

13



Associate Air Pollution Chemist*

PR

$ 97,344

$ 107,258

-10.2%

$ 96,091

$ 116,467

-19.6%

$ 19,123

16

$305,972

15

$286,849

2

Internal Alignment: 15% above Assistant Air Pollution Chemist

Associate Air Pollution Control Engineer*

PR

$ 102,627

$ 106,827

-4.1%

$ 105,045

$ 105,045

-2.4%

$ 2,418

20

$48,353

6

$14,506

6



Associate Air Resources Specialist*

PR

$ 88,462

$ 113,723

-28.6%

$ 102,560

$ 102,560

-15.9%

$ 14,098

4

$56,391

4

$56,391

4



Associate Health Physicist

PR

$ 110,157

$ 103,240

6.3%

$ 99,317

$ 107,636

2.3%

$ -2,521

3

$0

2

$0

1

Internal Alignment: 10% above Assistant Health Physicist

Associate Meteorologist

PR

$ 98,779

$ 115,231

-16.7%

$ 103,004

$ 100,533

-1.8%

$ 1,754

4

$7,015

3

$5,261

2

Internal Alignment: 10% above Assistant Meteorologist

Associate Real Property Agent

PR

$ 83,242

$ 95,964

-15.3%

$ 91,893

$ 91,893

-10.4%

$ 8,651

2

$17,302

3

$25,953

11



Associate Transportation Specialist

PR

$ 108,472

$ 107,305

1.1%

$ 92,092

$ 92,092

15.1%

$ -16,380

1

$0

0

$0

9



Audit-Appraiser I

AE

$ 72,093

$ 69,306

3.9%

$ 67,512

$ 67,512

6.4%

$ -4,581

0

$0

0

$0

11



Audit-Appraiser II

AE

$ 82,368

$ 86,211

-4.7%

$ 80,706

$ 80,706

2.0%

$ -1,662

7

$0

6

$0

12



Audit-Appraiser III

AE

$ 93,080

$ 92,373

0.8%

$ 88,711

$ 88,711

4.7%

$ -4,369

9

$0

8

$0

11



Audit-Appraiser IV

AE

$ 102,378

$ 100,485

1.8%

$ 95,416

$ 95,416

6.8%

$ -6,962

3

$0

3

$0

7



Biostatistician

PR

$ 87,942

$ 86,681

1.4%

$ 77,198

$ 77,198

12.2%

$ -10,744

0

$0

0

$0

4



Broadcast Engineer

PS

$ 95,160

$ 98,482

-3.5%

$ 98,422

$ 98,422

-3.4%

$ 3,262

1

$3,262

1

$3,262

6



Building Maintenance Supervisor

MM

$ 85,259

$ 100,027

-17.3%

$ 98,027

$ 98,027

-15.0%

$ 12,767

15

$191,512

14

$178,745

13



Building/Enforcement Supervisor

MM

$ 97,490

$ 114,134

-17.1%

$ 108,055

$ 108,055

-10.8%

$ 10,566

3

$31,697

3

$31,697

10



Cadastral Supervisor

MM

$ 93,163

$ 93,077

0.1%

$ 85,453

$ 85,453

8.3%

$ -7,710

1

$0

1

$0

11



Cadastral Technician

AE

$ 64,563

$ 72,329

-12.0%

$ 67,012

$ 67,012

-3.8%

$ 2,448

6

$14,691

7

$17,139

12



Cashier

CL

$45,032

$ 56,278

-25.0%

$ 50,306

$ 50,306

-11.7%

$ 5,274

11

$58,014

10

$52,740

4



Certified Nurse Assistant

HS

$ 43,430

$ 47,545

-9.5%

$ 43,089

$ 43,089

0.8%

$ -341

184

$0

169

$0

7



Certified Nurse Practitioner

RN

$ 115,253

$ 138,611

-20.3%

$ 135,839

$ 135,839

-17.9%

$ 20,586

9

$185,275

4

$82,345

13



Chaplain-Coordinator

PR

$ 63,003

$ 92,191

-46.3%

$ 79,990

$ 79,990

-27.0%

$ 16,987

0

$0

0

$0

4



Child Support Officer

PS

$ 66,227

$ 66,072

0.2%

$ 63,517

$ 63,517

4.1%

$ -2,711

218

$0

180

$0

13



Civil Engineer

PR

$ 111,675

$ 126,589

-13.4%

$ 120,327

$ 120,327

-7.7%

$ 8,651

91

$787,272

32

$276,843

13



Clinical Psychologist

PR

$ 86,486

$ 110,408

-27.7%

$ 106,351

$ 106,351

-23.0%

$ 19,864

1

$19,864

3

$59,593

12



Code Enforcement Officer

PS

$ 73,694

$ 84,049

-14.1%

$ 80,527

$ 80,527

-9.3%

$ 6,833

12

$81,992

10

$68,326

10



Communicable Disease Investigator

PS

$ 70,283

$ 71,585

-1.9%

$ 69,727

$ 69,727

0.8%

$ -556

26

$0

21

$0

12



Community Health Program Specialist

PR

$ 89,315

$ 102,832

-15.1%

$ 92,583

$ 92,583

-3.7%

$ 3,268

33

$107,852

26

$84,974

10



Community Health Promotion Assistant

PR

$ 55,952

$ 59,718

-6.7%

$ 59,340

$ 59,340

-6.1%

$ 3,388

0

$0

0

$0

10



Community Health Promotion Specialist I

PR

$ 68,037

$ 69,405

-2.0%

$ 69,779

$ 69,779

-2.6%

$ 1,742

3

$5,227

6

$10,453

8



Community Health Promotion Specialist II

PR

$ 76,253

$ 85,752

-12.5%

$ 82,401

$ 82,401

-8.1%

$ 6,148

30

$184,453

18

$110,672

12



Community Services Officer

PS

$ 47,382

$ 66,455

-40.3%

$ 56,790

$ 56,790

-19.9%

$ 9,408

59

$555,043

50

$470,375

11



Construction Technician (T)

PS

$ 109,678

$ 106,073

3.3%

$ 94,299

$ 94,299

14.0%

$ -15,380

1

$0

2

$0

5



Cook

FS

$ 42,578

$ 55,826

-31.1%

$ 50,363

$ 50,363

-18.3%

$ 7,786

8

$62,286

15

$116,786

12



Coordinator, Volunteer & Public Services

PS

$ 84,240

$ 81,866

2.8%

$ 75,300

$ 75,300

10.6%

$ -8,940

10

$0

8

$0

6



Coordinator, Volunteer Services

PS

$ 61,714

$ 57,704

6.5%

$ 59,445

$ 59,445

3.7%

$ -2,269

2

$0

3

$0

6



Correctional Counselor

PR

$ 83,200

$ 89,230

-7.2%

$ 85,895

$ 72,018

13.4%

$ -11,182

43

$0

31

$0

3

Internal Alignment: 20% below Supervising Correctional Counselor

Crime Prevention Specialist

PS

$ 51,979

$ 66,455

-27.8%

$ 58,196

$ 58,196

-12.0%

$ 6,217

21

$130,560

19

$118,126

5



Criminal Legal Secretary I

CL

$ 60,694

$ 58,322

3.9%

$ 54,694

$ 54,694

9.9%

$ -6,000

0

$0

10

$0

8



Criminal Legal Secretary II

CL

$ 64,854

$ 66,774

-3.0%

$ 64,650

$ 64,650

0.3%

$ -204

45

$0

34

$0

12



Criminal Legal Secretary III

MM

$ 69,306

$ 70,325

-1.5%

$ 68,918

$ 68,918

0.6%

$ -387

6

$0

7

$0

9



Page 2 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of

oiassmcation

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

euageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Criminalist I

PR

$ 102,274

$ 99,403

2.8%

$ 87,904

$ 87,904

14.0%

$ -14,369

0

$0

2

$0

11



Criminalist II

PR

$ 120,765

$ 113,268

6.2%

$ 105,729

$ 105,729

12.5%

$ -15,036

26

$0

25

$0

12



Criminalist III

PR

$ 127,837

$ 127,712

0.1%

$ 117,672

$ 117,672

8.0%

$ -10,164

11

$0

9

$0

11



Departmental Clerk

CL

$ 35,589

$ 41,439

-16.4%

$ 40,788

$ 40,788

-14.6%

$ 5,200

0

$0

0

$0

11



Departmental Payroll Technician

CL

$ 46,987

$ 63,603

-35.4%

$ 60,110

$ 60,110

-27.9%

$ 13,123

0

$0

1

$13,123

7



Deputy Medical Examiner I

PR

$ 185,661

$ 279,411

-50.5%

$ 260,501

$ 257,895

-38.9%

$ 72,234

0

$0

0

$0

2

internal Alignment: 10% below Deputy Medical Examiner II

Deputy Medical Examiner II

PR

$ 238,514

$ 314,181

-31.7%

$ 286,550

$ 286,550

-20.1%

$ 48,037

6

$288,220

5

$240,183

4



Deputy Public Admin-Guardian

PS

$ 67,538

$ 75,570

-11.9%

$ 72,775

$ 72,775

-7.8%

$ 5,237

15

$78,562

15

$78,562

12



Deputy Sheriff Cadet-Detentions/Court Services

PS

$ 45,074

$ 69,966

-55.2%

$ 67,886

$ 67,886

-50.6%

$ 22,813

0

$0

45

$1,026,573

4



Deputy Sheriff's Cadet

PS

$ 56,867

$ 73,009

-28.4%

$ 71,378

$ 71,378

-25.5%

$ 14,511

0

$0

58

$841,616

12



Detentions Information Assistant

CL

$ 47,403

$ 64,110

-35.2%

$ 56,905

$ 56,905

-20.0%

$ 9,501

70

$665,104

53

$503,579

4



Detentions Processing Supervisor

MM

$ 61,381

$ 72,449

-18.0%

$ 67,822

$ 69,463

-13.2%

$ 8,082

29

$234,383

28

$226,300

2

Internal Alignment: 15% above Detentions Processing Technician

Detentions Processing Technician

CL

$ 52,728

$ 66,088

-25.3%

$ 60,403

$ 60,403

-14.6%

$ 7,675

171

$1,312,456

147

$1,128,252

6



Dietitian

PR

$ 59,010

$ 77,958

-32.1%

$ 76,727

$ 76,727

-30.0%

$ 17,717

2

$35,434

1

$17,717

9



Disease Research Scientist

PR

$ 77,792

$ 103,793

-33.4%

$ 100,774

$ 100,774

-29.5%

$ 22,982

1

$22,982

1

$22,982

4



DraftingTechnician

PS

$ 61,568

$ 72,329

-17.5%

$ 71,304

$ 71,304

-15.8%

$ 9,736

0

$0

0

$0

10



Election Processing Supervisor

MM

$ 72,821

$ 77,122

-5.9%

$ 70,178

$ 70,178

3.6%

$ -2,643

8

$0

8

$0

10



Electronic Instrument Technician I

PS

$ 70,304

$ 82,609

-17.5%

$ 78,109

$ 78,109

-11.1%

$ 7,805

0

$0

2

$15,611

4



Electronic Instrument Technician II

PS

$ 77,584

$ 96,643

-24.6%

$ 85,854

$ 85,854

-10.7%

$ 8,270

12

$99,235

7

$57,887

7



Emergency Medical Services Specialist

PR

$ 89,752

$ 86,334

3.8%

$ 87,974

$ 87,974

2.0%

$ -1,778

6

$0

2

$0

9



Emergency Services Coordinator

MM

$ 88,192

$ 96,399

-9.3%

$ 92,092

$ 92,092

-4.4%

$ 3,900

5

$19,502

3

$11,701

9



Engineering Technician I

PS

$ 65,790

$ 73,747

-12.1%

$ 66,459

$ 66,459

-1.0%

$ 669

0

$0

2

$1,338

11



Engineering Technician II

PS

$ 74,318

$ 79,128

-6.5%

$ 73,546

$ 73,546

1.0%

$-772

9

$0

9

$0

12



Engineering Technician III

PS

$ 84,614

$ 88,164

-4.2%

$ 85,524

$ 85,524

-1.1%

$ 909

19

$17,280

16

$14,552

12



Environmental Health Specialist I

PR

$ 75,546

$ 73,829

2.3%

$ 71,203

$ 71,203

5.7%

$ -4,343

0

$0

18

$0

8



Environmental Health Specialist II

PR

$ 82,909

$ 88,235

-6.4%

$ 88,421

$ 88,421

-6.6%

$ 5,512

105

$578,796

61

$336,253

13



Environmental Health Specialist III

PR

$ 91,208

$ 98,026

-7.5%

$ 97,340

$ 97,340

-6.7%

$ 6,132

44

$269,812

32

$196,227

13



Environmental Health Specialist Trainee

PR

$ 66,144

$ 67,839

-2.6%

$ 67,907

$ 67,907

-2.7%

$ 1,763

0

$0

14

$24,680

9



Environmental Health Technician

PS

$48,152

$ 67,402

-40.0%

$ 62,032

$ 62,032

-28.8%

$ 13,880

22

$305,368

18

$249,846

11



Epidemiologist I

PR

$ 94,557

$ 98,773

-4.5%

$ 83,132

$ 83,132

12.1%

$ -11,425

3

$0

10

$0

5



Epidemiologist II

PR

$ 104,062

$ 109,054

-4.8%

$ 96,622

$ 96,622

7.1%

$ -7,440

44

$0

29

$0

9



Estate Assistant

PS

$ 50,648

$ 56,597

-11.7%

$ 55,465

$ 52,408

-3.5%

$ 1,760

3

$5,280

3

$5,280

3

Internal Alignment: Anchor to Office Support Specialist

Estate Property Manager

MM

$ 76,003

$ 79,260

-4.3%

$ 79,339

$ 79,339

-4.4%

$ 3,336

1

$3,336

1

$3,336

5



Executive Housekeeper

MM

$ 56,472

$ 43,413

23.1%

$ 44,238

$ 44,238

21.7%

$ -12,234

2

$0

2

$0

3

Above Market N/A

Facility Services Contract Specialist

PS

$ 66,456

$ 59,139

11.0%

$ 58,725

$ 58,725

11.6%

$ -7,731

3

$0

4

$0

3

Above Market N/A

Fleet Parts Specialist

AE

$ 53,810

$ 61,013

-13.4%

$ 57,698

$ 57,698

-7.2%

$ 3,889

3

$11,667

3

$11,667

12



Fleet Standards Technician

AE

$ 64,251

$ 76,939

-19.7%

$ 68,168

$ 66,353

-3.3%

$ 2,102

4

$8,407

4

$8,407

3

Internal Alignment: 15% above Fleet Parts Specialist

Fleet Support Specialist

PR

$ 81,474

$ 119,103

-46.2%

$ 99,094

$ 82,941

-1.8%

$ 1,467

1

$1,467

1

$1,467

1

Internal Alignment: 25% above Fleet Standards Tech

Food Services Supervisor

MM

$ 55,723

$ 61,124

-9.7%

$ 59,813

$ 59,813

-7.3%

$ 4,089

14

$57,253

14

$57,253

10



Food Services Worker

FS

$ 34,050

$ 39,334

-15.5%

$ 39,121

$ 39,121

-14.9%

$ 5,071

55

$278,912

50

$253,556

12



Forensic Autopsy Room Supervisor

MM

$ 91,582

$ 78,772

14.0%

$ 77,900

$ 77,900

14.9%

$ -13,682

1

$0

1

$0

4



Forensic Autopsy Specialist

PS

$ 66,269

$ 63,554

4.1%

$ 60,100

$ 60,100

9.3%

$ -6,169

7

$0

6

$0

10



Forensic Documents Examiner

PR

$ 119,330

$ 122,993

-3.1%

$ 112,409

$ 112,409

5.8%

$ -6,920

1

$0

1

$0

4



Forensic Evidence Technician

PS

$ 78,686

$ 78,170

0.7%

$ 73,537

$ 73,537

6.5%

$ -5,149

8

$0

8

$0

6



Geographic Information Systems Analyst

PR

$ 77,230

$ 103,627

-34.2%

$ 98,907

$ 98,907

-28.1%

$ 21,677

14

$303,477

6

$130,062

9



Page 3 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021

Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



||













Geographic Information Systems Technician

PS

$ 57,096

$ 69,929

-22.5%

$ 69,280

$ 69,280

-21.3%

$ 12,184

0

$0

4

$48,738

9



Graphic Artist

PS

$ 64,064

$ 65,936

-2.9%

$ 64,617

$ 64,617

-0.9%

$553

2

$1,107

2

$1,107

9



Graphic Design Specialist

PS

$ 81,973

$ 74,197

9.5%

$ 69,300

$ 69,300

15.5%

$ -12,673

1

$0

1

$0

9



Groundwater Geologist

PR

$ 120,037

$ 108,135

9.9%

$ 106,673

$ 106,673

11.1%

$ -13,364

0

$0

0

$0

6



Health Information Management Clerk

CL

$ 43,098

$ 59,374

-37.8%

$ 52,606



-16.4%

$ 7,082

4

$28,327

6

$42,491

3

Internal Alignment: 10% below Health Information Management Technician

Health Information Management Technician

HS

$ 47,403

$ 62,716

-32.3%

$ 55,755

$ 55,755

-17.6%

$ 8,352

44

$367,474

33

$275,605

5



Health Information Specialist I

PR

$ 67,226

$ 65,936

1.9%

$ 64,617

$ 64,617

3.9%

$ -2,608

2

$0

2

$0

5



Health Information Specialist II

PR

$ 76,253

$ 75,691

0.7%

$ 74,177

$ 74,177

2.7%

$ -2,075

12

$0

7

$0

9



Health Services Social Worker

SW

$ 74,922

$ 90,654

-21.0%

$ 85,062

$ 85,062

-13.5%

$ 10,140

3

$30,420

3

$30,420

10





AE

$ 81,557

$ 80,179



$ 80,259

$ 80,259



$ -1,298

9

$0

8

$0

5



Histology Technician

HS

$ 60,882

$ 72,750

-19.5%

$ 69,985

$ 69,985

-15.0%

$ 9,103

0

$0

0

$0

7



Historian

PR

$ 91,416

$ 98,795

-8.1%

$ 100,672

$ 100,672

-10.1%

$ 9,256

0

$0

0

$0

3

No alignment found

Housing Aide*

PS

$ 45,490

$ 56,273

-23.7%

$ 54,413

$ 54,413

-19.6%

$ 8,923

6

$53,539

6

$53,539

6



Housing Program Analyst I*

PR

$ 80,933

$ 69,306

14.4%

$ 70,622

$ 70,622

12.7%

$ -10,310

2

$0

5

$0

7



Housing Program Analyst II*

PR

$ 89,315

$ 86,525

3.1%

$ 86,612

$ 86,612

3.0%

$ -2,704

6

$0

4

$0

9



Housing Program Analyst III*

PR

$ 95,722

$ 106,941

-11.7%

$ 101,010

$ 101,010

-5.5%

$ 5,288

5

$26,442

2

$10,577

8



Housing Program Analyst IV*

PR

$ 104,312

$ 127,485

-22.2%

$ 115,811

$ 115,811

-11.0%

$ 11,499

4

$45,994

3

$34,496

7



Housing Specialist I*

PS

$ 56,410

$ 55,896

0.9%

$ 54,387

$ 54,387

3.6%

$ -2,023

4

$0

0

$0

7



Housing Specialist II*

PS

$ 66,747

$ 62,555

6.3%

$ 60,902

$ 60,902

8.8%

$ -5,845

43

$0

49

$0

10



Housing Specialist III*

PS

$ 77,106

$ 84,450

-9.5%

$ 85,561

$ 85,561

-11.0%

$ 8,455

6

$50,732

7

$59,187

10



Human Services Control Specialist

SW

$ 60,424

$ 88,051

-45.7%

$ 78,083

$ 78,083

-29.2%

$ 17,659

32

$565,083

29

$512,106

7



Human Services Specialist

SW

$ 57,491

$ 58,857

-2.4%

$ 58,235

$ 58,235

-1.3%

$ 744

1736

$1,291,538

1656

$1,232,020

12



Hydrogeologist

PR

$ 109,470

$ 124,169

-13.4%

$ 110,902

$ 96,006

12.3%

$ -13,464

0

$0

1

$0

2

Internal Alignment: 10% below Senior Hydrogeologist

Hydrographic Instrument Technician

PS

$ 77,376







$ 76,162

1.6%

$ -1,214

2

$0

1

$0

0

Internal Alignment: 10% below Junior Surveyor

ImagingTechnician I

CL

$47,320

$ 46,295

2.2%

$ 44,633

$ 44,633

5.7%

$ -2,687

0

$0

1

$0

4



ImagingTechnician II

CL

$ 52,936

$ 50,482

4.6%

$ 48,699

$ 48,699

8.0%

$ -4,237

10

$0

10

$0

5



ImagingTechnician III

MM

$ 60,611

$ 67,836

-11.9%

$ 61,429

$ 56,004

7.6%

$ -4,607

3

$0

2

$0

2

Internal Alignment: 15%above ImagingTechnician II

Industrial Hygienist I

PR

$ 87,422

$ 66,029

24.5%

$ 68,118

$ 88,066

-0.7%

$ 644

0

$0

1

$644

4

Internal Alignment: 10% below Industrial Hygienist II

Industrial Hygienist II

PR

$ 97,074

$ 101,716

-4.8%

$ 97,851

$ 97,851

-0.8%

$777

4

$3,110

3

$2,332

9





PR

$ 101,920

$ 92,488



$ 94,245



-5.6%

$ 5,716

1

$5,716

0

$0

5

Internal Alignment: 10% above Industrial Hygienist II

Insect Detection Specialist I

PS

$ 39,374

$ 42,307

-7.4%

$42,011

$42,011

-6.7%

$ 2,637

0

$0

0

$0

5



Insect Detection Specialist II

PS

$ 46,509

$ 60,876

-30.9%

$ 58,645

$ 58,645

-26.1%

$ 12,136

37

$449,032

31

$376,216

7



Inservice Education Coordinator

RN

$ 105,685

$ 148,207

-40.2%

$ 142,576

$ 134,886

-27.6%

$ 29,201

4

$116,805

3

$87,603

3

Internal Alignment: 5% above Public Health Nurse Supervisor

International Case Coordinator

PS

$ 115,024







$ 101,516

11.7%

$ -13,508

1

$0

1

$0

0

Internal Alignment: Anchor to Public Defender Investigator II

Investigative Specialist

PS

$49,712

$ 53,899

-8.4%

$ 53,521

$ 53,521

-7.7%

$ 3,809

13

$49,522

11

$41,903

7



Investigative Technician

PS

$ 79,622

$ 78,355

1.6%

$ 77,551

$ 77,551

2.6%

$ -2,071

0

$0

0

$0

4



Jr Air Pollution Chemist*

PR

$ 75,670







$ 88,066

-16.4%

$ 12,396

0

$0

0

$0

0

Internal Alignment: Anchor to Industrial Hygienist 1

Jr Air Pollution Control Engineer*

PR

$ 76,419

$ 92,232

-20.7%

$ 89,650

$ 85,907

-12.4%

$ 9,488

0

$0

1

$9,488

1

Internal Alignment: 10% below Assistant Air Pollution Control Engineer

Jr Land Use/Environmental Planner*

PR

$ 66,352

$ 74,194

-11.8%

$ 68,990

$ 68,990

-4.0%

$ 2,638

1

$2,638

7

$18,469

5



Jr Public Health Microbiologist

PR

$ 62,858

$ 69,950

-11.3%

$ 71,279

$ 71,279

-13.4%

$ 8,422

3

$25,266

3

$25,266

11



JrReal Property Agent

PR

$ 52,042

$ 65,354

-25.6%

$ 64,046

$ 64,046

-23.1%

$ 12,005

0

$0

0

$0

9



Jr Surveyor (T)

PR

$ 80,454

$ 94,451

-17.4%

$ 84,624

$ 84,624

-5.2%

$4,170

0

$0

3

$12,509

5



Laboratory Assistant

HS

$ 43,784

$ 53,539

-22.3%

$ 48,960

$ 48,960

-11.8%

$ 5,176

11

$56,934

6

$31,055

11



Land Surveyor

PR

$ 109,470

$ 124,591

-13.8%

$ 110,936

$ 110,936

-1.3%

$ 1,465

12

$17,584

5

$7,327

7



Land Use Aide

PS

$ 48,485

$46,145



$46,191



-2.6%

$ 1,277

2

$2,554

5

$6,386

3

Internal Alignment: 15% below Land Use Technician 1

Page 4 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



uiassiticanon

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

Buageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Land Use Technician I

PS

$ 56,014

$ 61,258

-9.4%

$ 58,543

$ 58,543

-4.5%

$ 2,528

2

$5,057

7

$17,699

7



Land Use Technician II

PS

$ 74,194

$ 72,170

2.7%

$ 67,484

$ 67,484

9.0%

$ -6,709

9

$0

4

$0

8



Land Use Technician III

PS

$ 81,869

$ 86,220

-5.3%

$ 85,048

$ 85,048

-3.9%

$ 3,179

10

$31,794

6

$19,076

6



Land Use/Environmental Planner I

PR

$ 79,622

$ 82,763

-3.9%

$ 81,108

$ 81,108

-1.9%

$ 1,485

8

$11,884

12

$17,826

9



Land Use/Environmental Planner II

PR

$ 93,850

$ 100,865

-7.5%

$ 91,869

$ 91,869

2.1%

$ -1,981

46

$0

39

$0

12



Land Use/Environmental Planner III

PR

$ 107,619

$ 114,587

-6.5%

$ 109,357

$ 109,357

-1.6%

$ 1,737

49

$85,126

43

$74,702

11



Landscape Architect

PR

$ 96,429

$ 124,591

-29.2%

$ 120,441

$ 120,441

-24.9%

$ 24,012

1

$24,012

1

$24,012

3

No alignment found

Latent Print Examiner

PS

$ 95,430

$ 87,078

8.8%

$ 88,311

$ 88,311

7.5%

$ -7,119

6

$0

6

$0

6



Laundry Supervisor

MM

$ 54,891

$ 54,532

0.7%

$ 54,150

$ 54,521

0.7%

$ -370

1

$0

1

$0

3

Internal Alignment: 20% above Senior Laundry Worker

Laundry Worker

FS

$42,432

$ 38,177

10.0%

$ 38,167

$ 38,167

10.1%

$ -4,265

23

$0

22

$0

10



Legal Support Assistant I

CL

$43,160

$ 54,757

-26.9%

$ 54,340

$ 54,340

-25.9%

$ 11,180

10

$111,798

55

$614,889

8



Legal Support Assistant II

CL

$48,714

$ 64,813

-33.0%

$ 57,835

$ 57,835

-18.7%

$ 9,122

232

$2,116,246

148

$1,350,019

11



Legal Support Assistant III

CL

$ 55,037

$ 68,024

-23.6%

$ 66,053

$ 66,053

-20.0%

$ 11,016

69

$760,118

52

$572,842

10



Legal Support Supervisor I

MM

$ 65,166

$ 68,528

-5.2%

$ 68,597

$ 68,597

-5.3%

$ 3,430

37

$126,918

33

$113,197

5



Legal Support Supervisor II

MM

$ 69,306

$ 76,427

-10.3%

$ 73,523

$ 73,523

-6.1%

$4,217

31

$130,732

24

$101,212

5



Librarian I

PR

$ 71,365

$ 80,451

-12.7%

$ 70,258

$ 70,258

1.6%

$ -1,107

43

$0

40

$0

10



Librarian II

PR

$ 78,853

$ 87,160

-10.5%

$ 78,453

$ 78,453

0.5%

$ -400

29

$0

25

$0

11



Librarian III

PR

$ 86,819

$ 99,501

-14.6%

$ 91,796

$ 91,796

-5.7%

$ 4,977

17

$84,607

17

$84,607

10



Librarian Substitute

PR

$ 70,574

$ 67,236

4.7%

$ 59,571

$ 66,745

5.4%

$ -3,829

0

$0

0

$0

1

Internal Alignment: 5% below Librarian 1

Library Associate

PR

$ 68,307

$ 77,304

-13.2%

$ 68,609

$ 70,588

-3.3%

$ 2,281

6

$13,685

3

$6,842

2

Internal Alignment: 5% above Library Technician IV

Library Technician I

PS

$ 38,334

$ 50,697

-32.2%

$ 45,925

$ 45,925

-19.8%

$ 7,591

71

$538,946

69

$523,765

7



Library Technician II

PS

$ 47,341

$ 54,704

-15.6%

$ 53,373

$ 53,373

-12.7%

$ 6,032

54

$325,723

46

$277,468

7



Library Technician III

PS

$ 54,642

$ 61,545

-12.6%

$ 61,115

$ 61,115

-11.8%

$ 6,473

35

$226,556

37

$239,502

5



Library Technician IV

PS

$ 63,544

$ 66,237

-4.2%

$ 63,720

$ 67,227

-5.8%

$ 3,683

16

$58,929

14

$51,563

3

Internal Alignment: 10% above Library Technician III

Library Technician Substitute

PS

$ 32,198

$ 50,486

-56.8%

$ 44,730

$ 43,629

-35.5%

$ 11,431

0

$0

0

$0

1

Internal Alignment: 5% below Library Technician 1

Licensed Mental Health Clinician

PR

$ 94,702

$ 90,924

4.0%

$ 90,602

$ 90,602

4.3%

$ -4,101

65

$0

51

$0

11



Licensed Vocational Nurse

HS

$ 52,603

$ 60,912

-15.8%

$ 58,801

$ 58,801

-11.8%

$ 6,198

32

$198,335

38

$235,523

13



Litigation Investigator

PS

$ 97,386

$ 123,974

-27.3%

$ 110,363

$ 110,363

-13.3%

$ 12,977

0

$0

0

$0

4



Mail Carrier

PS

$ 41,454

$ 46,693

-12.6%

$44,919

$44,919

-8.4%

$ 3,464

15

$51,967

15

$51,967

9



Mail Processor

PS

$ 39,437

$ 45,706

-15.9%

$45,981

$45,981

-16.6%

$ 6,545

0

$0

0

$0

6



Mail Systems Supervisor

MM

$ 60,944

$ 71,386

-17.1%

$ 61,039

$ 61,039

-0.2%

$95

1

$95

1

$95

5



Medical Claims Specialist

CL

$49,816

$ 66,360

-33.2%

$ 60,309

$ 60,309

-21.1%

$ 10,493

14

$146,898

14

$146,898

8



Medical Consultant

PR

$ 194,210

$ 187,141

3.6%

$ 184,323

$ 198,011

-2.0%

$ 3,801

5

$19,007

3

$11,404

2

Internal Alignment: 25% below Psychiatrist

Medical Examiner Invest I

PS

$ 63,731

$ 86,231

-35.3%

$ 81,109

$ 81,109

-27.3%

$ 17,378

0

$0

3

$52,133

7



Medical Examiner Invest II

PS

$ 77,501

$ 95,781

-23.6%

$ 92,847

$ 92,847

-19.8%

$ 15,346

16

$245,532

11

$168,804

10



Medical Examiner Invest III

MM

$ 85,862

$ 115,078

-34.0%

$ 108,598

$ 108,598

-26.5%

$ 22,735

3

$68,205

3

$68,205

4



Medical Transcriber

CL

$ 50,814

$ 58,977

-16.1%

$ 54,828

$ 54,828

-7.9%

$ 4,013

1

$4,013

1

$4,013

10



Mental Health Aide

HS

$ 43,597

$ 52,016

-19.3%

$ 50,039

$ 51,567

-18.3%

$ 7,970

20

$159,403

15

$119,552

3

Internal Alignment: 10% below Mental Health Specialist

Mental Health Case Management Assistant

HS

$ 44,990

$ 53,617

-19.2%

$ 53,345

$ 53,345

-18.6%

$ 8,354

8

$66,836

7

$58,481

8



Mental Health Case Management Clinician

PR

$ 72,654

$ 82,996

-14.2%

$ 79,401

$ 79,401

-9.3%

$ 6,746

31

$209,139

25

$168,660

6



Mental Health Conservatorship Clinician

PR

$ 91,229

$ 107,501

-17.8%

$ 95,511

$ 90,602

0.7%

$ -627

10

$0

10

$0

2

Internal Alignment: Anchor to Licensed Mental Health Clinician

Mental Health Specialist

HS

$ 52,770

$ 63,440

-20.2%

$ 57,297

$ 57,297

-8.6%

$ 4,528

7

$31,694

6

$27,166

9



Multimedia Designer

PR

$ 80,933

$ 75,442

6.8%

$ 73,132

$ 73,132

9.6%

$ -7,801

8

$0

8

$0

7



Nutritionist

PR

$ 67,891

$ 79,221

-16.7%

$ 76,912

$ 76,912

-13.3%

$ 9,021

3

$27,062

4

$36,083

12



Occupational/Physical Therapist

PR

$ 96,075

$ 105,352

-9.7%

$ 99,372

$ 99,372

-3.4%

$ 3,296

31

$102,189

32

$105,485

13



Page 5 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of

uiassiticanon

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

Buageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Occupational/Physical Therapist Assistant

HS

$ 63,066

$ 79,025

-25.3%

$ 74,046

$ 74,046

-17.4%

$ 10,980

0

$0

1

$10,980

12



Office Assistant

CL

$41,829

$ 45,622

-9.1%

$ 45,022

$ 45,022

-7.6%

$ 3,193

765

$2,442,462

788

$2,515,896

13



Office Support Specialist

CL

$ 48,422

$ 52,963

-9.4%

$ 52,408

$ 52,408

-8.2%

$ 3,986

112

$446,382

97

$386,599

12



Paralegal I

PS

$ 59,010

$ 63,177

-7.1%

$ 64,377

$ 64,377

-9.1%

$ 5,368

0

$0

21

$112,720

9



Paralegal II

PS

$ 79,082

$ 75,338

4.7%

$ 73,831

$ 73,831

6.6%

$ -5,251

158

$0

131

$0

11



Paralegal Supervisor

MM

$ 87,464

$ 111,730

-27.7%

$ 99,442

$ 88,597

-1.3%

$ 1,133

21

$23,792

13

$14,728

2

Internal Alignment: 20% above Paralegal II

Park Ranger

PS

$ 56,742

$ 61,183

-7.8%

$ 61,128

$ 61,128

-7.7%

$ 4,386

59

$258,757

49

$214,900

8



Parks Recreational Supervisor

MM

$ 68,411

$ 71,994

-5.2%

$ 72,066

$ 72,066

-5.3%

$ 3,655

8

$29,239

8

$29,239

5



Patient Services Specialist III (T)

SW

$ 65,229

$ 69,492

-6.5%

$ 65,623

$ 65,623

-0.6%

$ 394

1

$394

1

$394

6



Patient Services Specialist IV (T)

SS

$ 74,235

$ 90,371

-21.7%

$ 84,924

$ 84,924

-14.4%

$ 10,689

1

$10,689

1

$10,689

4



Payroll Clerk

CL

$ 44,054

$ 63,565

-44.3%

$ 58,733

$ 58,733

-33.3%

$ 14,678

8

$117,428

2

$29,357

4



Pediatrician

PR

$ 168,834

$ 228,680

-35.4%

$ 229,466

$ 229,466

-35.9%

$ 60,632

0

$0

0

$0

5



Permit Process Coordinator

MM

$ 89,045

$ 98,813

-11.0%

$ 88,580

$ 88,580

0.5%

$ -465

2

$0

2

$0

4



Pest Management Technician I

PS

$ 56,181

$ 45,230

19.5%

$ 44,600

$ 51,306

8.7%

$ -4,875

0

$0

1

$0

2

Internal Alignment: 10% below Pest ManagementTechnician II

Pest Management Technician II

PS

$ 61,755

$ 58,698

4.9%

$ 57,007

$ 57,007

7.7%

$ -4,749

7

$0

6

$0

6



Pharmacist

MM

$ 136,635

$ 161,356

-18.1%

$ 145,188

$ 145,188

-6.3%

$ 8,553

10

$85,531

10

$85,531

11



Pharmacy Stock Clerk

AE

$ 43,035

$ 50,703

-17.8%

$ 49,445

$ 49,445

-14.9%

$ 6,409

1

$6,409

0

$0

6



Pharmacy Storekeeper

MM

$ 48,693

$ 90,528

-85.9%

$ 74,776

$ 59,334

-21.9%

$ 10,641

0

$0

0

$0

1

Internal Alignment: 20% above Pharmacy Stock Clerk

Pharmacy Technician

HS

$ 55,557

$ 55,191

0.7%

$ 55,502

$ 55,502

0.1%

$-55

11

$0

10

$0

10



Photographic Audio-Visual Specialist

PS

$ 77,210

$ 75,296

2.5%

$ 73,132

$ 73,132

5.3%

$ -4,078

6

$0

5

$0

7



Physician Assistant

PR

$ 103,230

$ 129,612

-25.6%

$ 130,880

$ 130,880

-26.8%

$ 27,650

0

$0

0

$0

9



Precinct Planning Technician

PS

$ 51,688

$ 63,271

-22.4%

$ 62,828

$ 62,352

-20.6%

$ 10,664

1

$10,664

1

$10,664

3

Internal Alignment: 10% below GISTechnician

Principal Treasurer-Tax Collector Specialist

MM

$ 66,165

$ 93,186

-40.8%

$ 77,531

$ 77,531

-17.2%

$ 11,366

3

$34,098

2

$22,732

5



Probation Aide

PS

$ 54,288

$ 66,063

-21.7%

$ 58,730

$ 58,730

-8.2%

$ 4,442

22

$97,734

19

$84,406

7



Probation Operations Support Manager

MM

$ 83,533

$ 84,854

-1.6%

$ 79,520

$ 79,520

4.8%

$ -4,012

4

$0

4

$0

4



Process Server

PS

$ 47,382

$ 53,899

-13.8%

$ 53,521

$ 53,521

-13.0%

$ 6,139

1

$6,139

1

$6,139

5



Process Server Supervisor

MM

$ 54,246

$ 54,797

-1.0%

$ 56,011

$ 64,225

-18.4%

$ 9,979

1

$9,979

1

$9,979

2

Internal Alignment: 20% above Process Server

Procurement Contracting Officer

AE

$ 99,362

$ 99,385

-0.0%

$ 88,204

$ 88,204

11.2%

$ -11,157

19

$0

15

$0

10



Procurement Contracting Specialist

AE

$ 83,096

$ 89,463

-7.7%

$ 80,259

$ 80,259

3.4%

$ -2,837

2

$0

4

$0

11



Procurement Specialist

AE

$ 70,678

$ 74,078

-4.8%

$ 69,519

$ 69,519

1.6%

$ -1,159

9

$0

5

$0

8



Property Assessment Specialist I

AE

$ 51,501

$ 49,842

3.2%

$ 52,185

$ 52,657

-2.2%

$ 1,156

3

$3,469

15

$17,344

3

Internal Alignment: 10% below Property Assessment Specialist II

Property Assessment Specialist II

AE

$ 58,656

$ 60,253

-2.7%

$ 58,508

$ 58,508

0.3%

$ -148

51

$0

38

$0

8



Property Assessment Specialist III

AE

$ 70,450

$ 68,983

2.1%

$ 64,046

$ 64,046

9.1%

$ -6,403

11

$0

11

$0

5



Protective Services Assistant

SW

$ 45,968

$ 48,582

-5.7%

$ 48,837

$ 48,837

-6.2%

$ 2,869

1

$2,869

1

$2,869

6



Protective Services Supervisor

SS

$ 93,267

$ 100,913

-8.2%

$ 101,014

$ 101,014

-8.3%

$ 7,747

140

$1,084,540

129

$999,326

9



Protective Services Worker

SW

$ 75,379

$ 81,078

-7.6%

$ 75,909

$ 75,909

-0.7%

$ 529

631

$334,061

557

$294,884

11



Psychiatric Clinical Nurse Specialist

RN

$ 112,861

$ 153,059

-35.6%

$ 135,611

$ 135,611

-20.2%

$ 22,750

0

$0

0

$0

7



Psychiatric Nurse

RN

$ 98,384

$ 106,274

-8.0%

$ 106,856

$ 106,856

-8.6%

$ 8,472

109

$923,426

104

$881,067

12



Psychiatric Resident

PR

$ 185,058

$ 282,852

-52.8%

$ 248,970

$ 224,412

-21.3%

$ 39,354

0

$0

0

$0

3

Internal Alignment: 15% below Psychiatrist

Psychiatric Technician

HS

$ 52,707

$ 63,517

-20.5%

$ 62,851

$ 62,851

-19.2%

$ 10,144

0

$0

0

$0

11



Psychiatrist

PR

$ 219,794

$ 300,248

-36.6%

$ 264,014

$ 264,014

-20.1%

$ 44,220

5

$221,100

2

$88,440

7



Psychiatrist - Specialist

PR

$ 229,590

$ 323,461

-40.9%

$ 300,016

$ 300,016

-30.7%

$ 70,426

7

$492,982

5

$352,130

5



Public Assistance Investigator I

PS

$ 71,968

$ 88,816

-23.4%

$ 74,336

$ 79,660

-10.7%

$ 7,692

0

$0

8

$61,536

3

Internal Alignment: 10% below Public Assistance Investigator II

Public Assistance Investigator II

PS

$ 77,501

$ 95,754

-23.6%

$ 88,511

$ 88,511

-14.2%

$ 11,010

39

$429,403

19

$209,196

10



Public Assistance Investigator Supervisor

MM

$ 85,301

$ 109,803

-28.7%

$ 97,286

$ 97,286

-14.1%

$ 11,985

8

$95,879

8

$95,879

11



Page 6 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



oiassmcation

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

euageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Public Assistance Investigator Trainee

PS

$ 64,043

$ 67,719

-5.7%

$ 67,740

$ 71,694

-11.9%

$ 7,651

0

$0

3

$22,953

3

Internal Alignment: 10% below Public Assistance Investigator 1

Public Defender Investigator I

PS

$ 79,602

$ 93,864

-17.9%

$ 93,207

$ 93,207

-17.1%

$ 13,606

0

$0

16

$217,693

9



Public Defender Investigator II

PS

$ 85,675

$ 113,152

-32.1%

$ 101,516

$ 101,516

-18.5%

$ 15,841

35

$554,445

34

$538,603

11



Public Defender Investigator III

PS

$ 94,598

$ 122,960

-30.0%

$ 120,286

$ 120,286

-27.2%

$ 25,688

35

$899,065

12

$308,251

9



Public Defender Investigator Tr

PS

$ 62,504

$ 60,785

2.7%

$ 60,631

$ 60,631

3.0%

$ -1,874

0

$0

5

$0

6



Public Health Microbiologist

PR

$ 85,717

$ 92,292

-7.7%

$ 89,319

$ 89,319

-4.2%

$ 3,602

13

$46,831

5

$18,012

13



Public Health Nurse

RN

$ 94,682

$ 104,749

-10.6%

$ 104,614

$ 104,614

-10.5%

$ 9,933

125

$1,241,573

110

$1,092,584

13



Public Health Nurse Supervisor

MM

$ 111,675

$ 126,595

-13.4%

$ 128,463

$ 128,463

-15.0%

$ 16,788

33

$553,994

33

$553,994

12



Public Health Nutrition Manager

MM

$ 85,654

$ 110,695

-29.2%

$ 97,252

$ 97,252

-13.5%

$ 11,598

2

$23,195

1

$11,598

7



Purchasing Clerk

AE

$ 50,669

$ 59,738

-17.9%

$ 55,686

$ 55,686

-9.9%

$ 5,017

3

$15,050

3

$15,050

5



Quality Assurance Specialist (Registered Nurse)

PR

$ 102,710

$ 131,309

-27.8%

$ 118,222

$ 118,222

-15.1%

$ 15,512

23

$356,769

14

$217,164

4



Radio Communications System Engineer

PR

$ 110,365

$ 127,317

-15.4%

$ 109,770

$ 109,770

0.5%

$ -594

2

$0

2

$0

7



Radiologic Technologist

HS

$ 55,078

$ 84,469

-53.4%

$ 84,170

$ 84,170

-52.8%

$ 29,092

2

$58,184

2

$58,184

11



Radiologist

PR

$ 170,851

$ 261,253

-52.9%

$ 237,862

$ 229,466

-34.3%

$ 58,615

1

$58,615

1

$58,615

2

Internal Alignment: Anchor to Pediatrician

Recordable Documents Specialist I

PS

$ 56,410

$ 52,166

7.5%

$ 48,765

$ 48,765

13.6%

$ -7,644

0

$0

38

$0

9



Recordable Documents Specialist II

PS

$ 64,854

$ 59,355

8.5%

$ 52,545

$ 52,545

19.0%

$ -12,309

81

$0

45

$0

12



Recordable Documents Specialist III

MM

$ 75,109

$ 68,899

8.3%

$ 69,067

$ 69,067

8.0%

$ -6,042

18

$0

18

$0

10



Records Clerk

CL

$43,202

$ 60,147

-39.2%

$ 52,943

$ 45,025

-4.2%

$ 1,823

86

$156,816

77

$140,405

2

Internal Alignment: Anchor to Admissions Clerk

Records Management Coordinator

MM

$ 55,515

$ 72,041

-29.8%

$ 73,143

$ 73,143

-31.8%

$ 17,628

3

$52,884

3

$52,884

4



Recreation Program Coordinator

PS

$ 56,742

$ 52,506

7.5%

$ 53,503

$ 53,503

5.7%

$ -3,239

8

$0

4

$0

4



Recreation Therapy Aide

HS

$ 44,803

$ 67,827

-51.4%

$ 55,958

$ 59,963

-33.8%

$ 15,160

7

$106,117

6

$90,957

3

internal Alignment: 20% below Recreation Therapist

Recreation Therapy Supervisor

MM

$ 82,805

$ 104,910

-26.7%

$ 92,295

$ 92,295

-11.5%

$ 9,490

2

$18,980

2

$18,980

4



Recreational Therapist

PR

$ 68,786

$ 80,952

-17.7%

$ 74,953

$ 74,953

-9.0%

$ 6,168

11

$67,846

7

$43,175

7



Recycling Specialist I

PR

$ 67,018

$ 63,050

5.9%

$ 64,248

$ 70,122

-4.6%

$ 3,105

1

$3,105

0

$0

3

Internal Alignment: 10% below Recycling Specialist II

Recycling Specialist II

PR

$ 79,560

$ 76,461

3.9%

$ 77,914

$ 77,914

2.1%

$ -1,646

8

$0

6

$0

5



Registered Veterinary Technician

PS

$ 57,387

$ 67,781

-18.1%

$ 66,863

$ 66,863

-16.5%

$ 9,476

6

$56,854

5

$47,378

9



Residential Care Worker I

HS

$ 43,867

$ 38,342

12.6%

$ 38,480

$ 38,480

12.3%

$ -5,387

0

$0

2

$0

4



Residential Care Worker II

HS

$ 47,258

$ 44,627

5.6%

$ 44,764

$ 44,764

5.3%

$ -2,494

77

$0

76

$0

4



Residential Care Worker Supervisor

MM

$ 56,555

$ 53,064

6.2%

$ 53,701

$ 61,775

-9.2%

$ 5,220

27

$140,936

20

$104,397

1

Internal Alignment: 20% above Residential Childcare Specialist

Residential Care Worker Trainee

HS

$ 39,790







$ 34,632

13.0%

$ -5,158

0

$0

0

$0

0

Internal Alignment: 10% below Residential Care Worker 1

Residential Childcare Specialist

HS

$ 51,106

$ 86,091

-68.5%

$ 71,628

$ 51,479

-0.7%

$373

9

$3,361

9

$3,361

1

Internal Alignment: 15% above Residential Care Worker II

Revenue & Recovery Officer

PS

$ 62,878

$ 59,925

4.7%

$ 61,063

$ 61,063

2.9%

$ -1,815

26

$0

23

$0

11



Revenue & Recovery Officer Trainee

PS

$ 45,760

$ 53,329

-16.5%

$ 50,629

$ 50,629

-10.6%

$ 4,869

1

$4,869

1

$4,869

8



Road Crew Supervisor

MM

$ 81,266

$ 94,765

-16.6%

$ 88,349

$ 88,349

-8.7%

$ 7,083

20

$141,659

18

$127,493

13



Sanitation Regional Supervisor

MM

$ 90,979

$ 78,416

13.8%

$ 79,906

$ 79,906

12.2%

$ -11,073

3

$0

2

$0

5



Section Chief, Revenue & Recovery

MM

$ 89,731

$ 105,080

-17.1%

$ 94,061

$ 94,061

-4.8%

$4,329

5

$21,647

5

$21,647

7



Senior Account Clerk

MM

$ 50,024

$ 62,232

-24.4%

$ 59,126

$ 59,126

-18.2%

$ 9,102

7

$63,715

4

$36,409

11



Senior Accountant

MM

$ 91,354

$ 91,053

0.3%

$ 87,171

$ 87,171

4.6%

$ -4,183

47

$0

42

$0

13



Senior Admissions Clerk

CL

$ 52,333

$ 53,082

-1.4%

$ 54,090

$ 54,030

-3.2%

$ 1,697

2

$3,394

1

$1,697

3

Internal Alignment: 20% above Admissions Clerk

Senior Adult Protective Services Specialist

PS

$ 80,704

$ 89,419

-10.8%

$ 90,187

$ 90,187

-11.8%

$ 9,483

13

$123,279

10

$94,830

5



Senior Agricultural/Standards Inspector

PR

$ 82,659

$ 79,302

4.1%

$ 73,102

$ 73,102

11.6%

$ -9,557

67

$0

35

$0

11



Senior Air Pollution Chemist*

MM

$ 113,464

$ 127,455

-12.3%

$ 114,886

$ 133,937

-18.0%

$ 20,473

3

$61,420

3

$61,420

2

Internal Alignment: 15% above Associate Air Pollution Chemist

Senior Air Pollution Control Engineer*

PR

$ 118,706

$ 116,793

1.6%

$ 116,769

$ 116,769

1.6%

$ -1,936

5

$0

4

$0

4



Senior Airport Technician

MM

$ 79,518

$ 87,597

-10.2%

$ 80,561

$ 80,561

-1.3%

$ 1,043

2

$2,086

2

$2,086

6



Senior Animal Services Representative

CL

$ 52,874

$ 62,779

-18.7%

$ 56,428

$ 58,717

-11.1%

$ 5,843

2

$11,686

2

$11,686

2

Internal Alignment: 15% above Animal Services Representative

Page 7 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021

Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



||













Senior Assessment Clerk

CL

$ 49,670

$ 67,157

-35.2%

$ 63,713

$ 63,713

-28.3%

$ 14,042

7

$98,297

5

$70,212

5



Senior Cadastral Technician

AE

$ 72,946

$ 79,730

-9.3%

$ 71,160

$ 71,160

2.4%

$ -1,786

4

$0

3

$0

10



Senior Cashier

MM

$ 49,941

$ 78,969

-58.1%

$ 65,702

$ 57,852

-15.8%

$ 7,911

1

$7,911

0

$0

3

Internal Alignment: 15% above Cashier

Senior Civil Engineer

MM

$ 129,605

$ 144,401

-11.4%

$ 137,846

$ 137,846

-6.4%

$ 8,241

31

$255,467

29

$238,985

12



Senior Clinical Psychologist

PR

$ 104,998

$ 115,749

-10.2%

$ 110,549

$ 110,549

-5.3%

$ 5,551

20

$111,011

14

$77,708

8



Senior Communicable Disease Investigator

PS

$ 75,670

$ 76,274

-0.8%

$ 73,136

$ 73,136

3.3%

$ -2,535

6

$0

6

$0

7



Senior Construction Inspector

MM

$ 87,256

$ 99,515

-14.0%

$ 93,957

$ 93,957

-7.7%

$ 6,701

1

$6,701

1

$6,701

12



Senior Cook

FS

$ 48,298

$ 60,472

-25.2%

$ 55,887

$ 55,887

-15.7%

$ 7,589

68

$516,058

58

$440,167

11



Senior Electronic Security & Systems Technician

MM

$ 83,429

$ 96,871

-16.1%

$ 91,447

$ 91,447

-9.6%

$ 8,018

1

$8,018

1

$8,018

4



Senior Emergency Services Coordinator

MM

$ 101,130

$ 107,493

-6.3%

$ 98,739

$ 98,739

2.4%

$ -2,390

5

$0

3

$0

8



Senior Epidemiologist

PR

$ 114,504

$ 111,016

3.0%

$ 100,230

$ 100,230

12.5%

$ -14,274

12

$0

7

$0

7



Senior Forensic Evidence Technician

PS

$ 86,507

$ 95,711

-10.6%

$ 95,525

$ 95,525

-10.4%

$ 9,018

1

$9,018

1

$9,018

4



Senior Geographic Information Systems Analyst

PR

$ 94,994

$ 119,403

-25.7%

$ 114,866

$ 114,866

-20.9%

$ 19,872

11

$218,597

10

$198,725

5



Senior Health Information Management Technician

HS

$ 52,978

$ 62,064

-17.2%

$ 58,068

$ 64,118

-21.0%

$ 11,141

9

$100,265

8

$89,124

2

Internal Alignment: 15% above Health Information Management Technician

Senior Health Physicist

MM

$ 118,934

$ 161,700

-36.0%

$ 155,555

$ 119,180

-0.2%

$ 246

1

$246

1

$246

1

internal Alignment: 20% above Associate Health Physicist

Senior HHSA Contract Auditor

MM

$ 96,179

$ 100,462

-4.5%

$ 98,519

$ 98,519

-2.4%

$ 2,340

4

$9,361

4

$9,361

4



Senior Histology Technician

HS

$ 69,326

$ 102,988

-48.6%

$ 90,679

$ 80,483

-16.1%

$ 11,157

0

$0

0

$0

2

internal Alignment: 15% above Histology Technician

Senior Hydrogeologist

PR

$ 114,317

$ 100,859

11.8%

$ 103,832

$ 106,673

6.7%

$ -7,644

2

$0

1

$0

2

Internal Alignment: Anchor to Groundwater Geologist

Senior Insect Detection Specialist

PS

$ 57,886

$ 92,468

-59.7%

$ 76,340

$ 70,374

-21.6%

$ 12,488

6

$74,925

6

$74,925

2

Internal Alignment: 20% above Insect Detection Specialist II

Senior Laboratory Assistant

HS

$ 50,710

$ 56,410

-11.2%

$ 55,281

$ 55,281

-9.0%

$4,571

5

$22,855

3

$13,713

5



Senior Land Surveyor

MM

$ 129,605

$ 127,448

1.7%

$ 121,589

$ 121,589

6.2%

$ -8,016

4

$0

4

$0

10



Senior Latent Print Examiner

PS

$ 119,538

$ 120,696

-1.0%

$ 104,341

$ 101,558

15.0%

$ -17,980

2

$0

2

$0

3

Internal Alignment: 15% above Latent Print Examiner

Senior Laundry Worker

MM

$47,632

$ 43,394

8.9%

$ 45,434

$ 45,434

4.6%

$ -2,198

3

$0

3

$0

5



Senior Litigation Investigator

PS

$ 107,640

$ 144,352

-34.1%

$ 119,235

$ 121,399

-12.8%

$ 13,759

4

$55,036

4

$55,036

1

internal Alignment: 10% above Litigation Investigator

Senior Mail Carrier

PS

$ 48,090

$ 51,376

-6.8%

$ 52,352

$ 51,657

-7.4%

$ 3,567

1

$3,567

1

$3,567

3

Internal Alignment: 15% above Mail Carrier

Senior Medical Transcriber

CL

$ 55,869

$ 69,107

-23.7%

$ 61,526

$ 60,311

-8.0%

$ 4,442

1

$4,442

1

$4,442

2

internal Alignment: 10% above Medical Transcriber

Senior Meteorologist

PR

$ 114,442

$ 117,060

-2.3%

$ 113,782

$ 115,613

-1.0%

$ 1,171

1

$1,171

1

$1,171

1

internal Alignment: 15% above Associate Meteorologist

Senior Occupational/Physical Therapist

PR

$ 100,922

$ 112,216

-11.2%

$ 108,016

$ 108,016

-7.0%

$ 7,094

23

$163,169

19

$134,792

9



Senior Office Assistant

MM

$48,651

$ 55,973

-15.1%

$ 55,995

$ 55,995

-15.1%

$ 7,344

127

$932,651

118

$866,557

10



Senior Park Ranger

MM

$ 62,608

$ 64,501

-3.0%

$ 65,726

$ 65,726

-5.0%

$ 3,118

15

$46,776

17

$53,013

7



Senior Payroll Clerk

CL

$ 50,731

$ 83,605

-64.8%

$ 73,993

$ 70,479

-38.9%

$ 19,748

0

$0

0

$0

2

internal Alignment: 20% above Payroll Clerk

Senior Precinct Planning Technician

PS

$ 59,405

$ 69,432

-16.9%

$ 61,725

$ 68,587

-15.5%

$ 9,182

2

$18,364

2

$18,364

1

Internal Alignment: 10% above Precinct PlanningTechnician

Senior Procurement Contracting Officer

PR

$ 115,357

$ 109,293

5.3%

$ 104,170

$ 104,170

9.7%

$ -11,187

7

$0

6

$0

8



Senior Protective Services Worker

SW

$ 80,662

$ 89,419

-10.9%

$ 90,187

$ 90,187

-11.8%

$ 9,525

161

$1,533,447

145

$1,381,054

7



Senior Public Health Microbiologist

PR

$ 94,349

$ 108,574

-15.1%

$ 96,522

$ 96,522

-2.3%

$ 2,173

10

$21,735

5

$10,867

9



Senior Public Health Nurse

RN

$ 99,674

$ 112,042

-12.4%

$ 112,154

$ 112,154

-12.5%

$ 12,480

63

$786,268

52

$648,983

7



Senior Real Property Agent

PR

$ 94,328

$ 108,874

-15.4%

$ 96,789

$ 96,789

-2.6%

$ 2,461

12

$29,530

10

$24,608

9



Senior Revenue & Recovery Officer

PS

$ 69,368

$ 82,732

-19.3%

$ 73,549

$ 73,549

-6.0%

$4,181

10

$41,806

9

$37,625

9



Senior Storekeeper

MM

$ 56,306

$ 63,039

-12.0%

$ 61,502

$ 61,502

-9.2%

$ 5,196

9

$46,767

9

$46,767

12



Senior Structural Engineer

MM

$ 135,720

$ 138,601

-2.1%

$ 137,093

$ 137,093

-1.0%

$ 1,373

0

$0

0

$0

9



Senior Tax Payment Enforcement Officer

PS

$ 79,165

$ 85,150

-7.6%

$ 80,551

$ 80,551

-1.8%

$ 1,387

1

$1,387

1

$1,387

6



Senior Tax Payment Processor

CL

$ 53,747

$ 47,784

11.1%

$ 48,357

$ 54,217

-0.9%

$470

0

$0

0

$0

1

Internal Alignment: 10% above Tax Payment Processor

Senior Treasurer-Tax Collector Specialist

CL

$ 53,456

$ 67,322

-25.9%

$ 61,289

$ 61,289

-14.7%

$ 7,833

28

$219,323

27

$211,490

4



Senior Vector Control Technician

PS

$ 67,954

$ 74,268

-9.3%

$ 70,091

$ 70,091

-3.1%

$ 2,137

9

$19,236

8

$17,099

4



Senior Vector Ecologist

PR

$ 100,298

$ 106,386

-6.1%

$ 91,220

$ 107,636

-7.3%

$ 7,339

2

$14,677

1

$7,339

2

Internal Alignment: Anchor to Industrial Hygienist III

Page 8 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021

Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



||















MM

$ 73,861

$ 73,747



$ 73,033

$ 73,033



$ -828

2

$0

2

$0

6



Sewing Room Supervisor

MM

$ 38,397

$ 54,382

-41.6%

$ 52,315

$ 45,434

-18.3%

$ 7,037

1

$7,037

1

$7,037

1

Internal Alignment: Anchor to Senior Laundry Worker

Sheriff's Commissary Stores Supervisor

MM

$ 62,130







$ 70,727

-13.8%

$ 8,597

1

$8,597

1

$8,597

0

Internal Alignment: 15% above Senior Storekeeper

Sheriff's Communications Dispatcher

PS

$ 50,232

$ 55,016

-9.5%

$ 56,061

$ 56,061

-11.6%

$ 5,829

2

$11,659

3

$17,488

5



Sheriff's Detentions Licensed Vocational Nurse

HS

$ 60,507

$ 56,025

7.4%

$ 57,745

$ 57,745

4.6%

$ -2,763

97

$0

46

$0

8



Sheriff's Detentions Nurse

RN

$ 113,360

$ 111,949

1.2%

$ 114,076

$ 114,076

-0.6%

$ 716

239

$171,112

168

$120,280

8



Sheriff's Detentions Supervising Nurse

MM

$ 133,786

$ 129,690

3.1%

$ 132,140

$ 132,140

1.2%

$ -1,646

26

$0

7

$0

4



Sheriff's Detentions, Chief Mental Health Clinician

MM

$ 105,997

$ 106,214

-0.2%

$ 108,232

$ 113,712

-7.3%

$ 7,715

5

$38,576

2

$15,430

1

Internal Alignment: 20% above Sheriff's Detentions, Mental Health Clinician

Sheriff's Detentions, Mental Health Clinician

PR

$ 99,008

$ 98,758

0.3%

$ 94,760

$ 94,760

4.3%

$ -4,248

75

$0

22

$0

5



Sheriff's Detentions, Processing Assistant Manager

MM

$ 84,698







$ 79,889

5.7%

$ -4,809

1

$0

1

$0

0

Internal Alignment: 15% above Sheriff's Operations Supervisor

Sheriff's Emergency Services Dispatcher

PS

$ 76,960

$ 87,988

-14.3%

$ 85,633

$ 85,633

-11.3%

$ 8,673

127

$1,101,495

92

$797,933

13



Sheriff's Emergency Services Dispatcher Trainee

PS

$47,112

$ 75,858

-61.0%

$ 70,255

$ 70,255

-49.1%

$ 23,143

0

$0

27

$624,859

12



Sheriff's Fingerprint Examiner

PS

$ 53,539

$ 82,763

-54.6%

$ 75,497

$ 75,497

-41.0%

$ 21,958

9

$197,623

8

$175,665

9



Sheriff's Investigative Specialist

PS

$ 61,339

$ 65,936

-7.5%

$ 64,617

$ 53,521

12.7%

$ -7,818

0

$0

0

$0

3

Internal Alignment: Anchor to Investigative Specialist

Sheriff's Licensing Clerk I

CL

$43,160

$ 56,201

-30.2%

$ 54,603

$ 43,999

-1.9%

$ 839

0

$0

7

$5,874

2

Internal Alignment: 10% below Sheriff's Licensing Clerk II

Sheriff's Licensing Clerk II

CL

$48,714

$ 65,453

-34.4%

$ 57,456

$ 48,888

-0.4%

$ 174

10

$1,744

2

$349

3

Internal Alignment: 10% below Sheriff's Licensing Specialist

Sheriff's Licensing Specialist

CL

$ 52,686

$ 87,381

-65.9%

$ 85,633

$ 54,320

-3.1%

$ 1,634

4

$6,535

2

$3,267

1

Internal Alignment: 20% below Sheriff's Licensing Supervisor

Sheriff's Licensing Supervisor

MM

$ 54,538

$ 72,213

-32.4%

$ 69,469

$ 67,900

-24.5%

$ 13,362

3

$40,087

3

$40,087

1

Internal Alignment: 15% below Sheriff's Operations Supervisor

Sheriff's Operations Supervisor

MM

$ 73,445

$ 72,213

1.7%

$ 69,469

$ 79,882

-8.8%

$ 6,437

7

$45,060

6

$38,623

1

Internal Alignment: 15% above Detentions Processing Supervisor

Sheriff's Property & Evidence Custodian

PS

$ 59,072

$ 87,462

-48.1%

$ 72,156

$ 72,779

-23.2%

$ 13,707

3

$41,121

2

$27,414

1

Internal Alignment: 15% above Sheriff's Property & Evidence Specialist II

Sheriff's Property & Evidence Manager

MM

$ 73,382

$ 98,380

-34.1%

$ 87,460

$ 86,588

-18.0%

$ 13,205

1

$13,205

1

$13,205

3

Internal Alignment: 20% above Sheriff's Property & Evidence Custodian

Sheriff's Property & Evidence Specialist I

CL

$ 43,014

$ 62,100

-44.4%

$ 59,093

$ 59,093

-37.4%

$ 16,079

6

$96,472

9

$144,708

4



Sheriff's Property & Evidence Specialist II

CL

$ 49,504

$ 69,971

-41.3%

$ 63,286

$ 63,286

-27.8%

$ 13,782

14

$192,952

0

$0

7



Sheriff's Property Investigator

PS

$ 55,661







$ 65,498

-17.7%

$ 9,837

4

$39,349

3

$29,512

0

1 nternal Alignment: 10% below Deputy Public Administrator-Guardian

Sheriff's Range Guard

PS

$ 45,947

$ 53,120

-15.6%

$ 54,129

$ 67,886

-47.7%

$ 21,939

5

$109,694

3

$65,817

1

Internal Alignment: Anchor to Deputy Sheriff Cadet-Detention/Court Services

Sheriff's Records & Identification Clerk I

CL

$43,160

$49,166

-13.9%

$ 49,840

$ 49,840

-15.5%

$ 6,680

0

$0

1

$6,680

9



Sheriff's Records & Identification Clerk II

CL

$48,714

$ 55,345

-13.6%

$ 56,420

$ 56,420

-15.8%

$ 7,706

67

$516,334

55

$423,856

9



Sheriff's Records & Identification Supervisor

MM

$ 55,411

$ 67,836

-22.4%

$ 67,273

$ 67,273

-21.4%

$ 11,862

11

$130,484

10

$118,622

7



Sheriff's Senior Fingerprint Examiner

PS

$ 63,648

$ 97,977

-53.9%

$ 89,478

$ 89,478

-40.6%

$ 25,830

2

$51,660

1

$25,830

8



Sheriff's Supervisor Helicopter/Airplane Mechanic

MM

$ 104,187

$ 93,038

10.7%

$ 92,905

$ 92,905

10.8%

$ -11,282

1

$0

1

$0

4



Social Services Aide

SW

$ 41,850

$ 51,362

-22.7%

$ 50,369

$ 50,369

-20.4%

$ 8,519

20

$170,385

20

$170,385

9



Social Work Supervisor

SS

$ 78,146

$ 96,342

-23.3%

$ 89,419

$ 89,419

-14.4%

$ 11,274

25

$281,845

25

$281,845

12



Social Worker I

SW

$ 54,662

$ 66,731

-22.1%

$ 64,195

$ 64,195

-17.4%

$ 9,533

38

$362,249

33

$314,584

11



Social Worker II

SW

$ 57,491

$ 76,394

-32.9%

$ 72,091

$ 72,091

-25.4%

$ 14,599

17

$248,190

14

$204,391

12



Social Worker III

SW

$ 66,539

$ 92,088

-38.4%

$ 85,024

$ 85,024

-27.8%

$ 18,485

225

$4,159,166

202

$3,734,007

11



Solid Waste Site Supervisor

MM

$ 81,266

$ 71,710

11.8%

$ 73,072

$ 73,072

10.1%

$ -8,193

1

$0

1

$0

3

Above Market N/A

Staff Accountant

AE

$ 67,350

$ 74,498

-10.6%

$ 67,154

$ 67,154

0.3%

$ -196

24

$0

45

$0

13



Staff Nurse

RN

$ 89,606

$ 103,076

-15.0%

$ 103,920

$ 103,920

-16.0%

$ 14,314

46

$658,427

47

$672,740

13



Statistician

PR

$ 81,890

$ 88,291

-7.8%

$ 84,730

$ 84,730

-3.5%

$ 2,840

0

$0

0

$0

6



Stock Clerk

AE

$ 38,834

$ 48,952

-26.1%

$ 46,547

$ 46,547

-19.9%

$ 7,713

56

$431,925

47

$362,508

13



Storekeeper

AE

$ 44,054

$ 58,543

-32.9%

$ 54,392

$ 54,392

-23.5%

$ 10,338

19

$196,418

16

$165,405

12



Storekeeper II (T)

MM

$ 48,693

$ 61,906

-27.1%

$ 55,254

$ 55,254

-13.5%

$ 6,561

1

$6,561

1

$6,561

8



Substance Abuse Assessor

PR

$ 76,378

$ 89,130

-16.7%

$ 79,237

$ 72,018

5.7%

$ -4,360

4

$0

4

$0

1

Internal Alignment: Anchor to Correctional Counselor

Supervising Agricultural/Standards Inspector

MM

$ 96,990

$ 88,038

9.2%

$ 87,422

$ 87,422

9.9%

$ -9,568

14

$0

13

$0

9



Supervising Air Quality Inspector*

PS

$ 104,104

$ 126,339

-21.4%

$ 104,356

$ 102,677

1.4%

$ -1,427

7

$0

5

$0

3

Internal Alignment: 20% above Air Quality Inspector II

Page 9 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary



Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



oiassmcauon

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

euageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Supervising Air Resources Specialist*

MM

$ 120,037

$ 136,655

-13.8%

$ 127,942

$ 123,072

-2.5%

$ 3,035

2

$6,070

2

$6,070

3

internal Alignment: 20% above Associate Air Resources Specialist

Supervising Animal Care Attendant

MM

$ 60,653

$ 67,259

-10.9%

$ 64,020

$ 64,020

-5.6%

$ 3,367

4

$13,468

4

$13,468

5



Supervising Animal Control Officer

MM

$ 71,053

$ 82,599

-16.3%

$ 79,364

$ 79,364

-11.7%

$ 8,311

4

$33,244

4

$33,244

8



Supervising Appraiser I

MM

$ 109,907

$ 110,417

-0.5%

$ 104,841

$ 104,841

4.6%

$ -5,066

10

$0

11

$0

8



Supervising Appraiser II

MM

$ 120,952

$ 109,613

9.4%

$ 108,266

$ 108,266

10.5%

$ -12,686

4

$0

4

$0

10



Supervising Assessment Clerk

MM

$ 58,490

$ 75,069

-28.3%

$ 74,085

$ 74,085

-26.7%

$ 15,595

4

$62,382

4

$62,382

6



Supervising Audit-Appraiser

MM

$ 120,952

$ 114,161

5.6%

$ 109,079

$ 109,079

9.8%

$ -11,873

3

$0

3

$0

12



Supervising Child Support Officer

MM

$ 77,522

$ 83,606

-7.8%

$ 81,947

$ 81,947

-5.7%

$ 4,425

24

$106,206

17

$75,229

13



Supervising Communicable Disease Investigator

MM

$ 84,032

$ 82,805

1.5%

$ 73,675

$ 73,675

12.3%

$ -10,357

4

$0

4

$0

5



Supervising Community Health Promotion Specialist

MM

$ 84,219

$ 96,209

-14.2%

$ 86,979

$ 86,979

-3.3%

$ 2,760

1

$2,760

1

$2,760

6



Supervising Correctional Counselor

MM

$ 91,978

$ 123,124

-33.9%

$ 111,401

$ 90,022

2.1%

$ -1,956

6

$0

4

$0

2

internal Alignment: 5% below Sheriff's Detentions, Mental Health Clinician

Supervising Criminalist

MM

$ 141,232

$ 139,249

1.4%

$ 132,851

$ 132,851

5.9%

$ -8,380

6

$0

5

$0

11



Supervising Deputy Public Administrator-Guardian

MM

$ 79,810

$ 87,163

-9.2%

$ 86,990

$ 86,990

-9.0%

$ 7,181

2

$14,362

2

$14,362

10



Supervising Electronic Instrument Technician

MM

$ 87,506

$ 116,491

-33.1%

$ 104,007

$ 104,007

-18.9%

$ 16,501

2

$33,002

2

$33,002

4



Supervising Environmental Health Specialist

MM

$ 100,859

$ 110,892

-9.9%

$ 106,678

$ 106,678

-5.8%

$ 5,819

25

$145,474

22

$128,017

13



Supervising Health Information Specialist

MM

$ 84,219

$ 80,346

4.6%

$ 81,873

$ 81,873

2.8%

$ -2,346

2

$0

1

$0

4



Supervising Human Services Control Specialist

SS

$ 70,970

$ 104,148

-46.7%

$ 89,276

$ 89,276

-25.8%

$ 18,306

6

$109,837

6

$109,837

4



Supervising Human Services Specialist

SS

$ 67,642

$ 88,220

-30.4%

$ 83,156

$ 83,156

-22.9%

$ 15,515

226

$3,506,348

220

$3,413,259

10



Supervising Industrial Hygienist

MM

$ 106,142

$ 130,853

-23.3%

$ 115,936

$ 115,936

-9.2%

$ 9,793

1

$9,793

1

$9,793

5



Supervising Nurse

MM

$ 107,806

$ 119,374

-10.7%

$ 123,340

$ 123,340

-14.4%

$ 15,534

28

$434,938

20

$310,670

8



Supervising Occupational/Physical Therapist

MM

$ 108,805

$ 120,402

-10.7%

$ 118,153

$ 118,153

-8.6%

$ 9,348

11

$102,825

11

$102,825

10



Supervising Office Assistant

MM

$ 55,515

$ 73,827

-33.0%

$ 69,290

$ 69,290

-24.8%

$ 13,775

47

$647,434

43

$592,333

6



Supervising Park Ranger

MM

$ 68,411

$ 79,465

-16.2%

$ 79,073

$ 79,073

-15.6%

$ 10,662

23

$245,226

19

$202,578

8



Supervising Pest Management Technician

MM

$ 74,901

$ 83,162

-11.0%

$ 76,287

$ 76,287

-1.9%

$ 1,387

1

$1,387

1

$1,387

4



Supervising Public Health Microbiologist

MM

$ 104,083

$ 107,276

-3.1%

$ 103,504

$ 103,504

0.6%

$ -579

7

$0

6

$0

12



Supervising Sheriff's Emergency Services Dispatcher

MM

$ 96,699

$ 108,256

-12.0%

$ 97,214

$ 97,214

-0.5%

$ 515

15

$7,719

15

$7,719

12



Supervising Stores & Mail System Specialist, Auditor & Controller

MM

$ 60,944

$ 46,989

22.9%

$ 47,030

$ 55,178

9.5%

$ -5,766

1

$0

1

$0

2

Internal Alignment: 20%above Mail Processor

Supervising Treasurer-Tax Collector Specialist

MM

$ 60,320

$ 87,612

-45.2%

$ 75,520

$ 75,520

-25.2%

$ 15,200

6

$91,198

6

$91,198

5



Supervising Vector Ecologist

MM

$ 107,390

$ 112,389

-4.7%

$ 96,324

$ 108,382

-0.9%

$ 992

1

$992

1

$992

2

Internal Alignment: 15% above the Senior Vector Ecologist

Supervising, Trial Support Unit

MM

$ 96,138

$ 96,069

0.1%

$ 96,165

$ 91,349

5.0%

$ -4,789

1

$0

0

$0

1

Internal Alignment: 20% aboveTrial Support Specialist

Supervising, Vector Control Technician

MM

$ 74,901

$ 86,982

-16.1%

$ 88,635

$ 80,316

-7.2%

$ 5,415

5

$27,076

5

$27,076

2

Internal Alignment: 20% above Vector Control Technician

Tax Payment Enforcement Officer

PS

$ 64,834

$ 76,358

-17.8%

$ 66,986

$ 66,986

-3.3%

$ 2,152

1

$2,152

1

$2,152

8



Tax Payment Processor

CL

$ 48,693

$ 49,747

-2.2%

$ 49,288

$ 49,288

-1.2%

$ 595

0

$0

0

$0

4



Technical Writer

PR

$ 89,918

$ 116,102

-29.1%

$ 104,076

$ 104,076

-15.7%

$ 14,157

1

$14,157

1

$14,157

2

Internal Alignment: No alignmentfound

Telecommunications Technician III

MM

$ 90,126

$ 101,826

-13.0%

$ 91,262

$ 91,262

-1.3%

$ 1,135

8

$9,083

8

$9,083

7



Telecommunications Technician IV

MM

$ 99,050

$ 102,375

-3.4%

$ 102,477

$ 102,477

-3.5%

$ 3,428

2

$6,856

3

$10,283

7



Toxicologist I

PR

$ 82,014

$ 98,271

-19.8%

$ 83,889

$ 87,322

-6.5%

$ 5,308

0

$0

0

$0

2

Internal Alignment: 15% below Toxicologist II

Toxicologist II

PR

$ 100,152

$ 120,426

-20.2%

$ 102,732

$ 102,732

-2.6%

$ 2,580

4

$10,320

4

$10,320

4



Toxicologist III

MM

$ 114,234

$ 122,328

-7.1%

$ 108,750

$ 118,142

-3.4%

$ 3,908

1

$3,908

1

$3,908

3

Internal Alignment: 15% above Toxicologist II

Treasurer-Tax Collector Specialist

CL

$46,571

$ 64,908

-39.4%

$ 54,004

$ 54,004

-16.0%

$ 7,433

33

$245,279

30

$222,981

5



Trial Support Specialist

PS

$ 91,562

$ 83,394

8.9%

$ 76,124

$ 76,124

16.9%

$ -15,438

11

$0

8

$0

4



Utilization Review Quality Improvement Specialist

PR

$ 99,466

$ 140,588

-41.3%

$ 119,662

$ 119,662

-20.3%

$ 20,196

24

$484,705

20

$403,921

6



Utilization Review Quality Improvement Supervisor

MM

$ 104,437

$ 147,346

-41.1%

$ 125,672

$ 125,672

-20.3%

$ 21,235

5

$106,174

4

$84,940

4



Vector Control Technician

PS

$ 61,755

$ 67,402

-9.1%

$ 66,930

$ 66,930

-8.4%

$ 5,175

17

$87,967

16

$82,793

5



Vector Control Technician Aide

PS

$43,118

$ 57,710

-33.8%

$ 57,559

$ 57,559

-33.5%

$ 14,440

0

$0

0

$0

5



Page 10 of 11

Appendix I: San Diego Results

-------
County of San Diego
Appendix I: Results Summary
August 2021



Bargaining

Top Annual Salary

Adjusted Top Annual Salary

Cost
Difference

# of
Budgeted

Cost per

# of

Cost per
Actual

# of



oiassmcauon

Unit

Top Annual
Salary

Median of
Comparators

% or
below

Median of
Comparators

Recommended
Salary

% or
below

(Median
Annual)

Positions
per Class

euageiea
Positions

incumoenis
per Class

Incumbents

Matches

Alignment

Vector Ecologist

PR

$ 95,493

$ 96,262

-0.8%

$ 93,618

$ 97,851

-2.5%

$ 2,358

1

$2,358

2

$4,716

3

Internal Alignment: Anchor to Industrial Hygienist II

Veterans Services Representative

PS

$ 65,957

$ 66,566

-0.9%

$ 64,256

$ 64,256

2.6%

$ -1,700

11

$0

10

$0

13



Veterinarian

PR

$ 124,051

$ 138,300

-11.5%

$ 136,253

$ 136,253

-9.8%

$ 12,201

2

$24,403

1

$12,201

9



Victim Advocate

PR

$ 71,635

$ 59,025

17.6%

$ 56,680

$ 56,680

20.9%

$ -14,956

13

$0

17

$0

10



Victim/Witness Assist Program Manager

MM

$ 87,901

$ 115,850

-31.8%

$ 105,254

$ 105,254

-19.7%

$ 17,353

2

$34,706

1

$17,353

7



Victim/Witness Assistance Program Supervisor

MM

$ 80,413

$ 80,309

0.1%

$ 77,390

$ 77,390

3.8%

$ -3,023

7

$0

3

$0

9



Wastewater Facilities Supervisor

MM

$ 95,451

$ 103,111

-8.0%

$ 103,694

$ 103,694

-8.6%

$ 8,242

2

$16,485

1

$8,242

6



Wastewater Plant Operator III

MM

$ 82,618

$ 85,722

-3.8%

$ 89,128

$ 89,128

-7.9%

$ 6,510

5

$32,550

4

$26,040

5



Watershed Manager

MM

$ 95,805







$ 98,841

-3.2%

$ 3,036

0

$0

0

$0

0

internal Alignment: 25% above Supervising Park Ranger

AVERAGE: -13.9%
MEDIAN: -11.5%

AVERAGE: -7.3%
MEDIAN: -6.3%

TOTAL: $54,826,506

TOTAL: $50,361,190

Kev:

County salary is above the market median.
Recommended salary based on internal alignment.

Page 11 of 11

Appendix I: San Diego Results

-------
lose Salary Compensation Study - final Report

County of San Diego

Mas

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Accident Reconstruction Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Accident Reconstruction Specialist

$ 92,976

$ 114,317



$ 114,317

6/18/2021

unknown

unknown

2

County of San Bernardino

Incident Reconstruction Specialist

$ 72,758

$ 100,131

1.9%

$ 102,034

7/31/2021

7/30/2022

3.00%

3

County of Los Angeles

Claims Investigator II

$ 53,184

$ 71,676

-3.8%

$ 68,952

1/1/2021

unknown

unknown

4

County of Orange

N/C















5

County of Ventura

N/C















6

County of Contra Costa

N/C















7

County of Alameda

N/C















8

City and County of San Francisco

N/C















9

County of Santa Clara

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 85,904

$ 85,493

% County of San Diego Above/Below

24.9%

25.2%

Number of Matches

2

2

N/C - Non Comparator

Page 1 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Account Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Account Clerk

$ 59,514

$ 72,332

-17.4%

$ 59,746

7/1/2021

1/8/2022

.50%

2

County of Riverside

Accounting Assistant II

$ 34,740

$ 54,204

1.9%

$ 55,234

5/1/2021

5/1/2022

2.00%

3

County of Santa Clara

Account Clerk II

$ 53,604

$ 64,678

-16.8%

$ 53,812

6/14/2021

6/13/2022

3.00%

4

County of Los Angeles

Account Clerk II

$ 39,090

$ 53,983

-3.8%

$ 51,931

1/1/2021

unknown

unknown

5

County of Alameda

Account Clerk 1

$ 48,200

$57,140

-11.4%

$ 50,626

6/27/2021

6/26/2022

3.25%

6

County of San Mateo

Fiscal Office Assistant 1

$ 48,297

$ 60,381

-17.5%

$ 49,815

10/4/2020

unknown

unknown

7

County of San Bernardino

Fiscal Assistant

$ 33,779

$ 46,363

1.9%

$ 47,244

7/31/2021

7/30/2022

3.00%

8

County of Ventura

Accounting Assistant 1

$ 33,587

$ 47,022

-0.7%

$ 46,692

12/27/2020

12/26/2021

2.00%

9

County of Sacramento

Account Clerk 1

$ 36,937

$ 44,892

0.1%

$ 44,937

6/21/2020

unknown

unknown

10

County of Orange

Accounting Assistant 1

$ 35,235

$ 45,698

-2.0%

$ 44,784

7/2/2021

7/1/2022

3.50%

11

County of Contra Costa

Account Clerk - Beginning Level

$40,113

$ 48,758

-11.1%

$ 43,346

7/1/2021

unknown

unknown



County of San Diego

Account Clerk

$35,173

$ 43,243



$ 43,243

6/18/2021

unknown

unknown

13

County of Fresno

Account Clerk 1

$30,186

$ 38,610

4.7%

$ 40,425

11/2/2020

unknown

unknown

14

County of Kern

Fiscal Support Assistant

$ 29,748

$ 36,324

1.2%

$ 36,760

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 48,758

$ 47,244

% County of San Diego Above/Below

-12.8%

-9.3%

Number of Matches

13

13

N/C - Non Comparator

Page 2 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Account Clerk Specialist |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Account Clerk

$ 68,952

$ 83,746

-17.4%

$ 69,174

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Lead Fiscal Office Assistant

$ 55,535

$ 69,367

-17.5%

$ 57,228

10/4/2020

unknown

unknown

3

County of Alameda

Account Clerk II

$ 51,583

$ 61,005

-11.4%

$ 54,051

6/27/2021

6/26/2022

3.25%

4

County of Ventura

Accounting Assistant II

$ 37,319

$ 52,246

-0.7%

$ 51,881

12/27/2020

12/26/2021

2.00%

5

County of San Bernardino

Fiscal Specialist

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

6

County of Sacramento

Account Clerk II

$ 41,969

$ 51,010

0.1%

$ 51,061

6/21/2020

unknown

unknown

7

County of San Diego

Account Clerk Specialist

$ 40,539

$ 49,816



$ 49,816

6/18/2021

unknown

unknown

8

County of Fresno

Account Clerk III

$ 37,154

$ 47,554

4.7%

$ 49,789

11/2/2020

unknown

unknown

9

County of Orange

Accounting Assistant II

$ 37,856

$ 49,691

-2.0%

$ 48,697

7/2/2021

7/1/2022

3.50%

10

County of Contra Costa

Account Clerk - Experienced Level

$ 44,848

$ 48,758

-11.1%

$ 43,346

7/1/2021

unknown

unknown

11

County of Kern

Fiscal Support Technician

$ 32,868

$40,128

1.2%

$ 40,610

4/21/2021

unknown

unknown

12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,746

$ 51,251

% County of San Diego Above/Below

-1.9%

-2.9%

Number of Matches

10

10

N/C - Non Comparator

Page 3 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Accounting Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Principal Account Clerk

$ 77,868

$ 94,644

-17.4%

$ 78,176

7/1/2021

1/8/2022

.50%

2

County of Riverside

Accounting Technician II

$ 45,468

$ 69,096

1.9%

$ 70,409

5/1/2021

5/1/2022

2.00%

3

County of Alameda

Accounting Technician

$ 60,736

$ 73,819

-11.4%

$ 65,404

12/27/2020

12/26/2021

3.00%

4

County of Sacramento

Accounting Technician

$ 53,495

$ 65,020

0.1%

$ 65,085

6/21/2020

unknown

unknown

5

County of Ventura

Accounting Technician

$45,156

$ 63,218

-0.7%

$ 62,776

12/26/2020

12/27/2021

2.00%

6

County of Contra Costa

Accounting Technician

$ 55,143

$ 70,420

-11.1%

$ 62,603

7/1/2021

unknown

Unknown

7

County of Los Angeles

Accounting Technician II

$ 47,266

$ 63,684

-3.8%

$ 61,264

1/1/2021

unknown

unknown

8

County of San Mateo

Fiscal Office Specialist

$ 58,301

$ 72,861

-17.5%

$ 60,110

10/4/2020

unknown

unknown

9

County of Orange

Accounting Technician

$ 45,698

$ 61,298

-2.0%

$ 60,072

7/2/2021

7/1/2022

3.50%

10

County of Santa Clara

Accountant Assistant

$ 59,475

$ 71,791

-16.8%

$ 59,730

6/14/2021

6/13/2022

3.00%

11

County of Fresno

Supervising Account Clerk

$44,148

$ 56,472

4.7%

$ 59,126

11/2/2020

unknown

unknown

12

County of San Bernardino

Accounting Technician

$ 41,454

$ 57,075

1.9%

$ 58,160

7/31/2021

7/30/2022

3.00%

13

County of Kern

Fiscal Support Supervisor

$ 43,896

$ 53,592

1.2%

$ 54,235

4/21/2021

unknown

unknown

14

County of San Diego

Accounting Technician

$ 43,222

$ 53,144



$ 53,144

6/18/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,020

$ 61,264

% County of San Diego Above/Below

-22.3%

-15.3%

Number of Matches

13

13

N/C - Non Comparator

Page 4 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Administrative Secretary I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Senior Secretary 1

$ 49,765

$ 67,060

-3.8%

$ 64,512

1/1/2021

unknown

unknown

2

City and County of San Francisco

Secretary 1

$ 60,300

$ 73,272

-17.4%

$ 60,523

7/1/2021

1/8/2022

.50%

3

County of San Mateo

Administrative Secretary 1

$ 57,948

$ 72,383

-17.5%

$ 59,716

10/4/2020

unknown

unknown

4

County of Riverside

Administrative Secretary 1

$ 40,080

$ 55,980

1.9%

$ 57,044

7/1/2021

7/14/2022

2.00%

5

County of Alameda

Secretary 1

$ 52,509

$ 62,515

-11.4%

$ 55,389

6/27/2021

6/26/2022

3.25%

6

County of Orange

Secretary 1

$ 40,040

$ 52,998

-2.0%

$ 51,938

7/2/2021

7/1/2022

3.50%

7

County of San Bernardino

Secretary 1

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

8

County of San Diego

Administrative Secretary 1

$ 36,338

$ 44,616



$ 44,616

6/18/2021

unknown

unknown

9

County of Fresno

Administrative Assistant 1

$ 31,590

$ 40,404

4.7%

$ 42,303

11/2/2020

unknown

unknown

10

County of Contra Costa

N/C















11

County of Ventura

N/C















12

County of Sacramento

N/C















13

County of Kern

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,248

$ 56,216

% County of San Diego Above/Below

-32.8%

-26.0%

Number of Matches

8

8

N/C - Non Comparator

Page 5 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Administrative Secretary II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Secretary II

$ 68,474

$ 81,182

-11.4%

$ 71,928

12/27/2020

12/26/2021

3.00%

2

City and County of San Francisco

Secretary II

$ 69,780

$ 84,816

-17.4%

$ 70,058

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Senior Secretary II

$ 52,535

$ 70,803

-3.8%

$ 68,113

1/1/2021

unknown

unknown

4

County of San Mateo

Administrative Secretary II

$ 62,544

$ 78,165

-17.5%

$ 64,486

10/4/2020

unknown

unknown

5

County of Riverside

Administrative Secretary II

$ 43,308

$ 58,956

1.9%

$ 60,076

7/1/2021

7/14/2022

2.00%

6

County of Santa Clara

Administrative Assistant

$ 58,671

$ 70,816

-16.8%

$ 58,919

6/14/2021

6/13/2022

3.00%

7

County of Contra Costa

Secretary - Journey Level

$ 45,900

$ 63,274

-11.1%

$ 56,250

7/1/2021

unknown

Unknown

8

County of Orange

Secretary II

$ 43,014

$ 57,346

-2.0%

$ 56,199

7/2/2021

7/1/2022

3.50%

9

County of San Bernardino

Secretary II

$ 39,541

$ 54,350

1.9%

$ 55,383

7/31/2021

7/30/2022

3.00%

10

County of San Diego

Administrative Secretary II

$ 41,974

$ 51,542



$ 51,542

6/18/2021

unknown

unknown

11

County of Fresno

Administrative Assistant II

$ 35,178

$ 44,980

4.7%

$ 47,094

11/2/2020

unknown

unknown

12

County of Ventura

N/C















13

County of Kern

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,039

$ 59,497

% County of San Diego Above/Below

-30.1%

-15.4%

Number of Matches

10

10

N/C - Non Comparator

Page 6 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Admissions Clerk





















1

County of Riverside

Admissions and Collections Clerk

$ 35,676

$ 55,668

1.9%

$ 56,726

5/1/2021

5/1/2022

2.00%

2

County of San Bernardino

Office Assistant III

$ 33,779

$ 46,363

1.9%

$ 47,244

7/31/2021

7/30/2022

3.00%

3

County of Fresno

Admitting Interviewer II

$ 33,618

$ 43,004

4.7%

$ 45,025

11/2/2020

unknown

unknown

4

County of Ventura

Medical Office Assistant II

$ 31,955

$ 44,687

-0.7%

$ 44,374

12/27/2020

12/26/2021

2.00%





















6

County of Kern

Patient Access Services Representative II

$ 32,220

$ 39,336

1.2%

$ 39,808

4/21/2021

unknown

unknown

7

County of Orange

N/C















8

County of Contra Costa

N/C















9

County of Alameda

N/C















10

City and County of San Francisco

N/C















11

County of Santa Clara

N/C















12

County of Los Angeles

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 44,687

$ 45,025

% County of San Diego Above/Below

-1.1%

-1.9%

Number of Matches

5

5

N/C - Non Comparator

Page 7 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Adult Pro

tective Services Specialist





















1

City and County of San Francisco

Protective Services Worker

$ 95,676

$ 122,040

-17.4%

$ 100,805

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Deputy Public Guardian - Conservator

$ 86,501

$ 104,664

-16.8%

$ 87,080

6/14/2021

6/13/2022

3.00%

3

County of Alameda

Adult Protective Services Worker II

$ 85,246

$ 97,790

-11.4%

$ 86,642

6/27/2021

6/26/2022

3.25%

4

County of Orange

Senior Social Worker

$ 63,440

$ 85,613

-2.0%

$ 83,901

7/2/2021

7/1/2022

3.50%

5

County of San Bernardino

Social Service Practitioner II

$ 57,554

$ 81,078

1.9%

$ 82,619

3/13/2021

3/26/2022

3.00%

6

County of Contra Costa

Social Worker II

$ 78,259

$ 86,280

-11.1%

$ 76,703

7/1/2021

unknown

unknown





















8

County of Ventura

HS Adult Protective Services Social Worker II

$ 56,079

$ 74,772

-0.7%

$ 74,249

12/26/2020

12/27/2021

2.00%

9

County of Kern

Social Service Worker IV

$ 52,536

$ 64,128

1.2%

$ 64,898

4/21/2021

unknown

unknown

10

County of Fresno

Social Worker II

$ 44,980

$ 57,538

4.7%

$ 60,242

11/2/2020

unknown

unknown

11

County of Sacramento

N/C















12

County of Los Angeles

N/C















13

County of Riverside

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 85,613

$ 82,619

% County of San Diego Above/Below

-13.7%

-9.7%

Number of Matches

9

9

N/C - Non Comparator

Page 8 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Adult Protective Services Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Protective Services Supervisor

$ 107,460

$ 137,232

-17.4%

$ 113,354

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Supervising Deputy Public Guardian

$ 108,948

$ 132,434

-16.8%

$ 110,185

6/28/2021

6/27/2022

3.00%

3

County of Alameda

Adult Protection Supervisor

$ 96,554

$ 116,771

-11.4%

$ 103,459

12/27/2020

12/26/2021

3.00%

4

County of Contra Costa

Social Work Supervisor II

$ 94,644

$ 115,041

-11.1%

$ 102,272

7/1/2021

unknown

Unknown

5

County of San Bernardino

Supervising Social Service Practitioner

$ 69,243

$ 95,326

1.9%

$ 97,138

7/31/2021

7/30/2022

3.00%

6

County of San Diego

Adult Protective Services Supervisor

$ 75,317

$ 92,602



$ 92,602

6/18/2021

unknown

unknown

7

County of Ventura

HS Adult Protective Services Supervisor

$ 90,918

$ 93,042

-0.7%

$ 92,390

12/26/2020

12/27/2021

2.00%

8

County of Fresno

Social Work Supervisor

$ 64,350

$ 82,290

4.7%

$ 86,158

11/2/2020

unknown

unknown

9

County of Orange

Social Services Supervisor 1

$ 63,440

$ 85,613

-2.0%

$ 83,901

7/2/2021

7/1/2022

3.50%

10

County of Sacramento

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 105,184

$ 99,705

% County of San Diego Above/Below

-13.6%

-7.7%

Number of Matches

8

8

N/C - Non Comparator

Page 9 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Aging Program Specialist I





















1

County of San Mateo

Community Program Analyst 1

$ 73,776

$ 92,246

-17.5%

$ 76,103

10/4/2020

unknown

unknown

2

County of Riverside

Office on Aging Program Specialist 1

$46,213

$ 68,379

1.9%

$ 69,678

5/1/2021

5/1/2022

2.00%





















4

County of Orange

N/C















5

County of Ventura

N/C















6

County of Contra Costa

N/C















7

County of Sacramento

N/C















8

City and County of San Francisco

N/C















9

County of Santa Clara

N/C















10

County of Los Angeles

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Alameda

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 80,313

$ 72,891

% County of San Diego Above/Below

-39.8%

-26.9%

Number of Matches

2

2

N/C - Non Comparator

Page 10 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Aging Program Specialist II





















1

County of San Mateo

Community Program Analyst II

$ 86,630

$ 108,241

-17.5%

$ 89,299

10/4/2020

unknown

unknown

2

City and County of San Francisco

Program Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%

3

County of Riverside

Office on Aging Program Specialist II

$ 52,466

$ 77,642

1.9%

$ 79,118

5/1/2021

5/1/2022

2.00%

4

County of Contra Costa

Social Worker

$ 69,561

$ 84,551

-11.1%

$ 75,166

7/1/2021

unknown

Unknown





















6

County of Ventura

N/C















7

County of Orange

N/C















8

County of Kern

N/C















9

County of San Bernardino

N/C















10

County of Sacramento

N/C















11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 95,484

$ 83,509

% County of San Diego Above/Below

-36.6%

-19.5%

Number of Matches

4

4

N/C - Non Comparator

Page 11 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Aging Program Specialist III





















1

County of Contra Costa1

[Social Worker/Aging and Adult Services Senior Staff Assistant]

$ 82,641

$ 100,451

-11.1%

$ 89,301

7/1/2021

unknown

unknown

2

County of Orange

Social Services Supervisor 1

$ 63,440

$ 85,613

-2.0%

$ 83,901

7/2/2021

7/1/2022

3.50%





















4

City and County of San Francisco

N/C















5

County of Ventura

N/C















6

County of Los Angeles

N/C















7

County of San Mateo

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Sacramento

N/C















11

County of Alameda

N/C















12

County of San Bernardino

N/C















13

County of Riverside

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,032

$ 86,601

% County of San Diego Above/Below

-16.6%

-8.5%

Number of Matches

2

2

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 12 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Agricultural Civil Actions Investigator









































2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 13 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Ag ricu Itu ral Scientist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Agricultural Scientist

$ 89,398

$ 109,907



$ 109,907

6/18/2021

unknown

unknown

2

County of Los Angeles

Senior Biologist

$ 77,748

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown

3

County of Santa Clara

Agricultural Biologist II

$ 69,561

$ 84,080

-16.8%

$ 69,954

6/14/2021

6/13/2022

3.00%

4

County of Orange

N/C















5

County of Ventura

N/C















6

County of Contra Costa

N/C















7

City and County of San Francisco

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Sacramento

N/C















11

County of Alameda

N/C















12

County of San Mateo

N/C















13

County of San Bernardino

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 94,426

$ 85,373

% County of San Diego Above/Below

14.1%

22.3%

Number of Matches

2

2

N/C - Non Comparator

Page 14 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Agricultural Standards Inspector





















1

County of Orange

Agricultural/Standards Inspector

$ 59,384

$ 79,997

-2.0%

$ 78,397

7/2/2021

7/1/2022

3.50%

2

County of Santa Clara

Biologist/Standards Specialist

$ 76,465

$92,537

-16.8%

$ 76,991

6/14/2021

6/13/2022

3.00%

3

County of Los Angeles

Agricultural/Weights & Measures Inspector II

$ 58,848

$ 79,302

-3.8%

$ 76,288

1/1/2021

unknown

unknown





















5

County of Alameda

Agricultural and Standards Investigator II

$ 70,083

$84,123

-11.4%

$ 74,533

6/27/2021

6/26/2022

3.25%

6

County of San Mateo1

[Biologist / Standards Specialist 1/ Biologist/Standards Specialist II]

$ 77,770

$86,287

-17.5%

$ 71,187

10/4/2020

unknown

unknown

7

City and County of San Francisco

Agricultural Inspector

$ 69,108

$83,976

-17.4%

$ 69,364

7/1/2021

1/8/2022

.50%

8

County of Contra Costa

Agricultural Biologist 1

$ 62,558

$ 76,040

-11.1%

$ 67,599

7/1/2021

unknown

unknown

9

County of Fresno

Agricultural/Standards Specialist II

$ 50,206

$ 61,022

4.7%

$ 63,890

4/19/2021

unknown

unknown

10

County of Sacramento

Agricultural and Standards Inspector 1

$ 50,759

$ 61,721

0.1%

$ 61,783

6/30/2021

unknown

unknown

11

County of Riverside

Agricultural & Standards Investigator II

$ 44,064

$ 60,228

1.9%

$ 61,372

5/1/2021

5/1/2022

2.00%

12

County of Ventura

Agricultural Inspector/Biologist Associate

$ 42,044

$ 59,598

-0.7%

$ 59,181

12/27/2020

12/26/2021

2.00%

13

County of San Bernardino

Agricultural/Standards Officer Trainee

$ 40,872

$ 54,829

1.9%

$ 55,871

3/13/2021

3/26/2022

3.00%

14

County of Kern

Agricultural Biologist/Weights and Measures Inspector II

$42,816

$ 52,272

1.2%

$ 52,899

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,040

$ 67,599

% County of San Diego Above/Below

-1.8%

9.5%

Number of Matches

13

13

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches. Bottom of range is for II level only; I level has only 1 step.

Page 15 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Pollution Control Aide*





















1

South Coast Air Quality Management District

Staff Assistant

$ 43,572

$ 59,004

-2.8%

$ 57,352

1/1/2020

unknown

unknown

2

San Luis Obispo County Air Pollution Control District

APCD Administrative Assistant II

$ 45,490

$ 55,307

2.9%

$ 56,911

7/1/2020

unknown

unknown





















4

Bay Area Air Quality Management District

Office Assistant II

$ 52,496

$ 63,810

-17.4%

$ 52,707

11/8/2020

unknown

Unknown

5

Sacramento Metropolitan Air Quality Management District

N/C















6

County of Orange

N/C















7

County of Ventura

N/C















8

County of Contra Costa

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,004

$ 56,911

% County of San Diego Above/Below

-6.9%

-3.1%

Number of Matches

3

3

N/C - Non Comparator

Page 16 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Pollution Control Civil Actions Investigator*









































2

South Coast Air Quality Management District

Investigator

$ 75,696

$ 102,444

-2.8%

$99,576

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Air Quality Case Settlement Specialist II

$ 89,786

$ 109,136

-17.4%

$90,146

11/8/2020

unknown

Unknown

4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 105,790

$ 94,861

% County of San Diego Above/Below

-5.0%

5.9%

Number of Matches

2

2

N/C - Non Comparator

Page 17 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Pollution Control Small Business Assistant Program Specialist*









































2

South Coast Air Quality Management District

N/C















3

Bay Area Air Quality Management District

N/C















4

County of Orange

N/C















5

County of Ventura

N/C















6

Sacramento Metropolitan Air Quality Management District

N/C















7

San Luis Obispo County Air Pollution Control District

N/C















8

Imperial County Air Pollution Control District

N/C















9

County of Contra Costa

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 18 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Pollution Test Technician (T)*









































2

South Coast Air Quality Management District

Laboratory Technician

$ 51,648

$ 69,948

-2.8%

$ 67,989

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Air Quality Technical Assistant

$ 67,000

$ 81,439

-17.4%

$ 67,269

11/8/2020

unknown

Unknown

4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,693

$ 67,629

% County of San Diego Above/Below

-3.7%

7.3%

Number of Matches

2

2

N/C - Non Comparator

Page 19 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Quality Inspector I*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Specialist (Assistant)

$ 84,056

$ 102,171

0.1%

$ 102,273

7/1/2021

unknown

unknown

2

San Luis Obispo County Air Pollution Control District

Air Quality Specialist 1

$ 67,496

$ 82,035

2.9%

$ 84,414

7/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Air Quality Inspector 1

$ 77,561

$ 94,276

-17.4%

$ 77,872

11/8/2020

unknown

Unknown





















5

County of Kern

Air Quality Specialist 1

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

6

South Coast Air Quality Management District

Air Quality Inspector 1

$ 51,420

$ 69,600

-2.8%

$ 67,651

1/1/2020

unknown

unknown

7

Imperial County Air Pollution Control District

Air Pollution Control Inspector 1

$ 35,172

$ 44,964

5.6%

$ 47,482

7/3/2020

unknown

unknown

8

County of Ventura

N/C















9

County of Orange

N/C















10

County of Contra Costa

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,802

$ 75,149

% County of San Diego Above/Below

0.8%

2.9%

Number of Matches

6

6

N/C - Non Comparator

Page 20 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Quality Inspector II*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Specialist (Associate)

$ 97,627

$ 118,666

0.1%

$ 118,785

7/1/2021

unknown

unknown

2

San Luis Obispo County Air Pollution Control District

Air Quality Specialist II

$ 76,086

$ 92,498

2.9%

$95,180

7/1/2020

unknown

unknown





















4

Bay Area Air Quality Management District

Air Quality Inspector II

$85,511

$ 103,939

-17.4%

$ 85,854

11/8/2020

unknown

Unknown

5

South Coast Air Quality Management District

Air Quality Inspector II

$ 64,812

$ 87,732

-2.8%

$ 85,276

1/1/2020

unknown

unknown

6

County of Kern

Air Quality Specialist II

$ 64,776

$ 79,080

1.2%

$ 80,029

4/21/2021

unknown

unknown

7

Imperial County Air Pollution Control District

Air Pollution Control Inspector II

$ 40,668

$ 51,960

5.6%

$ 54,870

7/3/2020

unknown

unknown

8

County of Ventura

N/C















9

County of Orange

N/C















10

County of Contra Costa

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$90,115

$ 85,565

% County of San Diego Above/Below

-0.4%

4.6%

Number of Matches

6

6

N/C - Non Comparator

Page 21 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Air Quality Specialist*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Planner-Analyst (Associate)

$ 97,627

$ 118,666

0.1%

$ 118,785

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Air Quality Specialist

$ 80,952

$ 108,780

-2.8%

$ 105,734

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Environmental Planner II

$ 98,990

$ 120,322

-17.4%

$ 99,386

11/8/2020

unknown

unknown





















5

San Luis Obispo County Air Pollution Control District

Air Quality Specialist II

$ 76,086

$ 92,498

2.9%

$95,180

7/1/2020

unknown

unknown

6

Imperial County Air Pollution Control District

Air Pollution Control Environmental Coordinator II

$ 57,396

$ 73,308

5.6%

$ 77,413

7/3/2020

unknown

unknown

7

County of Ventura

N/C















8

County of Orange

N/C















9

County of Contra Costa

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 108,780

$ 99,386

% County of San Diego Above/Below

-9.8%

-0.3%

Number of Matches

5

5

N/C - Non Comparator

Page 22 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Alcohol & Drug Program Specialist





















1

County of San Mateo

Behavioral Health And Recovery Services Analyst II

$ 89,043

$ 111,257

-17.5%

$ 91,787

10/4/2020

unknown

unknown

2

County of Santa Clara

Quality Improvement Coordinator 1 - Alcohol & Drug Services

$ 89,037

$ 107,723

-16.8%

$ 89,626

6/14/2021

6/13/2022

3.00%

3

City and County of San Francisco

Program Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%





















5

County of Sacramento

Mental Hea Ith Planning Analyst

$ 65,354

$ 79,428

0.1%

$ 79,507

6/21/2020

unknown

unknown

6

County of Fresno

Substance Abuse Specialist II

$42,146

$ 53,924

4.7%

$ 56,458

11/2/2020

unknown

unknown

7

County of Los Angeles

Substance Abuse Counselor

$ 37,232

$ 50,010

-3.8%

$48,109

1/1/2021

unknown

unknown

8

County of Ventura

N/C















9

County of Contra Costa

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Alameda

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,922

$ 83,704

% County of San Diego Above/Below

-13.5%

-2.2%

Number of Matches

6

6

N/C - Non Comparator

Page 23 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Animal Care Attendant





















1

City and County of San Francisco

Animal Care Attendant

$ 57,828

$ 73,764

-17.4%

$ 60,929

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Animal Care Attendant II

$ 41,736

$ 56,148

-3.8%

$ 54,014

1/1/2021

unknown

unknown

3

County of Sacramento

Animal Care Attendant

$ 43,034

$ 52,304

0.1%

$ 52,356

6/21/2020

unknown

unknown

4

County of Orange

Animal Care Attendant

$ 37,710

$ 50,835

-2.0%

$ 49,819

7/2/2021

7/1/2022

3.50%

5

County of Contra Costa1

[Animal Services Utility Worker/Animal Center Technician]

$ 45,570

$ 55,391

-11.1%

$ 49,242

7/1/2021

unknown

Unknown

6

County of Ventura

Animal Control Officer 1

$ 34,958

$ 48,956

-0.7%

$ 48,613

12/26/2020

12/27/2021

2.00%

7

County of Alameda

Animal Control Aide

$ 45,059

$ 54,804

-11.4%

$ 48,556

6/27/2021

6/26/2022

3.25%

8

County of Santa Clara

Kennel Attendant

$ 48,441

$ 58,305

-16.8%

$ 48,509

6/14/2021

6/13/2022

3.00%





















10

County of Riverside

Animal Care Technician

$ 29,976

$ 46,764

1.9%

$ 47,653

5/1/2021

5/1/2022

2.00%

11

County of Kern

Animal Care Worker

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

12

County of San Mateo

N/C















13

County of Fresno

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,554

$ 48,928

% County of San Diego Above/Below

-10.8%

-1.3%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The
salary displayed is the higher of the matches.

Page 24 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Animal Control Officer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Animal Control Officer

$ 57,949

$78,104

-2.0%

$ 76,542

7/2/2021

7/1/2022

3.50%

2

County of Riverside

Animal Control & License Officer II

$ 42,408

$ 66,264

1.9%

$ 67,523

5/1/2021

5/1/2022

2.00%

3

City and County of San Francisco

Animal Control Officer

$ 64,068

$ 81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

4

County of Contra Costa

Animal Services Officer

$ 57,903

$ 75,747

-11.1%

$ 67,339

7/1/2021

unknown

unknown

5

County of Alameda

Sheriff's Technician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

6

County of Los Angeles

Animal Control Officer II

$ 48,556

$ 65,431

-3.8%

$ 62,944

1/1/2021

unknown

unknown

7

County of San Diego

Animal Control Officer

$ 46,384

$ 59,925



$ 59,925

6/18/2021

unknown

unknown

8

County of Ventura

Animal Control Officer III

$ 41,933

$ 59,078

-0.7%

$ 58,664

12/26/2020

12/27/2021

2.00%

9

County of Sacramento

Animal Control Officer

$48,170

$ 58,548

0.1%

$ 58,607

6/21/2020

unknown

unknown

10

County of Santa Clara

Animal Control Officer

$58,165

$ 70,217

-16.8%

$ 58,420

6/14/2021

6/13/2022

3.00%

11

County of San Bernardino

Animal Control Officer

$38,174

$ 52,458

1.9%

$ 53,454

7/31/2021

7/30/2022

3.00%

12

County of Kern

Animal Control Officer

$ 32,220

$ 39,336

1.2%

$ 39,808

4/21/2021

unknown

unknown

13

County of San Mateo

N/C















14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,264

$ 62,944

% County of San Diego Above/Below

-10.6%

-5.0%

Number of Matches

11

11

N/C - Non Comparator

Page 25 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Animal Medical Operations Manager





















1

County of Contra Costa1

[Animal Center Operations Manager/Chief of Shelter Medicine]

$ 98,752

$ 120,034

-11.1%

$ 106,710

7/1/2021

unknown

unknown





















3

County of Orange

N/C















4

County of Ventura

N/C















5

County of Santa Clara

N/C















6

County of Los Angeles

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Sacramento

N/C















10

County of Alameda

N/C















11

County of San Mateo

N/C















12

County of San Bernardino

N/C















13

County of Riverside

N/C















14

City and County of San Francisco

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 120,034

$ 106,710

% County of San Diego Above/Below

-18.2%

-5.0%

Number of Matches

1

1

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 26 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Animal Services Dispatcher	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Animal Control Assistant

$ 39,790

$ 53,622

-2.0%

$ 52,550

7/2/2021

7/1/2022

3.50%

2

County of Riverside

Animal Services Dispatcher

$ 37,015

$ 50,082

1.9%

$ 51,034

5/1/2021

5/1/2022

2.00%

3

County of San Diego

Animal Services Dispatcher

$ 38,813

$ 47,715



$ 47,715

6/18/2021

unknown

unknown

4

County of Kern

Animal Control Dispatcher

$ 30,348

$ 37,056

1.2%

$ 37,501

4/21/2021

unknown

unknown

5

County of Ventura

N/C















6

County of Contra Costa

N/C















7

County of Alameda

N/C















8

City and County of San Francisco

N/C















9

County of Santa Clara

N/C















10

County of Los Angeles

N/C















11

County of Fresno

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,082

$ 51,034

% County of San Diego Above/Below

-5.0%

-7.0%

Number of Matches

3

3

N/C - Non Comparator

Page 27 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Animal Services Representative





















1

County of Alameda

Sheriff'sTechnician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

2

City and County of San Francisco

ClerkTypist

$ 57,696

$ 70,152

-17.4%

$ 57,946

7/1/2021

1/8/2022

.50%

3

County of Orange

Animal Control Services Representative

$ 39,250

$ 52,125

-2.0%

$ 51,082

7/2/2021

7/1/2022

3.50%

4

County of Riverside

Animal Services Representative

$ 37,015

$ 50,082

1.9%

$ 51,034

5/1/2021

5/1/2022

2.00%

5

County of Santa Clara

Office Specialist II

$ 48,587

$ 58,483

-16.8%

$ 48,658

6/14/2021

6/13/2022

3.00%





















7

County of Contra Costa

Animal Services Clerk

$ 45,016

$ 50,643

-11.1%

$ 45,022

7/1/2021

unknown

Unknown

8

County of Ventura

N/C















9

County of Sacramento

N/C















10

County of Los Angeles

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,304

$ 51,058

% County of San Diego Above/Below

-20.2%

-11.0%

Number of Matches

6

6

N/C - Non Comparator

Page 28 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Appraiser I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Appraiser 1

$ 60,258

$81,182

-2.0%

$ 79,559

7/2/2021

7/1/2022

3.50%

2

County of Ventura

Appraiser 1

$ 53,560

$ 74,907

-0.7%

$ 74,383

1/10/2021

1/9/2022

2.00%

3

County of Sacramento

Real Property Appraiser II

$ 61,095

$ 74,249

0.1%

$ 74,323

6/21/2020

unknown

unknown

4

County of Alameda1

[Appraiser 1/ Appraiser II]

$ 72,043

$ 82,534

-11.4%

$73,125

6/27/2021

6/26/2022

3.25%

5

County of Riverside

Appraiser 1

$ 46,800

$ 69,252

1.9%

$ 70,568

5/1/2021

5/1/2022

2.00%

6

County of San Diego

Appraiser 1

$ 57,283

$ 70,450



$ 70,450

6/18/2021

unknown

unknown

7

County of Santa Clara

Appraiser 1

$ 69,518

$ 83,963

-16.8%

$ 69,858

6/14/2021

6/13/2022

3.00%

8

County of Contra Costa

Junior Appraiser

$ 70,833

$ 78,093

-11.1%

$ 69,425

7/1/2021

unknown

unknown

9

County of San Mateo2

Appraiser 1

$ 71,343

$ 79,725

-17.5%

$ 65,773

10/4/2020

unknown

unknown

10

County of Fresno

Appraiser 1

$ 43,342

$ 52,702

4.7%

$55,179

10/17/2019

unknown

unknown

11

County of Kern

Appraiser 1

$ 43,248

$ 52,800

1.2%

$ 53,434

4/21/2021

unknown

unknown

12

City and County of San Francisco

N/C















13

County of Los Angeles

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,500

$ 70,213

% County of San Diego Above/Below

-8.6%

0.3%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower
level classification at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Bottom of range is step 3.

Page 29 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Appraiser II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Appraiser

$51,631

$ 93,779

-3.8%

$ 90,215

1/1/2021

unknown

unknown

2

City and County of San Francisco

Real Property Appraiser

$ 89,028

$ 108,216

-17.4%

$ 89,386

7/1/2021

1/8/2022

.50%

3

County of Orange

Appraiser II

$ 67,246

$ 90,522

-2.0%

$ 88,711

7/2/2021

7/1/2022

3.50%

4

County of Sacramento

Associate Real Property Appraiser

$ 71,723

$ 87,174

0.1%

$ 87,261

6/21/2020

unknown

unknown

5

County of Ventura

Appraiser II

$ 61,761

$ 86,582

-0.7%

$ 85,976

1/10/2021

1/9/2022

2.00%

6

County of Riverside

Appraiser II

$ 55,092

$ 81,552

1.9%

$ 83,101

5/1/2021

5/1/2022

2.00%

7

County of San Mateo

Appraiser II

$ 78,851

$ 98,590

-17.5%

$ 81,337

10/4/2020

unknown

unknown

8

County of San Bernardino

Appraiser II

$ 58,074

$ 79,789

1.9%

$ 81,305

7/31/2021

7/30/2022

3.00%

9

County of Santa Clara

Appraiser II

$ 80,361

$ 97,221

-16.8%

$ 80,888

6/14/2021

6/13/2022

3.00%

10

County of San Diego

Appraiser II

$ 65,520

$ 80,454



$ 80,454

6/18/2021

unknown

unknown

11

County of Alameda

Appraiser II

$ 74,112

$ 88,709

-11.4%

$ 78,596

6/27/2021

6/26/2022

3.25%

12

County of Contra Costa

Assistant Appraiser

$ 70,973

$ 86,268

-11.1%

$ 76,693

7/1/2021

unknown

unknown

13

County of Fresno

Appraiser II

$ 50,024

$ 60,788

4.7%

$ 63,645

10/17/2019

unknown

unknown

14

County of Kern

Appraiser II

$ 48,744

$ 59,508

1.2%

$ 60,222

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,174

$ 81,337

% County of San Diego Above/Below

-8.4%

-1.1%

Number of Matches

13

13

N/C - Non Comparator

Page 30 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Appraiser III	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Real Property Appraiser

$ 103,092

$ 125,292

-17.4%

$ 103,491

7/1/2021

1/8/2022

.50%

2

County of Orange

Appraiser III

$ 74,589

$ 100,485

-2.0%

$ 98,475

7/2/2021

7/1/2022

3.50%



County of San Diego

Appraiser III

$ 73,840

$ 90,792



$ 90,792

6/18/2021

unknown

unknown

4

County of Ventura3

[Appraiser 11/Appraiser III]

$ 65,150

$ 91,334

-0.7%

$ 90,695

1/10/2021

1/9/2022

2.00%

5

County of Alameda

Appraiser III

$ 84,099

$ 101,273

-11.4%

$ 89,728

6/27/2021

6/26/2022

3.25%

6

County of San Bernardino

Appraiser III

$ 63,918

$ 87,942

1.9%

$ 89,613

7/31/2021

7/30/2022

3.00%

7

County of Santa Clara

Appraiser III

$ 88,159

$ 106,669

-16.8%

$ 88,748

6/14/2021

6/13/2022

3.00%

8

County of San Mateo2

[Appraiser ll/Senior Appraiser]

$ 84,197

$ 105,267

-17.5%

$ 86,845

10/4/2020

unknown

unknown

9

County of Contra Costa1

[Assistant Appraiser/Associate Appraiser]

$ 77,813

$ 94,582

-11.1%

$ 84,083

7/1/2021

unknown

unknown

10

County of Fresno

Appraiser III

$ 58,968

$ 71,656

4.7%

$ 75,024

10/17/2019

unknown

unknown

11

County of Kern

Appraiser III

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

12

County of Los Angeles

N/C















13

County of Riverside

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 97,533

$ 89,181

% County of San Diego Above/Below

-7.4%

1.8%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

3	- County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at
the comparator agency. The salary displayed is an average of the matches.

Page 31 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Appraiser IV	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Principal Appraiser

$ 83,408

$ 112,091

-2.0%

$ 109,849

7/2/2021

7/1/2022

3.50%

2

County of Los Angeles

Appraiser Specialist 1

$ 77,559

$ 104,517

-3.8%

$ 100,545

1/1/2021

unknown

unknown





Appraiser IV

$ 81,328

$ 99,882



$ 99,882

6/18/2021

unknown

unknown

4

County of Sacramento

Senior Real Property Appraiser

$ 78,947

$ 95,964

0.1%

$ 96,060

6/21/2020

unknown

unknown

5

County of Ventura

Appraiser III

$ 68,539

$ 96,088

-0.7%

$ 95,416

1/10/2021

1/9/2022

2.00%

6

County of San Mateo

Senior Appraiser

$ 89,542

$ 111,943

-17.5%

$ 92,353

10/4/2020

unknown

unknown

7

County of Contra Costa

Associate Appraiser

$ 84,652

$ 102,895

-11.1%

$ 91,474

7/1/2021

unknown

unknown

8

County of Riverside

Senior Appraiser

$ 59,301

$ 87,758

1.9%

$ 89,425

5/1/2021

5/1/2022

2.00%

9

County of Fresno

Special Properties Appraiser

$ 67,860

$ 82,498

4.7%

$ 86,375

4/19/2021

unknown

unknown

10

County of Alameda

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of San Bernardino

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 99,492

$ 93,885

% County of San Diego Above/Below

0.4%

6.0%

Number of Matches

8

8

N/C - Non Comparator

Page 32 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Appraiser Trainee	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

AppraiserTrainee

$ 51,274

$ 69,322

-0.7%

$ 68,837

1/10/2021

1/9/2022

2.00%

2

County of Alameda

Appraiser 1

$ 69,965

$ 76,367

-11.4%

$ 67,661

6/27/2021

6/26/2022

3.25%

3

City and County of San Francisco

Real Property AppraiserTrainee

$67,164

$ 81,564

-17.4%

$ 67,372

7/1/2021

1/8/2022

.50%

4

County of Orange

AppraiserTrainee

$ 48,942

$ 65,354

-2.0%

$ 64,046

7/2/2021

7/1/2022

3.50%

5

County of Santa Clara

Appraisal Aide

$ 62,483

$ 75,492

-16.8%

$ 62,809

6/14/2021

6/13/2022

3.00%

6

County of Sacramento

Real Property Appraiser 1

$ 50,634

$ 61,533

0.1%

$ 61,595

6/21/2020

unknown

unknown

7

County of Riverside

AppraiserTrainee

$ 40,280

$ 59,560

1.9%

$ 60,692

5/1/2021

5/1/2022

2.00%

8

County of San Diego

AppraiserTrainee

$ 47,195

$ 57,949



$ 57,949

6/18/2021

unknown

unknown

9

County of San Bernardino

AppraiserTrainee

$ 41,454

$ 55,640

1.9%

$ 56,697

7/31/2021

7/30/2022

3.00%

10

County of Contra Costa

N/C















11

County of San Mateo

N/C















12

County of Kern

N/C















13

County of Fresno

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,338

$ 63,428

% County of San Diego Above/Below

-16.2%

-9.5%

Number of Matches

8

8

N/C - Non Comparator

Page 33 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assessment Clerk





















1

City and County of San Francisco

Clerk

$ 55,488

$ 67,416

-17.4%

$ 55,686

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Assessment Clerk

$ 52,915

$ 63,792

-16.8%

$ 53,075

6/14/2021

6/13/2022

3.00%

3

County of Alameda1

[Clerk 11/ Assessor's Technician]

$ 51,675

$ 59,699

-11.4%

$ 52,894

6/27/2021

6/26/2022

3.25%

4

County of San Bernardino

Records Technician Trainee/Records Technician

$ 35,454

$ 48,204

1.9%

$ 49,120

7/31/2021

7/30/2022

3.00%

5

County of Orange

Assessment Technician Trainee

$ 36,920

$ 48,942

-2.0%

$ 47,964

7/2/2021

7/1/2022

3.50%

6

County of Sacramento

Office Specialist 1

$ 38,190

$ 46,416

0.1%

$ 46,462

6/21/2020

unknown

unknown



















8

County of Ventura

Records Technician 1

$ 31,271

$ 43,689

-0.7%

$ 43,383

12/27/2020

12/26/2021

2.00%

9

County of Kern

Assessment Technician

$ 32,064

$ 39,144

1.2%

$ 39,614

4/21/2021

unknown

unknown

10

County of Contra Costa

N/C















11

County of Riverside

N/C















12

County of San Mateo

N/C















13

County of Fresno

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 48,573

$ 48,542

% County of San Diego Above/Below

-10.3%

-10.2%

Number of Matches

8

8

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 34 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Air Pollution Chemist*









































2

Bay Area Air Quality Management District

Air Quality Chemist 1

$ 83,450

$ 101,434

-17.4%

$ 83,785

11/8/2020

unknown

unknown

3

South Coast Air Quality Management District

Assistant Air Quality Chemist

$ 63,624

$ 85,488

-2.8%

$ 83,094

1/1/2020

unknown

unknown

4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Contra Costa

N/C















6

County of Orange

N/C















7

County of Ventura

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,461

$ 83,439

% County of San Diego Above/Below

-11.2%

0.7%

Number of Matches

2

2

N/C - Non Comparator

Page 35 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Air Resources Specialist*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Specialist (Assistant)

$ 84,056

$ 102,171

0.1%

$ 102,273

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Air Quality Engineer 1

$ 76,440

$ 102,684

-2.8%

$ 99,809

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Staff Specialist 1

$ 89,786

$ 109,136

-17.4%

$90,146

11/8/2020

unknown

unknown





















5

County of Kern

Air Quality Specialist 1

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

6

County of Orange

N/C















7

County of Ventura

N/C















8

County of Contra Costa

N/C















9

San Luis Obispo County Air Pollution Control District

N/C















10

Imperial County Air Pollution Control District

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 102,427

$ 94,978

% County of San Diego Above/Below

-31.2%

-21.7%

Number of Matches

4

4

N/C - Non Comparator

Page 36 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Airport Manager





















1

County of Orange

Airport Maintenance Superintendent

$ 85,030

$ 114,587

-2.0%

$ 112,295

7/2/2021

7/1/2022

3.50%

2

County of Ventura1

[Airport Operations Supervisor/ Deputy Director Airports]

$ 80,511

$ 112,784

-0.7%

$ 111,995

unknown

unknown

unknown

3

County of Santa Clara

Assistant Director of County Airports

$ 108,418

$ 131,785

-16.8%

$ 109,645

6/28/2021

6/27/2022

3.00%

4

County of Sacramento

Airport Operations Officer

$ 87,487

$ 96,466

0.1%

$ 96,562

6/21/2020

unknown

unknown

5

County of Contra Costa

Airport Operations Manager

$ 85,471

$ 103,890

-11.1%

$ 92,359

7/1/2021

unknown

unknown

6

County of Riverside

Airport Supervisor

$ 59,372

$ 87,913

1.9%

$ 89,584

5/1/2021

5/1/2022

2.00%





















8

County of San Mateo

Airport Operations Supervisor

$ 84,072

$ 105,059

-17.5%

$ 86,674

10/4/2020

unknown

unknown

9

County of San Bernardino

Airport Operations Supervisor

$ 61,381

$ 84,365

1.9%

$ 85,968

7/31/2021

7/30/2022

3.00%

10

County of Los Angeles

Assistant Airport Manager

$ 48,913

$ 65,912

-3.8%

$ 63,407

1/1/2021

unknown

unknown

11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Fresno

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,890

$ 92,359

% County of San Diego Above/Below

-19.8%

-6.5%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 37 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant APC Engineer*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Engineer (Assistant)

$ 84,056

$ 102,171

0.1%

$ 102,273

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Air Quality Engineer 1

$ 76,440

$ 102,684

-2.8%

$ 99,809

1/1/2020

unknown

unknown

3

San Luis Obispo County Air Pollution Control District

Air Pollution Control Engineer 1

$ 76,960

$ 93,538

2.9%

$ 96,250

7/1/2020

unknown

unknown

4

Bay Area Air Quality Management District

Air Quality Engineer 1

$ 94,276

$ 114,593

-17.4%

$ 94,654

11/8/2020

unknown

unknown

5

County of Kern

Air Quality Engineer 1

$ 72,648

$ 88,692

1.2%

$ 89,756

4/21/2021

unknown

unknown





















7

Imperial County Air Pollution Control District

Air Pollution Control Engineer 1

$ 54,492

$ 69,612

5.6%

$ 73,510

7/3/2020

unknown

unknown

8

County of Ventura

N/C















9

County of Orange

N/C















10

County of Contra Costa

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 97,854

$ 95,452

% County of San Diego Above/Below

-10.7%

-8.0%

Number of Matches

6

6

N/C - Non Comparator

Page 38 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Assistant Child Support Officer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Child Support Officer 1

$69,108

$ 83,976

-17.4%

$ 69,364

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Child Support Specialist

$ 61,412

$ 74,187

-16.8%

$ 61,724

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Child Support Specialist 1

$ 58,301

$ 72,861

-17.5%

$ 60,110

10/4/2020

unknown

unknown

4

County of Alameda

Child Support Specialist 1

$ 54,864

$ 66,683

-11.4%

$ 59,081

6/27/2021

6/26/2022

3.25%

5

County of Sacramento

Child Support Officer 1

$ 48,316

$ 58,756

0.1%

$ 58,815

6/21/2021

unknown

unknown

6

County of Riverside

Child Support Interviewer

$ 36,610

$57,168

1.9%

$ 58,254

5/1/2021

5/1/2022

2.00%

7

County of Ventura

Child Support Services Specialist 1

$ 42,936

$ 54,769

-0.7%

$ 54,386

12/26/2020

12/27/2021

2.00%

8

County of Contra Costa

Child Support Specialist 1

$ 49,083

$ 59,661

-11.1%

$ 53,038

7/1/2021

unknown

unknown

9

County of San Bernardino

Child Support Officer Trainee

$ 38,584

$ 51,813

1.9%

$ 52,797

7/31/2021

7/30/2022

3.00%

10

County of Los Angeles

Child Support Specialist 1

$ 39,760

$ 53,450

-3.8%

$ 51,419

1/1/2021

unknown

unknown

11

County of San Diego

Assistant Child Support Officer

$ 38,397

$ 47,216



$ 47,216

6/18/2021

unknown

unknown

12

County of Kern

Child Support Specialist 1

$ 37,608

$45,912

1.2%

$ 46,463

4/21/2021

unknown

unknown

13

County of Fresno

Child Support Specialist 1

$ 34,450

$ 41,886

4.7%

$ 43,855

10/19/2020

unknown

unknown

14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 57,962

$ 56,320

% County of San Diego Above/Below

-22.8%

-19.3%

Number of Matches

12

12

N/C - Non Comparator

Page 39 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Division Chief, Assessor/Recorder/County Clerk





















1

County of Riverside

Principal Deputy Assessor-Clerk-Recorder

$ 83,014

$ 125,969

1.9%

$ 128,363

7/1/2021

7/14/2022

2.00%

2

County of Los Angeles

Assistant Division Manager, Registrar-Recorder/County Clerk

$ 97,794

$ 131,790

-3.8%

$ 126,782

1/1/2021

unknown

unknown

3

County of Orange

Managing Appraiser

$ 92,893

$ 125,070

-2.0%

$ 122,569

7/2/2021

7/1/2022

3.50%





















5

County of Sacramento

Assistant Deputy Clerk/Recorder

$ 65,939

$80,158

0.1%

$ 80,238

6/21/2020

unknown

unknown

6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

County of Alameda

N/C















9

City and County of San Francisco

N/C















10

County of Santa Clara

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of San Mateo

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 125,520

$ 124,675

% County of San Diego Above/Below

-50.9%

-49.9%

Number of Matches

4

4

N/C - Non Comparator

Page 40 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Assistant Engineer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Assistant Civil Engineer

$ 71,712

$ 106,212

1.9%

$ 108,230

5/1/2021

5/1/2022

2.00%

2

City and County of San Francisco

Assistant Engineer

$ 105,120

$ 127,764

-17.4%

$ 105,533

7/1/2021

1/8/2022

.50%

3

County of Sacramento

Assistant Engineer - Civil II

$ 81,996

$ 104,630

0.1%

$ 104,735

6/21/2020

unknown

unknown

4

County of Alameda1

[Junior Engineer/ Assistant Engineer]

$ 92,175

$ 106,662

-11.4%

$ 94,503

2/7/2021

2/6/2022

3.50%

5

County of San Diego

Assistant Engineer

$ 71,947

$ 92,893



$ 92,893

6/18/2021

unknown

unknown

6

County of San Bernardino

Engineer 1

$ 63,502

$ 89,482

1.9%

$ 91,182

3/13/2021

3/26/2022

3.00%

7

County of Orange

Junior Engineer/Architect

$ 67,912

$ 91,541

-2.0%

$ 89,710

7/2/2021

7/1/2022

3.50%

8

County of San Mateo

Assistant Engineer

$ 86,568

$ 108,179

-17.5%

$ 89,247

2/21/2021

unknown

unknown

9

County of Los Angeles

Civil Engineering Assistant

$ 76,238

$ 92,175

-3.8%

$ 88,673

1/1/2021

unknown

unknown

10

County of Santa Clara

Junior Civil Engineer

$ 87,464

$ 106,142

-16.8%

$ 88,310

10/21/2020

10/20/2021

3.00%

11

County of Ventura

Engineer 1

$ 56,570

$ 85,221

-0.7%

$ 84,624

1/10/2021

1/9/2022

2.00%

12

County of Contra Costa

Engineer - Entry Level

$ 79,463

$ 94,456

-11.1%

$ 83,972

7/1/2021

unknown

unknown

13

County of Fresno

Engineer 1

$ 62,556

$ 76,024

4.7%

$ 79,597

1/11/2021

11/15/2021

3.00%

14

County of Kern

Engineer 1

$ 59,508

$ 72,648

1.2%

$ 73,520

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 94,456

$ 89,247

% County of San Diego Above/Below

-1.7%

3.9%

Number of Matches

13

13

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

Page 41 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Assistant Health Physicist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Assistant Health Physicist

$ 76,482

$ 94,037

$ 94,037

6/18/2021

unknown

unknown

2

County of Orange

N/C















3

County of Ventura

N/C















4

County of Contra Costa

N/C















5

County of Sacramento

N/C















6

City and County of San Francisco

N/C















7

County of Santa Clara

N/C















8

County of Los Angeles

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Alameda

N/C















12

County of San Mateo

N/C















13

County of San Bernardino

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 42 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Manager, Sheriff's Food Services





















1

County of Riverside

Sheriff's Food Services Administrator

$ 83,589

$ 126,845

1.9%

$ 129,255

7/1/2021

7/14/2022

2.00%

2

County of Los Angeles

Assistant Manager, Food Services, Sheriff

$ 91,043

$ 122,688

-3.8%

$ 118,026

1/1/2021

unknown

unknown

3

County of Santa Clara

Assistant Director, Food Services

$ 104,753

$ 127,363

-16.8%

$ 105,966

6/28/2021

6/27/2022

3.00%





















5

County of Sacramento

Food Service Program Manager

$ 84,021

$ 92,624

0.1%

$92,717

6/21/2020

unknown

unknown

6

County of San Bernardino

Sheriff's Food Services Manager

$ 65,998

$ 90,750

1.9%

$ 92,475

7/31/2021

7/30/2022

3.00%

7

County of Contra Costa1

[Flead Detention Cook/Sheriff's Director of Food Services]

$83,106

$ 96,999

-11.1%

$ 86,232

7/1/2021

unknown

Unknown

8

County of Alameda

Food and Support Services Manager

$ 77,189

$ 93,746

-11.4%

$ 83,059

12/27/2020

12/26/2021

3.00%

9

County of San Mateo

Food Service Unit Manager

$ 70,843

$ 88,585

-17.5%

$ 73,083

12/13/2020

unknown

unknown

10

County of Ventura

Supervisor - Sheriff Food Services

$ 57,981

$ 73,133

-0.7%

$ 72,621

12/26/2020

12/27/2021

2.00%

11

County of Orange

N/C















12

City and County of San Francisco

N/C















13

County of Fresno

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,746

$ 92,475

% County of San Diego Above/Below

2.4%

3.7%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 43 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Meteorologist





















1

South Coast Air Quality Management District

Meteorologist

$ 79,752

$ 107,167

-2.8%

$ 104,167

1/1/2020

unknown

unknown

2

Bay Area Air Quality Management District

Air Quality Meteorologist 1

$ 92,004

$ 111,831

-17.4%

$92,372

11/8/2020

unknown

Unknown





















4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Contra Costa

N/C















6

County of Orange

N/C















7

County of Ventura

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 109,499

$98,270

% County of San Diego Above/Below

-28.4%

-15.3%

Number of Matches

2

2

N/C - Non Comparator

Page 44 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Procurement Specialist





















1

City and County of San Francisco

Assistant Purchaser

$ 70,440

$ 85,692

-17.4%

$ 70,782

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Procurement and Contracts Assistant/ Procurement and Contracts Specialist 1]

$ 67,217

$ 78,702

-11.4%

$ 69,730

6/27/2021

6/26/2022

3.25%

3

County of San Mateo

Buyer 1

$ 66,205

$ 82,762

-17.5%

$ 68,278

10/4/2020

unknown

unknown

4

County of Riverside

Senior Buyer Assistant

$ 42,683

$ 66,649

1.9%

$ 67,915

5/1/2021

5/1/2022

2.00%

5

County of Ventura

Buyer

$48,126

$ 67,345

-0.7%

$ 66,873

12/27/2020

12/26/2021

2.00%

6

County of San Bernardino

Buyer 1

$ 45,739

$ 61,381

1.9%

$ 62,547

7/31/2021

7/30/2022

3.00%

7

County of Fresno

Purchasing Analyst 1

$ 48,776

$ 59,306

4.7%

$ 62,093

4/19/2021

unknown

unknown





















9

County of Orange

Procurement Buyer Trainee

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

10

County of Santa Clara

Buyer Assistant

$ 55,517

$ 67,009

-16.8%

$ 55,752

6/14/2021

6/13/2022

3.00%

11

County of Sacramento

Contract Services Specialist 1

$ 43,117

$ 52,388

0.1%

$ 52,440

6/21/2020

unknown

unknown

12

County of Kern

Buyer 1

$ 35,784

$ 43,680

1.2%

$ 44,204

4/21/2021

unknown

unknown

13

County of Contra Costa

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,649

$ 62,547

% County of San Diego Above/Below

-10.6%

-3.8%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is
an average of the matches.

Page 45 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Real Property Agent





















1

County of Orange

Real Property Agent II

$ 63,586

$ 85,717

-2.0%

$ 84,003

7/2/2021

7/1/2022

3.50%

2

County of Ventura1

[Real Property Agent 1/ Real Property Agent II]

$ 57,603

$ 81,199

-0.7%

$ 80,630

12/27/2020

12/26/2021

2.00%

3

County of Sacramento

Real Estate Officer 1

$ 65,814

$ 79,991

0.1%

$ 80,071

6/21/2020

unknown

unknown

4

County of Los Angeles

Real Property Agent 1

$ 62,134

$ 79,302

-3.8%

$ 76,288

1/1/2021

unknown

unknown

5

County of Santa Clara

Assistant Real Estate Agent

$ 72,933

$ 88,207

-16.8%

$ 73,388

6/14/2021

6/13/2022

3.00%

6

County of Contra Costa

Assistant Real Property Agent

$ 65,550

$ 79,677

-11.1%

$ 70,833

7/1/2021

unknown

Unknown





















8

County of Riverside

Real Property Agent 1

$ 39,882

$ 58,957

1.9%

$ 60,078

5/1/2021

5/1/2022

2.00%

9

County of Kern

Real Property Agent 1

$ 41,976

$ 51,240

1.2%

$ 51,855

4/21/2021

unknown

unknown

10

County of Alameda

N/C















11

City and County of San Francisco

N/C















12

County of Fresno

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,834

$ 74,838

% County of San Diego Above/Below

-18.8%

-11.3%

Number of Matches

8

8

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 46 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Assistant Surveyor





















1

County of Los Angeles

Survey Party Chief II

$ 91,717

$ 117,064

-3.8%

$ 112,616

1/1/2021

unknown

unknown

2

County of Alameda1

[Survey Technician III/ Land Surveyor]

$ 109,179

$ 120,983

-11.4%

$ 107,191

10/4/2020

10/3/2021

3.25%

3

County of Sacramento

Assistant Land Surveyor

$ 81,996

$ 104,630

0.1%

$ 104,735

6/21/2020

unknown

unknown

4

City and County of San Francisco

Survey Associate

$ 101,112

$ 122,928

-17.4%

$ 101,539

7/1/2021

1/8/2022

.50%





















6

County of Orange

Surveyor 1

$ 59,738

$ 80,538

-2.0%

$ 78,927

7/2/2021

7/1/2022

3.50%

7

County of Kern

Engineer 1

$ 59,508

$ 72,648

1.2%

$ 73,520

4/21/2021

unknown

unknown

8

County of Ventura

N/C















9

County of Contra Costa

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Fresno

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 110,847

$ 103,137

% County of San Diego Above/Below

-19.3%

-11.0%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

Page 47 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Assistant Transportation Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Assistant Transportation Specialist

$ 74,672

$ 91,832



$ 91,832

6/18/2021

unknown

unknown

2

County of San Mateo

Associate Management Analyst

$ 86,152

$ 107,679

-17.5%

$ 88,836

12/13/2020

unknown

unknown

3

County of San Bernardino

Transportation Analyst 1

$ 59,883

$ 82,326

1.9%

$ 83,891

7/31/2021

7/30/2022

3.00%

4

County of Santa Clara

Assistant Planner

$ 78,684

$ 95,260

-16.8%

$ 79,256

6/14/2021

6/13/2022

3.00%

5

County of Alameda

Junior Transportation Planner

$ 67,267

$ 81,640

-11.4%

$ 72,333

2/7/2021

2/6/2022

3.50%

6

County of Kern

Planner 1

$ 50,988

$ 62,244

1.2%

$ 62,991

4/21/2021

unknown

unknown

7

County of Ventura

N/C















8

County of Orange

N/C















9

County of Contra Costa

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

City and County of San Francisco

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,326

$ 79,256

% County of San Diego Above/Below

10.4%

13.7%

Number of Matches

5

5

N/C - Non Comparator

Page 48 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Assistant Weapons Coordinator	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Armorer

$ 45,491

$ 71,070

1.9%

$ 72,420

5/1/2021

5/1/2022

2.00%

2

County of Orange

Weapons Instructor, Sheriff

$ 54,808

$ 73,403

-2.0%

$ 71,935

7/2/2021

7/1/2022

3.50%

3

County of San Diego

Assistant Weapons Coordinator

$ 58,282

$ 71,573



$ 71,573

6/18/2021

unknown

unknown

4

County of Santa Clara

Rangemaster 1 - U

$ 64,686

$78,127

-16.8%

$ 65,002

6/14/2021

6/13/2022

3.00%

5

County of Ventura

N/C















6

County of Contra Costa

N/C















7

County of Alameda

N/C















8

City and County of San Francisco

N/C















9

County of Los Angeles

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,403

$ 71,935

% County of San Diego Above/Below

-2.6%

-0.5%

Number of Matches

3

3

N/C - Non Comparator

Page 49 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Associate Accountant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Accountant/Auditor II

$ 64,418

$ 86,840

-2.0%

$ 85,103

7/2/2021

7/1/2022

3.50%

2

City and County of San Francisco

Accountant II

$ 83,232

$ 101,064

-17.4%

$ 83,479

7/1/2021

1/8/2022

.50%

3

County of Ventura

Accountant II

$ 59,125

$ 82,775

-0.7%

$ 82,196

12/27/2020

12/26/2021

2.00%

4

County of Sacramento

Accountant

$ 65,960

$ 80,179

0.1%

$ 80,259

6/21/2020

unknown

unknown

5

County of San Mateo

Accountant II

$ 75,918

$ 94,888

-17.5%

$ 78,282

10/4/2020

unknown

unknown

6

County of Santa Clara

Accountant II - U

$ 75,119

$ 90,852

-16.8%

$ 75,589

6/14/2021

6/13/2022

3.00%

7

County of Riverside

Accountant II

$ 49,234

$ 72,884

1.9%

$ 74,269

5/1/2021

5/1/2022

2.00%

8

County of San Bernardino

Accountant II

$ 52,978

$ 72,800

1.9%

$ 74,183

7/31/2021

7/30/2022

3.00%

9

County of San Diego

Associate Accountant

$ 60,278

$ 74,110



$ 74,110

6/18/2021

unknown

unknown

10

County of Contra Costa

Accountant II

$ 67,929

$ 82,568

-11.1%

$ 73,403

7/1/2021

unknown

Unknown

11

County of Alameda

Accountant

$ 75,179

$ 82,085

-11.4%

$ 72,728

6/27/2021

6/26/2022

3.25%

12

County of Los Angeles

Accountant II

$ 54,648

$ 73,644

-3.8%

$ 70,846

1/1/2021

unknown

unknown

13

County of Fresno

Accountant II

$53,170

$ 64,610

4.7%

$ 67,647

10/17/2019

unknown

unknown

14

County of Kern

Accountant II

$ 48,744

$ 59,508

1.2%

$ 60,222

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,085

$ 74,269

% County of San Diego Above/Below

-10.8%

-0.2%

Number of Matches

13

13

N/C - Non Comparator

Page 50 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Associate Air Pollution Chemist*





















1

South Coast Air Quality Management District

Air Quality Chemist

$ 76,440

$ 102,684

-2.8%

$ 99,809

1/1/2020

unknown

unknown





















3

Bay Area Air Quality Management District

Air Quality Chemist II

$ 92,004

$ 111,831

-17.4%

$ 92,372

11/8/2020

unknown

Unknown

4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 107,258

$ 96,091

% County of San Diego Above/Below

-10.2%

1.3%

Number of Matches

2

2

N/C - Non Comparator

Page 51 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Associate Air Pollution Control Engineer*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Engineer (Associate)

$ 97,627

$ 118,666

0.1%

$ 118,785

7/1/2021

unknown

unknown

2

San Luis Obispo County Air Pollution Control District

Air Pollution Control Engineer II

$ 86,278

$ 104,874

2.9%

$ 107,915

7/1/2020

unknown

unknown

3

South Coast Air Quality Management District

Air Quality Engineer II

$ 80,952

$ 108,780

-2.8%

$ 105,734

1/1/2020

unknown

unknown

4

Bay Area Air Quality Management District

Air Quality Engineer II

$ 103,939

$ 126,339

-17.4%

$ 104,356

11/8/2020

unknown

Unknown

5

County of Kern

Air Quality Engineer II

$ 84,372

$ 102,996

1.2%

$ 104,232

4/21/2021

unknown

unknown





















7

Imperial County Air Pollution Control District

Air Pollution Control Engineer II

$ 57,396

$ 73,308

5.6%

$ 77,413

7/3/2020

unknown

unknown

8

County of Ventura

N/C















9

County of Orange

N/C















10

County of Contra Costa

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,827

$ 105,045

% County of San Diego Above/Below

-4.1%

-2.4%

Number of Matches

6

6

N/C - Non Comparator

Page 52 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Associate Air Resources Specialist*





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Specialist (Associate)

$ 97,627

$ 118,666

0.1%

$ 118,785

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Air Quality Engineer II

$ 80,952

$ 108,780

-2.8%

$ 105,734

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Staff Specialist II

$ 98,990

$ 120,322

-17.4%

$ 99,386

11/8/2020

unknown

Unknown





















5

County of Kern

Air Quality Specialist II

$ 64,776

$ 79,080

1.2%

$ 80,029

4/21/2021

unknown

unknown

6

County of Orange

N/C















7

County of Ventura

N/C















8

County of Contra Costa

N/C















9

San Luis Obispo County Air Pollution Control District

N/C















10

Imperial County Air Pollution Control District

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 113,723

$ 102,560

% County of San Diego Above/Below

-28.6%

-15.9%

Number of Matches

4

4

N/C - Non Comparator

Page 53 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Associate Health Physicist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Associate Health Physicist

$ 89,690

$ 110,157

$ 110,157

6/18/2021

unknown

unknown

2

County of Los Angeles

Health Physicist

$ 76,616

$ 103,240

-3.8%

$ 99,317

1/1/2021

unknown

unknown

3

County of Orange

N/C















4

County of Ventura

N/C















5

County of Contra Costa

N/C















6

County of Alameda

N/C















7

City and County of San Francisco

N/C















8

County of Santa Clara

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of San Bernardino

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,240

$ 99,317

% County of San Diego Above/Below

6.3%

9.8%

Number of Matches

1

1

N/C - Non Comparator

Page 54 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Associate Meteorologist





















1

South Coast Air Quality Management District

Meteorologist

$ 79,752

$ 107,167

-2.8%

$ 104,167

1/1/2020

unknown

unknown

2

Bay Area Air Quality Management District

Air Quality Meteorologist II

$ 101,434

$ 123,294

-17.4%

$ 101,841

11/8/2020

unknown

Unknown





















4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Contra Costa

N/C















6

County of Orange

N/C















7

County of Ventura

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 115,231

$ 103,004

% County of San Diego Above/Below

-16.7%

-4.3%

Number of Matches

2

2

N/C - Non Comparator

Page 55 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Associate Real Property Agent	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Real Property Officer

$ 107,928

$ 131,124

-17.4%

$ 108,308

7/1/2021

1/8/2022

.50%

2

County of Orange

Real Property Agent III

$ 74,589

$ 100,485

-2.0%

$ 98,475

7/2/2021

7/1/2022

3.50%

3

County of San Mateo

Real Property Agent II

$95,137

$ 118,911

-17.5%

$98,102

10/4/2020

unknown

unknown

4

County of Sacramento

Real Estate Officer II

$ 78,947

$ 95,964

0.1%

$ 96,060

6/21/2020

unknown

unknown

5

County of Los Angeles

Real Property Agent II

$75,119

$ 95,884

-3.8%

$ 92,241

1/1/2021

unknown

unknown

6

County of Santa Clara

Real Estate Agent

$ 91,272

$ 110,448

-16.8%

$ 91,893

6/14/2021

6/13/2022

3.00%

7

County of Contra Costa

Associate Real Property Agent

$ 77,952

$ 99,489

-11.1%

$ 88,445

7/1/2021

unknown

Unknown

8

County of San Bernardino

Real Property Agent II

$ 61,381

$ 84,365

1.9%

$ 85,968

7/31/2021

7/30/2022

3.00%

9

County of Ventura

Real Property Agent II

$ 61,266

$ 85,046

-0.7%

$ 84,450

12/27/2020

12/26/2021

2.00%

10

County of San Diego

Associate Real Property Agent

$ 67,704

$ 83,242



$ 83,242

6/18/2021

unknown

unknown

11

County of Riverside

Real Property Agent II

$ 48,439

$ 71,710

1.9%

$ 73,072

5/1/2021

5/1/2022

2.00%

12

County of Kern

Real Property Agent II

$ 47,304

$ 57,756

1.2%

$ 58,449

4/21/2021

unknown

unknown

13

County of Fresno

N/C















14

County of Alameda

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 95,964

$ 91,893

% County of San Diego Above/Below

-15.3%

-10.4%

Number of Matches

11

11

N/C - Non Comparator

Page 56 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Associate Transportation Specialist





















1

County of Riverside

Associate Transportation Planner

$ 75,476

$ 111,781

1.9%

$ 113,905

5/1/2021

5/1/2022

2.00%

2

County of San Mateo

Senior Management Analyst

$ 109,926

$ 137,444

-17.5%

$ 113,391

12/13/2020

unknown

unknown





















4

County of Contra Costa

Transportation Planner

$ 99,156

$ 120,525

-11.1%

$ 107,147

7/1/2021

unknown

Unknown

5

County of San Bernardino

Transportation Analyst II

$ 65,998

$ 90,750

1.9%

$ 92,475

7/31/2021

7/30/2022

3.00%

6

City and County of San Francisco

Transportation Planner II

$ 91,704

$ 111,492

-17.4%

$ 92,092

7/1/2021

1/8/2022

.50%

7

County of Santa Clara

Associate Planner

$ 88,647

$ 107,305

-16.8%

$ 89,278

6/14/2021

6/13/2022

3.00%

8

County of Ventura

Transportation Analyst

$ 62,153

$ 87,193

-0.7%

$ 86,582

12/27/2020

12/26/2021

2.00%

9

County of Alameda

Assistant Transportation Planner

$ 80,080

$ 97,386

-11.4%

$ 86,284

2/7/2021

2/6/2022

3.50%

10

County of Kern

Planner II

$ 53,592

$ 65,424

1.2%

$ 66,209

4/21/2021

unknown

unknown

11

County of Fresno

N/C















12

County of Los Angeles

N/C















13

County of Orange

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 107,305

$ 92,092

% County of San Diego Above/Below

1.1%

15.1%

Number of Matches

9

9

N/C - Non Comparator

Page 57 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Audit-Appraiser I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Auditor-Appraiser 1

$ 53,556

$ 74,907

-0.7%

$ 74,382

1/10/2021

1/9/2022

2.00%

2

County of Contra Costa

Auditor - Appraiser 1

$ 73,914

$ 81,490

-11.1%

$ 72,444

7/1/2021

unknown

unknown

3

County of San Diego

Audit Appraiser 1

$ 64,709

$ 72,093





6/18/2021

unknown

unknown

4

County of San Bernardino

Auditor-Appraiser 1

$ 51,771

$ 69,306

1.9%

$ 70,622

7/31/2021

7/30/2022

3.00%

5

County of Riverside

Auditor/Appraiser 1

$ 46,800

$ 69,252

1.9%

$ 70,568

5/1/2021

5/1/2022

2.00%

6

County of Santa Clara

Auditor Appraiser 1

$ 69,499

$ 83,938

-16.8%

$ 69,837

6/14/2021

6/13/2022

3.00%

7

County of Orange

Auditor-Appraiser Trainee

$ 51,459

$ 68,890

-2.0%

$ 67,512

7/2/2021

7/1/2022

3.50%

8

County of Alameda

Auditor-Appraiser 1

$ 68,032

$ 74,253

-11.4%

$ 65,788

6/27/2021

6/26/2022

3.25%

9

County of San Mateo1

Auditor-Appraiser 1

$ 71,343

$ 79,725

-17.5%

$ 65,773

10/4/2020

unknown

unknown

10

County of Sacramento

Auditor Appraiser 1

$ 53,160

$ 61,533

0.1%

$ 61,595

6/21/2020

unknown

unknown

11

County of Fresno

Auditor-Appraiser 1

$ 43,342

$ 52,702

4.7%

$ 55,179

10/17/2019

unknown

unknown

12

County of Kern

Auditor-Appraiser 1

$ 43,248

$ 52,800

1.2%

$ 53,434

4/21/2021

unknown

unknown

13

City and County of San Francisco

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,306

$ 67,512

% County of San Diego Above/Below

3.9%

6.4%

Number of Matches

11

11

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 58 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Audit-Appraiser II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Tax Auditor-Appraiser

$ 89,028

$ 108,216

-17.4%

$ 89,386

7/1/2021

1/8/2022

.50%

2

County of San Bernardino

Auditor-Appraiser II

$ 62,421

$ 85,842

1.9%

$ 87,473

7/31/2021

7/30/2022

3.00%

3

County of Ventura

Auditor-Appraiser II

$ 61,761

$ 86,580

-0.7%

$ 85,974

1/10/2021

1/9/2022

2.00%

4

County of Riverside

Auditor/Appraiser II

$ 55,092

$ 81,552

1.9%

$ 83,101

5/1/2021

5/1/2022

2.00%



County of San Diego

Audit Appraiser II

$ 66,997

$ 82,368



$ 82,368

6/18/2021

unknown

unknown

6

County of San Mateo

Auditor-Appraiser II

$ 78,851

$ 98,590

-17.5%

$ 81,337

10/4/2020

unknown

unknown

7

County of Santa Clara

Auditor Appraiser II

$ 80,361

$ 97,221

-16.8%

$ 80,888

6/14/2021

6/13/2022

3.00%

8

County of Alameda

Auditor-Appraiser II

$ 75,924

$ 90,884

-11.4%

$ 80,523

6/27/2021

6/26/2022

3.25%

9

County of Contra Costa

Auditor - Appraiser II

$ 74,428

$ 90,468

-11.1%

$ 80,426

7/1/2021

unknown

unknown

10

County of Orange

Auditor-Appraiser 1

$ 60,258

$ 81,182

-2.0%

$ 79,559

7/2/2021

7/1/2022

3.50%

11

County of Sacramento

Auditor Appraiser II

$ 61,095

$ 74,249

0.1%

$ 74,323

6/21/2020

unknown

unknown

12

County of Fresno

Auditor-Appraiser II

$ 50,024

$ 60,788

4.7%

$ 63,645

10/17/2019

unknown

unknown

13

County of Kern

Auditor-Appraiser II

$ 48,744

$ 59,508

1.2%

$ 60,222

4/21/2021

unknown

unknown

14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,211

$ 80,706

% County of San Diego Above/Below

-4.7%

2.0%

Number of Matches

12

12

N/C - Non Comparator

Page 59 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Audit-Appraiser III





















1

City and County of San Francisco

Senior Tax Auditor-Appraiser

$ 103,092

$ 125,292

-17.4%

$ 103,491

7/1/2021

1/8/2022

.50%

2

County of San Bernardino

Auditor-Appraiser III

$ 67,142

$ 92,373

1.9%

$ 94,128

7/31/2021

7/30/2022

3.00%





















4

County of Alameda

Auditor-Appraiser III

$ 86,152

$ 103,729

-11.4%

$ 91,904

6/27/2021

6/26/2022

3.25%

5

County of Ventura3

[Auditor-Appraiser 11/ Auditor-Appraiser III]

$ 64,314

$ 91,334

-0.7%

$ 90,695

1/10/2021

1/9/2022

2.00%

6

County of Santa Clara

Auditor Appraiser III

$ 88,155

$ 106,667

-16.8%

$ 88,747

6/14/2021

6/13/2022

3.00%

7

County of Orange

Auditor-Appraiser II

$ 67,246

$ 90,522

-2.0%

$ 88,711

7/2/2021

7/1/2022

3.50%

8

County of Contra Costa1

[Auditor - Appraiser ll/Senior Auditor - Appraiser]

$ 81,163

$ 98,654

-11.1%

$ 87,703

7/1/2021

unknown

unknown

9

County of Sacramento

Associate Auditor Appraiser

$ 71,723

$ 87,174

0.1%

$ 87,261

6/21/2020

unknown

unknown

10

County of San Mateo2

[Auditor-Appraiser ll/Senior Auditor-Appraiser]

$ 84,197

$ 105,267

-17.5%

$ 86,845

10/4/2020

unknown

unknown

11

County of Fresno

Auditor-Appraiser III

$ 58,968

$ 71,656

4.7%

$ 75,024

10/17/2019

unknown

unknown

12

County of Kern

Auditor-Appraiser III

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

13

County of Los Angeles

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,373

$ 88,711

% County of San Diego Above/Below

0.8%

4.7%

Number of Matches

11

11

N/C - Non Comparator

1	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

3	- County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 60 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Audit-Appraiser IV









































2

County of Santa Clara

Senior Auditor Appraiser

$ 98,883

$ 119,658

-16.8%

$ 99,556

6/14/2021

6/13/2022

3.00%

3

County of Orange

Auditor-Appraiser III

$ 74,589

$ 100,485

-2.0%

$ 98,475

7/2/2021

7/1/2022

3.50%

4

County of Sacramento

Senior Auditor Appraiser

$ 78,947

$ 95,964

0.1%

$ 96,060

6/21/2020

unknown

unknown

5

County of Ventura

Auditor-Appraiser III

$66,868

$ 96,088

-0.7%

$ 95,416

1/10/2021

1/9/2022

2.00%

6

County of Contra Costa

Senior Auditor-Appraiser

$ 87,898

$ 106,840

-11.1%

$ 94,981

7/1/2021

unknown

Unknown

7

County of San Mateo1

Senior Auditor-Appraiser

$ 89,542

$ 111,943

-17.5%

$ 92,353

10/4/2020

unknown

unknown

8

County of Riverside

Senior Auditor/Appraiser

$ 59,883

$ 88,618

1.9%

$ 90,302

5/1/2021

5/1/2022

2.00%

9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,485

$ 95,416

% County of San Diego Above/Below

1.8%

6.8%

Number of Matches

7

7

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower
level classification at the comparator agency. The salary displayed is an average of the matches.

Page 61 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Biostatistician

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Data Scientist

$ 100,478

$ 135,409

-3.8%

$ 130,264

1/1/2021

unknown

unknown

2

County of San Diego

Biostatistician

$ 71,594

$ 87,942



$ 87,942

6/18/2021

unknown

unknown

3

City and County of San Francisco

Statistician

$82,810

$ 100,646

-17.4%

$83,134

7/1/2021

1/8/2022

.50%

4

County of Orange

Research Analyst II

$ 54,330

$72,717

-2.0%

$71,262

7/2/2021

7/1/2022

3.50%

5

County of Riverside

Statistician

$ 40,730

$ 60,226

1.9%

$61,370

5/1/2021

5/1/2022

2.00%

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$86,681

$77,198

% County of San Diego Above/Below

1.4%

12.2%

Number of Matches

4

4

N/C - Non Comparator

Page 62 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Broadcast Engineer





















1

County of Los Angeles

Telecommunications Systems Engineer

$ 117,357

$ 127,317

-3.8%

$ 122,479

1/1/2021

unknown

unknown

2

County of Santa Clara

Multimedia Technician

$ 101,236

$ 123,055

-16.8%

$ 102,382

6/14/2021

6/13/2022

3.00%

3

County of Riverside

RCIT Voice Engineer II

$ 64,813

$ 97,915

1.9%

$ 99,776

5/1/2021

5/1/2022

2.00%

4

County of Orange

Telecommunications Engineer II

$ 73,528

$ 99,050

-2.0%

$ 97,069

7/2/2021

7/1/2022

3.50%





















6

County of Ventura

Digital Systems Electronics Technician II

$ 66,898

$ 84,316

-0.7%

$ 83,726

1/10/2021

1/9/2022

2.00%

7

County of Kern

Broadcast Engineer

$ 56,052

$ 68,424

1.2%

$ 69,245

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,482

$ 98,422

% County of San Diego Above/Below

-3.5%

-3.4%

Number of Matches

6

6

N/C - Non Comparator

Page 63 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Building Maintenance Supervisor





















1

City and County of San Francisco

Buildings And Grounds Maintenance Supervisor

$ 136,764

$ 136,764

-17.4%

$ 112,967

7/1/2021

1/8/2022

.50%

2

County of Alameda

Supervisor, Building and Plant Maintenance

$ 125,694

$ 125,694

-11.4%

$ 111,365

12/27/2020

unknown

unknown

3

County of Santa Clara

Maintenance Project Manager

$ 107,879

$ 131,188

-16.8%

$ 109,148

6/28/2021

6/27/2022

3.00%

4

County of Sacramento

Senior Stationary Engineer

$ 89,366

$ 108,639

0.1%

$ 108,748

6/21/2020

unknown

unknown

5

County of Contra Costa

Facilities Maintenance Supervisor

$ 96,064

$ 116,766

-11.1%

$ 103,805

7/1/2021

unknown

unknown

6

County of San Mateo

Crafts Supervisor

$ 99,069

$ 123,882

-17.5%

$ 102,203

2/7/2021

2/6/2022

2-4%

7

County of Orange

Senior Maintenance Inspector

$ 74,235

$ 100,027

-2.0%

$ 98,027

7/2/2021

7/1/2022

3.50%

8

County of Ventura1

[Maintenance Engineer/ Manager - Facilities Maintenance]

$ 75,262

$ 94,946

-0.7%

$ 94,281

unknown

unknown

unknown

9

County of Fresno

Facilities Services Supervisor

$ 69,082

$ 84,006

4.7%

$ 87,954

4/19/2021

unknown

unknown

10

County of Riverside

Building Maintenance Supervisor

$ 57,101

$ 84,526

1.9%

$86,132

5/1/2021

5/1/2022

2.00%

11

County of San Bernardino

Maintenance Supervisor

$ 60,923

$ 83,741

1.9%

$ 85,332

7/31/2021

7/30/2022

3.00%





















13

County of Los Angeles

Flead, Building Maintenance, Public Works

$ 60,615

$ 81,681

-3.8%

$ 78,577

1/1/2021

unknown

unknown

14

County of Kern

Maintenance Supervisor

$ 50,232

$ 61,320

1.2%

$ 62,056

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,027

$ 98,027

% County of San Diego Above/Below

-17.3%

-15.0%

Number of Matches

13

13

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 64 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Building/Enforcement Supervisor





















1

Cityand County of San Francisco

Senior Building Inspector

$ 127,428

$ 154,860

-17.4%

$ 127,914

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Supervising Plans Checker/Senior Code Enforcement Investigator]

$ 115,253

$ 139,942

-11.4%

$ 123,989

12/27/2020

unknown

unknown

3

County of Riverside

Supervising Code Enforcement Officer

$ 74,963

$ 120,277

1.9%

$ 122,562

5/1/2021

5/1/2022

2.00%

4

County of Santa Clara

Code Enforcement Program Manager

$ 119,529

$ 145,298

-16.8%

$ 120,888

6/28/2021

6/27/2022

3.00%

5

County of Sacramento

Supervising Building Inspector

$ 88,844

$ 107,991

0.1%

$ 108,099

6/21/2020

unknown

unknown

6

County of San Mateo3

[Senior Code Compliance Officer/Assistant Building Inspector Manager]

$ 104,747

$ 130,923

-17.5%

$ 108,011

12/13/2020

unknown

unknown

7

County of Orange

Senior Building Inspector

$ 77,958

$ 104,749

-2.0%

$ 102,654

7/2/2021

7/1/2022

3.50%





















9

County of San Bernardino

Regional Building Inspector Supervisor

$ 69,243

$95,326

1.9%

$ 97,138

7/31/2021

7/30/2022

3.00%

10

County of Fresno

Supervising Building Inspector

$ 70,330

$ 85,488

4.7%

$ 89,506

4/19/2021

unknown

unknown

11

County of Kern2

[Supervising Building Inspector / Code Compliance Supervisor]

$ 58,920

$ 71,928

1.2%

$ 72,791

4/21/2021

unknown

unknown

12

County of Contra Costa

N/C















13

County of Los Angeles

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 114,134

$ 108,055

% County of San Diego Above/Below

-17.1%

-10.8%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the higher of the matches.

2	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
same for both matches.

3	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 65 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Cadastral Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Engineering Associate II

$ 98,724

$ 119,988

-17.4%

$ 99,110

7/1/2021

1/8/2022

.50%

2

County of San Mateo

GIS Supervisor

$ 93,141

$ 116,415

-17.5%

$ 96,043

10/4/2020

unknown

unknown

3

County of Los Angeles

Supervising Survey-Mapping Technician

$ 77,559

$ 98,999

-3.8%

$ 95,237

1/1/2021

unknown

unknown

4

County of San Diego

Cadastral Supervisor

$ 75,858

$ 93,163



$ 93,163

6/18/2021

unknown

unknown

5

County of Santa Clara

Mapping & I.D. Supervisor

$ 88,219

$ 107,220

-16.8%

$ 89,207

6/28/2021

6/27/2022

3.00%

6

County of Orange

Supervising Cadastral Technician

$ 66,248

$ 89,211

-2.0%

$ 87,427

7/2/2021

7/1/2022

3.50%

7

County of Ventura

Cadastral Technician IV

$ 61,410

$ 86,056

-0.7%

$ 85,453

12/26/2020

12/27/2021

2.00%

8

County of San Bernardino

Cadastral Services Supervisor

$ 59,883

$ 82,326

1.9%

$ 83,891

7/31/2021

7/30/2022

3.00%

9

County of Sacramento

Supervising Cadastral DraftingTechnician

$ 68,716

$ 83,541

0.1%

$ 83,625

6/21/2020

unknown

unknown

10

County of Alameda

Mapping Supervisor

$ 78,582

$ 93,912

-11.4%

$ 83,206

12/27/2020

12/26/2021

3.00%

11

County of Contra Costa

Drafting Services Coordinator

$ 76,575

$ 93,077

-11.1%

$ 82,746

7/1/2021

unknown

unknown

12

County of Fresno

Supervising Cadastral Technician

$ 57,694

$ 73,788

4.7%

$ 77,256

11/2/2020

unknown

unknown

13

County of Kern

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,077

$ 85,453

% County of San Diego Above/Below

0.1%

8.3%

Number of Matches

11

11

N/C - Non Comparator

Page 66 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Cadastral Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Survey-Mapping Technician

$ 65,912

$ 84,131

-3.8%

$ 80,934

1/1/2021

unknown

unknown

2

City and County of San Francisco

Engineering Assistant

$ 76,884

$ 93,468

-17.4%

$ 77,205

7/1/2021

1/8/2022

.50%

3

County of Riverside

Civil Engineering Drafting Technician II

$ 46,695

$ 72,960

1.9%

$ 74,346

5/1/2021

5/1/2022

2.00%

4

County of Orange

Cadastral Technician II

$ 53,539

$ 71,698

-2.0%

$ 70,264

7/2/2021

7/1/2022

3.50%

5

County of Contra Costa

Computer Aided Drafting Operator

$ 64,201

$ 78,037

-11.1%

$ 69,375

7/1/2021

unknown

Unknown

6

County of Ventura

Cadastral Technician II

$ 48,739

$ 68,040

-0.7%

$ 67,564

12/26/2020

12/27/2021

2.00%

7

County of San Mateo

GIS Technician 1

$ 64,437

$ 80,557

-17.5%

$ 66,459

10/4/2020

unknown

unknown

8

County of San Diego

Cadastral Technician

$ 52,520

$ 64,563



$ 64,563

6/18/2021

unknown

unknown

9

County of Santa Clara

Cadastral Mapping Technician II

$ 62,602

$ 75,600

-16.8%

$ 62,899

6/14/2021

6/13/2022

3.00%

10

County of Alameda

MappingTechnician II

$ 57,421

$ 68,435

-11.4%

$ 60,633

6/27/2021

6/26/2022

3.25%

11

County of Fresno

Cadastral Technician II

$ 44,798

$ 57,330

4.7%

$ 60,025

11/2/2020

unknown

unknown

12

County of San Bernardino

Cadastral Drafting Technician 1

$ 42,536

$ 58,490

1.9%

$ 59,601

7/31/2021

7/30/2022

3.00%

13

County of Kern

DraftingTechnician II

$ 48,024

$ 58,620

1.2%

$ 59,323

4/21/2021

unknown

unknown

14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,329

$ 67,012

% County of San Diego Above/Below

-12.0%

-3.8%

Number of Matches

12

12

N/C - Non Comparator

Page 67 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Cashier





















1

City and County of San Francisco

Cashier II

$ 61,776

$ 75,084

-17.4%

$ 62,019

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Cashiering Services Representative 1, Sheriff

$ 38,805

$ 53,583

-3.8%

$ 51,547

1/1/2021

unknown

unknown

3

County of Santa Clara

Cashier

$ 48,949

$ 58,972

-16.8%

$ 49,065

6/14/2021

6/13/2022

3.00%

4

County of Orange

Cashier

$ 37,856

$ 49,691

-2.0%

$ 48,697

7/2/2021

7/1/2022

3.50%





















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















15

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,278

$ 50,306

% County of San Diego Above/Below

-25.0%

-11.7%

Number of Matches

4

4

N/C - Non Comparator

Page 68 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Certified

Murse Assistant

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Nursing Assistant

$ 72,048

$ 87,540

-17.4%

$ 72,308

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Certified Nurse Assistant

$42,151

$ 56,711

-3.8%

$ 54,556

1/1/2021

unknown

unknown

3

County of Riverside

Certified Medical Assistants

$ 29,120

$ 47,545

1.9%

$ 48,448

5/1/2021

5/1/2022

2.00%

4

County of San Diego

Certified Nurse Assistant

$ 35,318

$ 43,430



$ 43,430

6/18/2021

unknown

unknown

5

County of Contra Costa

Certified Nursing Assistant

$ 39,876

$ 48,469

-11.1%

$ 43,089

7/1/2021

unknown

unknown

6

County of Orange

Nursing Assistant

$ 33,176

$43,160

-2.0%

$ 42,297

7/2/2021

7/1/2022

3.50%

7

County of San Bernardino

Patient Care Assistant

$ 30,243

$ 41,205

1.9%

$ 41,988

7/31/2021

7/30/2022

3.00%

8

County of Kern

Nursing Attendant

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

9

County of Alameda

N/C















10

County of Fresno

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 47,545

$ 43,089

% County of San Diego Above/Below

-9.5%

0.8%

Number of Matches

7

7

N/C - Non Comparator

Page 69 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Certified Nurse Practitioner





















1

City and County of San Francisco

Nurse Practitioner

$ 175,296

$ 248,148

-17.4%

$ 204,970

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Nurse Practitioner

$ 181,143

$ 243,483

-16.8%

$ 202,578

10/19/2020

11/1/2021

3.00%

3

County of Los Angeles

Nurse Practitioner

$ 118,224

$ 176,967

-3.8%

$ 170,242

1/1/2021

unknown

unknown

4

County of Contra Costa

Family Nurse Practitioner

$ 143,368

$ 179,047

-11.1%

$ 159,173

1/1/2021

unknown

unknown

5

County of San Mateo1

Nurse Practitioner

$ 161,051

$ 190,358

-17.5%

$ 157,045

2/7/2021

unknown

unknown

6

County of Riverside

Nurse Practitioner - Desert

$ 123,084

$ 143,472

1.9%

$ 146,198

5/1/2021

5/1/2022

2.00%

7

County of Orange

Nurse Practitioner II

$ 114,587

$ 138,611

-2.0%

$ 135,839

7/2/2021

7/1/2022

3.50%

8

County of Kern

Nurse Practitioner

$ 106,128

$ 129,612

1.2%

$ 131,167

4/21/2021

unknown

unknown

9

County of Sacramento

Nurse Practitioner

$ 104,149

$ 126,595

0.1%

$ 126,722

8/2/2020

unknown

unknown

10

County of Ventura

Nurse Practitioner

$ 118,862

$ 127,606

-0.7%

$ 126,713

3/21/2021

4/3/2022

2.50%

11

County of Fresno

Nurse Practitioner

$ 96,590

$ 117,416

4.7%

$ 122,935

11/2/2020

unknown

unknown

12

County of San Bernardino

Nurse Practitioner II

$ 90,085

$ 119,829

1.9%

$ 122,106

8/15/2020

unknown

unknown

13

County of Alameda

Mid-Level Practitioner

$ 105,447

$ 137,124

-11.4%

$ 121,492

6/27/2021

6/26/2022

3.25%





















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 138,611

$ 135,839

% County of San Diego Above/Below

-20.3%

-17.9%

Number of Matches

13

13

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 70 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Chaplain-Coordinator





















1

County of Santa Clara

Spiritual Services Coordinator

$ 87,949

$ 106,431

-16.8%

$ 88,551

6/14/2021

6/13/2022

3.00%

2

City and County of San Francisco

Chaplain

$ 80,520

$ 97,896

-17.4%

$ 80,862

7/1/2021

1/8/2022

.50%

3

County of Riverside

Chaplain

$ 52,466

$ 77,642

1.9%

$79,118

5/1/2021

5/1/2022

2.00%

4

County of Alameda

Chaplain

$ 70,512

$ 86,486

-11.4%

$ 76,627

11/1/2020

10/31/2021

2.00%





















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$92,191

$ 79,990

% County of San Diego Above/Below

-46.3%

-27.0%

Number of Matches

4

4

N/C - Non Comparator

Page 71 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Child Support Officer





















1

City and County of San Francisco

Child Support Officer II

$80,208

$97,500

-17.4%

$80,535

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Child Support Officer II

$ 73,950

$ 89,463

-16.8%

$ 74,433

6/14/2021

6/13/2022

3.00%

3

County of Alameda1

[Child Support Specialist 11/ Child Support Specialist III]

$ 66,743

$81,159

-11.4%

$ 71,907

6/27/2021

6/26/2022

3.25%

4

County of Riverside

Child Support Specialist

$45,760

$ 68,112

1.9%

$ 69,406

5/1/2021

5/1/2022

2.00%





















6

County of San Mateo

Child Support Specialist II

$ 62,524

$ 78,144

-17.5%

$ 64,469

10/4/2020

unknown

unknown

7

County of Los Angeles

Child Support Specialist II

$ 49,032

$ 66,072

-3.8%

$ 63,561

1/1/2021

unknown

unknown

8

County of Orange

Child Support Specialist

$ 48,090

$ 64,813

-2.0%

$ 63,517

7/2/2021

7/1/2022

3.50%

9

County of Sacramento

Child Support Officer II

$ 51,469

$ 62,556

0.1%

$ 62,619

6/21/2021

unknown

unknown

10

County of San Bernardino

Child Support Officer 1

$44,158

$ 60,674

1.9%

$ 61,826

7/31/2021

7/30/2022

3.00%

11

County of Contra Costa

Child Support Specialist II

$ 56,269

$ 68,396

-11.1%

$ 60,804

7/1/2021

unknown

unknown

12

County of Ventura

Child Support Services Specialist II

$47,133

$ 60,115

-0.7%

$ 59,695

12/26/2020

12/27/2021

2.00%

13

County of Fresno

Child Support Specialist II

$ 41,808

$ 50,804

4.7%

$ 53,192

10/19/2020

unknown

unknown

14

County of Kern

Child Support Specialist II

$42,396

$ 51,756

1.2%

$ 52,377

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,072

$ 63,517

% County of San Diego Above/Below

0.2%

4.1%

Number of Matches

13

13

N/C - Non Comparator

1 - County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The
salary displayed is the higher of the matches.

Page 72 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Civil Engineer





















1

County of Sacramento

Associate Civil Engineer

$ 102,500

$ 124,591

0.1%

$ 124,716

6/21/2020

unknown

unknown

2

County of Orange

Civil Engineer

$ 93,995

$ 126,589

-2.0%

$ 124,057

7/2/2021

7/1/2022

3.50%

3

County of Los Angeles

Associate Civil Engineer

$ 100,974

$ 128,899

-3.8%

$ 124,001

1/1/2021

unknown

unknown

4

City and County of San Francisco

Associate Engineer

$ 122,328

$ 148,692

-17.4%

$ 122,820

7/1/2021

1/8/2022

.50%

5

County of San Bernardino

Engineer III

$ 85,155

$ 120,203

1.9%

$ 122,487

3/13/2021

3/26/2022

3.00%

6

County of Ventura

Engineer IV

$ 81,564

$ 122,219

-0.7%

$ 121,364

1/10/2021

1/9/2022

2.00%

7

County of Riverside

Associate Civil Engineer

$ 79,718

$ 118,083

1.9%

$ 120,327

5/1/2021

5/1/2022

2.00%

8

County of San Mateo

Associate Civil Engineer

$ 114,668

$ 143,309

-17.5%

$ 118,230

2/21/2021

unknown

unknown

9

County of Santa Clara

Associate Civil Engineer

$ 114,887

$ 139,645

-16.8%

$ 116,185

10/21/2020

10/20/2021

3.00%

10

County of Alameda1

[Assistant Engineer/ Associate Civil Engineer]

$ 107,471

$ 127,702

-11.4%

$ 113,144

2/7/2021

2/6/2022

3.50%

11

County of Contra Costa

Engineer - Project

$ 109,302

$ 126,757

-11.1%

$ 112,687

7/1/2021

unknown

unknown





















13

County of Fresno

Engineer III

$ 82,342

$ 100,074

4.7%

$ 104,777

1/11/2021

11/15/2021

3.00%

14

County of Kern

Engineer II

$ 69,108

$ 84,372

1.2%

$ 85,384

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 126,589

$ 120,327

% County of San Diego Above/Below

-13.4%

-7.7%

Number of Matches

13

13

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 73 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Clinical Psychologist |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Psychologist

$ 125,842

$ 152,961

-16.8%

$ 127,264

6/14/2021

6/13/2022

3.00%

2

County of Los Angeles

Clinical Psychologist II

$ 99,735

$ 127,317

-3.8%

$ 122,479

1/1/2021

unknown

unknown

3

County of Ventura

Senior Psychologist

$89,172

$ 116,247

-0.7%

$ 115,433

12/27/2020

12/26/2021

2.00%

4

City and County of San Francisco

Clinical Psychologist

$ 110,736

$ 134,556

-17.4%

$ 111,143

7/1/2021

1/8/2022

.50%

5

County of Kern

Clinical Psychologist II

$ 88,248

$ 107,724

1.2%

$ 109,017

4/21/2021

unknown

unknown

6

County of San Mateo

Psychologist II

$ 105,412

$ 131,807

-17.5%

$ 108,741

10/4/2020

unknown

unknown

7

County of Fresno

Licensed Psychologist

$ 82,550

$ 99,294

4.7%

$ 103,961

11/2/2020

unknown

unknown

8

County of San Bernardino

Clinical Therapist 1 - Psychologist

$ 69,930

$ 101,171

1.9%

$ 103,093

3/13/2021

3/26/2022

3.00%

9

County of Orange

Clinical Psychologist 1

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

10

County of Alameda

Clinical Psychologist

$ 103,024

$ 113,091

-11.4%

$ 100,199

6/27/2021

6/26/2022

3.25%

11

County of Riverside

Senior Clinical Psychologist

$61,154

$ 90,585

1.9%

$ 92,306

5/1/2021

5/1/2022

2.00%

12

County of Contra Costa

Clinical Psychologist

$ 72,739

$ 102,778

-11.1%

$ 91,370

7/1/2021

unknown

unknown

13

County of San Diego

Clinical Psychologist

$ 78,437

$ 86,486



$ 86,486

6/18/2021

unknown

unknown

14

County of Sacramento

N/C















Summary Results

Median of Comparators
% County of San Diego Above/Below

Number of Matches

N/C - Non Comparator

Top Annual

Adjusted
Top Annual

$ 110,408
-27.7%

$ 106,351
-23.0%

12

12

Page 74 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Code Enforcement Officer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Code Enforcement Officer II

$ 68,398

$ 106,935

1.9%

$ 108,966

5/1/2021

5/1/2022

2.00%

2

County of Alameda

Zoning Investigator II

$ 86,591

$ 103,428

-11.4%

$ 91,638

6/27/2021

6/26/2022

3.25%

3

County of Santa Clara

Code Enforcement Officer II

$ 89,328

$ 108,120

-16.8%

$ 89,956

6/14/2021

6/13/2022

3.00%

4

County of Ventura

Code Compliance Officer II

$ 62,820

$ 88,100

-0.7%

$ 87,484

12/27/2020

12/26/2021

2.00%

5

County of San Mateo

Code Compliance Officer II

$ 78,664

$ 98,361

-17.5%

$ 81,148

10/4/2020

unknown

unknown

6

County of San Bernardino

Code Enforcement Officer II

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%

7

County of Orange

Code Enforcement Officer

$ 59,384

$ 79,997

-2.0%

$ 78,397

7/2/2021

7/1/2022

3.50%

8

County of San Diego

Code Enforcement Officer

$ 54,413

$ 73,694



$ 73,694

6/18/2021

unknown

unknown

9

County of Sacramento

Code Enforcement Officer II

$ 60,114

$ 73,080

0.1%

$ 73,153

6/21/2020

unknown

unknown

10

County of Kern

Code Compliance Officer

$ 50,724

$ 61,932

1.2%

$ 62,675

4/21/2021

unknown

unknown

11

County of Los Angeles

Code Enforcement Officer

$ 47,380

$ 63,840

-3.8%

$ 61,414

1/1/2021

unknown

unknown

12

City and County of San Francisco

N/C















13

County of Contra Costa

N/C















14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 84,049

$ 80,527

% County of San Diego Above/Below

-14.1%

-9.3%

Number of Matches

10

10

N/C - Non Comparator

Page 75 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Communicable Disease Investigator





















1

County of Los Angeles

Public Health Investigator

$ 62,904

$ 80,283

-3.8%

$ 77,233

1/1/2021

unknown

unknown

2

City and County of San Francisco

Disease Control Investigator

$ 75,216

$ 91,440

-17.4%

$ 75,529

7/1/2021

1/8/2022

.50%

3

County of San Mateo

Communicable Disease Investigator

$ 71,239

$ 89,022

-17.5%

$ 73,443

10/4/2020

unknown

unknown

4

County of Santa Clara

Communicable Disease Investigator

$ 72,072

$ 87,056

-16.8%

$ 72,431

6/14/2021

6/13/2022

3.00%

5

County of Orange

Public Health Investigator

$ 53,622

$ 72,280

-2.0%

$ 70,834

7/2/2021

7/1/2022

3.50%





















7

County of Riverside

Communicable Disease Specialist

$ 44,047

$ 68,789

1.9%

$ 70,096

5/1/2021

5/1/2022

2.00%

8

County of Contra Costa1

[Disease Intervention Technician/Senior Disease Intervention Technician]

$ 64,185

$ 78,018

-11.1%

$ 69,358

7/1/2021

unknown

Unknown

9

County of Alameda

Public Health Investigator

$ 59,274

$ 70,891

-11.4%

$ 62,809

6/27/2021

6/26/2022

3.25%

10

County of San Bernardino

Communicable Disease Investigator 1

$ 44,387

$ 60,986

1.9%

$ 62,144

7/31/2021

7/30/2022

3.00%

11

County of Sacramento

Communicable Disease Investigator II

$ 50,258

$ 61,074

0.1%

$ 61,135

6/21/2020

unknown

unknown

12

County of Fresno

Communicable Disease Specialist II

$ 44,538

$ 56,966

4.7%

$ 59,643

11/2/2020

unknown

unknown

13

County of Kern

Communicable Disease Investigator

$ 39,144

$ 47,784

1.2%

$ 48,357

4/21/2021

unknown

unknown

14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 71,585

$ 69,727

% County of San Diego Above/Below

-1.9%

0.8%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 76 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Community Health Program Specialist





















1

County of Fresno

Public HeaIth Program Manager

$ 73,320

$ 127,536

4.7%

$ 133,530

4/19/2021

unknown

unknown

2

County of Santa Clara

HeaIth Program Specialist

$ 114,390

$ 139,052

-16.8%

$ 115,691

6/28/2021

6/27/2022

3.00%

3

County of Sacramento

Fluman Services Program Specialist

$ 82,998

$ 100,892

0.1%

$ 100,993

6/21/2020

unknown

unknown

4

County of Los Angeles

H ea It h Education Coordinator

$ 77,748

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown

5

County of Alameda1

[Program Specialist/ Program Services Coordinator]

$ 90,314

$ 109,782

-11.4%

$97,267

12/27/2020

12/26/2021

3.00%





















7

City and County of San Francisco

Program Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%

8

County of Ventura

Public Hea It h Program Coordinator

$ 63,302

$ 88,337

-0.7%

$87,719

12/27/2020

12/26/2021

2.00%

9

County of Contra Costa

Public Hea It h Program Specialist 1

$ 79,432

$ 96,550

-11.1%

$ 85,833

7/1/2021

unknown

Unknown

10

County of Kern

Public Hea It h Program Specialist

$ 62,868

$ 76,740

1.2%

$ 77,661

4/21/2021

unknown

unknown

11

County of Orange

Hea It h Educator

$ 57,762

$ 77,605

-2.0%

$ 76,053

7/2/2021

7/1/2022

3.50%

12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 102,832

$92,583

% County of San Diego Above/Below

-15.1%

-3.7%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency.
The salary displayed is the higher of the matches.

Page 77 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Community Health Promotion Assistant





















1

City and County of San Francisco

Assistant Health Educator

$ 83,232

$ 101,064

-17.4%

$ 83,479

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Health Education Associate

$ 72,933

$ 88,207

-16.8%

$ 73,388

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Health Education Associate

$ 65,415

$ 81,805

-17.5%

$ 67,489

10/4/2020

unknown

unknown

4

County of San Bernardino

Health Education Assistant

$ 44,658

$ 61,464

1.9%

$ 62,632

7/31/2021

7/30/2022

3.00%

5

County of Los Angeles

Health Education Assistant

$47,151

$ 63,528

-3.8%

$ 61,114

1/1/2021

unknown

unknown

6

County of Ventura

Health Education Assistant II

$41,279

$ 57,972

-0.7%

$ 57,566

12/26/2020

12/27/2021

2.00%

7

County of Sacramento

Health Education Assistant

$ 46,876

$ 56,982

0.1%

$ 57,039

6/21/2020

unknown

unknown





















9

County of Orange

Health Education Assistant

$40,186

$ 53,414

-2.0%

$ 52,346

7/2/2021

7/1/2022

3.50%

10

County of Fresno

Health Education Assistant

$ 36,504

$ 46,696

4.7%

$ 48,891

11/2/2020

unknown

unknown

11

County of Kern

Health Education Assistant II

$ 36,144

$44,112

1.2%

$ 44,641

4/21/2021

unknown

unknown

12

County of Alameda

N/C















13

County of Contra Costa

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,718

$ 59,340

% County of San Diego Above/Below

-6.7%

-6.1%

Number of Matches

10

10

N/C - Non Comparator

Page 78 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Community Health Promotion Specialist!





















1

County of Riverside

Health Educator

$ 52,756

$ 78,075

1.9%

$ 79,558

5/1/2021

5/1/2022

2.00%

2

County of Los Angeles

Health Educator

$ 67,060

$ 81,082

-3.8%

$ 78,001

1/1/2021

unknown

unknown

3

County of Sacramento

Health Educator, Range A

$ 61,847

$ 75,168

0.1%

$ 75,243

6/21/2020

unknown

unknown

4

County of Ventura

Health Educator

$ 53,206

$ 72,687

-0.7%

$ 72,178

12/27/2020

12/26/2021

2.00%





















6

County of San Bernardino

Health Education Specialist 1

$ 48,090

$ 66,123

1.9%

$ 67,380

7/31/2021

7/30/2022

3.00%

7

County of Orange

Health Education Associate

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

8

County of Fresno

Health Education Specialist

$ 44,902

$ 57,434

4.7%

$ 60,133

11/2/2020

unknown

unknown

9

County of Contra Costa

Health Education Specialist

$ 53,721

$ 65,298

-11.1%

$ 58,050

7/1/2021

unknown

Unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Kern

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,405

$ 69,779

% County of San Diego Above/Below

-2.0%

-2.6%

Number of Matches

8

8

N/C - Non Comparator

Page 79 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Community Health Promotion Specialist II





















1

City and County of San Francisco

Health Educator

$ 96,252

$ 117,084

-17.4%

$ 96,711

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Public Health Educator

$ 87,795

$ 109,780

-17.5%

$ 90,569

10/4/2020

unknown

unknown

3

County of Santa Clara

Health Education Specialist

$ 89,037

$ 107,723

-16.8%

$ 89,626

6/14/2021

6/13/2022

3.00%

4

County of Los Angeles

Senior Health Educator

$ 65,110

$ 87,738

-3.8%

$ 84,403

1/1/2021

unknown

unknown

5

County of Sacramento

Health Educator, Range B

$ 68,967

$ 83,812

0.1%

$ 83,896

6/21/2020

unknown

unknown

6

County of Riverside

Senior Health Educator

$ 55,591

$ 82,276

1.9%

$ 83,840

5/1/2021

5/1/2022

2.00%

7

County of Contra Costa

Senior Health Education Specialist

$ 74,925

$ 91,072

-11.1%

$ 80,963

7/1/2021

unknown

unknown

8

County of Alameda

Health Educator II

$ 79,716

$ 87,692

-11.4%

$ 77,695

6/27/2021

6/26/2022

3.25%

9

County of Ventura

Senior Health Educator

$ 55,681

$ 78,040

-0.7%

$ 77,493

12/27/2020

12/26/2021

2.00%





















11

County of Orange

Health Program Specialist

$ 55,078

$ 74,235

-2.0%

$ 72,751

7/2/2021

7/1/2022

3.50%

12

County of San Bernardino

Health Education Specialist II

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

13

County of Kern

Health Educator

$ 45,912

$ 56,052

1.2%

$ 56,725

4/21/2021

unknown

unknown

14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 85,752

$ 82,401

% County of San Diego Above/Below

-12.5%

-8.1%

Number of Matches

12

12

N/C - Non Comparator

Page 80 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Community Services Officer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Community Services Officer II

$ 45,945

$ 71,783

1.9%

$ 73,147

5/1/2021

5/1/2022

2.00%

2

City and County of San Francisco

Community Police Services Aide

$ 69,552

$ 84,552

-17.4%

$ 69,840

7/1/2021

1/8/2022

.50%

3

County of Sacramento

Sheriff's Community Services Officer II

$ 56,376

$ 68,528

0.1%

$ 68,597

6/20/2021

1/2/2022

1.00%

4

County of Alameda

Sheriff's Technician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

5

County of Santa Clara

Protective Services Officer

$ 57,666

$ 69,624

-16.8%

$ 57,927

6/14/2021

6/13/2022

3.00%

6

County of Orange

Sheriff's Community Services Officer

$ 43,160

$ 57,949

-2.0%

$ 56,790

7/2/2021

7/1/2022

3.50%

7

County of Contra Costa

Sheriff's Ranger

$ 49,950

$ 62,232

-11.1%

$ 55,324

7/1/2021

7/1/2022

5.00%

8

County of San Mateo

Community Services Officer 1

$ 53,143

$ 66,455

-17.5%

$ 54,825

10/4/2020

unknown

unknown

9

County of San Bernardino

Community Services Officer

$ 35,048

$48,110

1.9%

$ 49,025

7/31/2021

7/30/2022

3.00%

10

County of San Diego

Community Services Officer

$ 38,501

$ 47,382



$ 47,382

6/18/2021

unknown

unknown

11

County of Fresno

Community Service Officer

$ 35,074

$ 44,850

4.7%

$ 46,958

7/1/2019

unknown

unknown

12

County of Ventura

Sheriff's Cadet II

$ 29,411

$ 39,701

-0.7%

$ 39,423

12/27/2020

12/26/2021

2.00%

13

County of Kern

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,455

$ 56,790

% County of San Diego Above/Below

-40.3%

-19.9%

Number of Matches

11

11

N/C - Non Comparator

Page 81 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Construction Technician (T)





















1

County of Riverside

Principal Construction Inspector

$ 74,085

$ 115,863

1.9%

$ 118,064

5/1/2021

5/1/2022

2.00%





















3

County of San Mateo2

[Construction Inspection 11/ Capital Projects Manager 1]

$91,862

$ 114,815

-17.5%

$94,722

10/4/2020

unknown

unknown

4

County of Contra Costa

Engineering Technician Supervisor - Construction

$87,267

$ 106,073

-11.1%

$94,299

7/1/2021

unknown

unknown

5

County of Orange1

[Supervising Construction Inspector/ Project Manager]

$ 70,335

$94,609

-2.0%

$92,717

7/2/2021

7/1/2022

3.50%

6

County of Ventura

Senior Public Works Inspector

$ 65,098

$91,522

-0.7%

$ 90,882

12/26/2020

12/27/2021

2.00%

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,073

$94,299

% County of San Diego Above/Below

3.3%

14.0%

Number of Matches

5

5

N/C - Non Comparator

1	- County of Orange: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 82 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Cook	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Cook

$ 67,284

$ 81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

2

County of Orange

Head Cook

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

3

County of San Mateo2

Cook II

$ 63,085

$ 70,552

-17.5%

$ 58,206

10/4/2020

unknown

unknown

4

County of Ventura3

[Cook/ Jail Cook]

$ 37,523

$ 55,254

-0.7%

$ 54,867

12/26/2020

12/27/2021

2.00%

5

County of Alameda

Cook

$ 50,817

$ 57,683

-11.4%

$ 51,107

6/27/2021

6/26/2022

3.25%

6

County of Santa Clara

Cook 1

$ 50,465

$ 60,805

-16.8%

$ 50,589

6/14/2021

6/13/2022

3.00%

7

County of Contra Costa

Cook

$ 46,398

$ 56,397

-11.1%

$ 50,137

7/1/2021

unknown

unknown

8

County of Kern1

[Cook 11/Juvenile Corrections Cook]

$ 39,924

$ 48,744

1.2%

$ 49,329

4/21/2021

unknown

unknown

9

County of Riverside

Cook

$ 29,977

$ 46,759

1.9%

$ 47,647

5/1/2021

5/1/2022

2.00%

10

County of Sacramento

Food Service Cook

$ 38,565

$ 46,876

0.1%

$ 46,923

6/21/2020

unknown

unknown

11

County of Los Angeles

Cook

$ 35,721

$ 47,962

-3.8%

$46,139

1/1/2021

unknown

unknown

12

County of San Bernardino

Cook II

$ 31,741

$ 43,659

1.9%

$ 44,489

7/31/2021

7/30/2022

3.00%

13

County of San Diego

Cook







$ 42,578

6/18/2021

unknown

unknown

14

County of Fresno

N/C













Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,826

$ 50,363

% County of San Diego Above/Below

-31.1%

-18.3%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the
comparator agency. The salary displayed is the higher of the matches.

2	- County of San Mateo: Bottom of range is step 3.

3	- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the
comparator agency. The salary displayed is the higher of the matches.

Page 83 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Coordinator, Volunteer & Public Services





















1

County of Sacramento

Volunteer Program Coordinator

$ 99,953

$ 110,184

0.1%

$ 110,294

6/21/2020

unknown

unknown

2

County of San Mateo

Program Coordinator II

$ 86,152

$ 107,679

-17.5%

$ 88,836

12/13/2020

unknown

unknown





















4

County of Contra Costa

Volunteer Program Coordinator

$ 77,875

$ 94,657

-11.1%

$ 84,150

7/1/2021

unknown

Unknown

5

County of Los Angeles

Volunteer Programs Coordinator II

$ 51,254

$ 69,075

-3.8%

$ 66,450

1/1/2021

unknown

unknown

6

County of Orange

Volunteer Services Coordinator II

$ 47,861

$ 64,168

-2.0%

$ 62,885

7/2/2021

7/1/2022

3.50%

7

County of Kern1

[Hospita 1 Volunteer Services Coordinator/ Animal Control Volunteer Coordinator]

$ 41,148

$ 50,232

1.2%

$ 50,835

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Ala meda

N/C















10

County of Fresno

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 81,866

$ 75,300

% County of San Diego Above/Below

2.8%

10.6%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Kern: Functional Match: This hybrid match re presents that the duties of the class are performed by more than one class atthe comparator agency. The salary displayed is the higher of the
matches.

Page 84 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Coordinator, Volunteer Services	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Sacramento

Volunteer Program Specialist

$ 78,154

$ 94,983

0.1%

$ 95,078

6/21/2020

unknown

unknown

2

City and County of San Francisco

Volunteer/Outreach Coordinator

$ 78,828

$ 95,832

-17.4%

$ 79,157

7/1/2021

1/8/2022

.50%

3

County of San Diego

Coordinator, Volunteer Services

$ 50,190

$ 61,714



$ 61,714

6/18/2021

unknown

unknown

4

County of Fresno

Volunteer Services Coordinator

$ 46,774

$ 56,836

4.7%

$ 59,507

4/19/2021

unknown

unknown

5

County of San Bernardino

Volunteer Services Coordinator

$ 41,454

$ 58,275

1.9%

$ 59,382

7/31/2021

7/30/2022

3.00%

6

County of Riverside

Volunteer Services Coordinators

$ 38,425

$ 56,831

1.9%

$57,911

5/1/2021

5/1/2022

2.00%

7

County of Los Angeles

Volunteer Programs Coordinator 1

$ 42,462

$ 57,133

-3.8%

$ 54,962

1/1/2021

unknown

unknown

8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 57,704

$ 59,445

% County of San Diego Above/Below

6.5%

3.7%

Number of Matches

6

6

N/C - Non Comparator

Page 85 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Correctional Counselor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Probation Counselor II

$ 101,768

$ 123,754

-16.8%

$ 102,963

6/14/2021

6/13/2022

3.00%

2

County of Riverside

Correctional Counselor

$ 63,506

$ 84,294

1.9%

$ 85,895

7/1/2021

7/1/2022

3-4%

3

County of San Diego

Correctional Counselor

$ 67,725

$ 83,200



$ 83,200

6/18/2021

unknown

unknown

4

County of San Mateo

Mental Health Counselor II

$ 71,384

$ 89,230

-17.5%

$ 73,615

10/4/2020

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 89,230

$ 85,895

% County of San Diego Above/Below

-7.2%

-3.2%

Number of Matches

3

3

N/C - Non Comparator

Page 86 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Crime Prevention Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Crime Analyst

$ 97,856

$ 118,986

-16.8%

$ 98,997

6/28/2021

6/27/2022

3.00%

2

County of Alameda

Sheriff's Technician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

3

County of Orange

Crime Prevention Specialist

$ 44,262

$ 59,384

-2.0%

$ 58,196

7/2/2021

7/1/2022

3.50%

4

County of San Mateo

Community Services Officer 1

$ 53,143

$ 66,455

-17.5%

$ 54,825

10/4/2020

unknown

unknown

5

County of San Diego

Crime Prevention Specialist

$ 42,307

$ 51,979



$ 51,979

6/18/2021

unknown

unknown

6

County of Kern

Crime Prevention Specialist

$ 40,536

$ 49,476

1.2%

$ 50,070

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,455

$ 58,196

% County of San Diego Above/Below

-27.8%

-12.0%

Number of Matches

5

5

N/C - Non Comparator

Page 87 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Criminal Legal Secretary I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Legal Office Support Assistant 1

$ 44,469

$ 64,950

-3.8%

$ 62,481

1/1/2021

unknown

unknown

2

County of San Mateo

Legal Secretary 1

$ 59,300

$74,171

-17.5%

$61,191

10/4/2020

unknown

unknown





Criminal Legal Secretary 1

$ 49,358

$ 60,694



$ 60,694

6/18/2021

unknown

unknown

4

County of Ventura

Management Assistant 1 - Legal

$ 42,891

$ 60,047

-0.7%

$ 59,627

12/27/2020

12/26/2021

2.00%

5

County of Orange

Legal SecretaryTrainee

$ 42,016

$ 56,597

-2.0%

$ 55,465

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Legal Support Assistant 1

$ 33,923

$ 52,918

1.9%

$ 53,923

5/1/2021

5/1/2022

2.00%

7

County of Santa Clara

Legal SecretaryTrainee

$ 52,680

$ 63,488

-16.8%

$ 52,822

6/14/2021

6/13/2022

3.00%

8

County of Sacramento

Legal Secretary 1

$ 43,242

$ 52,576

0.1%

$ 52,629

6/21/2020

unknown

unknown

9

County of Fresno

Legal Assistant 1

$ 29,224

$ 36,244

4.7%

$ 37,947

11/2/2020

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Contra Costa

N/C















13

County of Kern

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 58,322

$ 54,694

% County of San Diego Above/Below

3.9%

9.9%

Number of Matches

8

8

N/C - Non Comparator

Page 88 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Criminal Legal Secretary II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Legal Secretary 1

$ 80,988

$ 98,436

-17.4%

$ 81,308

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Legal Secretary II

$ 66,039

$ 82,574

-17.5%

$68,124

10/4/2020

unknown

unknown

3

County of San Bernardino

Executive Secretary II

$ 48,984

$ 66,269

1.9%

$ 67,528

7/31/2021

7/30/2022

3.00%

4

County of Ventura

Management Assistant II - Legal

$ 48,057

$ 67,279

-0.7%

$ 66,808

12/27/2020

12/26/2021

2.00%

5

County of Los Angeles

Legal Office Support Assistant II

$ 49,521

$ 68,565

-3.8%

$ 65,959

1/1/2021

unknown

unknown

6

County of Alameda

Legal Secretary

$ 60,844

$ 73,951

-11.4%

$ 65,521

6/27/2021

6/26/2022

3.25%



County of San Diego

Criminal Legal Secretary II

$ 52,811

$ 64,854



$ 64,854

6/18/2021

unknown

unknown

8

County of Santa Clara

Legal Secretary 1

$ 63,467

$ 76,658

-16.8%

$ 63,780

6/14/2021

6/13/2022

3.00%

9

County of Orange

Legal Secretary

$ 48,090

$ 64,813

-2.0%

$ 63,517

7/2/2021

7/1/2022

3.50%

10

County of Riverside

Legal Support Assistant II

$ 37,868

$59,128

1.9%

$ 60,251

5/1/2021

5/1/2022

2.00%

11

County of Sacramento

Legal Secretary II

$ 45,727

$ 55,583

0.1%

$ 55,639

6/21/2020

unknown

unknown

12

County of Kern

Legal Secretary

$ 36,864

$ 45,012

1.2%

$ 45,552

4/21/2021

unknown

unknown

13

County of Fresno

Legal Assistant II

$ 31,590

$ 40,404

4.7%

$ 42,303

11/2/2020

unknown

unknown

14

County of Contra Costa

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,774

$ 64,650

% County of San Diego Above/Below

-3.0%

0.3%

Number of Matches

12

12

N/C - Non Comparator

Page 89 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Criminal Legal Secretary III





















1

City and County of San Francisco

Legal Secretary II

$ 87,096

$ 105,876

-17.4%

$ 87,454

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Supervising Legal Secretary

$ 81,680

$ 102,064

-17.5%

$ 84,202

10/4/2020

unknown

unknown

3

County of Santa Clara

Legal Secretary II

$ 69,410

$ 83,882

-16.8%

$ 69,790

6/14/2021

6/13/2022

3.00%

4

County of Los Angeles

Senior Legal Office Support Assistant

$ 49,521

$ 72,392

-3.8%

$ 69,641

1/1/2021

unknown

unknown





















6

County of Orange

Senior Legal Secretary

$ 52,166

$ 70,325

-2.0%

$ 68,918

7/2/2021

7/1/2022

3.50%

7

County of Sacramento

Supervising Legal Secretary

$ 56,376

$ 68,528

0.1%

$ 68,597

6/21/2020

unknown

unknown

8

County of Riverside

Senior Legal Support Assistant

$ 42,068

$ 65,723

1.9%

$ 66,972

5/1/2021

5/1/2022

2.00%

9

County of Fresno

Supervising Legal Assistant

$ 42,822

$ 54,756

4.7%

$ 57,330

11/2/2020

unknown

unknown

10

County of Kern

Senior Legal Secretary

$ 43,464

$ 53,064

1.2%

$ 53,701

4/21/2021

unknown

unknown

11

County of Alameda

N/C















12

County of Contra Costa

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 70,325

$ 68,918

% County of San Diego Above/Below

-1.5%

0.6%

Number of Matches

9

9

N/C - Non Comparator

Page 90 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Criminalist I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Criminalist 1

$ 83,200

$ 102,274



$ 102,274

6/18/2021

unknown

unknown

2

County of Orange

Forensic Scientist 1

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

3

County of Contra Costa

Criminalist 1

$ 97,067

$ 107,016

-11.1%

$ 95,137

7/1/2021

7/1/2022

5.00%

4

County of Alameda

Criminalist 1

$ 88,116

$ 105,963

-11.4%

$ 93,883

6/27/2021

6/26/2022

3.25%

5

County of San Bernardino

Criminalist 1

$ 66,810

$ 91,894

1.9%

$ 93,640

7/31/2021

7/30/2022

3.00%

6

County of San Mateo

Criminalist 1

$ 86,859

$ 108,532

-17.5%

$ 89,539

12/13/2020

12/12/2021

2-4%

7

County of Ventura

Forensic Scientist 1

$ 63,276

$ 88,524

-0.7%

$ 87,904

12/27/2020

12/26/2021

2.00%

8

City and County of San Francisco

Criminalist 1

$ 86,508

$ 105,120

-17.4%

$ 86,829

7/1/2021

1/8/2022

.50%

9

County of Santa Clara

Criminalist 1

$ 82,175

$ 99,403

-16.8%

$ 82,703

6/14/2021

6/13/2022

3.00%

10

County of Fresno

Criminalist 1

$ 57,304

$ 73,294

4.7%

$ 76,739

7/1/2019

unknown

unknown

11

County of Sacramento

Criminalist 1

$ 59,675

$ 72,537

0.1%

$ 72,610

6/21/2021

unknown

unknown

12

County of Kern

Criminalist 1

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

13

County of Los Angeles

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 99,403

$ 87,904

% County of San Diego Above/Below

2.8%

14.0%

Number of Matches

11

11

N/C - Non Comparator

Page 91 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Criminalist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Criminalist II

$ 98,322

$ 120,765



$ 120,765

6/18/2021

unknown

unknown

2

County of Contra Costa

Criminalist II

$ 105,694

$ 131,684

-11.1%

$ 117,067

7/1/2021

7/1/2022

5.00%

3

City and County of San Francisco

Criminalist II

$ 116,484

$ 141,576

-17.4%

$ 116,942

7/1/2021

1/8/2022

.50%

4

County of Orange

Forensic Scientist II

$ 87,381

$ 117,728

-2.0%

$ 115,373

7/2/2021

7/1/2022

3.50%

5

County of San Bernardino

Criminalist II

$ 81,245

$ 111,862

1.9%

$ 113,988

7/31/2021

7/30/2022

3.00%

6

County of San Mateo

Criminalist II

$ 108,158

$ 135,197

-17.5%

$ 111,538

12/13/2020

12/12/2021

2-4%

7

County of Ventura

Forensic Scientist II

$ 78,051

$ 109,391

-0.7%

$ 108,625

12/27/2020

12/26/2021

2.00%

8

County of Alameda

Criminalist II

$ 96,658

$ 116,064

-11.4%

$ 102,833

6/27/2021

6/26/2022

3.25%

9

County of Fresno

Criminalist II

$ 76,570

$ 97,942

4.7%

$ 102,545

7/1/2019

unknown

unknown

10

County of Sacramento

Criminalist II

$ 79,678

$ 96,841

0.1%

$ 96,938

6/21/2021

unknown

unknown

11

County of Santa Clara

Criminalist II

$ 94,769

$ 114,675

-16.8%

$ 95,409

6/14/2021

6/13/2022

3.00%

12

County of Los Angeles

Criminalist

$ 74,935

$ 95,650

-3.8%

$ 92,015

1/1/2021

unknown

unknown

13

County of Kern

Criminalist II

$ 70,860

$ 86,508

1.2%

$ 87,546

4/21/2021

unknown

unknown

14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 113,268

$ 105,729

% County of San Diego Above/Below

6.2%

12.5%

Number of Matches

12

12

N/C - Non Comparator

Page 92 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Criminalist III	|

Salary	Next

_ „	_	..	Annual _ „ „ Geographic Adjusted	.. Next Salary _

Rank	Comparator Agency	Classification Title	... .	Top Annual	"V. . „ . . Effective „	' Percentage

Minimum	Differential Top Annual _ .	Increase

Date	Increase

1

County of Contra Costa

Criminalist III

$ 122,375

$ 152,466

-11.1%

$ 135,543

7/1/2021

7/1/2022

5.00% |

2

County of San Diego

Criminalist III

$ 103,979

$ 127,837



$ 127,837

6/18/2021

unknown

unknown

3

County of Orange

Forensic Scientist III

$ 94,765

$ 127,712

-2.0%

$ 125,158

7/2/2021

7/1/2022

3.50%

4

County of Los Angeles

Senior Criminalist

$ 100,974

$ 128,899

-3.8%

$ 124,001

1/1/2021

unknown

unknown

5

County of Sacramento

Criminalist III

$ 99,222

$ 120,624

0.1%

$ 120,745

6/21/2021

unknown

unknown

6

County of San Bernardino

Criminalist III

$ 85,363

$ 117,541

1.9%

$ 119,774

7/31/2021

7/30/2022

3.00%

7

County of San Mateo1

[Criminalist 1 I/Supervising Criminalist]

$ 114,117

$ 142,633

-17.5%

$ 117,672

12/13/2020

12/12/2021

2-4%

8

County of Ventura

Forensic Scientist III

$ 84,433

$ 118,450

-0.7%

$ 117,621

12/27/2020

12/26/2021

2.00%

9

County of Alameda

Criminalist III

$ 108,089

$ 130,338

-11.4%

$ 115,479

6/27/2021

6/26/2022

3.25%

10

County of Fresno

Criminalist Specialist

$ 82,368

$ 105,352

4.7%

$ 110,304

7/1/2019

unknown

unknown

11

County of Santa Clara

Criminalist III

$ 109,327

$ 132,380

-16.8%

$ 110,140

6/14/2021

6/13/2022

3.00%

12

County of Kern

Criminalist III

$ 82,296

$ 100,464

1.2%

$ 101,670

4/21/2021

unknown

unknown

13

City and County of San Francisco

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 127,712

$ 117,672

% County of San Diego Above/Below

0.1%

8.0%

Number of Matches

11

11

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 93 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Departmental Clerk





















1

City and County of San Francisco

Clerk

$ 55,488

$ 67,416

-17.4%

$ 55,686

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Office Specialist 1

$ 45,500

$ 54,704

-16.8%

$45,514

6/14/2021

6/13/2022

3.00%

3

County of Alameda

Clerk 1

$ 44,576

$ 50,697

-11.4%

$ 44,917

6/27/2021

6/26/2022

3.25%

4

County of Sacramento

Office Assistant 1

$ 35,517

$ 43,159

0.1%

$ 43,202

6/21/2020

unknown

unknown

5

County of Ventura

Office Assistant 1

$ 30,673

$ 41,439

-0.7%

$ 41,148

12/27/2020

12/26/2021

2.00%

6

County of Orange

Office Trainee

$ 32,282

$41,621

-2.0%

$ 40,788

7/2/2021

7/1/2022

3.50%

7

County of San Bernardino

Office Assistant 1

$ 30,077

$ 36,816

1.9%

$ 37,516

7/31/2021

7/30/2022

3.00%

8

County of Riverside

Departmental Aide

$ 29,120

$ 36,629

1.9%

$ 37,325

5/1/2021

5/1/2022

2.00%

9

County of Contra Costa1

[Clerk - Beginning Level (non-typing)/Clerk - Beginning Level (Typing)

$ 33,933

$ 41,245

-11.1%

$ 36,667

7/1/2021

unknown

Unknown

10

County of Kern

Office Services Assistant

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown





















12

County of Fresno

Office Assistant 1

$ 29,354

$ 32,188

4.7%

$ 33,701

11/2/2020

unknown

unknown

13

County of Los Angeles

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 41,439

$ 40,788

% County of San Diego Above/Below

-16.4%

-14.6%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed
is the higher of the matches.

Page 94 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Departmental Payroll Technician





















1

City and County of San Francisco

Payroll and Personnel Clerk

$ 70,980

$ 86,268

-17.4%

$ 71,257

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Health ServicesTimekeepingTechnician

$ 57,549

$ 69,951

-11.1%

$ 62,187

7/1/2021

unknown

unknown

3

County of Los Angeles

Payroll Clerk II

$ 45,908

$ 63,528

-3.8%

$ 61,114

1/1/2021

unknown

unknown

4

County of San Mateo

Payroll-Personnel Coordinator II

$ 58,281

$ 72,861

-17.5%

$ 60,110

10/4/2020

unknown

unknown

5

County of Orange

Accounting Technician

$ 45,698

$ 61,298

-2.0%

$ 60,072

7/2/2021

7/1/2022

3.50%

6

County of Alameda

Payroll Records Clerk

$ 53,898

$ 63,603

-11.4%

$ 56,352

6/27/2021

6/26/2022

3.25%

7

County of San Bernardino

Payroll Specialist

$ 35,048

$48,110

1.9%

$ 49,025

7/31/2021

7/30/2022

3.00%



















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,603

$ 60,110

% County of San Diego Above/Below

-35.4%

-27.9%

Number of Matches

7

7

N/C - Non Comparator

Page 95 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Deputy Medical Examiner I





















1

County of Alameda

Forensic Pathologist

$ 274,685

$ 333,736

-11.4%

$ 295,690

12/27/2020

unknown

unknown

2

County of Sacramento

Forensic Pathologist 1

$ 225,086

$ 225,086

0.1%

$ 225,311

6/21/2020

unknown

unknown





















4

City and County of San Francisco

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 279,411

$ 260,501

% County of San Diego Above/Below

-50.5%

-40.3%

Number of Matches

2

2

N/C - Non Comparator

Page 96 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Deputy Medical Examiner II





















1

County of Santa Clara

Assistant Medical Examiner-Coroner

$ 301,579

$ 366,600

-16.8%

$ 305,011

10/19/2020

11/1/2021

3.00%

2

City and County of San Francisco

Assistant Medical Examiner

$ 247,416

$ 348,192

-17.4%

$ 287,607

7/1/2021

1/8/2022

.50%

3

County of Riverside

Forensic Pathologist III

$ 204,766

$ 280,171

1.9%

$ 285,494

5/1/2021

5/1/2022

2.00%

4

County of Sacramento

Forensic Pathologist II

$ 228,636

$ 252,084

0.1%

$ 252,336

6/21/2020

unknown

unknown





















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 314,181

$ 286,550

% County of San Diego Above/Below

-31.7%

-20.1%

Number of Matches

4

4

N/C - Non Comparator

Page 97 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Deputy Public Admin-Guardian





















1

Cityand County of San Francisco

Protective Services Worker

$ 95,676

$ 122,040

-17.4%

$ 100,805

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Assistant Public Guardian-Conservator/ Estate Investigator]

$ 81,802

$ 99,455

-11.4%

$88,117

6/27/2021

6/26/2022

3.25%

3

County of Santa Clara

Deputy Public Guardian - Conservator

$ 86,501

$ 104,664

-16.8%

$ 87,080

6/14/2021

6/13/2022

3.00%

4

County of Riverside4

[Deputy Public Administrator/ Deputy Public Guardian]

$ 49,776

$ 77,736

1.9%

$ 79,213

5/1/2021

5/1/2022

2.00%

5

County of Los Angeles

Deputy Public Guardian/Deputy Public Conservator-Administrator II

$ 60,319

$81,282

-3.8%

$ 78,193

1/1/2021

unknown

unknown

6

County of San Mateo5

[Deputy Public Guardian Conservator ll/Deputy Public Administrator II]

$ 71,384

$ 89,230

-17.5%

$ 73,615

10/4/2020

unknown

unknown

7

County of Orange3

[Deputy Public Guardian 1/ Deputy Public Administrator]

$ 54,808

$ 73,403

-2.0%

$ 71,935

7/2/2021

7/1/2022

3.50%

8

County of San Bernardino

Deputy Public Guardian

$ 49,317

$ 67,638

1.9%

$ 68,923

7/31/2021

7/30/2022

3.00%

9

County of Sacramento

Deputy Public Guardian/Conservator II

$ 56,564

$ 68,737

0.1%

$ 68,806

6/21/2020

unknown

unknown





















11

County of Kern2

[Deputy Public Administrator/ Deputy Conservator]

$ 53,064

$ 64,776

1.2%

$ 65,553

4/21/2021

unknown

unknown

12

County of Fresno

Deputy Public Guardian II

$ 48,438

$ 61,958

4.7%

$ 64,870

11/2/2020

unknown

unknown

13

County of Ventura

Deputy Public Administrator-Guardian-Conservator

$ 46,010

$ 64,356

-0.7%

$ 63,906

12/26/2020

12/27/2021

2.00%

14

County of Contra Costa

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,570

$ 72,775

% County of San Diego Above/Below

-11.9%

-7.8%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the higher of the matches.

2	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
same for both matches.

3	- County of Orange: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
higher of the matches.

4	- County of Riverside: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the same for both matches.

5	- County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the higher of the matches.

Page 98 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Deputy Sheriff Cadet-Detentions/Court Services





















1

County of Ventura

Deputy Sheriff Trainee

$ 70,886

$ 81,984

-0.7%

$ 81,410

5/3/2020

unknown

unknown

2

County of Santa Clara

Deputy Sheriff Cadet - U

$ 94,931

$ 94,931

-16.8%

$ 78,983

10/7/2020

10/21/2021

3.00%

3

County of Orange

Sheriff's Correctional Services Asst Trainee

$ 43,160

$ 57,949

-2.0%

$ 56,790

7/2/2021

7/1/2022

3.50%

4

County of Kern

Sheriff's Detentions Deputy Trainee

$ 40,932

$ 52,536

1.2%

$ 53,166

4/21/2021

unknown

unknown





















6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,966

$ 67,886

% County of San Diego Above/Below

-55.2%

-50.6%

Number of Matches

4

4

N/C - Non Comparator

Page 99 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Deputy Sheriff's Cadet	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Deputy Sheriff Trainee

$ 63,977

$ 86,773

1.9%

$ 88,422

5/1/2021

5/1/2022

2.00%

2

County of Ventura

Deputy Sheriff Trainee

$ 70,886

$ 81,984

-0.7%

$ 81,410

5/3/2020

unknown

unknown

3

County of Santa Clara

Deputy Sheriff Cadet - U

$ 94,931

$ 94,931

-16.8%

$ 78,983

10/7/2020

10/21/2021

3.00%

4

County of Orange

Deputy Sheriff Trainee

$ 74,838

$ 74,838

-2.0%

$ 73,342

7/2/2021

7/1/2022

3.50%

5

County of Alameda

Deputy Sheriff's Recruit

$ 80,891

$ 80,891

-11.4%

$ 71,670

10/4/2020

10/3/2021

2.00%

6

County of San Mateo1

Deputy Sheriff Trainee

N/A

$ 86,672

-17.5%

$ 71,504

unknown

unknown

unknown

7

County of Sacramento

Deputy Sheriff Recruit

$71,180

$71,180

0.1%

$71,251

6/20/2021

1/2/2022

1.00%

8

County of Fresno

Deputy Sheriff 1 - Recruit

$ 51,272

$ 65,650

4.7%

$ 68,736

7/1/2019

unknown

unknown

9

County of San Bernardino

Sheriff's Trainee

$ 54,850

$60,174

1.9%

$61,318

7/31/2021

7/30/2022

3.00%

10

County of San Diego

Deputy Sheriff s Cadet

$ 56,867

$ 56,867



$ 56,867

6/18/2021

unknown

unknown

11

County of Contra Costa

Deputy Sheriff Recruit

$ 60,648

$ 60,648

-11.1%

$ 53,916

7/1/2021

7/1/2022

5.00%

12

City and County of San Francisco

Sheriffs Cadet

$ 53,304

$ 64,668

-17.4%

$ 53,416

7/1/2021

1/8/2022

.50%

13

County of Kern

Deputy Sheriff Trainee

$ 40,932

$ 49,980

1.2%

$ 50,580

4/21/2021

unknown

unknown

14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,009

$ 71,378

% County of San Diego Above/Below

-28.4%

-25.5%

Number of Matches

12

12

N/C - Non Comparator

1 - County of San Mateo: No range - only 1 step.

Page 100 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Detentions Information Assistant





















1

County of Orange

Sheriff's Correctional Services Assistant

$ 52,250

$ 69,971

-2.0%

$ 68,572

7/2/2021

7/1/2022

3.50%

2

County of Contra Costa

Sheriff's Aide

$ 55,258

$ 68,846

-11.1%

$ 61,204

7/1/2021

7/1/2022

5.00%

3

County of Alameda

Specialist Clerk 1

$ 52,388

$ 59,374

-11.4%

$ 52,606

6/27/2021

6/26/2022

3.25%





















5

County of Kern

Sheriff's Support Technician

$ 36,324

$ 44,340

1.2%

$ 44,872

4/21/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Fresno

N/C















8

County of Los Angeles

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 64,110

$ 56,905

% County of San Diego Above/Below

-35.2%

-20.0%

Number of Matches

4

4

N/C - Non Comparator

Page 101 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Detentions Processing Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Supervising Sheriff's Aide

$ 63,600

$ 79,239

-11.1%

$ 70,443

7/1/2021

7/1/2022

5.00%

2

County of Ventura

Sheriff's Records Supervisor 1

$ 46,900

$ 65,660

-0.7%

$ 65,200

12/26/2020

12/27/2021

2.00%

3

County of San Diego

Detentions Processing Supervisor







$ 61,381

6/18/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,449

$ 67,822

% County of San Diego Above/Below

-18.0%

-10.5%

Number of Matches

2

2

N/C - Non Comparator

Page 102 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Detentions Processing Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Sheriff's Service Technician 1

$ 44,416

$ 65,201

-0.7%

$ 64,744

8/9/2020

unknown

unknown

2

County of Alameda

Sheriff's Technician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

3

County of Los Angeles

Investigator Aid, Probation

$ 51,505

$ 65,751

-3.8%

$ 63,253

1/1/2021

unknown

unknown

4

County of San Mateo

Sheriff's Criminal Records Technician II

$ 55,785

$ 69,762

-17.5%

$ 57,554

10/4/2020

unknown

unknown

5

County of Santa Clara

Pretrial Services Technician

$ 54,991

$ 66,425

-16.8%

$ 55,265

6/14/2021

6/13/2022

3.00%

6

County of San Diego

Detentions Processing Technician

$ 42,890

$ 52,728



$ 52,728

6/18/2021

unknown

unknown

7

County of Orange

Information Processing Technician

$ 38,771

$ 51,064

-2.0%

$ 50,043

7/2/2021

7/1/2022

3.50%

8

City and County of San Francisco

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,088

$ 60,403

% County of San Diego Above/Below

-25.3%

-14.6%

Number of Matches

6

6

N/C - Non Comparator

Page 103 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Dietitian	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Clinical Dietitian II

$ 97,481

$ 117,963

-16.8%

$ 98,145

6/14/2021

6/13/2022

3.00%

2

County of Riverside

Dietitian

$ 61,037

$ 90,381

1.9%

$ 92,098

5/1/2021

5/1/2022

2.00%

3

County of San Mateo

Dietitian II

$ 84,843

$ 106,080

-17.5%

$ 87,516

10/4/2020

unknown

unknown

4

City and County of San Francisco

Dietitian

$ 87,096

$ 105,876

-17.4%

$ 87,454

7/1/2021

1/8/2022

.50%

5

County of San Bernardino

Dietician

$ 53,498

$ 75,296

1.9%

$ 76,727

3/13/2021

3/26/2022

3.00%

6

County of Orange

Public Health Nutritionist 1

$ 57,886

$ 77,958

-2.0%

$ 76,399

7/2/2021

7/1/2022

3.50%

7

County of Ventura

Registered Dietitian II

$ 50,663

$ 74,570

-0.7%

$ 74,048

12/27/2020

12/26/2021

2.00%

8

County of Contra Costa

Dietitian

$ 63,506

$ 77,192

-11.1%

$ 68,624

7/1/2021

unknown

Unknown

9

County of Los Angeles

Dietitian

$ 50,502

$ 68,054

-3.8%

$ 65,468

1/1/2021

unknown

unknown

10

County of San Diego

Dietitian







$ 59,010

6/18/2021

unknown

unknown

11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of Kern

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 77,958

$ 76,727

% County of San Diego Above/Below

-32.1%

-30.0%

Number of Matches

9

9

N/C - Non Comparator

Page 104 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Disease Research Scientist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Public Health Microbiologist

$ 106,332

$ 149,754

-16.8%

$ 124,595

10/21/2020

10/20/2021

3.00%

2

County of Los Angeles

Clinical Laboratory Scientist 1

$ 82,080

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown

3

County of Orange

Forensic Scientist 1

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

4

County of Riverside

Clinical Laboratory Scientist 1

$ 60,406

$ 89,483

1.9%

$ 91,183

5/1/2021

5/1/2022

2.00%

5

County of San Diego

Disease Research Scientist







$ 77,792

6/18/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,793

$ 100,774

% County of San Diego Above/Below

-33.4%

-29.5%

Number of Matches

4

4

N/C - Non Comparator

Page 105 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

I Drafting Technician

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Survey-Mapping Technician

$ 65,912

$ 84,131

-3.8%

$ 80,934

1/1/2021

unknown

unknown

2

County of San Mateo

DraftingTechnician II

$ 75,565

$ 94,451

-17.5%

$ 77,922

10/4/2020

unknown

unknown

3

City and County of San Francisco

Engineering Assistant

$ 76,884

$ 93,468

-17.4%

$ 77,205

7/1/2021

1/8/2022

.50%

4

County of Riverside

Civil Engineering DraftingTechnician II

$ 46,695

$ 72,960

1.9%

$ 74,346

5/1/2021

5/1/2022

2.00%

5

County of Santa Clara

Engineering Technician II

$ 71,920

$ 86,952

-16.8%

$ 72,344

6/14/2021

6/13/2022

3.00%

6

County of Orange

Cadastral Technician II

$ 53,539

$ 71,698

-2.0%

$ 70,264

7/2/2021

7/1/2022

3.50%

7

County of Sacramento

Engineering Technician II

$ 54,037

$ 65,688

0.1%

$ 65,754

6/21/2020

unknown

unknown

8

County of San Diego

Drafting Technician

$ 50,128

$ 61,568



$ 61,568

6/18/2021

unknown

unknown

9

County of Alameda

Mapping Technician II

$ 57,421

$ 68,435

-11.4%

$ 60,633

6/27/2021

6/26/2022

3.25%

10

County of Kern

DraftingTechnician II

$ 48,024

$ 58,620

1.2%

$ 59,323

4/21/2021

unknown

unknown

11

County of Contra Costa1

[Junior Drafter/Senior Drafter]

$ 49,615

$ 60,307

-11.1%

$ 53,613

7/1/2021

unknown

Unknown

12

County of Fresno

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,329

$ 71,304

% County of San Diego Above/Below

-17.5%

-15.8%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 106 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Election Processing Supervisor





















1

County of San Mateo

Elections Specialist Supervisor

$ 92,787

$ 115,958

-17.5%

$ 95,665

10/4/2020

unknown

unknown

2

County of Santa Clara

Elections Process Supervisor II

$ 84,005

$ 102,074

-16.8%

$ 84,926

6/28/2021

6/27/2022

3.00%

3

County of Orange

Election Section Supervisor

$ 61,194

$ 82,181

-2.0%

$ 80,537

7/2/2021

7/1/2022

3.50%

4

County of Alameda

Supervising Elections Technician

$ 72,675

$ 88,338

-11.4%

$ 78,267

12/27/2020

12/26/2021

3.00%





















6

County of Contra Costa

Election Processing Supervisor

$ 65,421

$ 79,519

-11.1%

$ 70,693

7/1/2021

unknown

unknown

7

County of Sacramento

Election Supervisor

$ 57,253

$ 69,593

0.1%

$ 69,663

6/21/2020

unknown

unknown

8

County of Riverside

Elections Coordinator - Services

$ 44,643

$ 66,031

1.9%

$ 67,286

5/1/2021

5/1/2022

2.00%

9

County of Los Angeles

Election/Recorder Services Supervisor

$ 48,556

$ 67,225

-3.8%

$ 64,671

1/1/2021

unknown

unknown

10

City and County of San Francisco

Elections Clerk

$ 61,464

$ 74,724

-17.4%

$ 61,722

7/1/2021

1/8/2022

.50%

11

County of Kern

Elections Process Supervisor

$ 43,896

$ 53,592

1.2%

$ 54,235

4/21/2021

unknown

unknown

12

County of Fresno

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 77,122

$ 70,178

% County of San Diego Above/Below

-5.9%

3.6%

Number of Matches

10

10

N/C - Non Comparator

Page 107 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Electronic Instrument Technician I





















1

Sacramento Metropolitan Air Quality Management District

Air Quality Instrument Specialist 1

$ 69,612

$ 84,614

0.1%

$ 84,699

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Air Quality Instrument Specialist 1

$ 59,532

$ 80,604

-2.8%

$ 78,347

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Air Quality Instrument Specialist 1

$ 77,561

$ 94,276

-17.4%

$ 77,872

11/8/2020

unknown

Unknown

4

County of Los Angeles

Assistant Instrument Technician

$ 59,136

$ 79,690

-3.8%

$ 76,662

1/1/2021

unknown

unknown





















6

County of Orange

N/C















7

County of Ventura

N/C















8

County of Contra Costa

N/C















9

San Luis Obispo County Air Pollution Control District

N/C















10

Imperial County Air Pollution Control District

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,609

$ 78,109

% County of San Diego Above/Below

-17.5%

-11.1%

Number of Matches

4

4

N/C - Non Comparator

Page 108 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Electronic Instrument Technician II





















1

City and County of San Francisco

Electronic Instrumentation Technician, Water Pollution Control

$ 112,560

$ 136,788

-17.4%

$ 112,987

7/1/2021

1/8/2022

.50%

2

Sacramento Metropolitan Air Quality Management District

Air Quality Instrument Specialist II

$ 80,057

$ 97,310

0.1%

$ 97,407

7/1/2021

unknown

unknown

3

County of Los Angeles

Instrument Technician

$ 69,586

$ 93,779

-3.8%

$ 90,215

1/1/2021

unknown

unknown

4

Bay Area Air Quality Management District

Air Quality Instrument Specialist II

$ 85,511

$ 103,939

-17.4%

$ 85,854

11/8/2020

unknown

Unknown

5

South Coast Air Quality Management District

Air Quality Instrument Specialist II

$ 64,812

$ 87,732

-2.8%

$ 85,276

1/1/2020

unknown

unknown

6

County of Santa Clara

Electronic Repair Technician

$ 79,934

$ 96,643

-16.8%

$ 80,407

6/14/2021

6/13/2022

3.00%





















8

Imperial County Air Pollution Control District

Air Pollution Control Monitoring Technician

$ 43,908

$ 56,136

5.6%

$ 59,280

7/3/2020

unknown

unknown

9

County of Ventura

N/C















10

County of Orange

N/C















11

San Luis Obispo County Air Pollution Control District

N/C















12

County of Contra Costa

N/C















13

County of Riverside

N/C















14

County of San Bernardino

N/C















15

County of San Mateo

N/C















16

County of Alameda

N/C















17

County of Sacramento

N/C















18

County of Kern

N/C















19

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 96,643

$ 85,854

% County of San Diego Above/Below

-24.6%

-10.7%

Number of Matches

7

7

N/C - Non Comparator

Page 109 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Emergency Medical Services Specialist





















1

County of Santa Clara

Emergency Medical Services (EMS) Specialist

$ 130,745

$ 158,933

-16.8%

$ 132,232

6/28/2021

6/27/2022

3.00%

2

City and County of San Francisco

Emergency Medical Services Agency Specialist

$ 115,548

$ 140,448

-17.4%

$ 116,010

7/1/2021

1/8/2022

.50%

3

County of Alameda

Program Specialist

$ 72,238

$ 106,600

-11.4%

$ 94,448

12/27/2020

12/26/2021

3.00%





















5

County of San Mateo

Community Program Analyst II

$ 86,630

$ 108,241

-17.5%

$ 89,299

10/4/2020

unknown

unknown

6

County of Riverside

Emergency Medical Services Specialist

$ 58,320

$ 86,334

1.9%

$ 87,974

5/1/2021

5/1/2022

2.00%

7

County of San Bernardino

Emergency Medical Services Specialist

$ 57,554

$ 83,096

1.9%

$ 84,675

3/13/2021

3/26/2022

3.00%

8

County of Sacramento

Emergency Medical Services Specialist II

$ 68,716

$ 83,520

0.1%

$ 83,604

6/21/2020

unknown

unknown

9

County of Orange

Emergency Medical Services Specialist

$ 57,886

$ 77,958

-2.0%

$ 76,399

7/2/2021

7/1/2022

3.50%

10

County of Fresno

Emergency Medical Services Specialist

$ 57,018

$ 69,316

4.7%

$ 72,574

4/19/2021

unknown

unknown

11

County of Contra Costa

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,334

$ 87,974

% County of San Diego Above/Below

3.8%

2.0%

Number of Matches

9

9

N/C - Non Comparator

Page 110 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Emergency Services Coordinator





















1

County of Sacramento

Assistant Emergency Operations Coordinator

$ 99,827

$ 110,058

0.1%

$ 110,168

6/21/2020

unknown

unknown

2

County of Santa Clara

Emergency Planning Coordinator

$ 97,866

$ 119,009

-16.8%

$ 99,016

6/28/2021

6/27/2022

3.00%

3

County of Riverside

Emergency Management Program Supervisor

$ 65,107

$ 96,399

1.9%

$ 98,230

5/1/2021

5/1/2022

2.00%

4

County of Los Angeles

Emergency Management Coordinator 1, CEO

$ 73,644

$ 99,240

-3.8%

$ 95,469

1/1/2021

unknown

unknown

5

City and County of San Francisco

Emergency Services Coordinator II

$ 91,704

$ 111,492

-17.4%

$ 92,092

7/1/2021

1/8/2022

.50%

6

County of Orange

Emergency Management Prog Coordinator

$ 68,432

$ 92,248

-2.0%

$ 90,403

7/2/2021

7/1/2022

3.50%





















8

County of Contra Costa1

[Emergency Planning Coordinator/Senior Emergency Planning Coordinator]

$ 77,710

$ 94,457

-11.1%

$ 83,972

7/1/2021

unknown

unknown

9

County of Alameda

Emergency Services Coordinator II

$ 69,562

$83,213

-11.4%

$ 73,727

6/27/2021

6/26/2022

3.25%

10

County of Kern

Emergency Medical Services Coordinator

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

11

County of Fresno

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 96,399

$ 92,092

% County of San Diego Above/Below

-9.3%

-4.4%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 111 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Engineering Technician I





















1

City and County of San Francisco

Engineering Assistant

$ 76,884

$ 93,468

-17.4%

$ 77,205

7/1/2021

1/8/2022

.50%

2

County of Riverside

Engineering Technician 1

$ 44,742

$ 73,747

1.9%

$ 75,148

5/1/2021

5/1/2022

2.00%

3

County of Alameda1

[Public Works Technical Assistant 1/ Survey Technician 1]

$ 73,320

$80,933

-11.4%

$ 71,706

10/4/2020

10/3/2021

3.25%

4

County of Ventura

Engineering Technician II

$48,757

$ 68,059

-0.7%

$ 67,582

12/26/2020

12/27/2021

2.00%

5

County of Contra Costa2

[Engineering Technician - Entry/Engineering Technician - Journey]

$ 63,182

$ 75,103

-11.1%

$ 66,767

7/1/2021

unknown

unknown

6

County of San Mateo

Public Works Technician 1

$ 64,437

$80,557

-17.5%

$ 66,459

10/4/2020

unknown

unknown





















8

County of Santa Clara

Engineering Technician 1

$ 62,774

$ 75,826

-16.8%

$ 63,088

6/14/2021

6/13/2022

3.00%

9

County of Fresno

Engineering Technician 1

$ 44,694

$ 57,200

4.7%

$ 59,888

12/17/2018

unknown

unknown

10

County of Kern

Engineering Technician 1

$ 48,024

$ 58,620

1.2%

$ 59,323

4/21/2021

unknown

unknown

11

County of Sacramento

Engineering Technician 1

$ 46,437

$ 56,460

0.1%

$ 56,516

6/21/2020

unknown

unknown

12

County of San Bernardino

Engineering Technician 1

$ 36,421

$ 50,149

1.9%

$ 51,102

7/31/2021

7/30/2022

3.00%

13

County of Orange

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,747

$ 66,459

% County of San Diego Above/Below

-12.1%

-1.0%

Number of Matches

11

11

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed
is the higher of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 112 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Engineering Technician II





















1

County of Riverside

Engineering Technician II

$49,771

$81,983

1.9%

$83,540

5/1/2021

5/1/2022

2.00%

2

County of Los Angeles

Civil Engineering Technician

$ 65,912

$84,131

-3.8%

$80,934

1/1/2021

unknown

unknown

3

County of Contra Costa2

[Engineering Technician - Journey/Engineering Technician - Senior]

$ 75,061

$ 90,435

-11.1%

$80,397

7/1/2021

unknown

unknown

4

County of Alameda1

[Public Works Technical Assistant 11/ Survey Technician II]

$81,682

$ 90,730

-11.4%

$80,386

10/4/2020

10/3/2021

3.25%

5

County of San Mateo

Public Works Technician II

$ 75,565

$94,451

-17.5%

$ 77,922

10/4/2020

unknown

unknown

6

County of Orange

Engineering Technician

$ 56,597

$ 76,274

-2.0%

$ 74,748

7/2/2021

7/1/2022

3.50%





















8

County of Santa Clara

Engineering Technician II

$ 71,920

$86,952

-16.8%

$ 72,344

6/14/2021

6/13/2022

3.00%

9

County of Ventura

Engineering Technician III

$ 51,581

$ 72,540

-0.7%

$ 72,033

12/26/2020

12/27/2021

2.00%

10

County of San Bernardino

Engineering Technician III

$ 50,170

$ 68,890

1.9%

$ 70,199

7/31/2021

7/30/2022

3.00%

11

County of Fresno

Engineering Technician II

$ 49,972

$ 63,934

4.7%

$ 66,939

12/17/2018

unknown

unknown

12

County of Sacramento

Engineering Technician II

$ 54,037

$ 65,688

0.1%

$ 65,754

6/21/2020

unknown

unknown

13

County of Kern

Engineering Technician II

$ 53,064

$ 64,776

1.2%

$ 65,553

4/21/2021

unknown

unknown

14

City and County of San Francisco

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,128

$ 73,546

% County of San Diego Above/Below

-6.5%

1.0%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed
is the higher of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 113 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Engineering Technician III





















1

County of Alameda1

[Public Works Technical Assistant III/ Survey Technician III]

$ 105,518

$ 116,868

-11.4%

$ 103,545

10/4/2020

10/3/2021

3.25%

2

County of Riverside

Senior Engineering Technician

$ 57,628

$ 95,004

1.9%

$ 96,809

5/1/2021

5/1/2022

2.00%

3

County of San Bernardino

Engineering Technician V

$ 63,669

$ 87,506

1.9%

$89,168

7/31/2021

7/30/2022

3.00%

4

County of Contra Costa

Engineering Technician - Senior

$81,511

$ 99,313

-11.1%

$ 88,289

7/1/2021

unknown

unknown

5

County of Orange

Senior Engineering Technician

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

6

City and County of San Francisco

Engineering Associate 1

$ 85,224

$ 103,632

-17.4%

$ 85,600

7/1/2021

1/8/2022

.50%

7

County of Los Angeles

Senior Civil Engineering Technician

$ 69,586

$ 88,823

-3.8%

$ 85,448

1/1/2021

unknown

unknown

8

County of Santa Clara

Engineering Technician III

$ 84,879

$ 102,698

-16.8%

$ 85,445

6/14/2021

6/13/2022

3.00%





















10

County of Ventura

Engineering Technician IV

$ 56,215

$ 78,817

-0.7%

$ 78,265

12/26/2020

12/27/2021

2.00%

11

County of Fresno

Senior Engineering Technician

$ 57,304

$ 73,294

4.7%

$ 76,739

12/17/2018

unknown

unknown

12

County of Sacramento

Senior Engineering Technician

$ 61,053

$ 74,208

0.1%

$ 74,282

6/21/2020

unknown

unknown

13

County of Kern

Engineering Technician III

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,164

$ 85,524

% County of San Diego Above/Below

-4.2%

-1.1%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 114 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Environmental Health Specialist I





















1

County of Riverside

Environmental Health Specialist II

$ 54,794

$ 81,043

1.9%

$82,583

5/1/2021

5/1/2022

2.00%

2

County of Orange

Environmental Health Specialist 1

$ 61,402

$ 82,763

-2.0%

$81,108

7/2/2021

7/1/2022

3.50%

3

County of San Bernardino

Environmental Health Specialist 1

$ 57,554

$ 77,189

1.9%

$ 78,655

3/13/2021

3/26/2022

3.00%





















5

County of San Mateo1

[Environmental Health Specialist I/Hazardous Materials Specialist 1]

$ 78,519

$ 87,795

-17.5%

$ 72,431

10/4/2020

unknown

unknown

6

County of Ventura

Environmental Health Specialist 1

$ 50,355

$ 70,468

-0.7%

$ 69,975

12/27/2020

12/26/2021

2.00%

7

County of Kern

Environmental Health Specialist 1

$ 51,492

$ 62,868

1.2%

$ 63,622

4/21/2021

unknown

unknown

8

County of Fresno

Environmental Health Specialist 1

$ 49,062

$ 59,618

4.7%

$ 62,420

10/17/2019

unknown

unknown

9

County of Los Angeles

Environmental Health Specialist 1

$ 50,878

$ 58,272

-3.8%

$ 56,058

1/1/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Contra Costa

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,829

$ 71,203

% County of San Diego Above/Below

2.3%

5.7%

Number of Matches

8

8

N/C - Non Comparator

1 - County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed
is the higher of the matches. Bottom of range is step 3 for both classes.

Page 115 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Environmental Health Specialist II





















1

City and County of San Francisco

Environmental Health Inspector

$ 110,736

$ 134,556

-17.4%

$ 111,143

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Registered Environmental Health Specialist/ Hazardous Materials Specialist]

$ 94,557

$ 113,235

-11.4%

$ 100,326

6/27/2021

6/26/2022

3.25%

3

County of Santa Clara

Environmental Health Specialist

$ 96,583

$ 116,892

-16.8%

$ 97,254

6/14/2021

6/13/2022

3.00%

4

County of San Mateo3

[Environmental Health Specialist ll/Hazardous Materials Specialist II]

$ 91,997

$ 114,959

-17.5%

$ 94,842

10/4/2020

unknown

unknown

5

County of Riverside

Environmental Health Specialist III

$ 59,640

$ 88,235

1.9%

$ 89,911

5/1/2021

5/1/2022

2.00%

6

County of Sacramento

Environmental Specialist II

$ 73,017

$ 88,761

0.1%

$ 88,850

6/30/2021

unknown

unknown

7

County of Contra Costa2

[Hazardous Materials Specialist I/Environmental Health Specialist 1]

$81,827

$ 99,461

-11.1%

$ 88,421

7/1/2021

unknown

unknown

8

County of San Bernardino

Environmental Health Specialist II

$ 59,717

$ 86,258

1.9%

$ 87,896

3/13/2021

3/26/2022

3.00%

9

County of Orange

Environmental Health Specialist II

$ 64,813

$ 87,381

-2.0%

$85,633

7/2/2021

7/1/2022

3.50%





















11

County of Los Angeles

Environmental Health Specialist II

$ 65,751

$ 83,926

-3.8%

$ 80,737

1/1/2021

unknown

unknown

12

County of Ventura

Environmental Health Specialist II

$ 55,629

$ 77,666

-0.7%

$ 77,122

12/27/2020

12/26/2021

2.00%

13

County of Kern

Environmental Health Specialist II

$ 56,892

$ 69,456

1.2%

$ 70,289

4/21/2021

unknown

unknown

14

County of Fresno

Environmental Health Specialist II

$ 55,120

$ 67,002

4.7%

$ 70,151

10/17/2019

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,235

$ 88,421

% County of San Diego Above/Below

-6.4%

-6.6%

Number of Matches

13

13

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of
the matches.

2	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
higher of the matches.

3	- County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher
of the matches.

Page 116 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Environmental Health Specialist III





















1

City and County of San Francisco

Senior Environmental Health Inspector

$ 118,488

$ 144,012

-17.4%

$ 118,954

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Senior Registered Environmental Health Specialist/Senior Hazardous Materials Specialist]

$ 102,913

$ 123,294

-11.4%

$ 109,238

6/27/2021

6/26/2022

3.25%

3

County of San Mateo3

[Environmental Health Specialist IV/Hazardous Materials Specialist IV]

$ 105,371

$ 131,703

-17.5%

$ 108,655

10/4/2020

unknown

unknown

4

County of Santa Clara

Senior Environmental Health Specialist

$ 106,228

$ 128,656

-16.8%

$ 107,042

6/14/2021

6/13/2022

3.00%

5

County of Sacramento

Environmental Specialist III

$ 87,132

$ 105,924

0.1%

$ 106,030

6/30/2021

unknown

unknown

6

County of Contra Costa2

[Environmental Health Specialist ll/Supervising Environmental Health Specialist]

$ 96,220

$ 116,956

-11.1%

$ 103,974

7/1/2021

unknown

unknown

7

County of Ventura

Environmental Health Specialist IV

$ 66,528

$ 98,026

-0.7%

$ 97,340

12/27/2020

12/26/2021

2.00%

8

County of Riverside

Environmental Health Specialist IV

$ 63,179

$ 93,551

1.9%

$ 95,328

5/1/2021

5/1/2022

2.00%

9

County of San Bernardino

Environmental Health Specialist III

$ 63,502

$ 91,707

1.9%

$ 93,450

3/13/2021

3/26/2022

3.00%





















11

County of Orange

Environmental Health Specialist III

$ 68,432

$ 92,248

-2.0%

$ 90,403

7/2/2021

7/1/2022

3.50%

12

County of Los Angeles

Environmental Health Specialist III

$ 68,565

$ 92,404

-3.8%

$ 88,893

1/1/2021

unknown

unknown

13

County of Kern

Environmental Health Specialist III

$ 62,868

$ 76,740

1.2%

$ 77,661

4/21/2021

unknown

unknown

14

County of Fresno

Environmental Health Specialist III

$ 60,736

$ 73,840

4.7%

$ 77,310

10/17/2019

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,026

$ 97,340

% County of San Diego Above/Below

-7.5%

-6.7%

Number of Matches

13

13

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the same for both matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an
average of the matches.

3	- County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the matches.

Page 117 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Environmental Health Specialist Tr





















1

County of Riverside

Environmental Health Specialist 1

$ 55,955

$ 82,842

1.9%

$ 84,416

5/1/2021

5/1/2022

2.00%

2

County of Santa Clara

Environmental Health Specialist Trainee

$ 75,743

$ 91,659

-16.8%

$ 76,261

6/14/2021

6/13/2022

3.00%

3

County of Contra Costa

Environmental Health Specialist Trainee

$ 65,356

$ 79,440

-11.1%

$ 70,623

7/1/2021

unknown

unknown

4

County of Alameda

Environmental Health Specialist Trainee

$ 67,821

$ 77,314

-11.4%

$ 68,500

6/27/2021

6/26/2022

3.25%

5

County of Sacramento

Environmental Specialist 1

$ 67,839

$ 67,839

0.1%

$ 67,907

6/30/2021

unknown

unknown





















7

County of San Bernardino

Environmental Health Specialist Trainee

$ 45,053

$ 60,445

1.9%

$ 61,593

3/13/2021

3/26/2022

3.00%

8

County of Kern

Environmental Health Specialist-in-Training

$ 46,608

$ 56,892

1.2%

$ 57,575

4/21/2021

unknown

unknown

9

County of Orange

Environmental Health Aide

$ 36,483

$ 48,235

-2.0%

$ 47,270

7/2/2021

7/1/2022

3.50%

10

County of Fresno

Environmental Health Specialist Trainee

$ 40,716

$ 40,716

4.7%

$ 42,630

10/17/2019

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Los Angeles

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,839

$ 67,907

% County of San Diego Above/Below

-2.6%

-2.7%

Number of Matches

9

9

N/C - Non Comparator

Page 118 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Environmental Health Technician





















1

County of Orange

Environmental Resources Technician

$ 64,813

$ 87,381

-2.0%

$85,633

7/2/2021

7/1/2022

3.50%

2

City and County of San Francisco

Environmental Health Technician 1

$ 74,496

$ 90,528

-17.4%

$ 74,776

7/1/2021

1/8/2022

.50%

3

County of Sacramento

Environmental Compliance Technician II

$ 55,812

$ 67,839

0.1%

$ 67,907

6/30/2021

unknown

unknown

4

County of San Mateo

Environmental Health Technician II

$ 65,810

$ 82,304

-17.5%

$ 67,901

10/4/2020

unknown

unknown

5

County of Ventura

Resource Management Agency Technician II - Environmental Health

$ 48,265

$ 67,402

-0.7%

$ 66,930

12/26/2020

12/27/2021

2.00%

6

County of Riverside

Environmental Health Technician II

$ 38,982

$ 60,876

1.9%

$ 62,032

5/1/2021

5/1/2022

2.00%

7

County of Contra Costa

Environmental Health Technician

$ 56,840

$ 69,089

-11.1%

$ 61,420

7/1/2021

unknown

unknown

8

County of Kern

Environmental Health Technician II

$ 48,024

$ 58,620

1.2%

$ 59,323

4/21/2021

unknown

unknown

9

County of Los Angeles

Environmental Health Technician

$ 41,637

$ 56,012

-3.8%

$ 53,883

1/1/2021

unknown

unknown

10

County of San Bernardino

Environmental Technician 1

$ 37,710

$ 51,792

1.9%

$ 52,776

7/31/2021

7/30/2022

3.00%





















12

County of Fresno

Environmental Health Aide

$ 36,322

$ 44,148

4.7%

$ 46,223

10/17/2019

unknown

unknown

13

County of Alameda

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,402

$ 62,032

% County of San Diego Above/Below

-40.0%

-28.8%

Number of Matches

11

11

N/C - Non Comparator

Page 119 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Epidemiologist I	|

Rank

Comparator Agency

Classification
Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Epidemiologist 1

$76,918

$ 94,557



$ 94,557

6/18/2021

unknown

unknown

2

County of Orange

Epidemiologist

$ 70,325

$ 94,765

-2.0%

$ 92,870

7/2/2021

7/1/2022

3.50%

3

County of Alameda

Epidemiologist 1

$ 79,539

$ 96,741

-11.4%

$85,712

12/27/2020

12/26/2021

3.00%

4

City and County of San Francisco

Epidemiologist 1

$82,812

$ 100,644

-17.4%

$83,132

7/1/2021

1/8/2022

.50%

5

County of San Mateo

Epidemiologist 1

$ 80,037

$ 100,025

-17.5%

$ 82,521

10/4/2020

unknown

unknown

6

County of Santa Clara

Epidemiologist 1

$81,607

$ 98,773

-16.8%

$82,179

6/14/2021

6/13/2022

3.00%

7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,773

$ 83,132

% County of San Diego Above/Below

-4.5%

12.1%

Number of Matches

5

5

N/C - Non Comparator

Page 120 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Epidemiologist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Epidemiologist

$ 85,178

$ 114,787

-3.8%

$ 110,425

1/1/2021

unknown

unknown

2

City and County of San Francisco

Epidemiologist II

$ 105,660

$ 128,436

-17.4%

$ 106,088

7/1/2021

1/8/2022

.50%

3

County of San Diego

Epidemiologist II

$ 84,656

$ 104,062



$ 104,062

6/18/2021

unknown

unknown

4

County of Sacramento

Epidemiologist

$ 85,190

$ 103,544

0.1%

$ 103,648

6/21/2020

unknown

unknown

5

County of Santa Clara

Epidemiologist II

$ 98,347

$ 118,986

-16.8%

$ 98,997

6/14/2021

6/13/2022

3.00%

6

County of Alameda

Epidemiologist II

$ 88,816

$ 109,054

-11.4%

$ 96,622

12/27/2020

12/26/2021

3.00%

7

County of San Mateo

Epidemiologist II

$ 89,459

$ 111,839

-17.5%

$ 92,268

10/4/2020

unknown

unknown

8

County of Fresno

Epidemiologist

$ 70,460

$ 85,644

4.7%

$ 89,669

10/19/2020

unknown

unknown

9

County of San Bernardino

Public Health Epidemiologist

$ 60,445

$ 85,176

1.9%

$ 86,794

3/13/2021

3/26/2022

3.00%

10

County of Kern

Public Health Epidemiologist

$ 66,084

$ 75,324

1.2%

$ 76,228

4/21/2021

unknown

unknown

11

County of Contra Costa

N/C















12

County of Orange

N/C















13

County of Riverside

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 109,054

$ 96,622

% County of San Diego Above/Below

-4.8%

7.1%

Number of Matches

9

9

N/C - Non Comparator

Page 121 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Estate Assistant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Deputy Public Guardian Assistant

$ 68,906

$ 83,294

-16.8%

$ 69,300

6/14/2021

6/13/2022

3.00%

2

County of Orange

Estate Inventory Clerk

$ 42,224

$ 56,597

-2.0%

$ 55,465

7/2/2021

7/1/2022

3.50%

3

County of Ventura

HS Case Aide II

$ 38,517

$ 51,362

-0.7%

$ 51,002

12/27/2020

12/26/2021

2.00%

4

County of San Diego

Estate Assistant

$ 41,205

$ 50,648



$ 50,648

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,597

$ 55,465

% County of San Diego Above/Below

-11.7%

-9.5%

Number of Matches

3

3

N/C - Non Comparator

Page 122 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Estate Property Manager





















1

County of Alameda

Estate Manager/Investigator

$ 79,602

$ 96,845

-11.4%

$ 85,804

12/27/2020

12/26/2021

3.00%

2

County of Orange1

[Senior Deputy Public Administrator/ Senior Deputy Public Guardian]

$ 64,168

$ 86,507

-2.0%

$ 84,777

7/2/2021

7/1/2022

3.50%

3

County of Sacramento

Estate Property Officer

$ 65,208

$ 79,260

0.1%

$ 79,339

6/21/2020

unknown

unknown





















5

County of Santa Clara

Estate Property Specialist

$ 63,864

$ 77,176

-16.8%

$ 64,211

6/14/2021

6/13/2022

3.00%

6

County of Riverside2

[Estate Property Technician/ Estate Investigator]

$ 38,817

$ 62,316

1.9%

$ 63,500

5/1/2021

5/1/2022

2.00%

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,260

$ 79,339

% County of San Diego Above/Below

-4.3%

-4.4%

Number of Matches

5

5

N/C - Non Comparator

1	- County of Orange: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
higher of the matches.

2	- County of Riverside: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 123 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Executive Housekeeper





















1

County of San Bernardino

Hospital Environmental Services Supervisor

$ 40,539

$ 55,702

1.9%

$ 56,761

7/31/2021

7/30/2022

3.00%





















3

County of Riverside

Lead Housekeeper

$ 33,613

$ 43,413

1.9%

$ 44,238

5/1/2021

5/1/2022

2.00%

4

County of Kern

Housekeeper

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 43,413

$ 44,238

% County of San Diego Above/Below

23.1%

21.7%

Number of Matches

3

3

N/C - Non Comparator

Page 124 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Facility Services Contract Specialist |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Maintenance Contract Manager - U

$ 84,074

$ 102,190

-16.8%

$ 85,022

6/28/2021

6/27/2022

3.00%

2

County of San Diego

Facility Services Contract Specialist

$ 54,101

$ 66,456



$ 66,456

6/18/2021

unknown

unknown

3

County of Ventura

Contract Support Specialist II

$ 42,249

$ 59,139

-0.7%

$ 58,725

12/27/2020

12/26/2021

2.00%

4

County of Orange

Facilities Contract Services Inspector

$ 42,640

$ 57,158

-2.0%

$ 56,015

7/2/2021

7/1/2022

3.50%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,139

$ 58,725

% County of San Diego Above/Below

11.0%

11.6%

Number of Matches

3

3

N/C - Non Comparator

Page 125 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Fleet Parts Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Parts Storekeeper

$ 68,220

$ 82,944

-17.4%

$ 68,512

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

MaterialsTechnician

$ 56,953

$ 69,226

-11.1%

$ 61,542

7/1/2021

unknown

unknown

3

County of San Bernardino

Equipment Parts Specialist 1

$ 43,285

$ 59,488

1.9%

$ 60,618

7/31/2021

7/30/2022

3.00%

4

County of Los Angeles

Procurement Assistant 1

$ 46,464

$ 62,592

-3.8%

$ 60,214

1/1/2021

unknown

unknown

5

County of Santa Clara

Fleet Parts Coordinator

$58,165

$ 70,217

-16.8%

$ 58,420

6/14/2021

6/13/2022

3.00%

6

County of Riverside

Equipment Parks Storekeeper

$ 36,610

$57,168

1.9%

$ 58,254

5/1/2021

5/1/2022

2.00%

7

County of Sacramento

Storekeeper - Fleet Service

$ 46,980

$ 57,086

0.1%

$57,143

6/21/2020

unknown

unknown

8

County of Alameda

Auto Parts Technician

$ 62,538

$ 62,538

-11.4%

$ 55,409

6/27/2021

6/26/2022

3.25%

9

County of San Mateo

Storekeeper II

$ 52,727

$ 65,914

-17.5%

$ 54,379

10/4/2020

unknown

unknown

10

County of San Diego

Fleet Parts Specialist

$ 43,763

$ 53,810



$ 53,810

6/18/2021

unknown

unknown

11

County of Ventura

Parts Specialist

$ 38,588

$ 53,997

-0.7%

$ 53,619

12/26/2020

12/27/2021

2.00%

12

County of Fresno

Fleet Services Parts Specialist

$ 34,372

$ 41,782

4.7%

$ 43,746

11/2/2020

unknown

unknown

13

County of Kern

Automotive Parts Storekeeper II

$ 34,212

$ 41,760

1.2%

$ 42,261

4/21/2021

unknown

unknown

14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,013

$ 57,698

% County of San Diego Above/Below

-13.4%

-7.2%

Number of Matches

12

12

N/C - Non Comparator

Page 126 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Fleet Standards Technician





















1

County of Los Angeles

Assistant Automotive Equipment Coordinator

$ 60,615

$ 81,681

-3.8%

$ 78,577

1/1/2021

unknown

unknown

2

County of Alameda

Sheriff's Fleet Services Coordinator

$ 63,315

$ 76,939

-11.4%

$ 68,168

12/27/2020

unknown

unknown





















4

County of Contra Costa

Fleet Equipment Specialist

$ 64,201

$ 70,782

-11.1%

$ 62,925

7/1/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,939

$ 68,168

% County of San Diego Above/Below

-19.7%

-6.1%

Number of Matches

3

3

N/C - Non Comparator

Page 127 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Fleet Support Specialist





















1

County of Santa Clara

Fleet Logistics Supervisor

$ 97,964

$ 119,103

-16.8%

$ 99,094

6/28/2021

6/27/2022

3.00%





















3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 119,103

$ 99,094

% County of San Diego Above/Below

-46.2%

-21.6%

Number of Matches

1

1

N/C - Non Comparator

Page 128 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Food Services Supervisor





















1

County of Contra Costa

Head Detention Cook

$ 68,870

$ 78,382

-11.1%

$ 69,681

7/1/2021

unknown

unknown

2

County of Alameda1

[Senior Food Service Worker/ Food and Support Services Manager]

$ 63,028

$ 75,596

-11.4%

$ 66,978

12/27/2020

12/26/2021

3.00%

3

City and County of San Francisco

Food Service Supervisor

$ 65,004

$ 78,960

-17.4%

$ 65,221

7/1/2021

1/8/2022

.50%

4

County of Kern

Juvenile Corrections Food Services Supervisor

$ 52,536

$ 64,128

1.2%

$ 64,898

4/21/2021

unknown

unknown

5

County of San Mateo2

Supervising Cook

$ 67,162

$ 75,045

-17.5%

$ 61,912

10/4/2020

unknown

unknown

6

County of Ventura

Assistant Food Services Supervisor

$41,587

$ 58,120

-0.7%

$ 57,713

12/26/2020

12/27/2021

2.00%

7

County of San Bernardino

Sheriff's Food Services Supervisor/Food Services Supervisor

$ 41,080

$ 56,514

1.9%

$ 57,587

7/31/2021

7/30/2022

3.00%

8

County of Sacramento

Food Service Supervisor

$46,813

$ 56,919

0.1%

$ 56,976

6/21/2020

unknown

unknown

9

County of Riverside

Food and Nutrition Services Supervisor

$ 37,631

$ 55,626

1.9%

$ 56,683

5/1/2021

5/1/2022

2.00%





















11

County of Orange

Senior Institutional Cook

$42,016

$ 56,410

-2.0%

$ 55,281

7/2/2021

7/1/2022

3.50%

12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,124

$ 59,813

% County of San Diego Above/Below

-9.7%

-7.3%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

2	- County of San Mateo: Bottom of range is step 3.

Page 129 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Food Services Worker	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo1

Cook 1

$ 58,322

$ 65,186

-17.5%

$ 53,778

10/4/2020

unknown

unknown

2

City and County of San Francisco

Food Service Worker

$ 50,232

$ 64,092

-17.4%

$ 52,940

7/1/2021

1/8/2022

.50%

3

County of Alameda

Food Service Worker

$ 48,381

$ 54,864

-11.4%

$ 48,610

6/27/2021

6/26/2022

3.25%

4

County of Santa Clara

Food Service Worker - Correction - U

$ 48,306

$ 58,132

-16.8%

$ 48,366

6/14/2021

6/13/2022

3.00%

5

County of Sacramento

Food Service Worker

$ 33,408

$ 40,612

0.1%

$ 40,653

6/21/2020

unknown

unknown

6

County of Contra Costa

Institutional Services Aide

$ 36,912

$ 44,867

-11.1%

$ 39,887

7/1/2021

unknown

unknown

7

County of Riverside

Food Service Worker

$ 31,200

$ 37,640

1.9%

$ 38,355

5/1/2021

5/1/2022

2.00%

8

County of Los Angeles

Food Services Worker

$ 31,320

$ 38,056

-3.8%

$ 36,610

1/1/2021

unknown

unknown

9

County of Ventura

Food Services Assistant II

$ 29,628

$ 36,764

-0.7%

$ 36,507

12/26/2020

12/27/2021

2.00%

10

County of Kern

Food Service Worker (II)

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

11

County of Orange

Food Service Worker

$ 28,434

$ 36,483

-2.0%

$ 35,754

7/2/2021

7/1/2022

3.50%

12

County of San Bernardino

Food Service Worker 1

$ 30,077

$ 34,882

1.9%

$ 35,544

7/31/2021

7/30/2022

3.00%

13

County of San Diego

Food Services Worker

$ 30,534

$ 34,050



$ 34,050

6/18/2021

unknown

unknown

14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 39,334

$ 39,121

% County of San Diego Above/Below

-15.5%

-14.9%

Number of Matches

12

12

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 130 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Forensic Autopsy Room Supervisor









































2

County of Orange

Supervisor, Forensics Operations

$ 67,912

$ 91,541

-2.0%

$ 89,710

7/2/2021

7/1/2022

3.50%

3

County of Los Angeles

Head, Forensic Autopsy Support Services

$ 63,372

$ 83,106

-3.8%

$ 79,948

1/1/2021

unknown

unknown

4

County of Riverside

Forensic Supervisor

$ 50,293

$ 74,438

1.9%

$ 75,852

5/1/2021

5/1/2022

2.00%

5

County of Sacramento

Supervising CoronerTechnician

$ 55,833

$ 67,860

0.1%

$ 67,928

6/21/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 78,772

$ 77,900

% County of San Diego Above/Below

14.0%

14.9%

Number of Matches

4

4

N/C - Non Comparator

Page 131 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Forensic Autopsy Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Forensic Autopsy Technician

$ 77,868

$ 94,644

-17.4%

$78,176

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Forensic PathologyTechnician

$ 75,028

$ 90,619

-16.8%

$ 75,395

6/14/2021

6/13/2022

3.00%

3

County of Riverside

Forensic Services Specialist II

$ 45,680

$ 71,328

1.9%

$ 72,683

5/1/2021

5/1/2022

2.00%

4

County of Orange

Forensic Assistant II

$ 53,539

$ 71,698

-2.0%

$ 70,264

7/2/2021

7/1/2022

3.50%



County of San Diego

Forensic Autopsy Specialist

$ 53,893

$ 66,269



$ 66,269

6/18/2021

unknown

unknown

6

County of San Bernardino

Autopsy Assistant

$ 44,387

$ 60,986

1.9%

$62,144

7/31/2021

7/30/2022

3.00%

7

County of Ventura

Forensic PathologyTechnician

$ 45,804

$ 58,465

-0.7%

$ 58,056

12/26/2020

12/27/2021

2.00%

8

County of Sacramento

Coroner Technician II

$46,187

$56,146

0.1%

$ 56,202

6/21/2020

unknown

unknown

9

County of San Mateo

Forensic Autopsy Technician

$ 52,893

$66,122

-17.5%

$ 54,551

10/4/2020

unknown

unknown

10

County of Fresno

Forensic Autopsy Technician

$ 38,402

$49,140

4.7%

$ 51,450

7/1/2019

unknown

unknown

11

County of Contra Costa

PathologyTechnician

$ 45,309

$ 55,073

-11.1%

$ 48,960

7/1/2021

unknown

unknown

12

County of Alameda

N/C















13

County of Kern

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,554

$60,100

% County of San Diego Above/Below

4.1%

9.3%

Number of Matches

10

10

N/C - Non Comparator

Page 132 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Forensic

Documents Examiner

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Forensic Documents Examiner

$ 103,751

$ 132,440

-3.8%

$ 127,407

1/1/2021

unknown

unknown

2

County of San Diego

Forensic Documents Examiner

$ 97,157

$ 119,330



$ 119,330

6/18/2021

unknown

unknown

3

City and County of San Francisco

Forensic Document Examiner

$ 113,076

$ 137,460

-17.4%

$ 113,542

7/1/2021

1/8/2022

.50%

4

County of Orange

Computer Forensic Examiner

$ 84,469

$ 113,547

-2.0%

$ 111,276

7/2/2021

7/1/2022

3.50%

5

County of Riverside

ForensicTechnician II

$ 58,320

$91,158

1.9%

$ 92,890

5/1/2021

5/1/2022

2.00%

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 122,993

$ 112,409

% County of San Diego Above/Below

-3.1%

5.8%

Number of Matches

4

4

N/C - Non Comparator

Page 133 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Forensic Evidence Technician





















1

County of Riverside

Forensic Technician II

$ 58,320

$ 91,158

1.9%

$92,890

5/1/2021

5/1/2022

2.00%

2

County of San Bernardino

Sheriff's Crime Scene Specialist III

$ 59,883

$ 82,326

1.9%

$ 83,891

7/31/2021

7/30/2022

3.00%





















4

County of Contra Costa1

[Forensic Technologist/Crime Scene Investigator II]

$ 68,503

$ 85,347

-11.1%

$ 75,873

7/1/2021

7/1/2022

5.00%

5

County of Los Angeles

Forensic Technician II

$ 61,218

$ 74,013

-3.8%

$ 71,200

1/1/2021

unknown

unknown

6

County of Orange

Forensics Technician

$ 44,262

$ 59,384

-2.0%

$ 58,196

7/2/2021

7/1/2022

3.50%

7

County of Kern

Evidence Technician II

$ 46,608

$ 56,892

1.2%

$ 57,575

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Fresno

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 78,170

$ 73,537

% County of San Diego Above/Below

0.7%

6.5%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator
agency. The salary displayed is the higher of the matches.

Page 134 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Geographic Information Systems Analyst





















1

County of Santa Clara

Geographic Information Systems (GIS) Analyst

$ 118,192

$ 143,668

-16.8%

$ 119,532

6/14/2021

6/13/2022

3.00%

2

County of Sacramento

Geographic Information Systems Analyst II

$ 81,223

$ 103,627

0.1%

$ 103,731

6/21/2020

unknown

unknown

3

County of Orange

Geographic Information Sys Analyst

$ 77,958

$ 104,749

-2.0%

$ 102,654

7/2/2021

7/1/2022

3.50%

4

County of Los Angeles

Geographic Information Systems Analyst

$ 81,880

$ 104,517

-3.8%

$ 100,545

1/1/2021

unknown

unknown

5

County of Alameda

Geographic Information Systems Analyst

$87,194

$ 111,634

-11.4%

$ 98,907

12/27/2020

unknown

unknown

6

County of Ventura1

[Geographic Information Systems Specialist 11/ GIS Analyst]

$ 73,778

$ 97,987

-0.7%

$ 97,301

1/10/2021

1/9/2022

2.00%

7

County of Riverside

GIS Analyst

$ 54,717

$ 81,004

1.9%

$ 82,543

5/1/2021

5/1/2022

2.00%

8

County of San Mateo

GIS Technician II

$ 75,565

$ 94,451

-17.5%

$ 77,922

10/4/2020

unknown

unknown





















10

County of Kern

Geographic Information Systems Programmer/Analyst

$ 55,776

$ 68,088

1.2%

$ 68,905

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Contra Costa

N/C















13

County of Fresno

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,627

$ 98,907

% County of San Diego Above/Below

-34.2%

-28.1%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 135 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Geographic Information Systems Technician





















1

County of Los Angeles

Geographic Information Systems Technician II

$ 72,034

$ 91,946

-3.8%

$ 88,452

1/1/2021

unknown

unknown

2

County of Alameda

Geographical Information Systems Technician

$ 82,446

$ 98,575

-11.4%

$ 87,337

6/27/2021

6/26/2022

3.25%

3

County of Orange

Geographic Information Sys Technician

$ 62,712

$ 84,469

-2.0%

$ 82,779

7/2/2021

7/1/2022

3.50%

4

County of Riverside

GIS Specialist II

$ 44,742

$ 69,929

1.9%

$ 71,257

5/1/2021

5/1/2022

2.00%

5

County of Ventura

Geographic Information Systems Technician II

$ 49,830

$ 69,769

-0.7%

$ 69,280

12/26/2020

12/27/2021

2.00%

6

County of Sacramento

Geographic Information Systems Technician II

$ 54,079

$ 65,730

0.1%

$ 65,796

6/21/2020

unknown

unknown

7

County of Contra Costa

Geographic Information Systems Technician

$ 59,698

$ 72,563

-11.1%

$ 64,509

7/1/2021

unknown

unknown

8

County of San Bernardino

Geographic Information Systems Technician 1

$ 44,158

$ 60,674

1.9%

$ 61,826

7/31/2021

7/30/2022

3.00%



















10

County of Kern

Geographic Information Systems Technician II

$ 41,352

$ 50,472

1.2%

$ 51,078

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Fresno

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,929

$ 69,280

% County of San Diego Above/Below

-22.5%

-21.3%

Number of Matches

9

9

N/C - Non Comparator

Page 136 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Graphic Artist





















1

County of Los Angeles

Graphic Artist

$ 52,146

$ 70,280

-3.8%

$ 67,609

1/1/2021

unknown

unknown

2

County of San Mateo2

[Graphics Associate/Graphics Specialist]

$ 64,728

$80,910

-17.5%

$ 66,751

10/4/2020

unknown

unknown

3

County of Riverside

Graphic Arts Illustrator

$41,345

$ 64,582

1.9%

$ 65,809

5/1/2021

5/1/2022

2.00%

4

County of Alameda1

[Photographic and Printing Services Technician/ Graphic Designer]

$ 61,200

$ 73,453

-11.4%

$ 65,080

12/27/2020

12/26/2021

3.00%

5

County of Orange

Computer Graphics Specialist

$49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%





















7

County of Santa Clara

Graphic Designer 1

$ 60,416

$ 72,956

-16.8%

$ 60,699

6/14/2021

6/13/2022

3.00%

8

County of San Bernardino

Graphic Designer 1

$42,536

$ 58,490

1.9%

$ 59,601

7/31/2021

7/30/2022

3.00%

9

County of Fresno

Graphic Arts Specialist

$43,316

$ 52,624

4.7%

$ 55,097

11/2/2020

unknown

unknown

10

County of Kern

Graphic Artist

$ 35,244

$43,032

1.2%

$43,548

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Contra Costa

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,936

$ 64,617

% County of San Diego Above/Below

-2.9%

-0.9%

Number of Matches

9

9

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 137 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Graphic Design Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Graphic Design Specialist

$ 66,685

$ 81,973



$ 81,973

6/18/2021

unknown

unknown

2

County of Alameda

Graphic Designer

$ 72,051

$ 86,944

-11.4%

$ 77,032

12/27/2020

12/26/2021

3.00%

3

County of San Mateo

Graphics Specialist

$ 69,263

$ 86,568

-17.5%

$ 71,419

10/4/2020

unknown

unknown

4

County of Los Angeles

Graphic Arts Specialist

$ 55,057

$ 74,197

-3.8%

$ 71,378

1/1/2021

unknown

unknown

5

County of Orange

Senior Computer Graphics Specialist

$ 53,539

$ 71,698

-2.0%

$ 70,264

7/2/2021

7/1/2022

3.50%

6

County of Santa Clara

Graphic Designer II

$ 68,906

$ 83,294

-16.8%

$ 69,300

6/14/2021

6/13/2022

3.00%

7

City and County of San Francisco

Graphic Artist

$ 65,604

$ 83,748

-17.4%

$ 69,176

7/1/2021

1/8/2022

.50%

8

County of Riverside

Graphic Arts Illustrator

$ 41,345

$ 64,582

1.9%

$ 65,809

5/1/2021

5/1/2022

2.00%

9

County of Sacramento

Graphic Designer

$ 51,636

$ 62,765

0.1%

$ 62,828

6/21/2020

unknown

unknown

10

County of Contra Costa

Graphic Designer

$ 52,824

$ 64,208

-11.1%

$ 57,081

7/1/2021

unknown

unknown

11

County of Fresno

N/C















12

County of Kern

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 74,197

$ 69,300

% County of San Diego Above/Below

9.5%

15.5%

Number of Matches

9

9

N/C - Non Comparator

Page 138 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Groundwater Geologist





















1

County of Santa Clara

Environmental Health Geologist/Engineer

$ 134,549

$ 163,966

-16.8%

$ 136,420

10/21/2020

10/20/2021

3.00%

2

County of Los Angeles

Engineering Geologist

$ 112,272

$ 128,582

-3.8%

$ 123,696

1/1/2021

unknown

unknown





















4

County of Ventura

Staff Geologist

$ 75,523

$ 107,778

-0.7%

$ 107,024

1/10/2021

1/9/2022

2.00%

5

County of Orange

Senior Environmental Resources Specialist

$ 80,538

$ 108,493

-2.0%

$ 106,323

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Associate Geologist

$ 68,016

$ 100,705

1.9%

$ 102,618

5/1/2021

5/1/2022

2.00%

7

County of Kern

Engineer II

$ 69,108

$ 84,372

1.2%

$ 85,384

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 108,135

$ 106,673

% County of San Diego Above/Below

9.9%

11.1%

Number of Matches

6

6

N/C - Non Comparator

Page 139 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Health Information Management Clerk





















1

City and County of San Francisco

Medical Records Clerk

$ 65,448

$ 79,584

-17.4%

$ 65,736

7/1/2021

1/8/2022

.50%

2

County of Alameda

Medical Clerk

$ 50,153

$ 59,374

-11.4%

$ 52,606

6/27/2021

6/26/2022

3.25%

3

County of San Bernardino

Health Information Management Assistant II

$ 33,779

$ 46,363

1.9%

$ 47,244

7/31/2021

7/30/2022

3.00%





















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,374

$ 52,606

% County of San Diego Above/Below

-37.8%

-22.1%

Number of Matches

3

3

N/C - Non Comparator

Page 140 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Health Information Management Technician





















1

County of San Mateo

Medical Records Technician II

$ 62,420

$ 78,061

-17.5%

$ 64,400

10/4/2020

unknown

unknown

2

County of Alameda

Medical Records Technician

$ 57,744

$ 68,435

-11.4%

$ 60,633

6/27/2021

6/26/2022

3.25%

3

County of Contra Costa

Medical Records Technician

$ 49,111

$ 62,716

-11.1%

$ 55,755

7/1/2021

unknown

unknown

4

County of Sacramento

Medical Records Technician

$ 41,196

$ 50,091

0.1%

$ 50,141

6/21/2020

unknown

unknown

5

County of Ventura

Records Technician II

$ 35,249

$ 49,293

-0.7%

$ 48,948

12/27/2020

12/26/2021

2.00%





















7

City and County of San Francisco

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,716

$ 55,755

% County of San Diego Above/Below

-32.3%

-17.6%

Number of Matches

5

5

N/C - Non Comparator

Page 141 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Health Information Specialist I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Health Education Associate

$ 72,933

$ 88,207

-16.8%

$ 73,388

6/14/2021

6/13/2022

3.00%

2

County of San Bernardino

Health Education Specialist 1

$ 48,090

$66,123

1.9%

$ 67,380

7/31/2021

7/30/2022

3.00%



County of San Diego

Health Information Specialist 1

$ 54,725

$ 67,226



$ 67,226

6/18/2021

unknown

unknown

4

County of Orange

Health Education Associate

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

5

County of Riverside

Health Education Assistant II

$39,127

$ 58,006

1.9%

$59,108

5/1/2021

5/1/2022

2.00%

6

County of Kern

Health Education Assistant 1

$ 32,712

$ 39,924

1.2%

$ 40,403

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,936

$ 64,617

% County of San Diego Above/Below

1.9%

3.9%

Number of Matches

5

5

N/C - Non Comparator

Page 142 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Health Information Specialist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Community Health Planner

$ 87,795

$ 109,780

-17.5%

$ 90,569

10/4/2020

unknown

unknown

2

County of Santa Clara

Health Education Specialist

$ 89,037

$ 107,723

-16.8%

$ 89,626

6/14/2021

6/13/2022

3.00%

3

County of Riverside

Health Educator

$ 52,756

$ 78,075

1.9%

$ 79,558

5/1/2021

5/1/2022

2.00%

4

County of Los Angeles

Health Educator

$ 67,060

$ 81,082

-3.8%

$ 78,001

1/1/2021

unknown

unknown

5

County of San Diego

Health Information Specialist II

$ 62,067

$ 76,253



$ 76,253

6/18/2021

unknown

unknown

6

County of Orange

Health Information Specialist

$ 56,410

$ 75,691

-2.0%

$74,177

7/2/2021

7/1/2022

3.50%

7

County of San Bernardino

Health Education Specialist II

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

8

County of Alameda

Health Educator 1

$ 63,864

$ 72,743

-11.4%

$ 64,451

6/27/2021

6/26/2022

3.25%

9

County of Sacramento

Health Education Assistant

$ 46,876

$ 56,982

0.1%

$ 57,039

6/21/2020

unknown

unknown

10

County of Kern

Health Education Assistant II

$36,144

$44,112

1.2%

$ 44,641

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Contra Costa

N/C















13

County of Fresno

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,691

$74,177

% County of San Diego Above/Below

0.7%

2.7%

Number of Matches

9

9

N/C - Non Comparator

Page 143 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Health Services Social Worker





















1

City and County of San Francisco

Medical Social Worker

$ 95,676

$ 116,244

-17.4%

$ 96,018

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Clinical Social Worker

$ 73,465

$ 93,779

-3.8%

$ 90,215

1/1/2021

unknown

unknown

3

County of Contra Costa

Medical Social Worker II

$ 81,179

$ 98,674

-11.1%

$ 87,721

7/1/2021

unknown

unknown

4

County of Sacramento

Human Services Social Worker - Master's Degree

$ 72,015

$ 87,529

0.1%

$ 87,616

6/21/2020

unknown

unknown

5

County of Santa Clara

Medical Social Worker 1

$ 85,617

$ 103,640

-16.8%

$ 86,229

6/14/2021

6/13/2022

3.00%

6

County of Alameda

Medical Social Worker II

$ 86,414

$ 94,689

-11.4%

$ 83,894

6/27/2021

6/26/2022

3.25%

7

County of San Bernardino

Social Service Practitioner II

$ 57,554

$ 81,078

1.9%

$ 82,619

3/13/2021

3/26/2022

3.00%

8

County of Riverside

Medical Social Worker II - Per Diem

$ 76,120

$ 76,120

1.9%

$ 77,566

5/1/2021

5/1/2022

2.00%

9

County of Fresno

Medical Social Worker II

$ 57,356

$ 73,372

4.7%

$ 76,820

11/2/2020

unknown

unknown





















11

County of Kern

Medical Social Worker II

$ 57,468

$ 70,152

1.2%

$ 70,994

4/21/2021

unknown

unknown

12

County of Orange

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 90,654

$ 85,062

% County of San Diego Above/Below

-21.0%

-13.5%

Number of Matches

10

10

N/C - Non Comparator

Page 144 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|HHSA Contract Auditor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Contract Program Auditor

$ 70,803

$ 95,415

-3.8%

$ 91,790

1/1/2021

unknown

unknown

2

County of San Mateo

Internal Auditor II

$ 80,432

$ 100,566

-17.5%

$ 82,967

10/4/2020

unknown

unknown

3

County of San Diego

HHSA Contract Auditor

$ 62,192

$ 81,557



$ 81,557

6/18/2021

unknown

unknown

4

County of Sacramento

Auditor

$ 65,960

$80,179

0.1%

$ 80,259

6/21/2020

unknown

unknown

5

County of Fresno

Financial Analyst II

$ 54,080

$ 65,728

4.7%

$ 68,817

4/19/2021

unknown

unknown

6

County of Orange

Contract Services Monitor

$ 49,851

$ 67,246

-2.0%

$ 65,902

7/2/2021

7/1/2022

3.50%

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$80,179

$ 80,259

% County of San Diego Above/Below

1.7%

1.6%

Number of Matches

5

5

N/C - Non Comparator

Page 145 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Histology Technician

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Histologic Technician

$ 83,192

$ 117,154

-16.8%

$ 97,472

10/21/2020

10/20/2021

3.00%

2

County of Riverside

Histology Technician

$ 55,008

$ 81,449

1.9%

$ 82,997

5/1/2021

5/1/2022

2.00%

3

County of Contra Costa

Histotechnician

$ 67,260

$ 81,755

-11.1%

$ 72,680

7/1/2021

unknown

unknown

4

County of Los Angeles

Tissue Analysis Technician 1

$ 53,983

$ 72,750

-3.8%

$ 69,985

1/1/2021

unknown

unknown

5

County of San Bernardino

Histology Technician

$ 47,736

$ 65,603

1.9%

$ 66,850

7/31/2021

7/30/2022

3.00%

6

County of Ventura

Histologist

$ 45,018

$ 62,904

-0.7%

$ 62,463

12/26/2020

12/27/2021

2.00%

7

County of San Diego

Histology Technician

$ 49,525

$ 60,882



$ 60,882

6/18/2021

unknown

unknown

8

County of Kern

Histologic Technician

$ 43,464

$ 53,064

1.2%

$ 53,701

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Fresno

N/C















12

County of Orange

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,750

$ 69,985

% County of San Diego Above/Below

-19.5%

-15.0%

Number of Matches

7

7

N/C - Non Comparator

Page 146 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Historian





















1

County of Los Angeles

Curator, Natural History

$ 88,172

$ 118,819

-3.8%

$ 114,304

1/1/2021

unknown

unknown

2

County of Riverside

Historic Preservation Officer - Parks

$ 66,821

$ 98,795

1.9%

$ 100,672

5/1/2021

5/1/2022

2.00%





















4

County of Orange

Archivist

$ 53,414

$ 71,531

-2.0%

$ 70,101

7/2/2021

7/1/2022

3.50%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,795

$ 100,672

% County of San Diego Above/Below

-8.1%

-10.1%

Number of Matches

3

3

N/C - Non Comparator

Page 147 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Aide*





















1

Housing Authority County of Santa Clara

Housing Assistant

$ 53,913

$ 72,248

-16.8%

$ 60,110

5/15/2021

unknown

unknown

2

Area Housing Authority of the County of Ventura1

[Eligibility Specialist/ Occupancy Specialist]

$ 46,946

$ 57,738

-1.1%

$ 57,103

7/8/2021

unknown

unknown

3

Housing Authority County of San Bernardino3

[Administrative Services Specialist/ Affordable Housing Specialist]

$ 42,159

$ 54,807

1.9%

$ 55,848

4/20/2021

unknown

unknown

4

Housing Authority Contra Costa County

Housing Assistant

$ 49,032

$ 59,592

-11.1%

$ 52,977

6/27/2020

unknown

unknown

5

Fresno Housing Authority2

[Office Assistant II - Case Management/ Housing Specialist]

$ 40,704

$ 49,476

4.7%

$ 51,801

1/1/2021

unknown

unknown

6

Sacramento Housing and Redevelopment Agency

Housing Assistant

$ 36,676

$ 46,809

0.1%

$ 46,856

1/4/2021

unknown

unknown





















8

County of Ventura

N/C















9

County of Contra Costa

N/C















10

San Francisco Housing Authority

N/C















11

Los Angeles County Development Authority

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Alameda

N/C















16

County of Orange

N/C















17

Housing Authority County of Kern

N/C















18

County of Fresno

N/C















19

County of Kern

N/C















20

County of Riverside

N/C















21

County of San Bernardino

N/C















22

County of San Mateo

N/C















23

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,273

$ 54,413

% County of San Diego Above/Below

-23.7%

-19.6%

Number of Matches

6

6

N/C - Non Comparator

1	- Area Housing Authority of the County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

2	- Fresno Housing Authority: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is
an average of the matches.

3	- Housing Authority County of San Bernardino: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 148 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Program Analyst I*









































2

Sacramento Housing and Redevelopment Agency

Redevelopment Analyst - Range 1

$61,492

$ 78,481

0.1%

$ 78,559

1/2/2021

unknown

unknown

3

Housing Authority County of San Bernardino1

[Real Estate Services Specialist/ Management Analyst]

$58,701

$ 76,311

1.9%

$ 77,761

4/20/2021

unknown

unknown

4

County of San Mateo

Housing/Community Development Specialist 1

$ 72,632

$ 90,832

-17.5%

$ 74,936

10/4/2020

unknown

unknown

5

County of San Bernardino

Economic and Community Development Analyst Trainee

$51,759

$ 69,306

1.9%

$ 70,622

7/31/2021

7/30/2022

3.00%

6

Fresno Housing Authority

Community Development Coordinator

$ 44,000

$ 66,500

4.7%

$69,626

1/1/2021

unknown

unknown

7

County of Orange

Research Analyst 1

$ 48,942

$ 65,354

-2.0%

$ 64,046

7/2/2021

7/1/2022

3.50%

8

Los Angeles County Development Authority

Development Specialist 1

$ 48,696

$63,927

-2.7%

$62,201

1/1/2021

unknown

unknown

9

Housing Authority County of Santa Clara

N/C















10

County of Ventura

N/C















11

Area Housing Authority of the County of Ventura

N/C















12

San Francisco Housing Authority

N/C















13

County of Contra Costa

N/C















14

County of Santa Clara

N/C















15

County of Alameda

N/C















16

County of Los Angeles

N/C















17

County of Fresno

N/C















18

County of Kern

N/C















19

County of Sacramento

N/C















20

Housing Authority Contra Costa County

N/C















21

County of Riverside

N/C















22

City and County of San Francisco

N/C















23

Housing Authority County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,306

$ 70,622

% County of San Diego Above/Below

14.4%

12.7%

Number of Matches

7

7

N/C - Non Comparator

1 - Housing Authority County of San Bernardino: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 149 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Program Analyst II*





















1

Housing Authority County of San Bernardino1

[Management Analyst/ Project Manager - Real Estate]

$ 88,002

$ 114,403

1.9%

$ 116,577

4/20/2021

unknown

unknown

2

Housing Authority County of Santa Clara2

[Housing Policy Analyst/ Assistant Project Manager]

$ 92,814

$ 124,380

-16.8%

$ 103,484

5/15/2021

unknown

unknown

3

County of San Bernardino

Economic and Community Development Analyst II

$ 65,998

$ 90,750

1.9%

$ 92,475

7/31/2021

7/30/2022

3.00%





















5

County of San Mateo

Housing/Community Development Specialist II

$ 86,173

$ 107,679

-17.5%

$ 88,836

10/4/2020

unknown

unknown

6

Sacramento Housing and Redevelopment Agency

Redevelopment Analyst - Range 2

$ 67,795

$ 86,525

0.1%

$ 86,612

1/2/2021

unknown

unknown

7

Housing Authority County of Kern

Planning and Development Specialist

$ 69,804

$85,212

1.2%

$ 86,235

4/14/2021

unknown

unknown

8

Fresno Housing Authority

Community Development Analyst

$ 50,000

$ 78,500

4.7%

$ 82,190

1/1/2021

unknown

unknown

9

Los Angeles County Development Authority

Development Specialist II

$ 54,111

$ 76,718

-2.7%

$ 74,646

1/1/2021

unknown

unknown

10

County of Orange

Research Analyst II

$ 54,330

$ 72,717

-2.0%

$ 71,262

7/2/2021

7/1/2022

3.50%

11

Cityand County of San Francisco

N/C















12

County of Ventura

N/C















13

Area Housing Authority of the County of Ventura

N/C















14

San Francisco Housing Authority

N/C















15

County of Contra Costa

N/C















16

County of Sacramento

N/C















17

County of Santa Clara

N/C















18

County of Los Angeles

N/C















19

County of Riverside

N/C















20

County of Fresno

N/C















21

County of Kern

N/C















22

Housing Authority Contra Costa County

N/C















23

County of Alameda

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,525

$ 86,612

% County of San Diego Above/Below

3.1%

3.0%

Number of Matches

9

9

N/C - Non Comparator

1	- Housing Authority County of San Bernardino: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency.
The salary displayed is the higher of the matches.

2	- Housing Authority County of Santa Clara: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The
salary displayed is the higher of the matches.

Page 150 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Program Analyst III*





















1

Housing Authority County of San Bernardino1

[Senior Management Analyst/ Real Estate Development Manager]

$ 99,567

$ 129,436

1.9%

$ 131,895

4/20/2021

unknown

unknown

2

Housing Authority County of Santa Clara2

[Senior Housing Policy Analyst/ Project Manager]

$ 103,730

$ 139,008

-16.8%

$ 115,655

5/15/2021

unknown

unknown

3

Los Angeles County Development Authority

Development Specialist IV

$ 80,241

$ 113,719

-2.7%

$ 110,649

1/1/2021

unknown

unknown

4

County of San Mateo

Housing/Community Development Specialist III

$ 98,652

$ 123,342

-17.5%

$ 101,757

10/4/2020

unknown

unknown

5

Sacramento Housing and Redevelopment Agency

Redevelopment Analyst - Range 3

$ 78,481

$ 100,163

0.1%

$ 100,263

1/2/2021

unknown

unknown





















7

Fresno Housing Authority

Senior Development Analyst- Special Projects

$ 54,000

$ 83,700

4.7%

$ 87,634

1/1/2021

unknown

unknown

8

County of Orange

Research Analyst III

$ 65,354

$ 88,088

-2.0%

$ 86,326

7/2/2021

7/1/2022

3.50%

9

Housing Authority Contra Costa County

Housing Development Officer

$ 77,820

$ 94,596

-11.1%

$ 84,096

6/27/2020

unknown

unknown

10

County of Ventura

N/C















11

Area Housing Authority of the County of Ventura

N/C















12

County of Santa Clara

N/C















13

City and County of San Francisco

N/C















14

San Francisco Housing Authority

N/C















15

County of Contra Costa

N/C















16

County of Sacramento

N/C















17

Housing Authority County of Kern

N/C















18

County of Los Angeles

N/C















19

County of Fresno

N/C















20

County of Riverside

N/C















21

County of San Bernardino

N/C















22

County of Kern

N/C















23

County of Alameda

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,941

$ 101,010

% County of San Diego Above/Below

-11.7%

-5.5%

Number of Matches

8

8

N/C - Non Comparator

1	- Housing Authority County of San Bernardino: Functional Match: This hybrid match re presents that the duties of the class are performed by more than one class atthe comparator agency. The salary
displayed is the higher of the matches.

2	- Housing Authority County of Santa Clara: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification atthe comparator agency. The
salary displayed is an average of the matches.

Page 151 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Program Analyst IV*





















1

Los Angeles County Development Authority

Consultant II

$ 88,110

$ 134,393

-2.7%

$ 130,764

1/1/2021

unknown

unknown

2

Sacramento Housing and Redevelopment Agency2

[Redevelopment Analyst - Range 3/ Redevelopment Manager]

$ 89,136

$ 127,485

0.1%

$ 127,612

1/4/2021

unknown

unknown

3

Housing Authority County of Santa Clara1

[Senior Housing Policy Analyst/ Project Manager]

$ 105,011

$ 140,725

-16.8%

$ 117,083

5/15/2021

unknown

unknown

4

County of San Mateo

Housing and Community Development Supervisor

$ 112,297

$ 140,376

-17.5%

$ 115,811

10/4/2020

unknown

unknown

5

County of Orange

Senior Research Analyst

$ 81,182

$ 109,158

-2.0%

$ 106,975

7/2/2021

7/1/2022

3.50%

6

County of San Bernardino

Supervising Economic and Community Development Analysts

$ 74,526

$ 102,502

1.9%

$ 104,450

7/31/2021

7/30/2022

3.00%





















8

San Francisco Housing Authority

Program Manager II

$ 90,454

$ 109,954

-17.4%

$ 90,822

6/10/2021

unknown

unknown

9

County of Ventura

N/C















10

County of Contra Costa

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

Fresno Housing Authority

N/C















14

Area Housing Authority of the County of Ventura

N/C















15

County of Alameda

N/C















16

County of Los Angeles

N/C















17

Housing Authority County of Kern

N/C















18

County of Fresno

N/C















19

Housing Authority County of San Bernardino

N/C















20

County of Riverside

N/C















21

County of Kern

N/C















22

County of Sacramento

N/C















23

Housing Authority Contra Costa County

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 127,485

$ 115,811

% County of San Diego Above/Below

-22.2%

-11.0%

Number of Matches

7

7

N/C - Non Comparator

1	- Housing Authority County of Santa Clara: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

2	- Sacramento Housing and Redevelopment Agency: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 152 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Specialist I*





















1

Housing Authority County of Santa Clara1

[Housing Assistant/ Housing Programs Specialist]

$ 56,7H

$ 75,998

-16.8%

$ 63,230

5/15/2021

unknown

unknown

2

County of Orange

Housing Specialist 1

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%





















4

Fresno Housing Authority

Housing Specialist

$43,926

$ 53,392

4.7%

$ 55,902

1/1/2021

unknown

unknown

5

Los Angeles County Development Authority

Program Specialist 1

$41,320

$ 55,896

-2.7%

$ 54,387

1/1/2021

unknown

unknown

6

San Francisco Housing Authority

Eligibility Worker 1

$ 52,589

$ 63,934

-17.4%

$ 52,809

6/10/2021

unknown

unknown

7

Sacramento Housing and Redevelopment Agency

Housing Program Technician 1

$ 40,418

$ 51,584

0.1%

$ 51,636

1/2/2021

unknown

unknown

8

Housing Authority County of Kern

Housing Specialist 1

$ 35,244

$43,032

1.2%

$43,548

4/14/2021

unknown

unknown

9

Area Housing Authority of the County of Ventura

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Ventura

N/C















13

County of Santa Clara

N/C















14

City and County of San Francisco

N/C















15

County of Contra Costa

N/C















16

County of Alameda

N/C















17

County of Kern

N/C















18

County of Sacramento

N/C















19

Housing Authority County of San Bernardino

N/C















20

County of Riverside

N/C















21

County of San Bernardino

N/C















22

County of San Mateo

N/C















23

Housing Authority Contra Costa County

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,896

$ 54,387

% County of San Diego Above/Below

0.9%

3.6%

Number of Matches

7

7

N/C - Non Comparator

1 - Housing Authority County of Santa Clara: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 153 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Specialist II*









































2

Housing Authority County of Santa Clara

Housing Programs Specialist

$ 59,509

$ 79,748

-16.8%

$ 66,351

5/15/2021

unknown

unknown

3

County of Orange

Housing Specialist II

$ 48,090

$64,813

-2.0%

$63,517

7/2/2021

7/1/2022

3.50%

4

Los Angeles County Development Authority

Program Specialist II

$ 45,940

$65,133

-2.7%

$ 63,375

1/1/2021

unknown

unknown

5

Housing Authority Contra Costa County

Housing Program Specialist

$ 57,096

$ 69,396

-11.1%

$ 61,693

6/27/2020

unknown

unknown

6

Housing Authority County of San Bernardino

Affordable Housing Specialist

$46,310

$ 60,203

1.9%

$ 61,347

4/20/2021

unknown

unknown

7

Fresno Housing Authority

Leasing Specialist

$ 47,506

$ 57,743

4.7%

$ 60,457

1/1/2021

unknown

unknown

8

Area Housing Authority of the County of Ventura

Senior HousingTechnician

$ 49,027

$ 60,297

-1.1%

$ 59,634

7/8/2021

unknown

unknown

9

Sacramento Housing and Redevelopment Agency

Housing Program Technician II

$ 44,560

$ 56,872

0.1%

$ 56,929

1/2/2021

unknown

unknown

10

San Francisco Housing Authority

Eligibility Worker II

$ 56,056

$68,146

-17.4%

$ 56,289

6/10/2021

unknown

unknown

11

Housing Authority County of Kern

Housing Specialist II

$ 38,940

$ 47,544

1.2%

$48,115

4/14/2021

unknown

unknown

12

County of Fresno

N/C















13

County of Contra Costa

N/C















14

City and County of San Francisco

N/C















15

County of Santa Clara

N/C















16

County of Los Angeles

N/C















17

County of San Mateo

N/C















18

County of Ventura

N/C















19

County of Kern

N/C















20

County of Sacramento

N/C















21

County of Alameda

N/C















22

County of Riverside

N/C















23

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,555

$ 60,902

% County of San Diego Above/Below

6.3%

8.8%

Number of Matches

10

10

N/C - Non Comparator

Page 154 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Housing Specialist III*





















1

Housing Authority County of Santa Clara

Housing Programs Supervisor

$ 92,814

$ 124,380

-16.8%

$ 103,484

5/15/2021

unknown

unknown

2

Sacramento Housing and Redevelopment Agency

Supervisor - Housing Authority

$ 64,326

$ 99,790

0.1%

$ 99,890

1/4/2021

unknown

unknown

3

Housing Authority County of San Bernardino

Housing Services Supervisor

$ 70,466

$ 91,606

1.9%

$ 93,346

4/20/2021

unknown

unknown

4

Los Angeles County Development Authority

Program Specialist IV

$ 63,762

$ 93,758

-2.7%

$91,227

1/1/2021

unknown

unknown

5

Area Housing Authority of the County of Ventura

HCV/Section 8 Supervisor

$ 69,170

$ 89,922

-1.1%

$ 88,932

7/8/2021

unknown

unknown

6

Fresno Housing Authority

Supervisor - Intake, Leasing & Case Management

$ 50,000

$ 78,500

4.7%

$82,190

1/1/2021

unknown

unknown





















8

Housing Authority Contra Costa County1

[Housing Program Specialist/ Housing Manager]

$ 64,980

$ 78,978

-11.1%

$ 70,211

6/27/2020

unknown

unknown

9

County of Orange

Housing Specialist III

$ 52,166

$ 70,325

-2.0%

$ 68,918

7/2/2021

7/1/2022

3.50%

10

San Francisco Housing Authority3

[Eligibility Worker 11/ Program Manager 1]

$ 60,879

$ 74,009

-17.4%

$ 61,131

6/10/2021

unknown

unknown

11

Housing Authority County of Kern2

[Housing Specialist 11/ Housing Programs Administrator]

$ 49,224

$ 60,096

1.2%

$ 60,817

4/14/2021

unknown

unknown

12

County of Los Angeles

N/C















13

County of Santa Clara

N/C















14

County of Fresno

N/C















15

City and County of San Francisco

N/C















16

County of Contra Costa

N/C















17

County of Alameda

N/C















18

County of Ventura

N/C















19

County of Kern

N/C















20

County of Sacramento

N/C















21

County of Riverside

N/C















22

County of San Bernardino

N/C















23

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 84,450

$85,561

% County of San Diego Above/Below

-9.5%

-11.0%

Number of Matches

10

10

N/C - Non Comparator

1	- Housing Authority Contra Costa County: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

2	- Housing Authority County of Kern: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

3	- San Francisco Housing Authority: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 155 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Human Services Control Specialist





















1

County of Sacramento

Human Services Program Integrity Specialist

$ 72,454

$ 88,051

0.1%

$ 88,139

6/21/2020

unknown

unknown

2

City and County of San Francisco

Program Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%

3

County of Santa Clara

Eligibility Examiner

$ 82,653

$ 100,004

-16.8%

$ 83,204

6/14/2021

6/13/2022

3.00%

4

County of Alameda

Quality Assurance/Quality Control Technician

$ 72,738

$ 88,130

-11.4%

$ 78,083

12/27/2020

12/26/2021

3.00%

5

County of San Mateo

Benefits Analyst III

$ 70,323

$ 87,899

-17.5%

$ 72,517

10/4/2020

unknown

unknown

6

County of Contra Costa

Social Service Program Assistant

$ 63,999

$ 77,791

-11.1%

$ 69,156

7/1/2021

unknown

unknown





















8

County of San Bernardino

Human Services System Quality Review Specialist

$ 42,224

$ 58,032

1.9%

$ 59,135

7/31/2021

7/30/2022

3.00%

9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Riverside

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,051

$ 78,083

% County of San Diego Above/Below

-45.7%

-29.2%

Number of Matches

7

7

N/C - Non Comparator

Page 156 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Human Services Specialist





















1

City and County of San Francisco

Program Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Eligibility Worker II

$ 67,608

$81,667

-16.8%

$ 67,947

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Benefits Analyst II

$ 65,415

$81,805

-17.5%

$ 67,489

10/4/2020

unknown

unknown

4

County of Sacramento

Human Services Specialist II

$ 53,787

$ 65,375

0.1%

$ 65,440

6/21/2020

unknown

unknown

5

County of Alameda1

[Eligibility Services Technician 11/ Eligibility Services Technician III]

$ 58,910

$ 71,614

-11.4%

$ 63,450

6/27/2021

6/26/2022

3.25%

6

County of Riverside

Eligibility Technician II

$ 37,546

$ 58,606

1.9%

$ 59,720

5/1/2021

5/1/2022

2.00%





















8

County of Los Angeles

Eligibility Worker II

$ 46,242

$ 58,992

-3.8%

$ 56,750

1/1/2021

unknown

unknown

9

County of Orange

Eligibility Technician

$42,515

$ 57,450

-2.0%

$ 56,301

7/2/2021

7/1/2022

3.50%

10

County of San Bernardino

Eligibility Worker II

$ 37,710

$ 51,792

1.9%

$ 52,776

7/31/2021

7/30/2022

3.00%

11

County of Contra Costa

Eligibility Worker II

$48,312

$ 58,723

-11.1%

$ 52,205

7/1/2021

unknown

unknown

12

County of Ventura

HS Client Benefit Specialist II

$ 50,155

$ 52,535

-0.7%

$ 52,167

12/27/2020

12/26/2021

2.00%

13

County of Kern

Human Services Technician III

$ 38,748

$ 47,304

1.2%

$47,872

4/21/2021

unknown

unknown

14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 58,857

$ 58,235

% County of San Diego Above/Below

-2.4%

-1.3%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 157 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Hydrogeologist





















1

County of Santa Clara

Environmental Health Geologist/Engineer

$ 134,549

$ 163,966

-16.8%

$ 136,420

10/21/2020

10/20/2021

3.00%





















3

County of Kern

Engineer II

$ 69,108

$ 84,372

1.2%

$ 85,384

4/21/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 124,169

$ 110,902

% County of San Diego Above/Below

-13.4%

-1.3%

Number of Matches

2

2

N/C - Non Comparator

Page 158 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Hydrographic Instrument Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Hydrographic Instrument Technician

$ 63,003

$ 77,376

$ 77,376

6/18/2021

unknown

unknown

2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 159 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Imaging Technician I

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Imaging Specialist 1

$ 35,073

$ 49,085

-0.7%

$ 48,741

12/26/2020

12/27/2021

2.00%

2

County of San Diego

Imaging Technician 1

$ 38,480

$ 47,320



$ 47,320

6/18/2021

unknown

unknown

3

County of Sacramento

Imaging Specialist 1

$ 37,438

$ 45,518

0.1%

$ 45,564

6/21/2020

unknown

unknown

4

County of Orange

MicrographicsTechnician 1

$ 34,154

$ 44,595

-2.0%

$ 43,703

7/2/2021

7/1/2022

3.50%

5

County of Alameda

Microfilm Technician Trainee

$ 41,798

$ 47,073

-11.4%

$ 41,706

6/27/2021

6/26/2022

3.25%

6

City and County of San Francisco

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 46,295

$ 44,633

% County of San Diego Above/Below

2.2%

5.7%

Number of Matches

4

4

N/C - Non Comparator

Page 160 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Imaging Technician II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Imaging Specialist II

$ 38,270

$ 53,715

-0.7%

$ 53,339

12/26/2020

12/27/2021

2.00%



County of San Diego

Imaging Technician II

$ 43,056

$ 52,936



$ 52,936

6/18/2021

unknown

unknown

3

County of San Bernardino

ArchivesTechnician

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

4

County of Sacramento

Imaging Specialist II

$ 40,006

$ 48,650

0.1%

$ 48,699

6/21/2020

unknown

unknown

5

County of Alameda

Microfilm Technician

$ 46,227

$ 54,562

-11.4%

$ 48,342

6/27/2021

6/26/2022

3.25%

6

County of Kern

Document Imaging Technician

$ 29,460

$ 35,964

1.2%

$ 36,396

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,482

$ 48,699

% County of San Diego Above/Below

4.6%

8.0%

Number of Matches

5

5

N/C - Non Comparator

Page 161 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Imaging Technician III





















1

County of Santa Clara

Supervising Recordable Document Technician

$ 63,012

$ 76,623

-16.8%

$ 63,750

6/28/2021

6/27/2022

3.00%





















3

County of Sacramento

Supervising Imaging Specialist

$ 48,588

$ 59,049

0.1%

$ 59,108

6/21/2020

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,836

$ 61,429

% County of San Diego Above/Below

-11.9%

-1.3%

Number of Matches

2

2

N/C - Non Comparator

Page 162 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Industrial Hygienist I





















1

City and County of San Francisco

Assistant Industrial Hygienist

$91,704

$ 111,492

-17.4%

$92,092

7/1/2021

1/8/2022

.50%





















3

County of Riverside

Industrial Hygienist 1

$ 48,995

$ 72,440

1.9%

$ 73,816

5/1/2021

5/1/2022

2.00%

4

County of Fresno

Environmental Health Specialist 1

$ 49,062

$ 59,618

4.7%

$ 62,420

10/17/2019

unknown

unknown

5

County of Kern

Hazardous Materials Specialist 1 - Environmental Health

$44,340

$ 54,132

1.2%

$ 54,782

4/21/2021

unknown

unknown

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,029

$ 68,118

% County of San Diego Above/Below

24.5%

22.1%

Number of Matches

4

4

N/C - Non Comparator

Page 163 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Industrial Hygienist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Industrial Hygienist

$ 121,704

$ 147,912

-17.4%

$ 122,175

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Industrial Hygienist

$ 99,264

$ 109,453

0.1%

$ 109,562

6/21/2020

unknown

unknown

3

County of Alameda

Industrial Hygiene Engineer

$ 103,020

$ 118,483

-11.4%

$ 104,976

6/27/2021

6/26/2022

3.25%

4

County of San Mateo

Hazardous Materials Specialist III

$ 97,633

$ 121,990

-17.5%

$ 100,641

10/4/2020

unknown

unknown

5

County of Los Angeles

Industrial Hygienist

$ 75,488

$ 101,716

-3.8%

$ 97,851

1/1/2021

unknown

unknown

6

County of San Diego

Industrial Hygienist II

$ 78,978

$ 97,074



$ 97,074

6/18/2021

unknown

unknown

7

County of Orange

Industrial Hygienist

$ 70,782

$ 95,347

-2.0%

$ 93,440

7/2/2021

7/1/2022

3.50%

8

County of Riverside

Industrial Hygienist II

$ 59,372

$ 87,913

1.9%

$ 89,584

5/1/2021

5/1/2022

2.00%

9

County of Fresno

Environmental Health Specialist II

$ 55,120

$ 67,002

4.7%

$70,151

10/17/2019

unknown

unknown

10

County of Kern

Hazardous Materials Specialist II

$ 48,984

$ 59,808

1.2%

$ 60,526

4/21/2021

unknown

unknown

11

County of Contra Costa

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 101,716

$ 97,851

% County of San Diego Above/Below

-4.8%

-0.8%

Number of Matches

9

9

N/C - Non Comparator

Page 164 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Industrial Hygienist III





















1

Cityand County of San Francisco

Senior Industrial Hygienist

$ 134,186

$ 175,396

-17.4%

$ 144,877

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Industrial Hygiene Engineer/Supervising Industrial Hygiene Engineer]

$ 106,184

$ 124,665

-11.4%

$ 110,453

12/27/2020

unknown

unknown





















4

County of Riverside

Industrial Hygienist III

$ 62,479

$ 92,488

1.9%

$ 94,245

5/1/2021

5/1/2022

2.00%

5

County of Fresno

Environmental Health Specialist III

$ 60,736

$ 73,840

4.7%

$ 77,310

10/17/2019

unknown

unknown

6

County of Kern

Hazardous Materials Specialist III

$ 54,132

$ 66,084

1.2%

$ 66,877

4/21/2021

unknown

unknown

7

County of Contra Costa

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,488

$ 94,245

% County of San Diego Above/Below

9.3%

7.5%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 165 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Insect Detection Specialist I





















1

County of Riverside

Environmental Health Technician 1

$ 36,977

$ 57,710

1.9%

$ 58,807

5/1/2021

5/1/2022

2.00%

2

County of Orange

Integrated Pest Management Technician 1

$ 35,755

$ 48,152

-2.0%

$ 47,189

7/2/2021

7/1/2022

3.50%

3

County of Ventura

Insect Detection Specialist 1

$ 29,411

$ 42,307

-0.7%

$ 42,011

12/26/2020

12/27/2021

2.00%

4

County of San Bernardino

Agricultural Field Aide 1

$ 30,243

$ 41,205

1.9%

$ 41,988

7/31/2021

7/30/2022

3.00%





















6

County of Fresno

Agricultural Field Aide

$ 29,458

$ 30,940

4.7%

$ 32,394

4/19/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 42,307

$ 42,011

% County of San Diego Above/Below

-7.4%

-6.7%

Number of Matches

5

5

N/C - Non Comparator

Page 166 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Insect Detection Specialist II





















1

City and County of San Francisco

Integrated Pest Management Specialist

$ 82,392

$ 100,128

-17.4%

$ 82,706

7/1/2021

1/8/2022

.50%

2

County of Alameda

Agricultural and Standards Technician

$ 57,744

$ 70,347

-11.4%

$ 62,328

6/27/2021

6/26/2022

3.25%

3

County of Riverside

Environmental Health Technician II

$ 38,982

$ 60,876

1.9%

$ 62,032

5/1/2021

5/1/2022

2.00%

4

County of Orange

Integrated Pest Management Technician II

$ 44,366

$ 59,842

-2.0%

$ 58,645

7/2/2021

7/1/2022

3.50%

5

County of San Mateo

Pest Detection Specialist

$ 51,125

$ 63,896

-17.5%

$ 52,715

10/4/2020

unknown

unknown





















7

County of Ventura

Insect Detection Specialist II

$ 34,366

$ 46,016

-0.7%

$ 45,694

12/26/2020

12/27/2021

2.00%

8

County of San Bernardino

Agricultural Field Aide II

$ 32,323

$ 44,429

1.9%

$ 45,273

7/31/2021

7/30/2022

3.00%

9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,876

$ 58,645

% County of San Diego Above/Below

-30.9%

-26.1%

Number of Matches

7

7

N/C - Non Comparator

Page 167 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Inservice Education Coordinator





















1

County of Contra Costa

HeaIth Services Education and Training Specialist

$ 143,368

$ 179,047

-11.1%

$ 159,173

1/1/2021

unknown

unknown

2

County of Los Angeles

Assistant Program Specialist, Public H ea It h Nursing

$99,011

$ 148,207

-3.8%

$ 142,576

1/1/2021

unknown

unknown

3

County of Riverside

Nursing Education Instructor

$ 80,837

$ 119,987

1.9%

$ 122,267

5/1/2021

5/1/2022

2.00%





















5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 148,207

$ 142,576

% County of San Diego Above/Below

-40.2%

-34.9%

Number of Matches

3

3

N/C - Non Comparator

Page 168 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[International Case Coordinator	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

International Case Coordinator

$ 93,662

$ 115,024

$ 115,024

6/18/2021

unknown

unknown

2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 169 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Investigative Specialist





















1

City and County of San Francisco

District Attorneys Investigative Assistant

$ 75,216

$ 95,988

-17.4%

$ 79,286

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Investigative Assistant

$ 55,687

$ 67,672

0.1%

$ 67,740

6/21/2021

unknown

unknown

3

County of Orange

Investigative Assistant - Sheriff

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

4

County of Ventura

Investigative Assistant II

$ 38,366

$ 53,899

-0.7%

$ 53,521

12/26/2020

12/27/2021

2.00%

5

County of San Bernardino

Investigative Technician 1

$ 35,797

$ 49,296

1.9%

$ 50,233

7/31/2021

7/30/2022

3.00%





















7

County of Fresno

Investigative Technician

$ 37,882

$ 46,046

4.7%

$ 48,210

10/19/2020

unknown

unknown

8

County of Kern

Investigative Aide

$ 35,604

$ 43,464

1.2%

$ 43,986

4/21/2021

unknown

unknown

9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,899

$ 53,521

% County of San Diego Above/Below

-8.4%

-7.7%

Number of Matches

7

7

N/C - Non Comparator

Page 170 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Investigative Technician |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Investigative Technician 1

$ 61,027

$82,181

-2.0%

$ 80,537

7/2/2021

7/1/2022

3.50%

2

County of San Diego

Investigative Technician

$ 64,771

$ 79,622



$ 79,622

6/18/2021

unknown

unknown

3

County of Los Angeles

Investigator, Photographer D.A.

$ 61,065

$ 82,285

-3.8%

$79,158

1/1/2021

unknown

unknown

4

County of Riverside

Investigative Technician II

$ 47,712

$ 74,529

1.9%

$ 75,945

5/1/2021

5/1/2022

2.00%

5

County of Kern

Investigative Technician II

$ 46,608

$ 56,892

1.2%

$ 57,575

4/21/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 78,355

$ 77,551

% County of San Diego Above/Below

1.6%

2.6%

Number of Matches

4

4

N/C - Non Comparator

Page 171 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Jr Air Pollution Chemist*









































2

South Coast Air Quality Management District

N/C















3

Bay Area Air Quality Management District

N/C















4

County of Orange

N/C















5

County of Ventura

N/C















6

Sacramento Metropolitan Air Quality Management District

N/C















7

San Luis Obispo County Air Pollution Control District

N/C















8

Imperial County Air Pollution Control District

N/C















9

County of Contra Costa

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 172 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Jr Air Pollution Control Engineer*





















1

South Coast Air Quality Management District

Assistant Air Quality Engineer

$ 68,616

$ 92,232

-2.8%

$ 89,650

1/1/2020

unknown

unknown





















3

Sacramento Metropolitan Air Quality Management District

N/C















4

Bay Area Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,232

$ 89,650

% County of San Diego Above/Below

-20.7%

-17.3%

Number of Matches

1

1

N/C - Non Comparator

Page 173 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

IJr Land Use/Environmental Planner*

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Planner 1

$ 53,349

$ 74,818

-0.7%

$ 74,294

12/27/2020

12/26/2021

2.00%

2

County of San Mateo

Planner 1

$ 67,952

$ 84,987

-17.5%

$ 70,114

10/4/2020

unknown

unknown

3

County of San Bernardino

PlannerTrainee

$ 50,440

$ 67,704

1.9%

$ 68,990

7/31/2021

7/30/2022

3.00%

4

County of San Diego

Jr Land Use/Environmental Planner*

$ 54,038

$ 66,352



$ 66,352

6/18/2021

unknown

unknown

5

County of Contra Costa

Environmental Assistant

$ 61,040

$ 74,194

-11.1%

$ 65,959

7/1/2021

unknown

unknown

6

County of Fresno

Planner 1

$ 48,698

$ 62,270

4.7%

$ 65,197

11/2/2020

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 74,194

$ 68,990

% County of San Diego Above/Below

-11.8%

-4.0%

Number of Matches

5

5

N/C - Non Comparator

Page 174 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Jr Public Health Microbiologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Clinical Microbiologist!

$ 94,008

$ 126,684

-3.8%

$ 121,870

1/1/2021

unknown

unknown

2

City and County of San Francisco

Microbiologist 1

$ 86,892

$ 122,330

-17.4%

$ 101,045

7/1/2021

1/8/2022

.50%

3

County of Riverside

Public Health Microbiologist 1

$ 51,608

$ 82,997

1.9%

$ 84,574

5/1/2021

5/1/2022

2.00%

4

County of Ventura

Microbiologist 1

$ 59,833

$ 83,687

-0.7%

$ 83,101

12/27/2020

12/26/2021

2.00%

5

County of Alameda1

[Laboratory Technician/ Microbiologist]

$ 71,770

$ 85,585

-11.4%

$ 75,829

6/27/2021

6/26/2022

3.25%

6

County of San Bernardino

Public Health Microbiologist 1

$ 52,187

$ 69,950

1.9%

$ 71,279

3/13/2021

3/26/2022

3.00%

7

County of Kern

Microbiologist Trainee

$ 55,500

$ 67,752

1.2%

$ 68,565

4/21/2021

unknown

unknown

8

County of San Diego

Jr Public Health Microbiologist

$ 51,168

$ 62,858



$ 62,858

6/18/2021

unknown

unknown

9

County of Fresno

Public Health MicrobiologistTrainee

$ 46,930

$ 57,070

4.7%

$ 59,752

10/17/2019

unknown

unknown

10

County of Orange

Public Health MicrobiologistTrainee

$ 38,688

$ 52,166

-2.0%

$ 51,123

7/2/2021

7/1/2022

3.50%

11

County of Contra Costa

MicrobiologistTrainee

$ 41,427

$ 50,355

-11.1%

$ 44,765

7/1/2021

unknown

unknown

12

County of Sacramento

Public Health MicrobiologistTrainee

$ 42,720

$ 42,720

0.1%

$ 42,763

6/21/2020

unknown

unknown

13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,950

$ 71,279

% County of San Diego Above/Below

-11.3%

-13.4%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

Page 175 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Jr Real Property Agent	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Real Property Agent 1

$ 54,588

$ 77,352

-0.7%

$ 76,810

12/27/2020

12/26/2021

2.00%

2

County of San Bernardino

Real Property Agent 1

$ 51,770

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

3

County of San Mateo1

Real Property Agent 1

$ 77,499

$ 86,672

-17.5%

$ 71,504

10/4/2020

unknown

unknown

4

County of Santa Clara

Junior Real Estate Agent

$ 64,977

$ 78,501

-16.8%

$ 65,313

6/14/2021

6/13/2022

3.00%

5

County of Orange

Real Property Agent 1

$ 48,942

$ 65,354

-2.0%

$ 64,046

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Real Property Agent 1

$ 39,882

$ 58,957

1.9%

$ 60,078

5/1/2021

5/1/2022

2.00%

7

County of Sacramento

Real Estate Specialist

$ 46,771

$ 56,877

0.1%

$ 56,934

6/21/2020

unknown

unknown

8

County of Contra Costa

Junior Real Property Agent

$48,177

$ 58,560

-11.1%

$ 52,060

7/1/2021

unknown

Unknown

9

County of San Diego

Jr Real Property Agent

$ 42,328

$ 52,042



$ 52,042

6/18/2021

unknown

unknown

10

County of Los Angeles

Junior Real Property Agent

$ 50,010

$ 51,380

-3.8%

$ 49,427

1/1/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Fresno

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,354

$ 64,046

% County of San Diego Above/Below

-25.6%

-23.1%

Number of Matches

9

9

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 176 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Jr Surveyor (T)





















1

County of Los Angeles

Survey Party Chief 1

$ 86,869

$ 110,892

-3.8%

$ 106,678

1/1/2021

unknown

unknown

2

County of Alameda1

[SurveyTechnician 11/SurveyTechnician III]

$ 93,600

$ 103,802

-11.4%

$ 91,969

10/4/2020

10/3/2021

3.25%

3

County of Ventura

Surveyor 1

$ 56,570

$ 85,221

-0.7%

$ 84,624

1/10/2021

1/9/2022

2.00%





















5

County of Orange

Surveyor 1

$ 59,738

$ 80,538

-2.0%

$ 78,927

7/2/2021

7/1/2022

3.50%

6

County of San Mateo

Public WorksTechnician II

$ 75,565

$ 94,451

-17.5%

$ 77,922

10/4/2020

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 94,451

$ 84,624

% County of San Diego Above/Below

-17.4%

-5.2%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at
the comparator agency. The salary displayed is an average of the matches.

Page 177 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Laboratory Assistant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Laboratory Technician II

$ 67,704

$ 82,392

-17.4%

$ 68,056

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Medical Laboratory Assistant II

$ 61,531

$ 74,295

-16.8%

$ 61,814

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Laboratory Assistant II

$ 52,561

$ 65,685

-17.5%

$ 54,190

10/4/2020

unknown

unknown

4

County of Orange

Laboratory Assistant

$ 40,186

$ 53,539

-2.0%

$ 52,468

7/2/2021

7/1/2022

3.50%

5

County of Alameda

Laboratory Assistant II

$ 48,603

$ 57,482

-11.4%

$ 50,929

6/27/2021

6/26/2022

3.25%

6

County of Contra Costa

Laboratory Technician 1

$ 45,309

$ 55,073

-11.1%

$ 48,960

7/1/2021

unknown

unknown

7

County of Ventura

Laboratory Assistant

$ 33,230

$ 46,363

-0.7%

$ 46,038

12/26/2020

12/27/2021

2.00%

8

County of Los Angeles

Laboratory Assistant

$ 34,200

$ 45,908

-3.8%

$ 44,163

1/1/2021

unknown

unknown

9

County of San Diego

Laboratory Assistant

$ 35,610

$ 43,784



$ 43,784

6/18/2021

unknown

unknown

10

County of San Bernardino

Laboratory Assistant

$ 30,597

$ 42,598

1.9%

$ 43,408

7/31/2021

7/30/2022

3.00%

11

County of Fresno

Public Health Laboratory Assistant II

$ 28,626

$ 36,608

4.7%

$ 38,329

11/2/2020

unknown

unknown

12

County of Kern

Laboratory Assistant

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

13

County of Riverside

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,539

$ 48,960

% County of San Diego Above/Below

-22.3%

-11.8%

Number of Matches

11

11

N/C - Non Comparator

Page 178 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Land Surveyor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Senior Land Surveyor

$ 88,152

$ 130,596

1.9%

$ 133,077

5/1/2021

5/1/2022

2.00%

2

County of Sacramento

Associate Land Surveyor

$ 102,500

$ 124,591

0.1%

$ 124,716

6/21/2020

unknown

unknown

3

County of Santa Clara

Land Surveyor

$ 111,349

$ 135,410

-16.8%

$ 112,661

10/21/2020

10/20/2021

3.00%

4

County of San Bernardino

Land Surveyor

$ 77,147

$ 108,867

1.9%

$ 110,936

3/13/2021

3/26/2022

3.00%

5

County of Alameda

Land Surveyor

$ 112,840

$ 125,091

-11.4%

$ 110,831

10/4/2020

10/3/2021

3.25%

6

County of San Diego

Land Surveyor

$ 89,045

$ 109,470



$ 109,470

6/18/2021

unknown

unknown

7

County of Orange

Surveyor II

$ 70,325

$ 94,765

-2.0%

$ 92,870

7/2/2021

7/1/2022

3.50%

8

County of Kern

Engineer II

$ 69,108

$ 84,372

1.2%

$ 85,384

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Los Angeles

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 124,591

$ 110,936

% County of San Diego Above/Below

-13.8%

-1.3%

Number of Matches

7

7

N/C - Non Comparator

Page 179 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use Aide

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

PlanningTechnician 1

$ 46,860

$ 56,958

-11.1%

$ 50,636

7/1/2021

unknown

unknown

2

County of San Diego

Land Use Aide

$ 39,416

$ 48,485



$ 48,485

6/18/2021

unknown

unknown

3

County of Sacramento

Engineering Aide

$ 37,981

$46,145

0.1%

$46,191

6/21/2020

unknown

unknown

4

County of San Bernardino

Land Use Technician Trainee

$ 32,490

$ 43,576

1.9%

$ 44,404

7/31/2021

7/30/2022

3.00%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$46,145

$46,191

% County of San Diego Above/Below

4.8%

4.7%

Number of Matches

3

3

N/C - Non Comparator

Page 180 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use Technician I





















1

County of Alameda

Public Works Tech nical Assistant 1

$ 66,296

$ 78,881

-11.4%

$ 69,889

6/27/2021

6/26/2022

3.25%

2

County of Riverside

Land Use Technician I

$ 43,137

$ 67,399

1.9%

$ 68,679

5/1/2021

5/1/2022

2.00%

3

County of Ventura2

[Resource Management Agency Technician 1 - Planning/ Resource Management Agency Technician 1 - Building and Safety]

$ 45,498

$ 63,525

-0.7%

$ 63,080

12/26/2020

12/27/2021

2.00%

4

County of Orange

PermitTechnician Trainee

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

5

County of Sacramento

Engineering Technician 1

$ 46,437

$ 56,460

0.1%

$ 56,516

6/21/2020

unknown

unknown





















7

County of Contra Costa1

[Planning Technician I/Planning Technician II]

$ 50,397

$ 61,258

-11.1%

$ 54,458

7/1/2021

unknown

unknown

8

County of Kern

Planning Technician

$ 41,352

$ 50,472

1.2%

$ 51,078

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,258

$ 58,543

% County of San Diego Above/Below

-9.4%

-4.5%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of the matches.
2- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the matches.

Page 181 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use Technician II





















1

County of Riverside

Land Use Technician II

$ 50,574

$ 78,984

1.9%

$ 80,485

5/1/2021

5/1/2022

2.00%

2

County of Alameda

Public Works Technical Assistant II

$ 75,574

$ 90,027

-11.4%

$ 79,764

6/27/2021

6/26/2022

3.25%

3

County of Orange

Permit Technician

$ 56,597

$ 76,274

-2.0%

$ 74,748

7/2/2021

7/1/2022

3.50%





















5

County of Ventura2

[Resource Management Agency Technician II - Planning/ Resource Management Agency Technician II - Building and Safety]

$ 48,757

$ 68,065

-0.7%

$ 67,589

12/26/2020

12/27/2021

2.00%

6

County of San Bernardino

Land Use Technician

$ 48,090

$ 66,123

1.9%

$ 67,380

7/31/2021

7/30/2022

3.00%

7

County of Sacramento

Engineering Technician II

$ 54,037

$ 65,688

0.1%

$ 65,754

6/21/2020

unknown

unknown

S

County of San Mateo1

[Planning Technician/Office Specialist]

$ 61,848

$ 77,302

-17.5%

$ 63,774

10/4/2020

unknown

unknown

9

County of Contra Costa

Planning Technician II

$ 53,934

$ 65,557

-11.1%

$ 58,280

7/1/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,170

$ 67,484

% County of San Diego Above/Below

2.7%

9.0%

Number of Matches

8

8

N/C- Non Comparator

1 - County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the matches.
2- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the matches.

Page 182 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use Technician III





















1

County of Riverside

Supervising Land Use Technician

$ 56,626

$ 90,740

1.9%

$ 92,464

5/1/2021

5/1/2022

2.00%

2

County of Alameda

Public Works Technical Assistant III

$ 82,446

$ 98,575

-11.4%

$ 87,337

6/27/2021

6/26/2022

3.25%

3

County of Orange

Senior Permit Technician

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

4

County of Ventura

Resource Management Agency Technician III

$ 60,625

$ 85,059

-0.7%

$ 84,463

12/26/2020

12/27/2021

2.00%





















6

County of Sacramento

Senior Engineering Technician

$ 61,053

$ 74,208

0.1%

$ 74,282

6/21/2020

unknown

unknown

7

County of San Bernardino

Senior Land Use Technician

$ 50,440

$ 69,389

1.9%

$ 70,707

7/31/2021

7/30/2022

3.00%

8

City and County of San Francisco

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,220

$ 85,048

% County of San Diego Above/Below

-5.3%

-3.9%

Number of Matches

6

6

N/C - Non Comparator

Page 183 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use/Environmental Planner I





















1

County of Los Angeles

Regional Planner

$ 75,672

$ 96,588

-3.8%

$ 92,918

1/1/2021

unknown

unknown

2

County of Sacramento

Assistant Planner

$ 69,322

$ 84,251

0.1%

$ 84,335

6/21/2020

unknown

unknown

3

County of Ventura

Planner II

$ 59,810

$ 83,638

-0.7%

$ 83,052

12/26/2020

12/27/2021

2.00%

4

County of San Bernardino

Planner 1

$ 58,427

$ 80,309

1.9%

$ 81,835

7/31/2021

7/30/2022

3.00%

5

County of Orange

Assistant Planner

$ 61,402

$ 82,763

-2.0%

$ 81,108

7/2/2021

7/1/2022

3.50%





















7

County of San Mateo2

[Planner I/Planner II]

$ 74,265

$ 92,849

-17.5%

$ 76,601

10/4/2020

unknown

unknown

8

County of Contra Costa1

[Planner I/Environmental Analyst 1]

$ 63,632

$ 77,345

-11.1%

$ 68,760

7/1/2021

unknown

unknown

9

County of Riverside

Environmental Planner 1

$ 42,690

$ 63,177

1.9%

$ 64,377

5/1/2021

5/1/2022

2.00%

10

County of Kern

Planner 1

$ 50,988

$ 62,244

1.2%

$ 62,991

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Fresno

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,763

$ 81,108

% County of San Diego Above/Below

-3.9%

-1.9%

Number of Matches

9

9

N/C - Non Comparator

1	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the
comparator agency. The salary displayed is the higher of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 184 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use/Environmental Planner II





















1

City and County of San Francisco

Planner Ill-Environmental Review

$ 108,840

$ 132,288

-17.4%

$ 109,270

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Associate Planner

$ 85,504

$ 103,941

0.1%

$ 104,045

6/21/2020

unknown

unknown

3

County of Orange

Associate Planner

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

4

County of Ventura

Planner III

$ 71,888

$ 101,019

-0.7%

$ 100,312

12/26/2020

12/27/2021

2.00%

5

County of Los Angeles

Senior Regional Planner

$ 79,884

$ 101,964

-3.8%

$ 98,089

1/1/2021

unknown

unknown

6

County of Alameda1

[Planner 11/ Assistant Environmental Compliance Specialist]

$ 91,936

$ 106,517

-11.4%

$ 94,374

2/7/2021

2/6/2022

3.50%





















8

County of Riverside

Environmental Planner III

$ 59,221

$ 87,698

1.9%

$ 89,364

5/1/2021

5/1/2022

2.00%

9

County of San Bernardino

Planner II

$ 62,837

$ 86,382

1.9%

$ 88,024

7/31/2021

7/30/2022

3.00%

10

County of San Mateo

Planner II

$ 80,578

$ 100,712

-17.5%

$ 83,087

10/4/2020

unknown

unknown

11

County of Contra Costa2

[Planner ll/Environmental Analyst II]

$ 75,297

$ 91,524

-11.1%

$ 81,365

7/1/2021

unknown

unknown

12

County of Fresno

Planner II

$ 54,080

$ 69,186

4.7%

$ 72,438

11/2/2020

unknown

unknown

13

County of Kern

Planner II

$ 53,592

$ 65,424

1.2%

$ 66,209

4/21/2021

unknown

unknown

14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,865

$ 91,869

% County of San Diego Above/Below

-7.5%

2.1%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

2	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The
salary displayed is the higher of the matches.

Page 185 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Land Use/Environmental Planner III





















1

County of Los Angeles

Supervising Regional Planner

$ 104,772

$ 133,740

-3.8%

$ 128,658

1/1/2021

unknown

unknown

2

County of Sacramento

Senior Planner

$ 108,472

$ 119,601

0.1%

$ 119,721

6/21/2020

unknown

unknown

3

County of Ventura

Planner IV

$ 80,303

$ 118,514

-0.7%

$ 117,684

12/26/2020

12/27/2021

2.00%

4

County of Riverside

Senior Environmental Planner

$ 75,645

$ 111,998

1.9%

$ 114,126

5/1/2021

5/1/2022

2.00%

5

County of Orange

Senior Planner

$ 85,030

$ 114,587

-2.0%

$ 112,295

7/2/2021

7/1/2022

3.50%

6

County of Alameda1

[Planner III/ Associate Environmental Compliance Specialist]

$ 101,566

$ 123,427

-11.4%

$ 109,357

2/7/2021

2/6/2022

3.50%





















8

County of San Bernardino

Planner III

$ 72,758

$ 100,131

1.9%

$ 102,034

7/31/2021

7/30/2022

3.00%

9

County of San Mateo

Planner III

$ 92,267

$ 115,292

-17.5%

$95,116

10/4/2020

unknown

unknown

10

County of Contra Costa2

[Planner Ill/Environmental Analyst III]

$ 87,094

$ 105,863

-11.1%

$94,112

7/1/2021

unknown

unknown

11

County of Fresno

Planner III

$ 62,452

$ 79,872

4.7%

$ 83,626

11/2/2020

unknown

unknown

12

County of Kern

Planner III

$ 63,492

$ 77,508

1.2%

$ 78,438

4/21/2021

unknown

unknown

13

City and County of San Francisco

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 114,587

$ 109,357

% County of San Diego Above/Below

-6.5%

-1.6%

Number of Matches

11

11

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

2	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 186 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Landscape Architect





















1

County of Sacramento

Associate Landscape Architect

$ 102,500

$ 124,591

0.1%

$ 124,716

6/21/2020

unknown

unknown

2

City and County of San Francisco

Landscape Architectural Associate II

$ 119,988

$ 145,812

-17.4%

$ 120,441

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Landscape Architect

$ 87,738

$ 111,996

-3.8%

$ 107,740

1/1/2021

unknown

unknown





















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 124,591

$ 120,441

% County of San Diego Above/Below

-29.2%

-24.9%

Number of Matches

3

3

N/C - Non Comparator

Page 187 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Latent Print Examiner





















1

County of Contra Costa

Fingerprint Examiner II

$ 87,050

$ 108,456

-11.1%

$ 96,417

7/1/2021

7/1/2022

5.00%





















3

County of Riverside

Fingerprint Examiner II

$ 58,320

$91,164

1.9%

$ 92,896

5/1/2021

5/1/2022

2.00%

4

County of Santa Clara

Latent Fingerprint Examiner II

$ 92,115

$ 111,457

-16.8%

$ 92,732

6/14/2021

6/13/2022

3.00%

5

County of San Bernardino

Latent Print Examiner

$ 59,883

$ 82,326

1.9%

$ 83,891

7/31/2021

7/30/2022

3.00%

6

County of Alameda

Latent Fingerprint Examiner

$ 69,180

$ 82,991

-11.4%

$ 73,530

6/27/2021

6/26/2022

3.25%

7

County of Kern

Latent Print Examiner

$ 54,672

$ 66,744

1.2%

$ 67,545

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,078

$ 88,311

% County of San Diego Above/Below

8.8%

7.5%

Number of Matches

6

6

N/C - Non Comparator

Page 188 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Laundry Supervisor

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Laundry Supervisor II

$ 49,765

$ 67,060

-3.8%

$ 64,512

1/1/2021

unknown

unknown

2

County of San Diego

Laundry Supervisor

$ 44,699

$ 54,891



$ 54,891

6/18/2021

unknown

unknown

3

County of Ventura

Supervisor - Laundry Services

$ 40,446

$ 54,532

-0.7%

$ 54,150

12/26/2020

12/27/2021

2.00%

4

County of Riverside

Laundry Supervisor

$ 32,306

$ 47,759

1.9%

$ 48,666

5/1/2021

5/1/2022

2.00%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 54,532

$ 54,150

% County of San Diego Above/Below

0.7%

1.3%

Number of Matches

3

3

N/C - Non Comparator

Page 189 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Laundry Worker	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Utility Worker II

$ 53,684

$ 67,100

-17.5%

$ 55,357

10/4/2020

unknown

unknown

2

County of Santa Clara

Laundry Worker II

$ 48,687

$ 58,608

-16.8%

$ 48,762

6/14/2021

6/13/2022

3.00%

3

County of Alameda

Laundry Service Worker

$ 43,428

$ 51,422

-11.4%

$ 45,560

6/27/2021

6/26/2022

3.25%

4

County of Sacramento

Laundry Worker

$ 36,603

$ 44,495

0.1%

$ 44,540

6/21/2020

unknown

unknown

5

County of San Diego

Laundry Worker

$ 34,528

$ 42,432



$ 42,432

6/18/2021

unknown

unknown

6

County of Riverside

Laundry Worker

$ 29,120

$ 38,664

1.9%

$ 39,398

5/1/2021

5/1/2022

2.00%

7

County of Orange

Laundry Worker

$ 30,306

$ 37,690

-2.0%

$ 36,936

7/2/2021

7/1/2022

3.50%

8

County of Ventura

Laundry Worker II

$ 29,505

$ 36,611

-0.7%

$ 36,355

12/26/2020

12/27/2021

2.00%

9

County of Kern

Linen Services Associate II

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

10

County of Los Angeles

Laundry Worker

$ 31,320

$ 37,411

-3.8%

$ 35,989

1/1/2021

unknown

unknown

11

County of San Bernardino

Linen Room Attendant

$ 29,848

$ 33,197

1.9%

$ 33,828

7/31/2021

7/30/2022

3.00%

12

City and County of San Francisco

N/C















13

County of Contra Costa

N/C















14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 38,177

$ 38,167

% County of San Diego Above/Below

10.0%

10.1%

Number of Matches

10

10

N/C - Non Comparator

Page 190 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Legal Support Assistant I





















1

County of Los Angeles

Legal Office Support Assistant 1

$ 44,469

$ 64,950

-3.8%

$ 62,481

1/1/2021

unknown

unknown

2

County of Santa Clara

Legal ClerkTrainee

$ 59,018

$ 71,269

-16.8%

$ 59,296

6/14/2021

6/13/2022

3.00%

3

County of Orange

Legal SecretaryTrainee

$ 42,016

$ 56,597

-2.0%

$ 55,465

7/2/2021

7/1/2022

3.50%

4

County of San Mateo

Legal Office Assistant 1

$ 53,101

$ 66,372

-17.5%

$ 54,757

10/4/2020

unknown

unknown

5

County of Riverside

Legal Support Assistant 1

$ 33,923

$ 52,918

1.9%

$ 53,923

5/1/2021

5/1/2022

2.00%

6

County of Ventura

Legal Processing Assistant 1

$ 34,888

$ 48,754

-0.7%

$ 48,413

12/27/2020

12/26/2021

2.00%





















8

County of Fresno

Legal Assistant 1

$ 29,224

$ 36,244

4.7%

$ 37,947

11/2/2020

unknown

unknown

9

County of Kern

Legal ProcessTechnician 1

$ 30,348

$ 37,056

1.2%

$ 37,501

4/21/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Contra Costa

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 54,757

$ 54,340

% County of San Diego Above/Below

-26.9%

-25.9%

Number of Matches

8

8

N/C - Non Comparator

Page 191 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Legal Support Assistant II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Legal Office Support Assistant II

$ 49,521

$ 68,565

-3.8%

$ 65,959

1/1/2021

unknown

unknown

2

County of Orange

Legal Secretary

$ 48,090

$ 64,813

-2.0%

$ 63,517

7/2/2021

7/1/2022

3.50%

3

County of Santa Clara

Legal Clerk

$ 61,545

$ 74,348

-16.8%

$ 61,857

6/14/2021

6/13/2022

3.00%

4

City and County of San Francisco

Legal Process Clerk

$ 60,300

$ 73,272

-17.4%

$ 60,523

7/1/2021

1/8/2022

.50%

5

County of Riverside

Legal Support Assistant II

$ 37,868

$59,128

1.9%

$ 60,251

5/1/2021

5/1/2022

2.00%

6

County of Contra Costa

Clerk - Specialist Level

$ 50,943

$ 65,057

-11.1%

$ 57,835

7/1/2021

unknown

unknown

7

County of San Mateo

Legal Office Assistant II

$ 55,992

$ 69,991

-17.5%

$ 57,742

10/4/2020

unknown

unknown

8

County of Ventura

Legal Processing Assistant II

$ 38,407

$ 53,717

-0.7%

$ 53,341

12/27/2020

12/26/2021

2.00%

9

County of Sacramento

Legal Secretary 1

$ 43,242

$ 52,576

0.1%

$ 52,629

6/21/2020

unknown

unknown

10

County of San Diego

Legal Support Assistant II

$ 39,624

$ 48,714



$ 48,714

6/18/2021

unknown

unknown

11

County of Fresno

Legal Assistant II

$ 31,590

$ 40,404

4.7%

$ 42,303

11/2/2020

unknown

unknown

12

County of Kern

Legal Process Technician II

$ 33,528

$ 40,932

1.2%

$ 41,423

4/21/2021

unknown

unknown

13

County of Alameda

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 64,813

$ 57,835

% County of San Diego Above/Below

-33.0%

-18.7%

Number of Matches

11

11

N/C - Non Comparator

Page 192 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Legal Support Assistant III	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Senior Legal Office Support Assistant

$ 49,521

$ 72,392

-3.8%

$ 69,641

1/1/2021

unknown

unknown

2

County of Orange

Senior Legal Secretary

$ 52,166

$ 70,325

-2.0%

$ 68,918

7/2/2021

7/1/2022

3.50%

3

County of Riverside

Senior Legal Support Assistant

$ 42,068

$ 65,723

1.9%

$ 66,972

5/1/2021

5/1/2022

2.00%

4

City and County of San Francisco

Senior Legal Process Clerk

$ 66,144

$ 80,388

-17.4%

$ 66,400

7/1/2021

1/8/2022

.50%

5

County of San Mateo

Lead Legal Office Assistant

$ 64,084

$ 80,079

-17.5%

$ 66,065

10/4/2020

unknown

unknown

6

County of Contra Costa

Senior Legal Coordinator

$ 58,171

$ 74,287

-11.1%

$ 66,041

7/1/2021

unknown

unknown

7

County of Ventura

Legal Processing Assistant III

$ 42,295

$ 59,178

-0.7%

$ 58,764

12/27/2020

12/26/2021

2.00%

8

County of Sacramento

Legal Secretary II

$ 45,727

$ 55,583

0.1%

$ 55,639

6/21/2020

unknown

unknown

9

County of San Diego

Legal Support Assistant III

$ 44,803

$ 55,037



$ 55,037

6/18/2021

unknown

unknown

10

County of Fresno

Senior Legal Assistant

$ 38,896

$ 49,764

4.7%

$ 52,103

11/2/2020

unknown

unknown

11

County of Kern

Senior Legal Process Technician

$ 36,684

$ 44,784

1.2%

$45,321

4/21/2021

unknown

unknown

12

County of Alameda

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 68,024

$ 66,053

% County of San Diego Above/Below

-23.6%

-20.0%

Number of Matches

10

10

N/C - Non Comparator

Page 193 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Legal Support Supervisor I





















1

County of San Mateo

Legal Office Services Supervisor

$ 76,251

$ 95,262

-17.5%

$ 78,591

10/4/2020

unknown

unknown

2

County of Alameda

Supervising Clerk 1

$ 67,454

$ 81,827

-11.4%

$ 72,499

12/27/2020

12/26/2021

3.00%

3

County of Sacramento

Supervising Legal Secretary

$ 56,376

$ 68,528

0.1%

$ 68,597

6/21/2020

unknown

unknown





















5

County of Fresno

Supervising Legal Assistant

$ 42,822

$ 54,756

4.7%

$ 57,330

11/2/2020

unknown

unknown

6

County of Kern

Supervising Legal Process Technician

$ 42,600

$ 52,008

1.2%

$ 52,632

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 68,528

$ 68,597

% County of San Diego Above/Below

-5.2%

-5.3%

Number of Matches

5

5

N/C - Non Comparator

Page 194 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Legal Support Supervisor II





















1

County of Santa Clara

Legal Support Supervisor

$ 92,398

$ 112,320

-16.8%

$ 93,450

6/28/2021

6/27/2022

3.00%

2

County of Alameda

Supervising Clerk II

$ 70,845

$ 85,987

-11.4%

$ 76,185

12/27/2020

12/26/2021

3.00%

3

County of Los Angeles

Supervising Legal Office Support Assistant

$ 55,194

$ 76,427

-3.8%

$ 73,523

1/1/2021

unknown

unknown





















5

County of Sacramento

Supervising Legal Secretary

$ 56,376

$ 68,528

0.1%

$ 68,597

6/21/2020

unknown

unknown

6

County of Fresno

Chief Legal Assistant

$ 48,828

$ 59,384

4.7%

$ 62,175

4/19/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,427

$ 73,523

% County of San Diego Above/Below

-10.3%

-6.1%

Number of Matches

5

5

N/C - Non Comparator

Page 195 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Librarian I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Librarian 1

$ 86,736

$ 105,432

-17.4%

$ 87,087

7/1/2021

1/8/2022

.50%

2

County of Orange

Librarian 1

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

3

County of Los Angeles

Librarian 1

$ 62,904

$ 84,757

-3.8%

$ 81,536

1/1/2021

unknown

unknown

4

County of Santa Clara

Librarian 1

$ 73,950

$ 89,463

-16.8%

$ 74,433

6/14/2021

6/13/2022

3.00%

5

County of San Mateo

Librarian 1

$ 70,303

$ 87,878

-17.5%

$ 72,500

10/4/2020

unknown

unknown

6

County of San Diego

Librarian 1

$ 58,032

$ 71,365



$ 71,365

6/18/2021

unknown

unknown

7

County of San Bernardino

Librarian 1

$ 47,362

$ 66,747

1.9%

$ 68,015

3/13/2021

3/26/2022

3.00%

8

County of Alameda

Librarian 1

$ 66,522

$ 76,146

-11.4%

$ 67,465

6/27/2021

6/26/2022

3.25%

9

County of Fresno

Librarian 1

$ 47,242

$ 60,398

4.7%

$ 63,237

11/2/2020

unknown

unknown

10

County of Contra Costa1

[Librarian Trainee/Librarian]

$ 59,627

$ 68,100

-11.1%

$ 60,541

7/1/2021

unknown

unknown

11

County of Kern

Librarian 1

$ 45,012

$ 54,948

1.2%

$ 55,607

4/21/2021

unknown

unknown

12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 80,451

$ 70,258

% County of San Diego Above/Below

-12.7%

1.6%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower
level classification at the comparator agency. The salary displayed is an average of the matches.

Page 196 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Librarian II





















1

City and County of San Francisco

Librarian II

$ 95,988

$ 116,688

-17.4%

$ 96,384

7/1/2021

1/8/2022

.50%

2

County of Orange

Librarian II

$ 72,280

$ 97,365

-2.0%

$ 95,417

7/2/2021

7/1/2022

3.50%

3

County of Ventura1

[Librarian/ Librarian Specialist]

$ 62,272

$87,160

-0.7%

$ 86,550

12/27/2020

12/26/2021

2.00%

4

County of Los Angeles

Librarian II

$ 66,402

$ 89,485

-3.8%

$ 86,085

1/1/2021

unknown

unknown

5

County of San Mateo

Librarian II

$ 76,667

$ 95,803

-17.5%

$ 79,037

10/4/2020

unknown

unknown





















7

County of Santa Clara

Librarian II

$ 77,894

$ 94,295

-16.8%

$ 78,453

6/14/2021

6/13/2022

3.00%

8

County of San Bernardino

Librarian II

$ 53,498

$ 75,296

1.9%

$ 76,727

3/13/2021

3/26/2022

3.00%

9

County of Alameda

Librarian II

$ 70,690

$ 81,401

-11.4%

$72,121

6/27/2021

6/26/2022

3.25%

10

County of Fresno

Librarian II

$ 52,052

$ 66,638

4.7%

$ 69,770

11/2/2020

unknown

unknown

11

County of Contra Costa

Librarian

$ 61,173

$78,120

-11.1%

$ 69,449

7/1/2021

unknown

unknown

12

County of Kern

Librarian II

$ 47,304

$ 57,756

1.2%

$ 58,449

4/21/2021

unknown

unknown

13

County of Riverside

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$87,160

$ 78,453

% County of San Diego Above/Below

-10.5%

0.5%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at
the comparator agency. The salary displayed is the higher of the matches.

Page 197 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Librarian

II





















1

City and County of San Francisco

Librarian III

$ 105,876

$ 128,676

-17.4%

$ 106,286

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Supervising Librarian

$ 99,721

$ 121,299

-16.8%

$ 100,921

6/28/2021

6/27/2022

3.00%

3

County of Orange

Librarian III

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

4

County of Alameda

Library Manager 1

$ 92,477

$ 112,507

-11.4%

$ 99,681

12/27/2020

12/26/2021

3.00%

5

County of Ventura

City Librarian

$ 66,703

$ 93,359

-0.7%

$ 92,705

12/27/2020

12/26/2021

2.00%

6

County of Los Angeles

Librarian III

$ 70,105

$ 94,477

-3.8%

$ 90,887

1/1/2021

unknown

unknown





















8

County of Contra Costa1

[Librarian Specialist/Community Library Manager]

$ 75,550

$ 96,481

-11.1%

$ 85,772

7/1/2021

unknown

unknown

9

County of San Mateo

Senior Librarian

$ 82,013

$ 102,521

-17.5%

$ 84,580

10/4/2020

unknown

unknown

10

County of Fresno

Librarian III

$ 59,228

$ 75,764

4.7%

$ 79,325

11/2/2020

unknown

unknown

11

County of Kern

Librarian III

$ 50,232

$ 61,320

1.2%

$ 62,056

4/21/2021

unknown

unknown

12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 99,501

$ 91,796

% County of San Diego Above/Below

-14.6%

-5.7%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 198 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Librarian Substitute	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Librarian Substitute

$ 57,366

$ 70,574

$ 70,574

6/18/2021

unknown

unknown

2

County of Alameda

Librarian 1 (Services as Needed)

$ 67,236

$ 67,236

-11.4%

$ 59,571

6/27/2021

6/26/2022

3.25%

3

City and County of San Francisco

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,236

$ 59,571

% County of San Diego Above/Below

4.7%

15.6%

Number of Matches

1

1

N/C - Non Comparator

Page 199 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Library Associate |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Senior Library Literacy Assistant

$61,173

$78,120

-11.1%

$ 69,449

7/1/2021

unknown

Unknown

2

County of San Diego

Library Associate

$ 56,368

$ 68,307



$ 68,307

6/18/2021

unknown

unknown

3

County of Alameda

Literacy Specialist

$ 64,368

$ 76,488

-11.4%

$ 67,768

6/27/2021

6/26/2022

3.25%

4

City and County of San Francisco

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 77,304

$ 68,609

% County of San Diego Above/Below

-13.2%

-0.4%

Number of Matches

2

2

N/C - Non Comparator

Page 200 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Library Technician I

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Library Assistant

$ 63,336

$ 76,884

-17.4%

$ 63,506

7/1/2021

1/8/2022

.50%

2

County of Ventura

Library Technician 1

$ 37,552

$ 52,477

-0.7%

$52,110

12/27/2020

12/26/2021

2.00%

3

County of San Mateo1

Library Assistant 1

$ 53,829

$ 60,152

-17.5%

$ 49,626

10/4/2020

unknown

unknown

4

County of Orange

Library Assistant 1

$ 34,736

$ 46,862

-2.0%

$ 45,925

7/2/2021

7/1/2022

3.50%

5

County of Alameda

Library Clerk 1

$ 44,576

$ 50,697

-11.4%

$ 44,917

6/27/2021

6/26/2022

3.25%

6

County of San Bernardino

Library Assistant

$ 30,597

$ 42,598

1.9%

$ 43,408

7/31/2021

7/30/2022

3.00%

7

County of San Diego

Library Technician 1

$ 31,200

$ 38,334



$ 38,334

6/18/2021

unknown

unknown

8

County of Fresno

Library Assistant 1

$ 29,718

$ 35,750

4.7%

$ 37,430

11/2/2020

unknown

unknown

9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,697

$ 45,925

% County of San Diego Above/Below

-32.2%

-19.8%

Number of Matches

7

7

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 201 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

LibraryTechnician II





















1

City and County of San Francisco

Library Technical Assistant II

$ 80,988

$ 98,436

-17.4%

$ 81,308

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Library Assistant 1

$ 44,138

$ 59,428

-3.8%

$ 57,170

1/1/2021

unknown

unknown

3

County of Ventura1

[LibraryTechnician 1/ LibraryTechnician II]

$ 38,904

$ 54,387

-0.7%

$ 54,006

12/27/2020

12/26/2021

2.00%

4

County of Alameda

Library Lead Clerk

$ 50,958

$ 60,240

-11.4%

$ 53,373

6/27/2021

6/26/2022

3.25%

5

County of Orange

Library Assistant II

$ 37,690

$ 50,794

-2.0%

$ 49,778

7/2/2021

7/1/2022

3.50%





















7

County of Santa Clara

LibraryTechnician

$ 45,500

$ 54,704

-16.8%

$ 45,514

6/14/2021

6/13/2022

3.00%

8

County of Fresno

Library Assistant II

$ 30,966

$ 39,598

4.7%

$ 41,459

11/2/2020

unknown

unknown

9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 54,704

$ 53,373

% County of San Diego Above/Below

-15.6%

-12.7%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at
the comparator agency. The salary displayed is an average of the matches.

Page 202 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Library Technician III	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

LibraryTechnical Assistant II

$ 80,988

$ 98,436

-17.4%

$ 81,308

7/1/2021

1/8/2022

.50%

2

County of San Bernardino

Library Associate

$ 42,931

$ 60,507

1.9%

$ 61,657

3/13/2021

3/26/2022

3.00%

3

County of Ventura

LibraryTechnician III

$ 43,962

$ 61,545

-0.7%

$ 61,115

12/27/2020

12/26/2021

2.00%

4

County of Los Angeles

Library Assistant II

$ 46,579

$ 62,748

-3.8%

$ 60,364

1/1/2021

unknown

unknown

5

County of San Diego

LibraryTechnician III

$ 44,491

$ 54,642



$ 54,642

6/18/2021

unknown

unknown

6

County of Fresno

Senior Library Assistant

$ 33,540

$ 42,926

4.7%

$ 44,944

11/2/2020

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,545

$ 61,115

% County of San Diego Above/Below

-12.6%

-11.8%

Number of Matches

5

5

N/C - Non Comparator

Page 203 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Library Technician IV





















1

County of Alameda1

[Library Assistant 1/ Library Assistant Manager]

$ 68,399

$ 82,248

-11.4%

$ 72,872

12/27/2020

12/26/2021

3.00%

2

County of Los Angeles

Library Assistant III

$ 49,154

$ 66,237

-3.8%

$ 63,720

1/1/2021

unknown

unknown





















4

County of Fresno

Supervising Library Assistant

$ 36,998

$ 47,294

4.7%

$ 49,517

11/2/2020

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Contra Costa

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,237

$ 63,720

% County of San Diego Above/Below

-4.2%

-0.3%

Number of Matches

3

3

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 204 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Library Technician Substitute |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Library Clerk II (Services as Needed)

$ 50,486

$ 50,486

-11.4%

$ 44,730

6/27/2021

6/26/2022

3.25%

2

County of San Diego

Library Technician Substitute



$ 32,198



$ 32,198

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,486

$ 44,730

% County of San Diego Above/Below

-56.8%

-38.9%

Number of Matches

1

1

N/C - Non Comparator

Page 205 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Licensed Mental Health Clinician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Clinical Psychologist 1

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

2

County of San Mateo

Marriage and Family Therapist II

$ 92,350

$ 115,459

-17.5%

$ 95,253

10/4/2020

unknown

unknown

3

County of Los Angeles

Mental Health Clinician II

$ 98,758

$ 98,758

-3.8%

$ 95,005

1/1/2021

unknown

unknown

4

County of San Diego

Licensed Mental Health Clinician

$ 77,043

$ 94,702



$ 94,702

6/18/2021

unknown

unknown

5

County of San Bernardino

Clinical Therapist I/Clinical Therapist II

$ 64,241

$ 90,574

1.9%

$ 92,295

3/13/2021

3/26/2022

3.00%

6

County of Kern

Behavioral Health Therapist II

$ 74,484

$ 90,924

1.2%

$ 92,015

4/21/2021

unknown

unknown

7

County of Alameda

Behavioral Health Clinician II

$ 88,729

$ 102,259

-11.4%

$ 90,602

6/27/2021

6/26/2022

3.25%

8

County of Fresno

Licensed Mental Health Clinician

$ 70,538

$ 84,838

4.7%

$ 88,825

11/2/2020

unknown

unknown

9

County of Sacramento

Senior Mental Health Counselor

$ 80,075

$ 88,281

0.1%

$ 88,369

6/21/2020

unknown

unknown

10

County of Riverside

Clinical Therapist II

$ 58,002

$ 85,858

1.9%

$ 87,490

5/1/2021

5/1/2022

2.00%

11

County of Contra Costa

Mental Health Clinical Specialist

$ 65,947

$ 97,899

-11.1%

$ 87,032

7/1/2021

unknown

unknown

12

County of Ventura

Behavioral Health Clinician III

$ 58,896

$ 82,499

-0.7%

$ 81,921

12/27/2020

12/26/2021

2.00%

13

City and County of San Francisco

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 90,924

$ 90,602

% County of San Diego Above/Below

4.0%

4.3%

Number of Matches

11

11

N/C - Non Comparator

Page 206 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Licensed Vocational Nurse





















1

City and County of San Francisco

Licensed Vocational Nurse

$ 77,508

$ 94,224

-17.4%

$ 77,829

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Licensed Vocational Nurse

$ 72,444

$ 87,501

-16.8%

$ 72,801

6/14/2021

6/13/2022

3.00%

3

County of San Mateo1

Licensed Vocational Nurse

$ 71,114

$ 84,093

-17.5%

$ 69,377

10/4/2020

unknown

unknown

4

County of Contra Costa

Licensed Vocational Nurse

$ 57,999

$ 74,067

-11.1%

$ 65,845

7/1/2021

unknown

unknown

5

County of Sacramento

Licensed Vocational Nurse

$ 50,718

$ 61,638

0.1%

$ 61,700

6/21/2020

unknown

unknown

6

County of Alameda

Licensed Vocational Nurse

$ 63,139

$ 69,502

-11.4%

$ 61,578

6/27/2021

6/26/2022

3.25%

7

County of Ventura

Licensed Vocational Nurse

$ 55,130

$ 59,216

-0.7%

$ 58,801

4/4/2021

4/17/2022

3.25%

8

County of Los Angeles

Licensed Vocational Nurse II

$ 45,240

$ 60,912

-3.8%

$ 58,597

1/1/2021

unknown

unknown

9

County of Fresno

Licensed Vocational Nurse II

$ 42,822

$ 54,756

4.7%

$ 57,330

11/2/2020

unknown

unknown

10

County of Riverside

Licensed Vocational Nurse II

$ 37,419

$ 55,341

1.9%

$ 56,393

5/1/2021

5/1/2022

2.00%

11

County of Kern

Vocational Nurse II

$ 44,340

$ 54,132

1.2%

$ 54,782

4/21/2021

unknown

unknown

12

County of Orange

Licensed Vocational Nurse

$ 41,080

$ 54,974

-2.0%

$ 53,875

7/2/2021

7/1/2022

3.50%

13

County of San Bernardino

Licensed Vocational Nurse II

$ 38,210

$ 52,458

1.9%

$ 53,454

7/31/2021

7/30/2022

3.00%





















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,912

$ 58,801

% County of San Diego Above/Below

-15.8%

-11.8%

Number of Matches

13

13

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 207 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Litigation Investigator





















1

County of Santa Clara

County Counsel Investigator

$ 113,736

$ 138,389

-16.8%

$ 115,139

6/28/2021

6/27/2022

3.00%

2

County of Los Angeles

Investigator II

$ 86,869

$ 117,064

-3.8%

$ 112,616

1/1/2021

unknown

unknown

3

City and County of San Francisco

Claims Investigator, City Attorneys Office

$ 107,724

$ 130,884

-17.4%

$ 108,110

7/1/2021

1/8/2022

.50%





















5

County of Orange

Senior Claims Representative

$ 69,597

$ 93,766

-2.0%

$ 91,891

7/2/2021

7/1/2022

3.50%

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 123,974

$ 110,363

% County of San Diego Above/Below

-27.3%

-13.3%

Number of Matches

4

4

N/C - Non Comparator

Page 208 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Mail Carrier	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Mail Services Driver

$ 49,066

$ 61,338

-17.5%

$ 50,604

10/4/2020

unknown

unknown

2

County of Santa Clara

Messenger Driver

$ 49,731

$ 59,860

-16.8%

$ 49,804

6/14/2021

6/13/2022

3.00%

3

County of Contra Costa

Driver Clerk

$ 44,907

$ 54,584

-11.1%

$ 48,526

7/1/2021

unknown

unknown

4

County of Alameda

Messenger

$ 45,402

$ 53,636

-11.4%

$ 47,522

6/27/2021

6/26/2022

3.25%

5

County of Los Angeles

County Messenger Driver

$ 34,788

$ 46,693

-3.8%

$ 44,919

1/1/2021

unknown

unknown

6

County of Ventura

Courier 1

$31,133

$ 43,479

-0.7%

$43,175

12/27/2020

12/26/2021

2.00%

7

County of Riverside

Messenger

$29,120

$ 41,447

1.9%

$ 42,235

5/1/2021

5/1/2022

2.00%

8

County of San Bernardino

Mail Processor II

$ 30,243

$ 41,205

1.9%

$ 41,988

7/31/2021

7/30/2022

3.00%

9

County of San Diego

Mail Carrier

$ 33,738

$ 41,454



$ 41,454

6/18/2021

unknown

unknown

10

County of Kern

Mail Clerk II

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Fresno

N/C















13

County of Orange

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 46,693

$ 44,919

% County of San Diego Above/Below

-12.6%

-8.4%

Number of Matches

9

9

N/C - Non Comparator

Page 209 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mail Processor





















1

City and County of San Francisco

Clerk

$ 55,488

$ 67,416

-17.4%

$ 55,686

7/1/2021

1/8/2022

.50%

2

County of Alameda

Mail Clerk

$ 45,402

$ 53,636

-11.4%

$47,522

6/27/2021

6/26/2022

3.25%

3

County of Riverside

Mail Clerk

$ 29,323

$ 45,790

1.9%

$ 46,660

5/1/2021

5/1/2022

2.00%

4

County of Ventura

Courier II

$32,650

$45,622

-0.7%

$45,303

12/27/2020

12/26/2021

2.00%





















6

County of Kern

Mail Clerk 1

$ 29,304

$ 35,784

1.2%

$36,213

4/21/2021

unknown

unknown

7

County of San Bernardino

Mail Processor 1

$ 29,848

$33,197

1.9%

$ 33,828

7/31/2021

7/30/2022

3.00%

8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 45,706

$ 45,981

% County of San Diego Above/Below

-15.9%

-16.6%

Number of Matches

6

6

N/C - Non Comparator

Page 210 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

IMail Systems Supervisor

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Print and Mail Services Supervisor

$ 68,605

$ 83,390

-11.1%

$ 74,134

7/1/2021

unknown

unknown

2

County of Alameda

Supervising Messenger

$ 60,528

$ 71,386

-11.4%

$ 63,248

12/27/2020

12/26/2021

3.00%

3

County of Santa Clara

Mail Room Supervisor

$ 60,333

$ 73,364

-16.8%

$ 61,039

6/28/2021

6/27/2022

3.00%

4

County of San Diego

Mail Systems Supervisor

$ 49,587

$ 60,944



$ 60,944

6/18/2021

unknown

unknown

5

County of Los Angeles

Supervisor, Mail and Delivery Service

$ 44,138

$ 59,428

-3.8%

$ 57,170

1/1/2021

unknown

unknown

6

County of Riverside

Supervising Mail Clerk

$ 32,491

$ 47,981

1.9%

$ 48,893

5/1/2021

5/1/2022

2.00%

7

City and County of San Francisco

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 71,386

$ 61,039

% County of San Diego Above/Below

-17.1%

-0.2%

Number of Matches

5

5

N/C - Non Comparator

Page 211 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Medical Claims Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Claim Process Clerk

$ 65,448

$ 79,584

-17.4%

$ 65,736

7/1/2021

1/8/2022

.50%

2

County of Orange

ClaimsTechnician

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

3

County of San Mateo

Patient Services Specialist

$ 62,420

$ 78,082

-17.5%

$ 64,417

10/4/2020

unknown

unknown

4

County of Santa Clara

Valley Health Plan (VHP) Claims Examiner

$ 61,162

$ 73,855

-16.8%

$ 61,447

6/14/2021

6/13/2022

3.00%

5

County of Alameda

Health Care Claims Examiner II

$ 58,911

$ 66,784

-11.4%

$ 59,170

6/27/2021

6/26/2022

3.25%

6

County of Ventura

Medical Claims Processor II

$ 35,045

$ 52,573

-0.7%

$ 52,205

12/27/2020

12/26/2021

2.00%

7

County of Sacramento

Claims Assistance Specialist

$ 42,303

$ 51,407

0.1%

$ 51,458

6/21/2020

unknown

unknown

8

County of San Diego

Medical Claims Specialist

$ 40,539

$ 49,816



$ 49,816

6/18/2021

unknown

unknown

9

County of Kern

Billing Office Specialist II

$ 32,868

$ 40,128

1.2%

$ 40,610

4/21/2021

unknown

unknown

10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Los Angeles

N/C















13

County of Riverside

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,360

$ 60,309

% County of San Diego Above/Below

-33.2%

-21.1%

Number of Matches

8

8

N/C - Non Comparator

Page 212 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Medical Consultant

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Physician, M.D. (Non-Megaflex)

$ 223,649

$ 223,649

-3.8%

$ 215,150

1/1/2021

unknown

unknown

2

County of San Diego

Medical Consultant

$ 174,158

$ 194,210



$ 194,210

6/18/2021

unknown

unknown

3

County of Riverside

Medical Consultant

$ 150,634

$ 150,634

1.9%

$ 153,496

7/1/2021

7/14/2022

2.00%

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 187,141

$ 184,323

% County of San Diego Above/Below

3.6%

5.1%

Number of Matches

2

2

N/C - Non Comparator

Page 213 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Medical Examiner Invest I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Medical Examiner Investigator 1

$ 65,667

$ 90,742

-0.7%

$90,107

6/28/2020

unknown

unknown

2

City and County of San Francisco

Medical Examiners Investigator 1

$ 82,812

$ 100,644

-17.4%

$83,132

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Coroner InvestigatorTrainee

$ 63,996

$ 86,231

-3.8%

$ 82,954

1/1/2021

unknown

unknown

4

County of Riverside

Deputy Coroner 1

$54,143

$ 79,596

1.9%

$81,109

5/1/2021

5/1/2022

2.00%

5

County of Sacramento

Deputy Coroner 1

$ 61,345

$ 78,300

0.1%

$ 78,378

6/21/2020

unknown

unknown

6

County of Alameda

Coroner's Investigator 1

$ 78,044

$ 86,613

-11.4%

$ 76,739

6/27/2021

6/26/2022

3.25%

7

County of Fresno

Deputy Coroner 1

$ 50,830

$ 65,000

4.7%

$ 68,055

7/1/2019

unknown

unknown

8

County of San Diego

Medical Examiner Invest 1

$ 47,112

$ 63,731



$ 63,731

6/18/2021

unknown

unknown

9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,231

$81,109

% County of San Diego Above/Below

-35.3%

-27.3%

Number of Matches

7

7

N/C - Non Comparator

Page 214 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Medical Examiner Invest II





















1

County of Santa Clara

Medical Examiner-Coroner Investigator

$ 105,202

$ 127,868

-16.8%

$ 106,386

6/14/2021

6/13/2022

3.00%

2

City and County of San Francisco

Medical Examiners Investigator II

$ 100,644

$ 122,328

-17.4%

$ 101,043

7/1/2021

1/8/2022

.50%

3

County of Ventura

Medical Examiner Investigator II

$ 68,537

$ 95,443

-0.7%

$ 94,775

6/28/2020

unknown

unknown

4

County of San Mateo

Deputy Coroner

$ 91,477

$ 114,315

-17.5%

$ 94,310

12/13/2020

12/12/2021

2-4%

5

County of Riverside

Deputy Coroner II

$ 62,222

$ 91,488

1.9%

$ 93,227

5/1/2021

5/1/2022

2.00%

6

County of Los Angeles

Coroner Investigator

$ 71,327

$ 96,119

-3.8%

$ 92,467

1/1/2021

unknown

unknown

7

County of San Bernardino

Deputy Coroner Investigator

$ 62,546

$ 85,987

1.9%

$ 87,621

12/19/2020

12/18/2021

3.00%

8

County of Alameda

Coroner's Investigator II

$ 81,630

$ 98,382

-11.4%

$ 87,166

6/27/2021

6/26/2022

3.25%

9

County of Sacramento

Deputy Coroner II

$ 67,359

$ 85,963

0.1%

$ 86,049

6/21/2020

unknown

unknown





















11

County of Fresno

Deputy Coroner II

$ 55,900

$ 71,474

4.7%

$ 74,833

7/1/2019

unknown

unknown

12

County of Contra Costa

N/C















13

County of Kern

N/C















14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 95,781

$ 92,847

% County of San Diego Above/Below

-23.6%

-19.8%

Number of Matches

10

10

N/C - Non Comparator

Page 215 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Medical Examiner Invest III





















1

City and County of San Francisco

Medical Examiners Investigator III

$ 110,736

$ 134,556

-17.4%

$ 111,143

7/1/2021

1/8/2022

.50%

2

County of Ventura

Senior Medical Examiner Investigator

$ 82,594

$ 110,724

-0.7%

$ 109,949

6/28/2020

unknown

unknown

3

County of Fresno

Senior Deputy Coroner

$ 71,316

$ 102,432

4.7%

$ 107,246

4/19/2021

unknown

unknown

4

County of San Mateo1

[Deputy Coroner/Supervising Deputy Coroner]

$ 95,553

$ 119,431

-17.5%

$ 98,531

12/13/2020

12/12/2021

2-4%





















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 115,078

$ 108,598

% County of San Diego Above/Below

-34.0%

-26.5%

Number of Matches

4

4

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 216 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Medical Transcriber	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Medical Transcriber Typist

$ 67,284

$ 81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Medical Transcriptionist

$ 57,407

$71,821

-17.5%

$ 59,252

10/4/2020

unknown

unknown

3

County of Alameda

Medical Transcriptionist

$ 58,629

$ 66,597

-11.4%

$ 59,005

6/27/2021

6/26/2022

3.25%

4

County of Santa Clara

Medical Transcriptionist

$ 58,038

$ 70,059

-16.8%

$ 58,289

6/14/2021

6/13/2022

3.00%

5

County of Los Angeles

Medical Transcriber - Typist

$ 43,609

$ 57,133

-3.8%

$ 54,962

1/1/2021

unknown

unknown

6

County of Riverside

Medical Transcriptionist II

$ 34,391

$ 53,674

1.9%

$ 54,693

5/1/2021

5/1/2022

2.00%

7

County of Contra Costa

Medical Transcriber

$ 47,626

$ 60,821

-11.1%

$ 54,070

7/1/2021

unknown

unknown

8

County of Orange

Medical Transcriber II

$ 39,582

$ 52,520

-2.0%

$ 51,470

7/2/2021

7/1/2022

3.50%

9

County of San Diego

Medical Transcriber

$ 41,330

$ 50,814



$ 50,814

6/18/2021

unknown

unknown

10

County of Sacramento

Medical Transcriber II

$41,196

$ 50,091

0.1%

$ 50,141

6/21/2020

unknown

unknown

11

County of Ventura

Information Processing Operator II

$ 33,744

$47,167

-0.7%

$ 46,837

12/27/2020

12/26/2021

2.00%

12

County of Fresno

N/C















13

County of Kern

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 58,977

$ 54,828

% County of San Diego Above/Below

-16.1%

-7.9%

Number of Matches

10

10

N/C - Non Comparator

Page 217 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mental Health Aide





















1

County of Santa Clara

Mental Health Worker

$ 50,259

$ 60,576

-16.8%

$ 50,399

6/14/2021

6/13/2022

3.00%

2

County of Los Angeles

Community Health Worker

$ 34,788

$ 52,016

-3.8%

$ 50,039

1/1/2021

unknown

unknown





















4

County of Kern

Behavioral Health Recovery Specialist Aide

$ 34,728

$ 42,396

1.2%

$ 42,905

4/21/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 52,016

$ 50,039

% County of San Diego Above/Below

-19.3%

-14.8%

Number of Matches

3

3

N/C - Non Comparator

Page 218 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mental Health Case Management Assistant





















1

City and County of San Francisco

Human Services Agency Social Worker

$ 64,380

$ 98,928

-17.4%

$ 81,715

7/1/2021

1/8/2022

.50%

2

County of Fresno

Community Mental Health Specialist II

$ 41,730

$ 53,378

4.7%

$ 55,887

11/2/2020

unknown

unknown

3

County of Ventura

Mental Health Associate

$ 40,146

$ 56,218

-0.7%

$ 55,824

12/26/2020

12/27/2021

2.00%

4

County of Kern

Behavioral Health Recovery Specialist 1

$ 44,112

$ 53,856

1.2%

$ 54,502

4/21/2021

unknown

unknown

5

County of Los Angeles

Medical Case Worker 1

$ 50,010

$ 54,249

-3.8%

$ 52,187

1/1/2021

unknown

unknown

6

County of Sacramento

Mental Health Worker

$ 42,804

$ 52,054

0.1%

$ 52,106

6/21/2020

unknown

unknown

7

County of Riverside

Social Service Assistant

$ 30,028

$ 44,364

1.9%

$ 45,207

5/1/2021

5/1/2022

2.00%





















9

County of Orange

Mental Health Worker 1

$ 33,446

$ 43,576

-2.0%

$ 42,704

7/2/2021

7/1/2022

3.50%

10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,617

$ 53,345

% County of San Diego Above/Below

-19.2%

-18.6%

Number of Matches

8

8

N/C - Non Comparator

Page 219 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mental Health Case Management Clinician





















1

County of Orange

Behavioral Health Clinician II

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

2

County of Santa Clara

Psychiatric Social Worker 1

$ 84,055

$ 101,756

-16.8%

$ 84,661

6/14/2021

6/13/2022

3.00%

3

County of Fresno

Unlicensed Mental Health Clinician

$ 64,116

$ 77,116

4.7%

$ 80,740

11/2/2020

unknown

unknown

4

County of Ventura

Behavioral Health Clinician II

$ 56,081

$ 78,611

-0.7%

$ 78,061

12/27/2020

12/26/2021

2.00%

5

County of San Mateo

Mental Health Counselor II

$ 71,384

$ 89,230

-17.5%

$ 73,615

10/4/2020

unknown

unknown





















7

County of Riverside

Social Services Practitioner II

$ 43,379

$ 64,160

1.9%

$ 65,379

5/1/2021

5/1/2022

2.00%

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,996

$ 79,401

% County of San Diego Above/Below

-14.2%

-9.3%

Number of Matches

6

6

N/C - Non Comparator

Page 220 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mental Health Conservatorship Clinician





















1

City and County of San Francisco

Behavioral Health Clinician

$ 95,676

$ 116,244

-17.4%

$ 96,018

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Psychiatric Social Worker II

$ 77,371

$ 98,758

-3.8%

$ 95,005

1/1/2021

unknown

unknown





















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 107,501

$ 95,511

% County of San Diego Above/Below

-17.8%

-4.7%

Number of Matches

2

2

N/C - Non Comparator

Page 221 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Mental Health Specialist





















1

City and County of San Francisco

Mental Health Treatment Specialist

$ 98,436

$ 119,604

-17.4%

$ 98,793

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Mental Health Specialist 1

$ 52,981

$ 71,000

-11.1%

$ 63,119

7/1/2021

unknown

unknown

3

County of Orange

Mental Health Specialist

$ 47,507

$ 63,440

-2.0%

$ 62,171

7/2/2021

7/1/2022

3.50%

4

County of San Bernardino

Mental Health Specialist

$ 42,236

$ 58,032

1.9%

$ 59,135

7/31/2021

7/30/2022

3.00%

5

County of Riverside

Behavioral Health Specialist II

$ 38,028

$ 56,229

1.9%

$ 57,297

5/1/2021

5/1/2022

2.00%

6

County of Kern

Behavioral Health Recovery Specialist II

$ 46,368

$ 56,616

1.2%

$ 57,295

4/21/2021

unknown

unknown

7

County of Alameda

Mental Health Specialist II

$ 56,435

$ 64,408

-11.4%

$ 57,065

6/27/2021

6/26/2022

3.25%

8

County of Santa Clara

Mental Health Community Worker

$ 54,991

$ 66,425

-16.8%

$ 55,265

6/14/2021

6/13/2022

3.00%

9

County of Sacramento

Mental Health Worker - Discharge Planner

$ 44,934

$ 54,643

0.1%

$ 54,698

6/21/2020

unknown

unknown





















11

County of Fresno

N/C















12

County of Los Angeles

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,440

$ 57,297

% County of San Diego Above/Below

-20.2%

-8.6%

Number of Matches

9

9

N/C - Non Comparator

Page 222 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Multimedia Designer





















1

County of San Mateo

Senior Graphics Specialist

$ 84,363

$ 105,475

-17.5%

$ 87,017

10/4/2020

unknown

unknown

2

County of Santa Clara

Multimedia Communications Specialist

$ 85,567

$ 104,013

-16.8%

$ 86,538

6/14/2021

6/13/2022

3.00%





















4

City and County of San Francisco

Media Production Specialist

$ 74,928

$ 91,104

-17.4%

$ 75,252

7/1/2021

1/8/2022

.50%

5

County of Sacramento

Public Information Specialist

$ 60,093

$ 73,059

0.1%

$ 73,132

6/21/2020

unknown

unknown

6

County of Orange

Senior Computer Graphics Specialist

$ 53,539

$ 71,698

-2.0%

$ 70,264

7/2/2021

7/1/2022

3.50%

7

County of Riverside

Media Production Specialist

$ 45,233

$ 66,951

1.9%

$ 68,223

5/1/2021

5/1/2022

2.00%

8

County of Alameda

Sheriff's Multimedia Producer

$ 62,878

$ 75,442

-11.4%

$ 66,841

6/27/2021

6/26/2022

3.25%

9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,442

$ 73,132

% County of San Diego Above/Below

6.8%

9.6%

Number of Matches

7

7

N/C - Non Comparator

Page 223 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Nutritionist

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Nutritionist

$ 96,252

$ 117,084

-17.4%

$ 96,711

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Public Health Nutritionist

$ 89,532

$ 108,372

-16.8%

$ 90,166

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Dietitian 1

$ 80,203

$ 100,254

-17.5%

$ 82,710

10/4/2020

unknown

unknown

4

County of Alameda

Nutritionist II

$ 75,642

$ 90,783

-11.4%

$ 80,434

6/27/2021

6/26/2022

3.25%

5

County of Sacramento

Dietitian

$ 64,018

$ 77,799

0.1%

$ 77,877

6/21/2020

unknown

unknown

6

County of Los Angeles

Nutritionist II

$ 59,725

$ 80,483

-3.8%

$ 77,425

1/1/2021

unknown

unknown

7

County of Orange

Public Health Nutritionist 1

$ 57,886

$ 77,958

-2.0%

$ 76,399

7/2/2021

7/1/2022

3.50%

8

County of San Bernardino

Nutritionist

$ 53,082

$ 74,776

1.9%

$ 76,197

3/13/2021

3/26/2022

3.00%

9

County of Riverside

Nutritionist

$ 49,373

$ 73,092

1.9%

$ 74,481

5/1/2021

5/1/2022

2.00%

10

County of Ventura

Public Health Nutritionist II

$ 52,158

$ 74,566

-0.7%

$ 74,044

12/27/2020

12/26/2021

2.00%

11

County of Contra Costa

Public Health Nutritionist

$ 66,994

$ 81,431

-11.1%

$ 72,393

7/1/2021

unknown

unknown

12

County of Kern

Public Health Nutritionist

$ 57,468

$ 70,152

1.2%

$ 70,994

4/21/2021

unknown

unknown

13

County of San Diego

Nutritionist







$ 67,891

6/18/2021

unknown

unknown

14

County of Fresno

N/C















Summary Results

Median of Comparators
% County of San Diego Above/Below

Number of Matches

N/C - Non Comparator

Page 224 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Occupational/Physical Therapist





















1

County of Los Angeles

Occupational Therapist 1 I/Physical Therapist II

$ 91,043

$ 122,688

-3.8%

$ 118,026

1/1/2021

unknown

unknown

2

County of Santa Clara

Occupational Therapist II / Physical Therapist II

$ 117,125

$ 141,702

-16.8%

$ 117,896

6/14/2021

6/13/2022

3.00%

3

City and County of San Francisco1

[Occupational Therapist/ Physical Therapist]

$99,108

$ 139,548

-17.4%

$ 115,267

7/1/2021

1/8/2022

.50%

4

County of Orange6

[Occupational Therapist 11/ Physical Therapist II]

$ 85,717

$ 115,149

-2.0%

$ 112,846

7/2/2021

7/1/2022

3.50%

5

County of Riverside7

[Occupational Therapist 11/ Physical Therapist II]

$ 68,949

$ 110,512

1.9%

$ 112,612

5/1/2021

5/1/2022

2.00%

6

County of San Bernardino

Occupational Therapist 1 I/Physical Therapist II

$ 74,734

$ 105,352

1.9%

$ 107,354

3/13/2021

3/26/2022

3.00%

7

County of San Mateo8

[Occupational Therapist II - CCS/Physical Therapist II - CCS]

$ 96,365

$ 120,450

-17.5%

$ 99,372

10/4/2020

unknown

unknown

8

County of Sacramento

Therapist

$ 84,773

$98,136

0.1%

$ 98,234

6/21/2020

unknown

unknown

9

County of Ventura9

[Occupational Therapist/ Physical Therapist]

$ 69,451

$97,108

-0.7%

$ 96,429

12/27/2020

12/26/2021

2.00%





















11

County of Kern5

[Occupational Therapist/ Physical Therapist]

$ 77,508

$ 94,632

1.2%

$ 95,768

4/21/2021

unknown

unknown

12

County of Fresno4

[Occupational Therapist II / Physical Therapist II]

$ 69,290

$ 88,608

4.7%

$ 92,773

11/2/2020

unknown

unknown

13

County of Alameda2

[Occupational Therapist 1/ Physical Therapist 1]

$ 84,582

$ 101,796

-11.4%

$90,191

6/27/2021

6/26/2022

3.25%

14

County of Contra Costa3

[Occupational Therapist I/Physical Therapist 1]

$ 83,381

$ 101,350

-11.1%

$90,100

7/1/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 105,352

$ 99,372

% County of San Diego Above/Below

-9.7%

-3.4%

Number of Matches

13

13

N/C - Non Comparator

1	- City and County of San Francisco: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency.
The salary displayed is the same for both matches.

2	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

3	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

4	- County of Fresno: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

5	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

6	- County of Orange: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

7	- County of Riverside: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

8	- County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches

9	- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 225 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Occupational/Physical Therapist Assistant





















1

City and County of San Francisco

Physical Therapist Assistant

$ 83,412

$ 111,780

-17.4%

$ 92,330

7/1/2021

1/8/2022

.50%

2

County of Fresno3

[Occupational Therapist 1 / Physical Therapist 1]

$ 65,494

$ 83,798

4.7%

$ 87,737

11/2/2020

unknown

unknown

3

County of Santa Clara

Occupational Therapy Assistant II

$ 81,014

$ 97,922

-16.8%

$ 81,471

6/14/2021

6/13/2022

3.00%

4

County of Riverside6

[Occupational Therapist Assistant/ Physical Therapist Assistant]

$ 49,498

$ 79,331

1.9%

$ 80,838

5/1/2021

5/1/2022

2.00%

5

County of Los Angeles

Occupational Therapist Assistant/Physical Therapist Assistant

$ 49,643

$ 78,719

-3.8%

$ 75,728

1/1/2021

unknown

unknown

6

County of Orange5

[Occupational Therapist Asst 11/ Physical Therapist Asst II]

$ 57,158

$ 76,877

-2.0%

$ 75,339

7/2/2021

7/1/2022

3.50%

7

County of Contra Costa2

[Therapist Aide/Therapy Assistant]

$ 67,326

$ 81,836

-11.1%

$ 72,752

7/1/2021

unknown

unknown

8

County of San Mateo

Therapy Assistant

$ 68,826

$ 86,006

-17.5%

$ 70,955

10/4/2020

unknown

unknown

9

County of San Bernardino

Occupational Therapy Assistant/Physical Therapy Assistant

$ 47,736

$ 65,603

1.9%

$ 66,850

7/31/2021

7/30/2022

3.00%





















11

County of Ventura7

[Certified Occupational Therapy Assistant/ Licensed Physical Therapy Assistant]

$ 40,612

$ 62,629

-0.7%

$ 62,191

12/26/2020

12/27/2021

2.00%

12

County of Alameda1

[Occupational Therapy Assistant/ Physical Therapy Assistant]

$ 50,681

$ 60,158

-11.4%

$ 53,300

6/27/2021

6/26/2022

3.25%

13

County of Kern4

[Occupational Therapy Technician/ Physical Therapy Assistant]

$ 31,116

$ 37,992

1.2%

$ 38,448

4/21/2021

unknown

unknown

14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,025

$ 74,046

% County of San Diego Above/Below

-25.3%

-17.4%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the same for
both matches.

2	- County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the
higher of the matches.

3	- County of Fresno: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the same for
both matches.

4	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the
matches.

5	- County of Orange: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of
the matches.

6	- County of Riverside: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the same for
both matches.

7	- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of
the matches.

Page 226 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Office Assistant





















1

City and County of San Francisco

Clerk

$ 55,488

$ 67,416

-17.4%

$ 55,686

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Office Specialist II - Confidential Clerical

$ 51,166

$ 62,221

-16.8%

$ 51,768

6/28/2021

6/27/2022

3.00%

3

County of Alameda

Clerk II

$ 50,697

$ 57,039

-11.4%

$ 50,536

6/27/2021

6/26/2022

3.25%

4

County of San Mateo

Office Assistant II

$ 48,983

$ 61,234

-17.5%

$ 50,518

10/4/2020

unknown

unknown

5

County of Riverside

Office Assistant II

$ 29,120

$ 45,084

1.9%

$ 45,940

5/1/2021

5/1/2022

2.00%

6

County of Ventura

Office Assistant II

$ 32,650

$ 45,622

-0.7%

$ 45,303

12/27/2020

12/26/2021

2.00%

7

County of Contra Costa

Clerk - Experienced Level

$ 40,817

$ 50,643

-11.1%

$ 45,022

7/1/2021

unknown

unknown

8

County of Orange

Office Assistant

$ 35,235

$ 45,698

-2.0%

$ 44,784

7/2/2021

7/1/2022

3.50%

9

County of Sacramento

Office Assistant II

$ 36,498

$ 44,349

0.1%

$ 44,393

6/21/2020

unknown

unknown

10

County of San Bernardino

Office Assistant II

$ 30,597

$ 42,598

1.9%

$ 43,408

7/31/2021

7/30/2022

3.00%



















12

County of Los Angeles

Office Support Assistant

$ 31,320

$ 43,086

-3.8%

$ 41,448

1/1/2021

unknown

unknown

13

County of Fresno

Office Assistant II

$ 29,224

$ 36,244

4.7%

$ 37,947

11/2/2020

unknown

unknown

14

County of Kern

Office ServicesTechnician

$ 29,460

$ 35,964

1.2%

$ 36,396

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 45,622

$ 45,022

% County of San Diego Above/Below

-9.1%

-7.6%

Number of Matches

13

13

N/C - Non Comparator

Page 227 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Office Support Specialist





















1

City and County of San Francisco

Senior Clerk

$ 57,538

$81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Clerk - Specialist Level

$ 50,943

$ 65,057

-11.1%

$ 57,835

7/1/2021

unknown

unknown

3

County of Santa Clara

Office Specialist III - U - Confidential Clerical

$ 55,557

$ 67,558

-16.8%

$ 56,209

6/28/2021

6/27/2022

3.00%

4

County of San Mateo

Office Specialist

$ 54,058

$ 67,557

-17.5%

$ 55,735

10/4/2020

unknown

unknown

5

County of Orange

Office Specialist

$40,581

$ 53,768

-2.0%

$ 52,693

7/2/2021

7/1/2022

3.50%

6

County of Alameda

Specialist Clerk 1

$ 52,388

$ 59,374

-11.4%

$ 52,606

6/27/2021

6/26/2022

3.25%

7

County of Sacramento

Office Specialist II

$ 42,908

$ 52,158

0.1%

$ 52,210

6/21/2020

unknown

unknown

8

County of San Bernardino

Office Specialist

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

9

County of Riverside

Office Assistant III

$ 32,065

$ 50,082

1.9%

$ 51,033

5/1/2021

5/1/2022

2.00%

10

County of Ventura

Office Assistant III

$ 35,892

$ 50,191

-0.7%

$ 49,840

12/27/2020

12/26/2021

2.00%





















12

County of Fresno

Office Assistant III

$ 31,590

$ 40,404

4.7%

$42,303

11/2/2020

unknown

unknown

13

County of Kern1

[Office Services Specialist/ Office Services Technician]

$ 31,416

$ 38,346

1.2%

$ 38,806

4/21/2021

unknown

unknown

14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 52,963

$ 52,408

% County of San Diego Above/Below

-9.4%

-8.2%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Kern: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 228 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Paralegal I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Paralegal - Confidential Administrative

$ 77,994

$ 94,378

-16.8%

$ 78,522

6/28/2021

6/27/2022

3.00%

2

County of Los Angeles

Paralegal

$ 56,430

$ 80,283

-3.8%

$ 77,233

1/1/2021

unknown

unknown

3

County of San Bernardino

Paralegal

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

4

County of Ventura

Paralegal

$ 47,576

$ 66,735

-0.7%

$ 66,268

12/27/2020

12/26/2021

2.00%

5

County of Riverside

Paralegal 1

$ 42,690

$ 63,177

1.9%

$ 64,377

5/1/2021

5/1/2022

2.00%

6

County of Sacramento

Paralegal

$ 49,841

$ 60,573

0.1%

$ 60,634

6/21/2020

unknown

unknown

7

County of San Diego

Paralegal 1

$ 43,576

$ 59,010



$ 59,010

6/18/2021

unknown

unknown

8

County of Kern

Paralegal

$ 45,684

$ 55,776

1.2%

$ 56,445

4/21/2021

unknown

unknown

9

County of Contra Costa

Paralegal

$ 51,735

$ 62,875

-11.1%

$ 55,896

7/1/2021

unknown

unknown

10

County of Fresno

Paralegal 1

$ 31,746

$ 38,584

4.7%

$ 40,397

4/19/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Orange

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,177

$ 64,377

% County of San Diego Above/Below

-7.1%

-9.1%

Number of Matches

9

9

N/C - Non Comparator

Page 229 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Paralegal II





















1

County of Santa Clara

Senior Paralegal - Confidential Administrative

$ 85,754

$ 103,821

-16.8%

$ 86,379

6/28/2021

6/27/2022

3.00%

2

County of Los Angeles

Senior Paralegal

$ 59,577

$ 89,485

-3.8%

$ 86,085

1/1/2021

unknown

unknown

3

City and County of San Francisco

Legal Assistant

$ 85,692

$ 104,100

-17.4%

$ 85,987

7/1/2021

1/8/2022

.50%

4

County of Alameda

Civil Paralegal

$ 72,821

$ 89,419

-11.4%

$ 79,225

12/27/2020

unknown

unknown





















6

County of Riverside

Paralegal II

$ 49,453

$ 73,173

1.9%

$ 74,563

5/1/2021

5/1/2022

2.00%

7

County of Orange

Paralegal

$ 56,347

$ 75,338

-2.0%

$ 73,831

7/2/2021

7/1/2022

3.50%

8

County of San Mateo

Paralegal

$ 71,031

$ 88,752

-17.5%

$ 73,220

10/4/2020

unknown

unknown

9

County of Ventura

Senior Paralegal

$ 60,230

$ 73,081

-0.7%

$ 72,569

12/27/2020

12/26/2021

2.00%

10

County of Kern

Senior Paralegal

$ 48,024

$ 58,620

1.2%

$ 59,323

4/21/2021

unknown

unknown

11

County of Contra Costa

Paralegal

$ 51,735

$ 62,875

-11.1%

$ 55,896

7/1/2021

unknown

unknown

12

County of Fresno

Paralegal II

$ 37,726

$ 45,864

4.7%

$ 48,020

4/19/2021

unknown

unknown

13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,338

$ 73,831

% County of San Diego Above/Below

4.7%

6.6%

Number of Matches

11

11

N/C - Non Comparator

Page 230 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Paralegal Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Supervising Paralegal

$ 101,760

$ 123,725

-16.8%

$ 102,939

6/28/2021

6/27/2022

3.00%

2

County of Los Angeles

Supervising Paralegal

$ 66,402

$ 99,735

-3.8%

$ 95,945

1/1/2021

unknown

unknown

3

County of San Diego

Paralegal Supervisor

$ 71,136





$ 87,464

6/18/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 111,730

$ 99,442

% County of San Diego Above/Below

-27.7%

-13.7%

Number of Matches

2

2

N/C - Non Comparator

Page 231 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Park Ranger

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Park Ranger II

$ 77,203

$ 93,365

-16.8%

$ 77,680

6/14/2021

6/13/2022

3.00%

2

County of San Mateo

Park Ranger II

$ 70,698

$ 88,419

-17.5%

$ 72,946

10/2/2020

unknown

unknown

3

City and County of San Francisco

Park Ranger

$ 67,944

$ 82,572

-17.4%

$ 68,204

7/1/2021

1/8/2022

.50%

4

County of Orange

Park Ranger 1

$ 46,634

$ 62,442

-2.0%

$ 61,193

7/2/2021

7/1/2022

3.50%

5

County of San Bernardino

Park Ranger II

$ 43,597

$ 59,925

1.9%

$ 61,063

7/31/2021

7/30/2022

3.00%

6

County of Riverside

Park Ranger II - Parks

$ 38,982

$ 57,467

1.9%

$ 58,559

5/1/2021

5/1/2022

2.00%

7

County of San Diego

Park Ranger

$ 46,197

$ 56,742



$ 56,742

6/18/2021

unknown

unknown

8

County of Ventura

Park Services Ranger 1

$ 41,181

$ 55,300

-0.7%

$ 54,913

10/4/2020

unknown

unknown

9

County of Kern

Park Ranger

$ 37,608

$ 45,912

1.2%

$ 46,463

4/21/2021

unknown

unknown

10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,183

$ 61,128

% County of San Diego Above/Below

-7.8%

-7.7%

Number of Matches

8

8

N/C - Non Comparator

Page 232 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Parks Recreational Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Recreation Supervisor

$ 88,788

$ 107,928

-17.4%

$89,149

7/1/2021

1/8/2022

.50%

2

County of Orange

Supervising Park Ranger 1

$ 57,491

$ 77,459

-2.0%

$ 75,910

7/2/2021

7/1/2022

3.50%

3

County of Sacramento

Recreation Supervisor

$ 59,237

$ 71,994

0.1%

$ 72,066

6/21/2020

unknown

unknown

4

County of San Diego

Parks Recreational Supervisor

$ 55,661

$ 68,411



$ 68,411

6/18/2021

unknown

unknown

5

County of Los Angeles

Recreation Services Supervisor

$ 52,535

$ 70,803

-3.8%

$68,113

1/1/2021

unknown

unknown

6

County of Riverside

Service Area Manager 1

$ 41,366

$61,177

1.9%

$ 62,340

5/1/2021

5/1/2022

2.00%

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 71,994

$ 72,066

% County of San Diego Above/Below

-5.2%

-5.3%

Number of Matches

5

5

N/C - Non Comparator

Page 233 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Patient Services Specialist III (T)





















1

County of Alameda1

[Health Insurance Technician/ Supervising Health Insurance Technician]

$ 72,758

$ 85,925

-11.4%

$ 76,129

12/27/2020

unknown

unknown

2

County of San Mateo

Lead Health Benefits Analyst

$ 69,699

$ 87,067

-17.5%

$ 71,830

10/4/2020

unknown

unknown

3

County of Sacramento

Human Services Quality and Review Specialist

$ 56,480

$ 68,653

0.1%

$ 68,722

6/21/2020

unknown

unknown





















5

County of Contra Costa

Senior Patient Financial Services Specialist

$ 57,862

$ 70,332

-11.1%

$ 62,525

7/1/2021

unknown

unknown

6

County of Los Angeles

Patient Financial Services Worker

$ 45,908

$ 61,828

-3.8%

$ 59,479

1/1/2021

unknown

unknown

7

County of Kern

Patient Access Services Representative III

$ 38,364

$ 46,836

1.2%

$ 47,398

4/21/2021

unknown

unknown

8

Cityand County of San Francisco

N/C















9

County of Fresno

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,492

$ 65,623

% County of San Diego Above/Below

-6.5%

-0.6%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 234 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Patient Services Specialist IV (T)





















1

County of San Mateo

Health Benefits Supervisor

$ 87,753

$ 109,718

-17.5%

$ 90,517

10/4/2020

unknown

unknown

2

County of Alameda1

[Supervising Health Insurance Technician/ Patient Services Supervisor]

$ 79,331

$ 96,304

-11.4%

$85,325

9/6/2020

unknown

unknown

3

County of Sacramento

Human Services Supervisor

$ 69,468

$ 84,439

0.1%

$ 84,523

6/21/2020

unknown

unknown





















5

County of Contra Costa

Patient Financial Services Supervisor

$ 65,745

$ 79,914

-11.1%

$ 71,043

7/1/2021

unknown

unknown

6

Cityand County of San Francisco

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 90,371

$ 84,924

% County of San Diego Above/Below

-21.7%

-14.4%

Number of Matches

4

4

N/C - Non Comparator

1 - County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the higher of the matches.

Page 235 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Payroll Clerk





















1

City and County of San Francisco

Payroll and Personnel Clerk

$ 70,980

$ 86,268

-17.4%

$ 71,257

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Payroll Clerk II

$ 45,908

$ 63,528

-3.8%

$ 61,114

1/1/2021

unknown

unknown

3

County of Alameda1

[Payroll Records Clerk/Specialist Clerk II]

$ 56,093

$ 63,603

-11.4%

$ 56,352

6/27/2021

6/26/2022

3.25%

4

County of San Bernardino

Payroll Specialist

$ 35,048

$ 48,110

1.9%

$ 49,025

7/31/2021

7/30/2022

3.00%





















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,565

$ 58,733

% County of San Diego Above/Below

-44.3%

-33.3%

Number of Matches

4

4

N/C - Non Comparator

1 - County of Alameda: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the
comparator agency. The salary displayed is the higher of the matches.

Page 236 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Pediatrician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Physician Specialist

$ 212,576

$ 293,826

-17.4%

$ 242,700

7/1/2021

1/8/2022

.50%

2

County of Riverside

Physician IV

$ 190,995

$ 228,680

1.9%

$ 233,024

5/1/2021

5/1/2022

2.00%

3

County of Ventura

Primary Care Clinic Pediatrician

$ 199,500

$ 231,084

-0.7%

$ 229,466

unknown

12/26/2021

2.00%

4

County of Los Angeles

Physician, M.D.

$ 223,649

$ 223,649

-3.8%

$ 215,150

1/1/2021

unknown

unknown

5

County of Orange

Physician II

$ 186,763

$ 213,940

-2.0%

$ 209,661

7/2/2021

7/1/2022

3.50%

6

County of San Diego

Pediatrician

$ 137,322

$ 168,834



$ 168,834

6/18/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 228,680

$ 229,466

% County of San Diego Above/Below

-35.4%

-35.9%

Number of Matches

5

5

N/C - Non Comparator

Page 237 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Permit Process Coordinator





















1

County of San Mateo

Building Permit Services Supervisor

$ 87,982

$ 109,988

-17.5%

$ 90,740

10/4/2020

unknown

unknown

2

County of Sacramento

Principal Engineering Technician

$ 70,219

$ 89,617

0.1%

$ 89,707

6/21/2020

unknown

unknown





















4

City and County of San Francisco

Permit Technician III

$ 87,096

$ 105,876

-17.4%

$ 87,454

7/1/2021

1/8/2022

.50%

5

County of Contra Costa1

[PlanningTechnician ll/Manager, Application and Permit Center]

$ 68,703

$ 91,750

-11.1%

$ 81,566

7/1/2021

unknown

unknown

6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,813

$ 88,580

% County of San Diego Above/Below

-11.0%

0.5%

Number of Matches

4

4

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 238 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Pest Management Technician I









































2

County of Orange

Integrated Pest Management Technician 1

$ 35,755

$ 48,152

-2.0%

$ 47,189

7/2/2021

7/1/2022

3.50%

3

County of Ventura

Insect Detection Specialist 1

$ 29,411

$ 42,307

-0.7%

$ 42,011

12/26/2020

12/27/2021

2.00%

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 45,230

$ 44,600

% County of San Diego Above/Below

19.5%

20.6%

Number of Matches

2

2

N/C - Non Comparator

Page 239 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Pest Management Technician II





















1

City and County of San Francisco

Integrated Pest Management Specialist

$ 82,392

$ 100,128

-17.4%

$ 82,706

7/1/2021

1/8/2022

.50%

2

County of Alameda

Vegetation Technician

$ 71,781

$ 75,275

-11.4%

$ 66,694

10/4/2020

10/3/2021

3.25%





















4

County of Orange

Integrated Pest Management Technician II

$ 44,366

$ 59,842

-2.0%

$ 58,645

7/2/2021

7/1/2022

3.50%

5

County of Los Angeles

Pest Exterminator

$ 42,772

$ 57,555

-3.8%

$ 55,368

1/1/2021

unknown

unknown

6

County of Riverside

Agricultural Inspector

$ 29,120

$ 45,333

1.9%

$ 46,194

5/1/2021

5/1/2022

2.00%

7

County of Kern

Spray Equipment Operator

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 58,698

$ 57,007

% County of San Diego Above/Below

4.9%

7.7%

Number of Matches

6

6

N/C - Non Comparator

Page 240 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Pharmacist	j

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

l

County of Riverside

Clinical Pharmacist II

$ 105,428

$ 173,864

1.9%

$ 177,167

5/1/2021

5/1/2022

2.00%

2

County ofSanta Clara

Pharmacist

$ 155,532

$ 188,510

-16.8%

$ 156,841

6/14/2021

6/13/2022

3.00%

3

Cityand County ofSan Francisco

Pharmacist

$ 147,156

$ 187,800

-17.4%

$ 155,123

7/1/2021

1/8/2022

.50%

4

County of Los Angeles

Pharmacist

$ 138,443

$ 158,550

-3.8%

$ 152,525

1/1/2021

unknown

unknown

5

County of Sacramento

Pharmacist

$ 140,314

$ 147,329

0.1%

$ 147,476

6/21/2020

unknown

unknown

6

County of Contra Costa

Pharmacist 1

$ 141,079

$ 163,317

-11.1%

$ 145,188

7/1/2021

unknown

unknown

7

County of Kern

Pharmacist

$ 116,148

$ 141,792

1.2%

$ 143,494

4/21/2021

unknown

unknown

8

County of Orange

Pharmacist

$ 108,493

$ 146,307

-2.0%

$ 143,381

7/2/2021

7/1/2022

3.50%

9

County of Alameda1

[Pharmacist, Alameda County Behavioral Health/ Senior Clinical Pharmacist, Alameda County Behavioral Health]

$ 132,735

$ 161,356

-11.4%

$ 142,961

6/27/2021

6/26/2022

3.25%

10

CountyofSan Mateo

Pharmacist

$ 137,589

$ 171,992

-17.5%

$ 141,893

10/4/2020

unknown

unknown



County of San Diego

Pharmacist

S 111,134

S 136,635



S 136,635

6/18/2021

unknown

unknown

12

County of Ventura

Pharmacist I

$ 83,090

$ 116,243

-0.7%

$ 115,430

12/27/2020

12/26/2021

2.00%

13

County of Fresno

N/C















14

CountyofSan Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 161,356

$ 145,188

% CountyofSan Diego Above/Below

-18.1%

-6.3%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of the matches.

Page 241 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Pharmacy Stock Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Pharmacy Helper

$ 74,148

$90,144

-17.4%

$ 74,459

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Pharmacy Assistant

$ 41,885

$ 50,905

0.1%

$ 50,956

6/21/2020

unknown

unknown

3

County of San Bernardino

Sheriff's Medical Stores Specialist

$ 35,797

$ 49,296

1.9%

$ 50,233

7/31/2021

7/30/2022

3.00%

4

County of Orange

Store Clerk

$ 37,606

$ 49,650

-2.0%

$ 48,657

7/2/2021

7/1/2022

3.50%

5

County of Los Angeles

Pharmacy Helper

$ 37,593

$ 50,502

-3.8%

$ 48,582

1/1/2021

unknown

unknown

6

County of Santa Clara

Pharmacy Assistant

$ 45,500

$ 54,704

-16.8%

$45,514

6/14/2021

6/13/2022

3.00%

7

County of San Diego

Pharmacy Stock Clerk

$ 35,006

$ 43,035



$ 43,035

6/18/2021

unknown

unknown

8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 50,703

$ 49,445

% County of San Diego Above/Below

-17.8%

-14.9%

Number of Matches

6

6

N/C - Non Comparator

Page 242 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Pharmacy Storekeeper





















1

City and County of San Francisco

Senior Pharmacy Helper

$ 74,496

$ 90,528

-17.4%

$ 74,776

7/1/2021

1/8/2022

.50%





















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 90,528

$ 74,776

% County of San Diego Above/Below

-85.9%

-53.6%

Number of Matches

1

1

N/C - Non Comparator

Page 243 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Pharmacy Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Pharmacy Technician

$ 84,816

$ 103,092

-17.4%

$ 85,154

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Pharmacy Technician

$ 66,829

$83,531

-17.5%

$ 68,913

10/4/2020

unknown

unknown

3

County of Santa Clara

Pharmacy Technician

$ 65,782

$ 79,421

-16.8%

$ 66,078

6/14/2021

6/13/2022

3.00%

4

County of Contra Costa

Pharmacy Technician

$56,010

$ 68,080

-11.1%

$ 60,523

7/1/2021

unknown

unknown

5

County of Sacramento

Pharmacy Technician

$ 46,061

$ 56,000

0.1%

$ 56,056

6/21/2020

unknown

unknown

6

County of San Diego

Pharmacy Technician

$ 45,178

$ 55,557



$ 55,557

6/18/2021

unknown

unknown

7

County of Riverside

PharmacyTechnician II

$ 34,551

$ 53,924

1.9%

$ 54,948

5/1/2021

5/1/2022

2.00%

8

County of Los Angeles

Pharmacy Technician

$ 40,448

$ 54,382

-3.8%

$52,315

1/1/2021

unknown

unknown

9

County of Orange

PharmacyTechnician

$ 38,688

$52,166

-2.0%

$51,123

7/2/2021

7/1/2022

3.50%

10

County of Kern

PharmacyTechnician II

$ 35,424

$ 43,248

1.2%

$ 43,767

4/21/2021

unknown

unknown

11

County of Ventura

PharmacyTechnician II

$ 30,294

$ 42,266

-0.7%

$ 41,970

12/26/2020

12/27/2021

2.00%

12

County of Alameda

N/C















13

County of Fresno

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$55,191

$ 55,502

% County of San Diego Above/Below

0.7%

0.1%

Number of Matches

10

10

N/C - Non Comparator

Page 244 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Photographic Audio-Visual Specialist





















1

County of Los Angeles

Video Production Specialist

$ 69,586

$ 93,779

-3.8%

$ 90,215

1/1/2021

unknown

unknown

2

County of Contra Costa

Sheriffs Photographer

$ 77,913

$ 97,071

-11.1%

$ 86,296

7/1/2021

7/1/2022

5.00%





















4

County of San Bernardino

Multimedia Production Specialist II

$ 53,498

$ 75,296

1.9%

$ 76,727

3/13/2021

3/26/2022

3.00%

5

County of Sacramento

Public Information Specialist

$ 60,093

$ 73,059

0.1%

$ 73,132

6/21/2020

unknown

unknown

6

County of Alameda

Sheriffs Multimedia Producer

$ 62,878

$ 75,442

-11.4%

$ 66,841

6/27/2021

6/26/2022

3.25%

7

County of Ventura

Photographic/Imaging Services Technician

$ 43,356

$ 60,616

-0.7%

$ 60,192

12/26/2020

12/27/2021

2.00%

8

County of Fresno

Multimedia Technician II

$ 38,714

$ 47,034

4.7%

$ 49,245

11/2/2020

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,296

$ 73,132

% County of San Diego Above/Below

2.5%

5.3%

Number of Matches

7

7

N/C - Non Comparator

Page 245 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Physician Assistant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Physician Assistant

$ 175,296

$ 248,148

-17.4%

$ 204,970

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Physicians Assistant

$ 158,306

$ 197,887

-17.5%

$ 163,257

10/2/2020

unknown

unknown

3

County of Los Angeles

Physician Assistant

$ 113,376

$ 152,783

-3.8%

$ 146,977

1/1/2021

unknown

unknown

4

County of Kern

Physician's Assistant

$ 106,128

$ 129,612

1.2%

$ 131,167

4/21/2021

unknown

unknown

5

County of San Bernardino

Physician Assistant

$ 91,021

$ 128,440

1.9%

$ 130,880

3/13/2021

3/26/2022

3.00%

6

County of Riverside

Physician Assistant II

$ 91,539

$ 121,943

1.9%

$ 124,260

5/1/2021

5/1/2022

2.00%

7

County of Alameda

Mid-Level Practitioner

$ 105,447

$ 137,124

-11.4%

$ 121,492

6/27/2021

6/26/2022

3.25%

8

County of Ventura

Physician Assistant

$ 101,612

$ 106,953

-0.7%

$ 106,204

3/21/2021

4/3/2022

2.50%

9

County of San Diego

Physician Assistant

$ 84,053

$ 103,230



$ 103,230

6/18/2021

unknown

unknown

10

County of Sacramento

Physician Assistant

$ 74,333

$ 90,348

0.1%

$ 90,438

6/21/2020

unknown

unknown

11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Orange

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 129,612

$ 130,880

% County of San Diego Above/Below

-25.6%

-26.8%

Number of Matches

9

9

N/C - Non Comparator

Page 246 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Precinct Planning Technician

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Precinct Planning Specialist

$ 76,650

$ 92,760

-16.8%

$77,176

6/14/2021

6/13/2022

3.00%

2

County of Ventura

Elections Precinct Coordinator

$45,193

$ 63,271

-0.7%

$ 62,828

12/27/2020

12/26/2021

2.00%

3

County of Contra Costa

Elections Services Technician

$ 50,024

$ 60,805

-11.1%

$ 54,056

7/1/2021

unknown

unknown

4

County of San Diego

Precinct Planning Technician

$ 38,126

$ 51,688



$ 51,688

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,271

$ 62,828

% County of San Diego Above/Below

-22.4%

-21.6%

Number of Matches

3

3

N/C - Non Comparator

Page 247 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Principal Treasurer-Tax Collector Specialist





















1

County of Los Angeles

Flead, Tax Services

$ 71,855

$ 99,488

-3.8%

$ 95,707

1/1/2021

unknown

unknown

2

County of Alameda

Treasurer-Tax Collector Supervisor

$ 86,757

$ 104,166

-11.4%

$ 92,291

12/27/2020

12/26/2021

3.00%

3

County of Santa Clara

Supervising Tax Collection Clerk

$ 76,685

$93,186

-16.8%

$ 77,531

6/28/2021

6/27/2022

3.00%

4

County of Contra Costa1

[Account Clerk - Advanced Level/Tax Operations Supervisor]

$ 65,169

$ 80,745

-11.1%

$ 71,782

7/1/2021

unknown

unknown





















6

County of Fresno

Tax Collections Supervisor

$ 47,944

$ 58,292

4.7%

$ 61,032

4/19/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$93,186

$ 77,531

% County of San Diego Above/Below

-40.8%

-17.2%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 248 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Probation Aide

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Program Assistant

$ 63,341

$ 88,686

-0.7%

$ 88,065

unknown

unknown

unknown

2

County of Alameda

Probation Aide

$61,318

$ 74,651

-11.4%

$ 66,141

9/20/2020

unknown

unknown

3

City and County of San Francisco

Probation Assistant

$ 61,908

$ 75,216

-17.4%

$62,128

7/1/2021

1/8/2022

.50%

4

County of Contra Costa

Administrative Aide

$ 42,585

$ 66,063

-11.1%

$58,730

7/1/2021

unknown

unknown

5

County of Santa Clara

Law Enforcement Clerk

$ 54,207

$ 65,453

-16.8%

$ 54,457

6/14/2021

6/13/2022

3.00%

6

County of San Diego

Probation Aide

$ 44,179

$ 54,288



$ 54,288

6/18/2021

unknown

unknown

7

County of Riverside

Probation Assistant

$32,625

$ 50,929

1.9%

$51,897

5/1/2021

5/1/2022

2.00%

8

County of Fresno

Probation Technician II

$ 36,842

$ 44,772

4.7%

$ 46,876

10/19/2020

unknown

unknown

9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,063

$ 58,730

% County of San Diego Above/Below

-21.7%

-8.2%

Number of Matches

7

7

N/C - Non Comparator

Page 249 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Probation Operations Support Manager	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Administrative Services Manager 1

$ 115,438

$ 144,287

-17.5%

$ 119,037

12/13/2020

unknown

unknown

2

County of Contra Costa

Administrative Services Assistant III

$ 81,746

$ 99,363

-11.1%

$ 88,334

7/1/2021

unknown

unknown

3

County of San Diego

Probation Operations Support Manager

$ 67,954

$ 83,533



$ 83,533

6/18/2021

unknown

unknown

4

County of San Bernardino

Probation Office Operations Manager

$ 50,440

$ 69,389

1.9%

$ 70,707

7/31/2021

7/30/2022

3.00%

5

County of Ventura

Clerical Supervisor III

$ 50,221

$ 70,345

-0.7%

$ 69,853

12/26/2020

12/27/2021

2.00%

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 84,854

$ 79,520

% County of San Diego Above/Below

-1.6%

4.8%

Number of Matches

4

4

N/C - Non Comparator

Page 250 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Process Server	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Legal Process Officer

$ 55,987

$ 67,569

-16.8%

$ 56,217

6/14/2021

6/13/2022

3.00%

2

County of Sacramento

Process Server

$ 44,704

$ 54,330

0.1%

$ 54,384

6/21/2021

unknown

unknown

3

County of Ventura

Investigative Assistant II

$ 38,366

$ 53,899

-0.7%

$ 53,521

12/26/2020

12/27/2021

2.00%

4

County of San Bernardino

Investigative Technician 1

$ 35,797

$ 49,296

1.9%

$ 50,233

7/31/2021

7/30/2022

3.00%

5

County of Fresno

Process Server

$ 37,544

$ 45,656

4.7%

$ 47,802

10/19/2020

unknown

unknown

6

County of San Diego

Process Server

$ 38,501





$ 47,382

6/18/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Riverside

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,899

$ 53,521

% County of San Diego Above/Below

-13.8%

-13.0%

Number of Matches

5

5

N/C - Non Comparator

Page 251 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Process Server Supervisor

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Sacramento

Supervising Process Server

$ 48,671

$ 59,153

0.1%

$ 59,212

6/21/2020

unknown

unknown

2

County of San Diego

Process Server Supervisor

$ 44,637

$ 54,246



$ 54,246

6/18/2021

unknown

unknown

3

County of Fresno

Supervising Process Server

$ 41,496

$ 50,440

4.7%

$ 52,811

4/19/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 54,797

$ 56,011

% County of San Diego Above/Below

-1.0%

-3.3%

Number of Matches

2

2

N/C - Non Comparator

Page 252 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Procurement Contracting Officer





















1

County of Los Angeles

Principal Purchasing & Contracts Analyst

$ 89,263

$ 120,288

-3.8%

$ 115,717

1/1/2021

unknown

unknown

2

City and County of San Francisco

Senior Purchaser

$ 107,148

$ 130,308

-17.4%

$ 107,634

7/1/2021

1/8/2022

.50%

3

County of Riverside

Senior Procurement Contract Specialist

$ 62,479

$ 102,875

1.9%

$ 104,830

5/1/2021

5/1/2022

2.00%





















5

County of Sacramento

Senior Contract Services Officer

$ 79,114

$ 96,152

0.1%

$ 96,248

6/21/2020

unknown

unknown

6

County of Contra Costa

Senior Buyer

$ 81,746

$ 99,363

-11.1%

$ 88,334

7/1/2021

unknown

unknown

7

County of Alameda1

[Procurement and Contracts Specialist 11/ Procurement and Contracts Supervisor]

$ 82,357

$ 99,407

-11.4%

$ 88,075

12/27/2020

12/26/2021

3.00%

8

County of Santa Clara

Buyer III

$ 86,501

$ 104,664

-16.8%

$ 87,080

6/14/2021

6/13/2022

3.00%

9

County of San Bernardino

Buyer III

$ 61,381

$ 84,365

1.9%

$ 85,968

7/31/2021

7/30/2022

3.00%

10

County of Fresno

Purchasing Analyst III

$ 62,478

$ 75,920

4.7%

$ 79,488

4/19/2021

unknown

unknown

11

County of Kern

Contract Administrator

$ 55,224

$ 67,416

1.2%

$ 68,225

4/21/2021

unknown

unknown

12

County of Orange

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 99,385

$ 88,204

% County of San Diego Above/Below

-0.0%

11.2%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is
an average of the matches.

Page 253 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Procurement Contracting Specialist





















1

County of Riverside

Procurement Contract Specialist

$ 59,142

$ 97,399

1.9%

$ 99,249

5/1/2021

5/1/2022

2.00%

2

County of Los Angeles

Purchasing and Contracts Analyst II

$ 75,861

$ 102,219

-3.8%

$ 98,335

1/1/2021

unknown

unknown

3

County of Orange

Procurement Contract Specialist

$ 68,432

$ 92,248

-2.0%

$ 90,403

7/2/2021

7/1/2022

3.50%

4

City and County of San Francisco

Purchaser

$ 88,140

$ 107,148

-17.4%

$ 88,504

7/1/2021

1/8/2022

.50%

5

County of Alameda

Procurement and Contracts Specialist II

$ 78,340

$ 93,803

-11.4%

$ 83,110

6/27/2021

6/26/2022

3.25%





















7

County of Sacramento

Contract Services Officer II

$ 65,960

$ 80,179

0.1%

$ 80,259

6/21/2020

unknown

unknown

8

County of Contra Costa

Buyer II

$ 73,601

$ 89,463

-11.1%

$ 79,533

7/1/2021

unknown

unknown

9

County of Santa Clara

Buyer II

$ 72,238

$ 87,360

-16.8%

$ 72,684

6/14/2021

6/13/2022

3.00%

10

County of San Bernardino

Buyer II

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

11

County of Fresno

Purchasing Analyst II

$ 54,080

$ 65,728

4.7%

$ 68,817

4/19/2021

unknown

unknown

12

County of Kern

Buyer III

$ 47,076

$ 57,468

1.2%

$ 58,158

4/21/2021

unknown

unknown

13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 89,463

$ 80,259

% County of San Diego Above/Below

-7.7%

3.4%

Number of Matches

11

11

N/C - Non Comparator

Page 254 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Procurement Specialist |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Purchasing and Contracts Analyst 1

$ 64,468

$ 86,869

-3.8%

$ 83,568

1/1/2021

unknown

unknown

2

County of Orange

Procurement Buyer

$ 61,402

$ 82,763

-2.0%

$ 81,108

7/2/2021

7/1/2022

3.50%

3

County of San Mateo

Buyer II

$ 76,335

$ 95,408

-17.5%

$ 78,711

10/4/2020

unknown

unknown

4

County of San Diego

Procurement Specialist

$ 57,512

$ 70,678



$ 70,678

6/18/2021

unknown

unknown

5

County of Ventura

Senior Buyer

$ 50,564

$ 70,716

-0.7%

$ 70,221

12/27/2020

12/26/2021

2.00%

6

County of Fresno

Purchasing Analyst II

$ 54,080

$ 65,728

4.7%

$ 68,817

4/19/2021

unknown

unknown

7

County of Santa Clara

Buyer 1

$64,133

$ 77,440

-16.8%

$ 64,430

6/14/2021

6/13/2022

3.00%

8

County of Contra Costa

Buyer 1

$ 55,781

$ 67,802

-11.1%

$ 60,276

7/1/2021

unknown

unknown

9

County of Kern

Buyer II

$ 43,032

$ 52,536

1.2%

$ 53,166

4/21/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 74,078

$ 69,519

% County of San Diego Above/Below

-4.8%

1.6%

Number of Matches

8

8

N/C - Non Comparator

Page 255 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Property Assessment Specialist I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Assessor's Technician 1

$ 44,477

$ 56,931

-0.7%

$ 56,533

1/10/2021

1/9/2022

2.00%

2

County of Fresno

Assessment Technician 1

$ 41,002

$ 49,842

4.7%

$ 52,185

4/19/2021

unknown

unknown

3

County of San Diego

Property Assessment Specialist 1

$ 41,933





$ 51,501

6/18/2021

unknown

unknown

4

County of Orange

Assessment Technician Trainee

$ 36,920

$ 48,942

-2.0%

$ 47,964

7/2/2021

7/1/2022

3.50%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 49,842

$ 52,185

% County of San Diego Above/Below

3.2%

-1.3%

Number of Matches

3

3

N/C - Non Comparator

Page 256 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Property Assessment Specialist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Assessor-Recorder Office Specialist

$ 66,144

$ 80,392

-17.4%

$ 66,404

7/1/2021

1/8/2022

.50%

2

County of Ventura

Assessor's Technician II

$ 49,491

$ 63,348

-0.7%

$ 62,904

1/10/2021

1/9/2022

2.00%

3

County of Santa Clara

Appraisal Aide

$ 62,483

$ 75,492

-16.8%

$ 62,809

6/14/2021

6/13/2022

3.00%

4

County of Fresno

Assessment Technician II

$ 46,488

$ 56,524

4.7%

$ 59,181

4/19/2021

unknown

unknown

5

County of San Diego

Property Assessment Specialist II

$ 47,736

$ 58,656



$ 58,656

6/18/2021

unknown

unknown

6

County of Contra Costa

Clerk - Specialist Level

$ 50,943

$ 65,057

-11.1%

$ 57,835

7/1/2021

unknown

unknown

7

County of Sacramento

Assessment Technician

$ 46,771

$ 56,877

0.1%

$ 56,934

6/21/2020

unknown

unknown

8

County of Orange

Assessment Technician II

$ 42,640

$ 57,158

-2.0%

$ 56,015

7/2/2021

7/1/2022

3.50%

9

County of Kern

Appraisal Assistant

$ 32,064

$ 39,144

1.2%

$ 39,614

4/21/2021

unknown

unknown

10

County of Alameda

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,253

$ 58,508

% County of San Diego Above/Below

-2.7%

0.3%

Number of Matches

8

8

N/C - Non Comparator

Page 257 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Property Assessment Specialist III





















1

City and County of San Francisco

Assessor-Recorder Senior Office Specialist

$ 73,060

$ 93,210

-17.4%

$ 76,991

7/1/2021

1/8/2022

.50%





















3

County of Ventura

Assessor'sTechnician III

$ 53,893

$ 68,983

-0.7%

$ 68,500

1/10/2021

1/9/2022

2.00%

4

County of Orange

Assessment Technician III

$ 48,942

$ 65,354

-2.0%

$ 64,046

7/2/2021

7/1/2022

3.50%

5

County of Fresno

Assessment Technician III

$ 50,284

$ 61,152

4.7%

$ 64,026

4/19/2021

unknown

unknown

6

County of Santa Clara

Appraisal Data Coordinator

$ 58,689

$ 70,849

-16.8%

$ 58,946

6/14/2021

6/13/2022

3.00%

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 68,983

$ 64,046

% County of San Diego Above/Below

2.1%

9.1%

Number of Matches

5

5

N/C - Non Comparator

Page 258 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Protective Services Assistant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Social Casework Assistant

$ 69,561

$ 84,551

-11.1%

$ 75,166

7/1/2021

unknown

unknown

2

County of Los Angeles

Human Services Aide

$ 41,041

$ 55,194

-3.8%

$ 53,096

1/1/2021

unknown

unknown

3

County of Ventura

HS Case Aide II

$ 38,517

$ 51,362

-0.7%

$ 51,002

12/27/2020

12/26/2021

2.00%

4

County of San Bernardino

Social Service Aide

$ 33,322

$ 45,802

1.9%

$ 46,672

7/31/2021

7/30/2022

3.00%

5

County of San Diego

Protective Services Assistant

$ 35,568

$ 45,968



$ 45,968

6/18/2021

unknown

unknown

6

County of Sacramento

Family Services Worker 1

$ 35,287

$ 42,908

0.1%

$ 42,951

6/21/2020

unknown

unknown

7

County of Fresno

Social Worker Aide II

$ 29,692

$ 36,842

4.7%

$ 38,574

11/2/2020

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 48,582

$ 48,837

% County of San Diego Above/Below

-5.7%

-6.2%

Number of Matches

6

6

N/C - Non Comparator

Page 259 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Protective Services Supervisor





















1

City and County of San Francisco

Protective Services Supervisor

$ 107,460

$ 137,232

-17.4%

$ 113,354

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Children's Services Social Work Supervisor

$ 108,740

$ 135,925

-17.5%

$ 112,138

10/4/2020

unknown

unknown

3

County of Alameda

Child Welfare Supervisor

$ 96,533

$ 116,522

-11.4%

$ 103,238

9/6/2020

unknown

unknown

4

County of Contra Costa

Social Work Supervisor II

$ 94,644

$ 115,041

-11.1%

$ 102,272

7/1/2021

unknown

unknown

5

County of Sacramento

Human Services Supervisor - Master's Degree

$ 83,019

$ 100,913

0.1%

$ 101,014

6/21/2020

unknown

unknown

6

County of Ventura

HS Child Welfare Supervisor

$ 97,165

$ 99,434

-0.7%

$ 98,738

12/26/2020

12/27/2021

2.00%

7

County of San Bernardino

Supervising Social Service Practitioner

$ 69,243

$ 95,326

1.9%

$ 97,138

7/31/2021

7/30/2022

3.00%





















9

County of Fresno

Social Work Supervisor

$ 64,350

$ 82,290

4.7%

$ 86,158

11/2/2020

unknown

unknown

10

County of Orange

Social Services Supervisor 1

$ 63,440

$ 85,613

-2.0%

$ 83,901

7/2/2021

7/1/2022

3.50%

11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of Riverside

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,913

$ 101,014

% County of San Diego Above/Below

-8.2%

-8.3%

Number of Matches

9

9

N/C - Non Comparator

Page 260 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Protective Services Worker	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Protective Services Worker

$ 95,676

$ 122,040

-17.4%

$ 100,805

7/1/2021

1/8/2022

.50%

2

County of Alameda

Child Welfare Worker II

$ 88,287

$ 101,333

-11.4%

$ 89,781

6/27/2021

6/26/2022

3.25%

3

County of San Bernardino

Social Service Practitioner II

$ 57,554

$ 81,078

1.9%

$ 82,619

3/13/2021

3/26/2022

3.00%

4

County of San Mateo

Children's Services Social Worker II

$ 78,290

$ 97,862

-17.5%

$ 80,736

10/4/2020

unknown

unknown

5

County of Contra Costa

Social Worker II

$ 78,259

$ 86,280

-11.1%

$ 76,703

7/1/2021

unknown

unknown

6

County of Ventura

HS Child Welfare Social Worker II

$ 57,333

$ 76,444

-0.7%

$ 75,909

12/26/2020

12/27/2021

2.00%

7

County of San Diego

Protective Services Worker

$ 58,448

$ 75,379



$ 75,379

6/18/2021

unknown

unknown

8

County of Santa Clara

Social Worker 1

$ 74,310

$ 89,796

-16.8%

$ 74,710

6/14/2021

6/13/2022

3.00%

9

County of Sacramento

Human Services Social Worker

$ 60,322

$ 73,310

0.1%

$ 73,383

6/21/2020

unknown

unknown

10

County of Orange

Social Worker II

$ 55,578

$ 74,651

-2.0%

$ 73,158

7/2/2021

7/1/2022

3.50%

11

County of Los Angeles

Social Worker

$ 50,254

$ 75,488

-3.8%

$ 72,619

1/1/2021

unknown

unknown

12

County of Fresno

Social Worker II

$ 44,980

$ 57,538

4.7%

$ 60,242

11/2/2020

unknown

unknown

13

County of Kern

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 81,078

$ 75,909

% County of San Diego Above/Below

-7.6%

-0.7%

Number of Matches

11

11

N/C - Non Comparator

Page 261 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Psychiatric Clinical Nurse Specialist





















1

City and County of San Francisco

Clinical Nurse Specialist

$ 175,368

$ 248,196

-17.4%

$ 205,010

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Clinical Nurse Specialist

$ 118,224

$ 176,967

-3.8%

$ 170,242

1/1/2021

unknown

unknown

3

County of Contra Costa

Clinical Nurse Specialist

$ 143,368

$ 179,047

-11.1%

$ 159,173

1/1/2021

unknown

unknown

4

County of Alameda

Clinical Nurse Specialist

$ 114,038

$ 153,059

-11.4%

$ 135,611

6/27/2021

6/26/2022

3.25%

5

County of Ventura1

[Senior Registered Nurse - Mental Health/Senior Registered Nurse - Mental Health Acute Care]

$ 105,400

$ 126,015

-0.7%

$ 125,133

4/4/2021

4/17/2022

3.25%

6

County of Orange

Comprehensive Care Nurse II

$ 92,248

$ 124,301

-2.0%

$ 121,815

7/2/2021

7/1/2022

3.50%





















8

County of Sacramento

Senior Psychiatric Nurse

$92,164

$ 112,402

0.1%

$ 112,514

8/2/2020

unknown

unknown

9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 153,059

$ 135,611

% County of San Diego Above/Below

-35.6%

-20.2%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the matches.

Page 262 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Psychiatric Nurse	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Psychiatric Nurse II

$ 141,912

$ 190,203

-16.8%

$ 158,249

10/19/2020

11/1/2021

3%

2

City and County of San Francisco

Registered Nurse

$ 141,518

$ 185,848

-17.4%

$ 153,510

7/1/2021

1/8/2022

.50%

3

County of Contra Costa

Registered Nurse

$ 124,777

$ 155,829

-11.1%

$ 138,532

1/1/2021

unknown

unknown

4

County of Los Angeles

Registered Nurse II

$ 85,408

$ 127,845

-3.8%

$ 122,987

1/1/2021

unknown

unknown

5

County of San Mateo1

Psychiatric Nurse

$ 123,737

$ 146,242

-17.5%

$ 120,650

2/7/2021

unknown

unknown

6

County of Ventura

Registered Nurse - Mental Health

$89,199

$ 110,566

-0.7%

$ 109,792

4/4/2021

4/17/2022

3.25%

7

County of San Bernardino

Mental Health Nurse II

$ 75,858

$ 101,982

1.9%

$ 103,920

8/15/2020

unknown

unknown

8

County of Sacramento

Psychiatric Nurse

$ 91,287

$ 100,662

0.1%

$ 100,763

8/2/2020

unknown

unknown

9

County of San Diego

Psychiatric Nurse

$ 80,101

$ 98,384



$ 98,384

6/18/2021

unknown

unknown

10

County of Fresno

Mental Health Nurse II

$ 76,414

$ 92,872

4.7%

$ 97,237

11/2/2020

unknown

unknown

11

County of Riverside

Registered Nurse II

$ 76,023

$ 93,416

1.9%

$ 95,190

5/1/2021

5/1/2022

2.00%

12

County of Orange

Behavioral Health Nurse

$ 69,826

$ 93,995

-2.0%

$ 92,115

7/2/2021

7/1/2022

3.50%

13

County of Kern

Behavioral Health Nurse II

$ 69,456

$ 84,792

1.2%

$ 85,810

4/21/2021

unknown

unknown

14

County of Alameda

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,274

$ 106,856

% County of San Diego Above/Below

-8.0%

-8.6%

Number of Matches

12

12

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 263 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Psychiatric Resident |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Staff Psychiatrist 1

$ 213,940

$ 282,852

1.9%

$ 288,226

7/1/2021

7/14/2022

2.00%

2

County of San Mateo1

Psychiatric Resident - Psych Emergency Services

N/A

$ 301,781

-17.5%

$ 248,970

unknown

unknown

unknown

3

County of Orange

Physician 1

$ 146,307

$ 197,163

-2.0%

$ 193,220

7/2/2021

7/1/2022

3.50%

4

County of San Diego

Psychiatric Resident

$ 150,675

$ 185,058



$ 185,058

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 282,852

$ 248,970

% County of San Diego Above/Below

-52.8%

-34.5%

Number of Matches

3

3

N/C - Non Comparator

1 - County of San Mateo: No range - only 1 step.

Page 264 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Psychiatric Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Psychiatric Technician

$ 77,868

$ 94,644

-17.4%

$78,176

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Psychiatric Technician II

$ 71,664

$ 86,530

-16.8%

$ 71,993

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Licensed PsychiatricTechnician

$ 67,245

$ 84,093

-17.5%

$ 69,377

10/4/2020

unknown

unknown

4

County of Ventura

PsychiatristTechnician - IPU

$63,120

$ 67,939

-0.7%

$ 67,463

3/21/2021

4/3/2022

2.50%

5

County of Sacramento

Mental Health Worker - Licensed

$ 52,263

$ 63,517

0.1%

$ 63,580

6/21/2020

unknown

unknown

6

County of Contra Costa

Psychiatric Technician

$ 55,362

$ 70,699

-11.1%

$ 62,851

7/1/2021

unknown

unknown

7

County of Los Angeles

PsychiatricTechnician II

$46,130

$62,134

-3.8%

$ 59,773

1/1/2021

unknown

unknown

8

County of San Bernardino

PsychiatricTechnician 1

$ 40,227

$ 55,286

1.9%

$ 56,337

7/31/2021

7/30/2022

3.00%

9

County of Riverside

Licensed PsychiatricTechnician

$ 35,537

$ 52,485

1.9%

$ 53,483

5/1/2021

5/1/2022

2.00%

10

County of San Diego

Psychiatric Technician

$ 52,707

$ 52,707



$ 52,707

6/18/2021

unknown

unknown

11

County of Fresno

PsychiatricTechnician II

$39,130

$ 50,076

4.7%

$ 52,430

11/2/2020

unknown

unknown

12

County of Kern

Mental Health Technician II

$ 31,896

$ 38,940

1.2%

$ 39,407

4/21/2021

unknown

unknown

13

County of Alameda

N/C















14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,517

$ 62,851

% County of San Diego Above/Below

-20.5%

-19.2%

Number of Matches

11

11

N/C - Non Comparator

Page 265 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Psychiatrist

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Staff Psychiatrist III

$ 245,309

$ 307,519

1.9%

$ 313,362

7/1/2021

7/14/2022

2.00%

2

County of San Bernardino

Psychiatrist 1

$ 252,970

$ 300,248

1.9%

$ 305,953

3/13/2021

3/26/2022

3.00%

3

County of Los Angeles

Mental Health Psychiatrist

$ 309,699

$ 309,699

-3.8%

$ 297,930

1/1/2021

unknown

unknown

4

County of Orange

Psychiatrist

$ 194,917

$ 269,402

-2.0%

$ 264,014

7/2/2021

7/1/2022

3.50%

5

County of San Mateo

Adult Psychiatrist

$ 241,400

$ 301,781

-17.5%

$ 248,970

5/2/2021

unknown

unknown

6

County of Santa Clara

Psychiatrist

$ 227,510

$ 277,160

-16.8%

$ 230,597

10/19/2020

11/1/2021

3.00%

7

County of San Diego

Psychiatrist

$ 178,776

$ 219,794



$ 219,794

6/18/2021

unknown

unknown

8

County of Kern

Psychiatrist II, Mental Health

$ 166,248

$ 202,956

1.2%

$ 205,391

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 300,248

$ 264,014

% County of San Diego Above/Below

-36.6%

-20.1%

Number of Matches

7

7

N/C - Non Comparator

Page 266 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Psychiatrist - Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Bernardino

Child Psychiatrist

$ 285,605

$ 339,706

1.9%

$ 346,160

3/13/2021

3/26/2022

3.00%

2

County of Riverside

Staff Psychiatrist IV

$ 258,011

$ 323,461

1.9%

$ 329,607

7/1/2021

7/14/2022

2.00%

3

City and County of San Francisco

Senior Psychiatric Physician Specialist

$ 256,668

$ 363,216

-17.4%

$ 300,016

7/1/2021

1/8/2022

.50%

4

County of San Mateo1

Child Psychiatrist

$ 266,672

$ 315,260

-17.5%

$ 260,089

5/2/2021

unknown

unknown

5

County of San Diego

Psychiatrist Specialist

$ 186,930

$ 229,590



$ 229,590

6/18/2021

unknown

unknown

6

County of Kern

Psychiatrist III, Mental Health

$ 172,164

$ 210,168

1.2%

$ 212,690

4/21/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 323,461

$ 300,016

% County of San Diego Above/Below

-40.9%

-30.7%

Number of Matches

5

5

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 267 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Assistance Investigator I |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Welfare Investigator 1

$74,131

$ 88,816

-11.4%

$ 78,691

5/2/2021

5/1/2022

4.00%

2

County of San Mateo

Fraud Investigator 1

$ 72,071

$90,104

-17.5%

$ 74,336

10/4/2020

unknown

unknown

3

County of Ventura

Welfare Investigator 1

$ 54,645

$ 73,256

-0.7%

$ 72,743

4/19/2020

unknown

unknown

4

County of San Diego

Public Assistance Investigator 1

$ 58,531

$ 71,968



$ 71,968

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,816

$ 74,336

% County of San Diego Above/Below

-23.4%

-3.3%

Number of Matches

3

3

N/C - Non Comparator

Page 268 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Assistance Investigator II





















1

County of Orange

Public Assistance Investigator

$ 78,000

$ 105,102

-2.0%

$ 103,000

7/2/2021

7/1/2022

3.50%

2

City and County of San Francisco

Welfare Fraud Investigator

$ 102,048

$ 124,068

-17.4%

$ 102,480

7/1/2021

1/8/2022

.50%

3

County of Santa Clara

Welfare Fraud Investigator

$ 96,310

$ 117,179

-16.8%

$ 97,493

6/14/2021

6/13/2022

3.00%

4

County of Riverside

Welfare Fraud Investigator-B

$ 57,715

$ 90,212

1.9%

$ 91,926

5/1/2021

5/1/2022

2.00%

5

County of Alameda

Welfare Investigator II

$ 84,573

$ 101,296

-11.4%

$ 89,748

5/2/2021

5/1/2022

4.00%

6

County of San Mateo

Fraud Investigator II

$ 84,592

$ 105,787

-17.5%

$ 87,274

10/4/2020

unknown

unknown

7

County of Fresno

District Attorney Investigator

$ 63,544

$ 81,276

4.7%

$ 85,096

11/4/2019

unknown

unknown

8

County of Ventura

Welfare Investigator II

$ 58,741

$ 78,749

-0.7%

$ 78,198

4/19/2020

unknown

unknown





















10

County of Los Angeles

Welfare Fraud Investigator

$ 57,133

$ 76,993

-3.8%

$ 74,067

1/1/2021

unknown

unknown

11

County of Contra Costa1

[Social Service Welfare Fraud Investigator/Social Service Welfare Fraud Field Investigator]

$ 67,273

$ 81,771

-11.1%

$ 72,694

7/1/2021

unknown

unknown

12

County of Kern

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 95,754

$88,511

% County of San Diego Above/Below

-23.6%

-14.2%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the
matches.

Page 269 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Assistance Investigator Supervisor





















1

County of Orange

Supervising Public Assistance Investigator

$ 91,790

$ 123,698

-2.0%

$ 121,224

7/2/2021

7/1/2022

3.50%

2

County of Santa Clara

Supervising Welfare Fraud Investigator

$ 141,199

$ 141,199

-16.8%

$ 117,477

6/28/2021

6/27/2022

3.00%

3

County of Fresno

Supervising District Attorney Investigator

$ 90,662

$ 110,188

4.7%

$ 115,367

4/19/2021

unknown

unknown

4

City and County of San Francisco

Supervising Welfare Fraud Investigator

$ 110,940

$ 134,808

-17.4%

$ 111,351

7/1/2021

1/8/2022

.50%

5

County of Riverside

Supervising Welfare Fraud Investigator-B

$ 62,614

$ 100,425

1.9%

$ 102,333

5/1/2021

5/1/2022

2.00%

6

County of Alameda

Supervising Welfare Investigator

$90,355

$ 109,803

-11.4%

$97,286

12/27/2020

12/26/2021

3.00%

7

County of San Mateo

Supervisor Fraud Investigation Unit

$ 92,974

$ 116,207

-17.5%

$ 95,871

10/4/2020

unknown

unknown

8

County of Ventura

Supervising Welfare Fraud Investigator

$ 67,885

$ 91,004

-0.7%

$ 90,367

4/19/2020

unknown

unknown

9

County of Contra Costa

Social Services Fraud Prevention Supervisor

$ 82,982

$ 100,865

-11.1%

$ 89,669

7/1/2021

unknown

unknown





















11

County of Los Angeles

Supervising Welfare Fraud Investigator

$ 63,684

$ 85,810

-3.8%

$ 82,549

1/1/2021

unknown

unknown

12

County of Kern

Senior District Attorney Welfare Fraud Investigator

$ 54,672

$ 66,744

1.2%

$ 67,545

4/21/2021

unknown

unknown

13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 109,803

$97,286

% County of San Diego Above/Below

-28.7%

-14.1%

Number of Matches

11

11

N/C - Non Comparator

Page 270 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Public Assistance Investigator Trainee |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Public Assistance Investigator Trainee

$ 51,938

$ 69,950

-2.0%

$ 68,551

7/2/2021

7/1/2022

3.50%

2

County of Sacramento

Investigative Assistant

$ 55,687

$ 67,672

0.1%

$ 67,740

6/21/2021

unknown

unknown

3

County of Los Angeles

Welfare Fraud Investigator Trainee

$ 50,254

$ 67,719

-3.8%

$ 65,146

1/1/2021

unknown

unknown

4

County of San Diego

Public Assistance Investigator Trainee

$ 52,146

$ 64,043



$ 64,043

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,719

$ 67,740

% County of San Diego Above/Below

-5.7%

-5.8%

Number of Matches

3

3

N/C - Non Comparator

Page 271 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Defender Investigator I





















1

County of Santa Clara

Public Defender Investigator 1

$ 102,561

$ 124,667

-16.8%

$ 103,723

6/14/2021

6/13/2022

3.00%

2

County of Alameda1

[Public Defender Investigator 1/ Public Defender Investigator II]

$ 87,214

$ 107,983

-11.4%

$ 95,673

12/27/2020

12/26/2021

3.00%

3

County of Los Angeles

Investigator 1, Public Defender

$ 73,286

$ 98,758

-3.8%

$ 95,005

1/1/2021

unknown

unknown

4

County of Riverside

The Public Defender Investigator 1

$ 58,735

$ 91,814

1.9%

$ 93,559

5/1/2021

5/1/2022

2.00%

5

County of Ventura

Public Defender Investigator 1

$ 75,091

$ 93,864

-0.7%

$ 93,207

12/27/2020

12/26/2021

2.00%

6

County of Orange

Defense Investigator 1

$ 67,891

$ 91,374

-2.0%

$ 89,547

7/2/2021

7/1/2022

3.50%

7

County of Contra Costa

Public Defender Investigator 1

$82,110

$ 99,805

-11.1%

$ 88,727

7/1/2021

unknown

unknown





















9

County of Kern

Public Defender's Investigator 1

$ 56,328

$ 68,772

1.2%

$ 69,597

4/21/2021

unknown

unknown

10

County of Fresno

Defense Investigator 1

$ 49,738

$ 63,674

4.7%

$ 66,667

11/2/2020

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,864

$ 93,207

% County of San Diego Above/Below

-17.9%

-17.1%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 272 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Public Defender Investigator II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Public Defender Investigator III

$ 122,699

$ 147,389

-11.4%

$ 130,586

12/27/2020

12/26/2021

3.00%

2

County of Los Angeles

Investigator II, Public Defender

$ 91,946

$ 130,814

-3.8%

$ 125,843

1/1/2021

unknown

unknown

3

County of Santa Clara

Public Defender Investigator II

$ 110,425

$ 134,360

-16.8%

$ 111,787

6/14/2021

6/13/2022

3.00%

4

County of Orange

Defense Investigator II

$84,178

$ 113,152

-2.0%

$ 110,889

7/2/2021

7/1/2022

3.50%

5

County of Riverside

The Public Defender Investigator II

$ 65,663

$ 102,655

1.9%

$ 104,605

5/1/2021

5/1/2022

2.00%

6

County of Contra Costa

Public Defender Investigator II

$ 93,946

$ 114,192

-11.1%

$ 101,516

7/1/2021

unknown

unknown

7

County of Ventura

Public Defender Investigator II

$ 79,670

$ 99,599

-0.7%

$ 98,902

12/27/2020

12/26/2021

2.00%

8

City and County of San Francisco

Public Defenders Investigator

$ 95,832

$ 116,484

-17.4%

$ 96,216

7/1/2021

1/8/2022

.50%

9

County of San Bernardino

Public Defender Investigator

$ 67,142

$ 92,373

1.9%

$ 94,128

7/31/2021

7/30/2022

3.00%

10

County of San Diego

Public Defender Investigator II

$ 69,742

$ 85,675



$ 85,675

6/18/2021

unknown

unknown

11

County of Fresno

Defense Investigator II

$60,190

$ 76,986

4.7%

$ 80,604

11/2/2020

unknown

unknown

12

County of Kern

Public Defender's Investigator II

$ 62,244

$ 75,984

1.2%

$ 76,896

4/21/2021

unknown

unknown

13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 113,152

$ 101,516

% County of San Diego Above/Below

-32.1%

-18.5%

Number of Matches

11

11

N/C - Non Comparator

Page 273 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public De

Fender Investigator III





















1

County of Alameda

Senior Investigator, Public Defender's Office

$ 147,410

$ 178,838

-11.4%

$ 158,451

12/27/2020

12/26/2021

3.00%

2

County of Santa Clara

Supervising Public Defender Investigator

$ 137,725

$ 167,421

-16.8%

$ 139,294

6/28/2021

6/27/2022

3.00%

3

County of Los Angeles

Investigator III, Public Defender

$ 102,475

$ 138,099

-3.8%

$ 132,852

1/1/2021

unknown

unknown

4

County of Ventura

Supervising Public Defender Investigator

$ 98,358

$ 122,960

-0.7%

$ 122,099

12/27/2020

12/26/2021

2.00%

5

County of Orange

Defense Investigator III

$ 91,374

$ 122,741

-2.0%

$ 120,286

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Supervising Public Defender Investigator

$ 72,204

$ 115,866

1.9%

$ 118,067

5/1/2021

5/1/2022

2.00%

7

City and County of San Francisco

Senior Public Defenders Investigator

$ 104,100

$ 126,564

-17.4%

$ 104,542

7/1/2021

1/8/2022

.50%

8

County of San Bernardino

Supervising Public Defender Investigator

$ 74,526

$ 102,502

1.9%

$ 104,450

7/31/2021

7/30/2022

3.00%

9

County of Fresno

Senior Defense Investigator

$ 74,386

$ 95,134

4.7%

$ 99,605

11/2/2020

unknown

unknown





















11

County of Contra Costa

N/C















12

County of Kern

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 122,960

$ 120,286

% County of San Diego Above/Below

-30.0%

-27.2%

Number of Matches

9

9

N/C - Non Comparator

Page 274 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Public Defender Investigator Tr

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Public Defender Investigator 1

$ 78,187

$ 97,510

-11.4%

$ 86,394

12/27/2020

12/26/2021

3.00%

2

County of Orange

Defense Investigator Trainee

$ 57,762

$ 77,605

-2.0%

$ 76,053

7/2/2021

7/1/2022

3.50%

3

County of Sacramento

Investigative Assistant

$ 55,687

$ 67,672

0.1%

$ 67,740

6/21/2021

unknown

unknown

4

County of San Diego

Public Defender Investigator Tr

$ 56,701

$ 62,504



$ 62,504

6/18/2021

unknown

unknown

5

County of Ventura

Investigative Assistant II

$ 38,366

$ 53,899

-0.7%

$ 53,521

12/26/2020

12/27/2021

2.00%

6

County of Kern

Public Defender's Investigative Aid

$ 37,236

$ 45,456

1.2%

$ 46,001

4/21/2021

unknown

unknown

7

County of Contra Costa

Public Defender Investigator Assistant

$ 42,075

$ 51,142

-11.1%

$ 45,465

7/1/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,785

$ 60,631

% County of San Diego Above/Below

2.7%

3.0%

Number of Matches

6

6

N/C - Non Comparator

Page 275 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Public Health Microbiologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Public Health Microbiologist

$ 106,332

$ 149,754

-16.8%

$ 124,595

10/21/2020

10/20/2021

3.00%

2

City and County of San Francisco

Microbiologist 1

$ 86,892

$ 122,330

-17.4%

$ 101,045

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Public Health Microbiologist 1

$ 82,080

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown

4

County of San Mateo

Public Health Microbiologist II

$ 94,763

$ 118,433

-17.5%

$ 97,707

10/4/2020

unknown

unknown

5

County of Kern

Microbiologist

$ 75,600

$ 92,292

1.2%

$ 93,400

4/21/2021

unknown

unknown

6

County of Riverside

Public Health Microbiologist II

$ 61,658

$ 91,310

1.9%

$ 93,045

5/1/2021

5/1/2022

2.00%

7

County of Ventura

Microbiologist II

$ 64,066

$ 89,949

-0.7%

$ 89,319

12/27/2020

12/26/2021

2.00%

8

County of Contra Costa

Public Health Microbiologist

$ 80,961

$ 98,409

-11.1%

$ 87,486

7/1/2021

unknown

unknown

9

County of Fresno

Public Health Microbiologist

$ 67,834

$ 82,446

4.7%

$ 86,321

10/17/2019

unknown

unknown

10

County of San Diego

Public Health Microbiologist

$ 69,784

$ 85,717



$ 85,717

6/18/2021

unknown

unknown

11

County of Orange

Public Health Microbiologist 1

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

12

County of San Bernardino

Public Health Microbiologist II

$ 57,554

$ 83,096

1.9%

$ 84,675

3/13/2021

3/26/2022

3.00%

13

County of Sacramento

Public Health Microbiologist

$ 68,173

$ 82,852

0.1%

$ 82,935

6/21/2020

unknown

unknown

14

County of Alameda

Microbiologist

$ 78,824

$ 93,561

-11.4%

$ 82,895

6/27/2021

6/26/2022

3.25%

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,292

$ 89,319

% County of San Diego Above/Below

-7.7%

-4.2%

Number of Matches

13

13

N/C - Non Comparator

Page 276 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Public Health Nurse	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Public Health Nurse

$ 141,516

$ 185,844

-17.4%

$ 153,507

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Public Health Nurse

$ 131,018

$ 163,623

-11.1%

$ 145,461

1/1/2021

unknown

unknown

3

County of Los Angeles

Public Health Nurse

$ 90,609

$ 135,631

-3.8%

$ 130,477

1/1/2021

unknown

unknown

4

County of Santa Clara

Public Health Nurse II

$ 128,509

$ 155,780

-16.8%

$ 129,609

6/14/2021

6/13/2022

3.00%

5

County of San Mateo1

Public Health Nurse

$ 126,441

$ 149,445

-17.5%

$ 123,292

2/7/2021

unknown

unknown

6

County of Alameda

Registered Nurse II (PHN Designation)

$ 109,764

$ 135,449

-11.4%

$ 120,008

6/27/2021

6/26/2022

3.25%

7

County of Fresno

Public Health Nurse II

$ 82,212

$ 99,918

4.7%

$ 104,614

11/2/2020

unknown

unknown

8

County of Sacramento

Public Health Nurse II

$ 85,817

$ 104,337

0.1%

$ 104,441

8/2/2020

unknown

unknown

9

County of San Bernardino

Public Health Nurse II

$ 75,858

$ 101,982

1.9%

$ 103,920

8/15/2020

unknown

unknown

10

County of Orange

Public Health Nurse II

$ 91,541

$ 104,749

-2.0%

$ 102,654

7/2/2021

7/1/2022

3.50%

11

County of Ventura

Registered Nurse - Public Health

$ 83,822

$ 103,076

-0.7%

$ 102,354

4/4/2021

4/17/2022

3.25%

12

County of Kern

Public Health Nurse II

$ 78,684

$ 96,060

1.2%

$ 97,213

4/21/2021

unknown

unknown

13

County of Riverside

Registered Nurse II

$ 76,023

$ 93,416

1.9%

$ 95,190

5/1/2021

5/1/2022

2.00%

14

County of San Diego

Public Health Nurse

$ 77,022

$ 94,682



$ 94,682

6/18/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 104,749

$ 104,614

% County of San Diego Above/Below

-10.6%

-10.5%

Number of Matches

13

13

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 277 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Health Nurse Supervisor





















1

County of Contra Costa2

[Public Health Nurse/Public Health Nurse Program Manager]

$ 136,181

$ 167,717

-11.1%

$ 149,100

7/1/2021

unknown

unknown

2

County of Los Angeles

Public Health Nursing Supervisor

$ 101,982

$ 152,654

-3.8%

$ 146,853

1/1/2021

unknown

unknown

3

County of Santa Clara

Supervising Public Health Nurse

$ 131,188

$ 159,469

-16.8%

$ 132,679

6/28/2021

6/27/2022

3.00%

4

County of San Mateo

Senior Public Health Nurse

$ 126,482

$ 158,098

-17.5%

$ 130,431

2/7/2021

unknown

unknown

5

County of Alameda1

[Registered Nurse III/ Registered Nurse IV (PHN Designation]

$ 121,191

$ 146,744

-11.4%

$ 130,015

12/27/2020

12/26/2021

3.00%

6

County of Riverside

Assistant Nurse Manager

$ 75,379

$ 127,512

1.9%

$ 129,935

5/1/2021

5/1/2022

2.00%

7

County of Fresno

Supervising Public Health Nurse

$ 94,822

$ 121,290

4.7%

$ 126,991

11/2/2020

unknown

unknown

8

County of Sacramento

Supervising Public Health Nurse

$ 103,377

$ 125,677

0.1%

$ 125,803

6/21/2020

unknown

unknown

9

County of Ventura

Supervising Public Health Nurse

$ 85,512

$ 119,729

-0.7%

$ 118,891

unknown

unknown

unknown

10

County of Orange

Supervising Public Health Nurse 1

$ 86,840

$ 116,584

-2.0%

$ 114,252

7/2/2021

7/1/2022

3.50%

11

County of San Bernardino

Supervising Public Health Nurse

$ 79,706

$ 109,720

1.9%

$ 111,805

7/31/2021

7/30/2022

3.00%





















13

County of Kern

Supervising Public Health Nurse

$ 86,940

$ 106,128

1.2%

$ 107,402

4/21/2021

unknown

unknown

14

City and County of San Francisco

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 126,595

$ 128,463

% County of San Diego Above/Below

-13.4%

-15.0%

Number of Matches

12

12

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 278 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Public Health Nutrition Manager





















1

County of Ventura

Supervisor - Public Health Services

$ 87,467

$ 122,466

-0.7%

$ 121,609

unknown

unknown

unknown

2

County of Santa Clara

Nutrition Services Manager

$ 114,955

$ 139,732

-16.8%

$ 116,257

6/28/2021

6/27/2022

3.00%

3

County of Alameda

Health Care Program Administrator II

$ 95,285

$ 127,088

-11.4%

$ 112,600

12/27/2020

unknown

unknown

4

County of Sacramento

Nutrition Program Coordinator

$ 79,929

$ 97,155

0.1%

$ 97,252

6/21/2020

unknown

unknown

5

County of San Mateo

Supervising Public Health Nutritionist

$ 88,523

$ 110,695

-17.5%

$ 91,324

10/4/2020

unknown

unknown

6

County of Riverside

Supervising Nutritionist 1

$ 58,795

$ 87,060

1.9%

$ 88,714

5/1/2021

5/1/2022

2.00%





















8

County of Contra Costa

Senior Public Health Nutritionist

$ 73,674

$ 89,552

-11.1%

$ 79,611

7/1/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of Orange

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 110,695

$ 97,252

% County of San Diego Above/Below

-29.2%

-13.5%

Number of Matches

7

7

N/C - Non Comparator

Page 279 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Purchasing Clerk

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Procurement Buyer Trainee

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

2

County of Santa Clara

Buyer Assistant

$ 55,517

$ 67,009

-16.8%

$ 55,752

6/14/2021

6/13/2022

3.00%

3

City and County of San Francisco

Clerk

$ 55,488

$ 67,416

-17.4%

$ 55,686

7/1/2021

1/8/2022

.50%

4

County of San Diego

Purchasing Clerk

$ 41,226

$ 50,669



$ 50,669

6/18/2021

unknown

unknown

5

County of Ventura

Purchasing Technician

$ 36,119

$ 50,566

-0.7%

$ 50,212

12/26/2020

12/27/2021

2.00%

6

County of Fresno

Purchasing Technician 1

$ 38,714

$ 47,034

4.7%

$ 49,245

4/19/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,738

$ 55,686

% County of San Diego Above/Below

-17.9%

-9.9%

Number of Matches

5

5

N/C - Non Comparator

Page 280 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Quality Assurance Specialist (Registered Nurse)





















1

County of Santa Clara

Quality Improvement Coordinator - SCVMC

$ 153,762

$ 196,298

-16.8%

$ 163,320

6/28/2021

6/27/2022

3.00%

2

County of San Mateo1

Clinical Nurse

$ 135,905

$ 160,635

-17.5%

$ 132,524

2/7/2021

unknown

unknown

3

County of San Bernardino

Quality Management Nurse

$ 75,858

$ 101,982

1.9%

$ 103,920

8/15/2020

unknown

unknown





















5

County of Kern

Quality Management Analyst

$ 78,684

$ 96,060

1.2%

$ 97,213

4/21/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 131,309

$ 118,222

% County of San Diego Above/Below

-27.8%

-15.1%

Number of Matches

4

4

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 281 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Radio Communications System Engineer





















1

County of Riverside

Radio Communications Engineer II

$ 106,074

$ 165,782

1.9%

$ 168,932

5/1/2021

5/1/2022

2.00%

2

County of Los Angeles

Telecommunications Systems Engineer

$ 117,357

$ 127,317

-3.8%

$ 122,479

1/1/2021

unknown

unknown

3

County of Santa Clara

Telecommunications Engineer

$ 119,529

$ 145,298

-16.8%

$ 120,888

6/28/2021

6/27/2022

3.00%





















5

County of San Mateo

Systems Engineer

$ 106,452

$ 133,055

-17.5%

$ 109,770

10/4/2020

unknown

unknown

6

County of Fresno

Senior Network Systems Engineer

$ 79,612

$ 96,772

4.7%

$ 101,320

9/21/2020

unknown

unknown

7

County of Sacramento

Radio Communications Systems Technician

$ 80,346

$ 97,656

0.1%

$ 97,754

6/21/2020

unknown

unknown

8

County of Orange

Telecommunications Engineer II

$ 73,528

$ 99,050

-2.0%

$ 97,069

7/2/2021

7/1/2022

3.50%

9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Kern

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 127,317

$ 109,770

% County of San Diego Above/Below

-15.4%

0.5%

Number of Matches

7

7

N/C - Non Comparator

Page 282 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Radiologic Technologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Radiologic Technologist II

$ 104,100

$ 153,864

-17.4%

$ 127,092

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Diagnostic Imaging Technologist 1

$ 105,533

$ 127,727

-16.8%

$ 106,268

6/14/2021

6/13/2022

3.00%

3

County of Contra Costa

Senior RadiologicTechnologist

$ 90,792

$ 110,358

-11.1%

$98,109

7/1/2021

unknown

unknown

4

County of San Mateo

Radiologic Technologist 1

$ 88,440

$ 110,550

-17.5%

$ 91,204

10/4/2020

unknown

unknown

5

County of Los Angeles

Radiologic Technologist

$ 70,454

$ 89,930

-3.8%

$ 86,513

1/1/2021

unknown

unknown

6

County of Riverside

RadiologicTechnologist II

$ 55,771

$ 82,601

1.9%

$84,170

5/1/2021

5/1/2022

2.00%

7

County of Orange

Radiologic Technologist

$ 62,712

$ 84,469

-2.0%

$ 82,779

7/2/2021

7/1/2022

3.50%

8

County of San Bernardino

RadiologicTechnologist II

$ 58,074

$ 79,789

1.9%

$ 81,305

7/31/2021

7/30/2022

3.00%

9

County of Ventura

Radiologic Technologist

$ 50,293

$ 75,056

-0.7%

$ 74,530

12/26/2020

12/27/2021

2.00%

10

County of Sacramento

Radiologic Technologist

$55,186

$ 67,087

0.1%

$67,154

6/21/2020

unknown

unknown

11

County of Kern

RadiologicTechnologist II

$ 49,728

$ 60,828

1.2%

$ 61,558

4/21/2021

unknown

unknown





Radiologic Technologist

$ 44,741

$ 55,078



$ 55,078

6/18/2021

unknown

unknown

13

County of Alameda

N/C















14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 84,469

$84,170

% County of San Diego Above/Below

-53.4%

-52.8%

Number of Matches

11

11

N/C - Non Comparator

Page 283 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Radiologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Physician Specialist

$ 212,576

$ 293,826

-17.4%

$ 242,700

7/1/2021

1/8/2022

.50%

2

County of Riverside

Physician IV

$ 190,995

$ 228,680

1.9%

$ 233,024

5/1/2021

5/1/2022

2.00%

3

County of San Diego

Radiologist

$ 138,965

$ 170,851



$ 170,851

6/18/2021

unknown

unknown

4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 261,253

$ 237,862

% County of San Diego Above/Below

-52.9%

-39.2%

Number of Matches

2

2

N/C - Non Comparator

Page 284 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Recordable Documents Specialist I





















1

County of Alameda

Clerk-Recorder's Specialist III

$ 60,039

$ 71,052

-11.4%

$ 62,952

6/27/2021

6/26/2022

3.25%





















3

County of Riverside

Assessor-Clerk-Recorder Technician 1

$ 33,641

$ 52,569

1.9%

$ 53,568

5/1/2021

5/1/2022

2.00%

4

County of Orange

Recordable Documents Examiner Trainee

$ 38,688

$ 52,166

-2.0%

$ 51,123

7/2/2021

7/1/2022

3.50%

5

County of San Mateo

Assessor / RecorderTechnician 1

$ 48,297

$ 60,381

-17.5%

$ 49,815

10/4/2020

unknown

unknown

6

County of Santa Clara

Clerk-Recorder Office Specialist 1

$ 48,695

$ 58,612

-16.8%

$ 48,765

6/14/2021

6/13/2022

3.00%

7

County of San Bernardino

Legal Document Classifier 1

$ 33,779

$ 46,363

1.9%

$ 47,244

7/31/2021

7/30/2022

3.00%

8

County of Sacramento

Office Specialist 1

$ 38,190

$ 46,416

0.1%

$ 46,462

6/21/2020

unknown

unknown

9

County of Ventura

Records Technician 1

$ 31,271

$ 43,689

-0.7%

$ 43,383

12/27/2020

12/26/2021

2.00%

10

County of Kern

Legal Process Technician 1

$ 30,348

$ 37,056

1.2%

$ 37,501

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Contra Costa

N/C















13

County of Fresno

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 52,166

$ 48,765

% County of San Diego Above/Below

7.5%

13.6%

Number of Matches

9

9

N/C - Non Comparator

Page 285 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Recordable Documents Specialist II





















1

City and County of San Francisco

Assessor-Recorder Office Specialist

$ 66,144

$ 80,392

-17.4%

$ 66,404

7/1/2021

1/8/2022

.50%





















3

County of Contra Costa

Recordable Documents Technician

$ 56,169

$ 68,273

-11.1%

$ 60,695

7/1/2021

unknown

unknown

4

County of Riverside

Assessor-Clerk-Recorder Technician II

$ 37,788

$ 59,021

1.9%

$ 60,142

5/1/2021

5/1/2022

2.00%

5

County of Orange

Recordable Documents Examiner

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

6

County of Alameda1

[Clerk-Recorder's Specialist 1/ Clerk-Recorder's Specialist II]

$ 51,675

$ 59,690

-11.4%

$ 52,885

6/27/2021

6/26/2022

3.25%

7

County of Santa Clara

Clerk-Recorder Office Specialist II

$ 52,466

$ 63,240

-16.8%

$ 52,616

6/14/2021

6/13/2022

3.00%

8

County of San Mateo

Assessor / Recorder Technician II

$ 50,876

$ 63,605

-17.5%

$ 52,474

10/4/2020

unknown

unknown

9

County of Sacramento

Office Specialist II

$ 42,908

$ 52,158

0.1%

$ 52,210

6/21/2020

unknown

unknown

10

County of San Bernardino

Legal Document Classifier II

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

11

County of Ventura

Records Technician II

$ 35,249

$ 49,293

-0.7%

$ 48,948

12/27/2020

12/26/2021

2.00%

12

County of Fresno

Property Recording Clerk

$ 33,852

$ 43,290

4.7%

$ 45,325

11/2/2020

unknown

unknown

13

County of Kern

Legal Process Technician II

$ 33,528

$ 40,932

1.2%

$ 41,423

4/21/2021

unknown

unknown

14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,355

$ 52,545

% County of San Diego Above/Below

8.5%

19.0%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 286 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Recordable Documents Specialist III





















1

County of Santa Clara

Clerk-Recorder Supervisor

$85,756

$ 104,247

-16.8%

$86,734

6/28/2021

6/27/2022

3.00%

2

City and County of San Francisco

Assessor-Recorder Senior Office Specialist

$ 73,060

$93,210

-17.4%

$ 76,991

7/1/2021

1/8/2022

.50%





















4

County of Alameda

Clerk-Recorder's Supervisor 1

$ 67,475

$81,910

-11.4%

$ 72,573

12/27/2020

12/26/2021

3.00%

5

County of San Mateo

Assessor / Recorder Support Services Supervisor

$ 69,263

$86,568

-17.5%

$ 71,419

10/4/2020

unknown

unknown

6

County of Riverside

Supervising Assessor-Clerk-Recorder Technician

$43,293

$ 69,366

1.9%

$ 70,683

5/1/2021

5/1/2022

2.00%

7

County of Ventura

Clerk and Recorder Program Supervisor II

$49,106

$ 67,926

-0.7%

$ 67,450

unknown

unknown

unknown

8

County of Orange

Supervising Recordable Documents Examiner

$ 50,794

$ 68,432

-2.0%

$ 67,063

7/2/2021

7/1/2022

3.50%

9

County of San Bernardino1

[Records Technician Supervisor 1/ Records Technician Supervisor II]

$47,382

$ 65,094

1.9%

$ 66,330

7/31/2021

7/30/2022

3.00%

10

County of Sacramento

Clerk/Recorder Supervisor

$ 51,908

$ 63,078

0.1%

$ 63,141

6/21/2020

unknown

unknown

11

County of Kern

Supervising Legal Process Technician

$ 42,600

$ 52,008

1.2%

$ 52,632

4/21/2021

unknown

unknown

12

County of Contra Costa

N/C















13

County of Fresno

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 68,899

$ 69,067

% County of San Diego Above/Below

8.3%

8.0%

Number of Matches

10

10

N/C - Non Comparator

1 - County of San Bernardino: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 287 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Records Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Assessor-Recorder Office Assistant

$ 59,514

$ 72,332

-17.4%

$ 59,746

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Intermediate Clerk

$ 34,788

$ 47,962

-3.8%

$ 46,139

1/1/2021

unknown

unknown

3

County of San Diego

Records Clerk







$ 43,202

6/18/2021

unknown

unknown

4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,147

$ 52,943

% County of San Diego Above/Below

-39.2%

-22.5%

Number of Matches

2

2

N/C - Non Comparator

Page 288 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Records Management Coordinator





















1

County of Riverside

Assistant Medical Records Manager

$ 60,007

$ 90,839

1.9%

$ 92,565

7/1/2021

7/14/2022

2.00%

2

County of Fresno

Medical Records Coordinator

$ 62,478

$ 75,920

4.7%

$ 79,488

4/19/2021

unknown

unknown

3

County of Orange

Sheriff's Records Supervisor

$ 50,918

$ 68,162

-2.0%

$ 66,798

7/2/2021

7/1/2022

3.50%





















5

County of San Bernardino

Records Management Coordinator

$ 35,797

$ 49,296

1.9%

$ 50,233

7/31/2021

7/30/2022

3.00%

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,041

$ 73,143

% County of San Diego Above/Below

-29.8%

-31.8%

Number of Matches

4

4

N/C - Non Comparator

Page 289 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Recreation Program Coordinator |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Recreation Coordinator

$ 64,668

$ 78,648

-17.4%

$ 64,963

7/1/2021

1/8/2022

.50%

2

County of San Diego

Recreation Program Coordinator

$ 46,197

$ 56,742



$ 56,742

6/18/2021

unknown

unknown

3

County of Riverside

Recreation Coordinator

$ 34,925

$ 54,530

1.9%

$ 55,566

5/1/2021

5/1/2022

2.00%

4

County of San Bernardino

Recreation Coordinator

$ 36,754

$ 50,482

1.9%

$ 51,441

7/31/2021

7/30/2022

3.00%

5

County of Kern

Elder Life Activity Coordinator

$ 37,992

$ 46,368

1.2%

$ 46,924

4/21/2021

unknown

unknown

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 52,506

$ 53,503

% County of San Diego Above/Below

7.5%

5.7%

Number of Matches

4

4

N/C - Non Comparator

Page 290 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Recreation Therapy Aide

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Therapy Technician

$ 57,712

$ 69,630

-16.8%

$ 57,932

6/14/2021

6/13/2022

3.00%

2

County of San Mateo

Therapy Aide

$ 54,266

$ 67,827

-17.5%

$ 55,958

10/4/2020

unknown

unknown

3

County of Los Angeles

Recreation Therapy Aide

$ 38,995

$ 52,405

-3.8%

$ 50,414

1/1/2021

unknown

unknown

4

County of San Diego

Recreation Therapy Aide

$ 36,462

$ 44,803



$ 44,803

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,827

$ 55,958

% County of San Diego Above/Below

-51.4%

-24.9%

Number of Matches

3

3

N/C - Non Comparator

Page 291 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Recreation Therapy Supervisor





















1

County of Los Angeles

Recreation Therapy Supervisor

$ 74,750

$ 100,726

-3.8%

$ 96,898

1/1/2021

unknown

unknown

2

County of Santa Clara

Recreation Therapist III

$ 93,902

$ 113,687

-16.8%

$ 94,587

6/14/2021

6/13/2022

3.00%

3

County of San Mateo

Supervising Creative Arts Therapist

$ 87,275

$ 109,094

-17.5%

$ 90,002

10/4/2020

unknown

unknown





















5

County of Sacramento

Recreation Supervisor - Therapeutic

$ 59,237

$ 71,994

0.1%

$ 72,066

6/21/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 104,910

$ 92,295

% County of San Diego Above/Below

-26.7%

-11.5%

Number of Matches

4

4

N/C - Non Comparator

Page 292 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Recreational Therapist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Recreation Therapist II

$ 69,931

$ 94,243

-3.8%

$ 90,661

1/1/2021

unknown

unknown

2

County of Santa Clara

Recreation Therapist II

$ 83,364

$ 100,859

-16.8%

$ 83,915

6/14/2021

6/13/2022

3.00%

3

County of Sacramento

Activities Therapist

$ 69,927

$ 80,952

0.1%

$ 81,033

6/21/2020

unknown

unknown

4

County of San Mateo

Creative Arts Therapist

$ 72,653

$ 90,853

-17.5%

$ 74,953

10/4/2020

unknown

unknown

5

County of Riverside

Recreation Therapist

$ 46,956

$ 69,457

1.9%

$ 70,777

5/1/2021

5/1/2022

2.00%

6

County of San Diego

Recreational Therapist

$ 56,014

$ 68,786



$ 68,786

6/18/2021

unknown

unknown

7

County of Contra Costa

Recreation Therapist

$ 58,961

$ 71,667

-11.1%

$ 63,712

7/1/2021

unknown

unknown

8

County of Kern

Recreational Therapist

$39,732

$ 48,504

1.2%

$ 49,086

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Fresno

N/C















12

County of Orange

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 80,952

$ 74,953

% County of San Diego Above/Below

-17.7%

-9.0%

Number of Matches

7

7

N/C - Non Comparator

Page 293 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Recycling Specialist I |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Resource Conservation Specialist 1

$ 76,418

$ 95,574

-17.5%

$ 78,849

10/4/2020

unknown

unknown

2

County of San Diego

Recycling Specialist 1

$ 54,517

$ 67,018



$ 67,018

6/18/2021

unknown

unknown

3

County of Riverside

Recycling Specialist 1

$ 42,796

$ 63,050

1.9%

$ 64,248

5/1/2021

5/1/2022

2.00%

4

County of Contra Costa

Resource Recovery Assistant

$ 47,373

$ 57,582

-11.1%

$ 51,191

7/1/2021

unknown

Unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,050

$ 64,248

% County of San Diego Above/Below

5.9%

4.1%

Number of Matches

3

3

N/C - Non Comparator

Page 294 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Recycling Specialist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Resource Conservation Specialist II

$84,134

$ 105,142

-17.5%

$ 86,742

10/4/2020

unknown

unknown

2

County of Alameda

Sustainability Specialist

$ 66,290

$ 91,624

-11.4%

$ 81,179

12/27/2020

unknown

unknown

3

County of San Diego

Recycling Specialist II

$ 64,709

$ 79,560



$ 79,560

6/18/2021

unknown

unknown

4

County of San Bernardino

Recycling Specialist

$ 55,619

$ 76,461

1.9%

$ 77,914

7/31/2021

7/30/2022

3.00%

5

County of Riverside

Recycling Specialist II

$ 47,459

$ 69,901

1.9%

$71,229

5/1/2021

5/1/2022

2.00%

6

County of Contra Costa

Resource Recovery Specialist

$ 57,576

$ 69,984

-11.1%

$ 62,216

7/1/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,461

$ 77,914

% County of San Diego Above/Below

3.9%

2.1%

Number of Matches

5

5

N/C - Non Comparator

Page 295 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Registered Veterinary Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Registered Veterinary Technician

$ 53,622

$ 72,280

-2.0%

$ 70,834

7/2/2021

7/1/2022

3.50%

2

County of Los Angeles

Registered Veterinary Technician

$ 53,850

$ 72,571

-3.8%

$ 69,813

1/1/2021

unknown

unknown

3

County of Ventura

Veterinary Technician - Registered

$ 49,846

$ 69,982

-0.7%

$ 69,492

12/26/2020

12/27/2021

2.00%

4

County of Sacramento

Registered Veterinary Technician

$ 55,040

$ 66,900

0.1%

$ 66,967

6/21/2020

unknown

unknown

5

County of Riverside

Registered Veterinary Technician

$ 41,987

$ 65,616

1.9%

$ 66,863

5/1/2021

5/1/2022

2.00%

6

County of Contra Costa

Registered Veterinary Technician

$ 49,083

$ 69,065

-11.1%

$ 61,399

7/1/2021

unknown

unknown

7

County of San Bernardino

Registered Veterinary Technician

$ 41,246

$ 56,722

1.9%

$ 57,799

7/31/2021

7/30/2022

3.00%

8

County of San Diego

Registered Veterinary Technician

$ 46,717

$ 57,387



$ 57,387

6/18/2021

unknown

unknown

9

County of Santa Clara

Registered Veterinary Technician

$ 55,763

$ 67,781

-16.8%

$ 56,394

6/14/2021

6/13/2022

3.00%

10

County of Kern

Registered Veterinary Technician

$ 36,324

$ 44,340

1.2%

$ 44,872

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Fresno

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,781

$ 66,863

% County of San Diego Above/Below

-18.1%

-16.5%

Number of Matches

9

9

N/C - Non Comparator

Page 296 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Residential Care Worker I





















1

County of Santa Clara

Associate Children's Counselor

$ 56,913

$ 68,711

-16.8%

$ 57,167

6/14/2021

6/13/2022

3.00%





















3

County of Kern

Group Counselor l/Dept Human Services

$ 35,076

$ 42,816

1.2%

$ 43,330

4/21/2021

unknown

unknown

4

County of Ventura

Family Services Residential Worker 1

$ 29,140

$ 33,868

-0.7%

$ 33,631

12/26/2020

12/27/2021

2.00%

5

County of Fresno

Behavioral Health Worker 1

$ 29,120

$ 31,928

4.7%

$ 33,429

11/2/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 38,342

$ 38,480

% County of San Diego Above/Below

12.6%

12.3%

Number of Matches

4

4

N/C - Non Comparator

Page 297 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Residential Care Worker II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Children's Counselor

$ 64,977

$ 78,501

-16.8%

$ 65,313

6/14/2021

6/13/2022

3.00%

2

County of Kern

Group Counselor ll/Dept Human Services

$ 38,748

$ 47,304

1.2%

$ 47,872

4/21/2021

unknown

unknown

3

County of San Diego

Residential Care Worker II

$ 38,397

$ 47,258



$ 47,258

6/18/2021

unknown

unknown

4

County of Ventura

Family Services Residential Worker II

$ 29,813

$ 41,950

-0.7%

$ 41,656

12/26/2020

12/27/2021

2.00%

5

County of Fresno

Behavioral Health Worker II

$ 29,770

$ 35,802

4.7%

$ 37,485

11/2/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 44,627

$ 44,764

% County of San Diego Above/Below

5.6%

5.3%

Number of Matches

4

4

N/C - Non Comparator

Page 298 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Residential Care Worker Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Residential Care Worker Supervisor

$ 45,947

$ 56,555

$ 56,555

6/18/2021

unknown

unknown

2

County of Kern

Group Counselor lll/Dept Human Services

$ 43,464

$ 53,064

1.2%

$ 53,701

4/21/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,064

$ 53,701

% County of San Diego Above/Below

6.2%

5.0%

Number of Matches

1

1

N/C - Non Comparator

Page 299 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Residential Care Worker Trainee	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Residential Care Worker Trainee

$ 32,427

$ 39,790

$ 39,790

6/18/2021

unknown

unknown

2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

1

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 300 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Residential Childcare Specialist |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Senior Children's Counselor

$ 71,230

$ 86,091

-16.8%

$ 71,628

6/14/2021

6/13/2022

3.00%

2

County of San Diego

Residential Childcare Specialist

$ 41,579

$ 51,106



$ 51,106

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,091

$ 71,628

% County of San Diego Above/Below

-68.5%

-40.2%

Number of Matches

1

1

N/C - Non Comparator

Page 301 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Revenue & Recovery Officer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Collections Officer

$ 71,474

$ 86,892

-17.4%

$ 71,773

7/1/2021

1/8/2022

.50%

2

County of Alameda

Collection Enforcement Deputy II

$ 63,083

$ 76,733

-11.4%

$ 67,985

6/27/2021

6/26/2022

3.25%

3

County of San Mateo

Revenue Collector II

$ 65,768

$82,179

-17.5%

$ 67,798

10/4/2020

unknown

unknown

4

County of Santa Clara

Revenue Collections Officer

$ 65,859

$ 79,535

-16.8%

$ 66,173

6/14/2021

6/13/2022

3.00%

5

County of Contra Costa

Collection Enforcement Officer II

$59,125

$ 71,867

-11.1%

$ 63,890

7/1/2021

unknown

unknown

6

County of San Diego

Revenue & Recovery Officer

$ 46,446

$ 62,878



$ 62,878

6/18/2021

unknown

unknown

7

County of San Bernardino

Collections Officer 1

$ 43,597

$ 59,925

1.9%

$ 61,063

7/31/2021

7/30/2022

3.00%

8

County of Orange

Collections Officer 1

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

9

County of Los Angeles

Delinquent Accounts Investigator

$44,138

$ 59,428

-3.8%

$ 57,170

1/1/2021

unknown

unknown

10

County of Sacramento

Collection Services Agent II

$ 46,354

$ 56,355

0.1%

$ 56,411

6/21/2020

unknown

unknown

11

County of Ventura

Collections Officer II

$ 36,684

$ 51,334

-0.7%

$ 50,975

12/27/2020

12/26/2021

2.00%

12

County of Fresno

Collections Representative II

$ 34,320

$ 43,914

4.7%

$ 45,978

11/2/2020

unknown

unknown

13

County of Kern

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,925

$ 61,063

% County of San Diego Above/Below

4.7%

2.9%

Number of Matches

11

11

N/C - Non Comparator

Page 302 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Revenue & Recovery Officer Trainee





















1

County of Alameda

Collection Enforcement Deputy 1

$ 56,024

$ 66,339

-11.4%

$ 58,776

6/27/2021

6/26/2022

3.25%

2

County of San Mateo

Revenue Collector 1

$ 53,164

$ 66,476

-17.5%

$ 54,842

10/4/2020

unknown

unknown

3

County of Sacramento

Collection Services Agent 1

$ 43,639

$ 53,035

0.1%

$ 53,088

6/21/2020

unknown

unknown

4

County of Orange

Collection Officer Trainee

$ 39,790

$ 53,622

-2.0%

$ 52,550

7/2/2021

7/1/2022

3.50%

5

County of Contra Costa

Collection Enforcement Officer 1

$ 45,076

$ 54,791

-11.1%

$ 48,709

7/1/2021

unknown

unknown

6

County of San Bernardino

Collections Officer Trainee

$ 34,133

$ 45,802

1.9%

$ 46,672

7/31/2021

7/30/2022

3.00%





















8

County of Ventura

Collections Officer 1

$ 32,674

$ 45,657

-0.7%

$ 45,337

12/27/2020

12/26/2021

2.00%

9

County of Fresno

Collections Representative 1

$ 30,290

$ 38,740

4.7%

$ 40,561

11/2/2020

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of Riverside

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,329

$ 50,629

% County of San Diego Above/Below

-16.5%

-10.6%

Number of Matches

8

8

N/C - Non Comparator

Page 303 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Road Crew Supervisor





















1

City and County of San Francisco

Street Repair Supervisor II

$ 103,896

$ 126,308

-17.4%

$ 104,330

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Road Maintenance Supervisor

$ 79,496

$ 101,469

-3.8%

$ 97,613

1/1/2021

unknown

unknown

3

County of San Mateo

Road Construction Supervisor

$ 93,681

$ 117,102

-17.5%

$ 96,609

2/7/2021

2/6/2022

2-4%

4

County of Alameda

Field Maintenance Supervisor

$ 108,950

$ 108,950

-11.4%

$ 96,530

12/27/2020

12/26/2021

3.00%

5

County of Orange

Public Works Maintenance Supervisor

$ 70,325

$ 94,765

-2.0%

$ 92,870

7/2/2021

7/1/2022

3.50%

6

County of Sacramento

Highway Maintenance Supervisor

$ 73,790

$ 89,721

0.1%

$ 89,811

6/21/2020

unknown

unknown

7

County of Santa Clara

Road Maintenance Supervisor

$ 87,759

$ 106,188

-16.8%

$ 88,349

6/14/2021

6/13/2022

3.00%

8

County of Contra Costa

Public Works Maintenance Supervisor

$ 82,078

$ 95,186

-11.1%

$ 84,620

7/1/2021

unknown

Unknown

9

County of Riverside

Assistant District Road Maintenance Supervisor

$ 53,109

$ 82,898

1.9%

$ 84,473

5/1/2021

5/1/2022

2.00%





















11

County of Ventura

Supervisor - Public Works Maintenance

$ 58,163

$ 81,489

-0.7%

$ 80,918

12/26/2020

12/27/2021

2.00%

12

County of San Bernardino

Maintenance and Construction Supervisor II

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%

13

County of Fresno

Road Maintenance Supervisor

$ 58,604

$ 71,214

4.7%

$ 74,561

4/19/2021

unknown

unknown

14

County of Kern

Supervising Road Maintenance Worker 1

$ 43,680

$ 53,328

1.2%

$ 53,968

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 94,765

$ 88,349

% County of San Diego Above/Below

-16.6%

-8.7%

Number of Matches

13

13

N/C - Non Comparator

Page 304 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sanitation Regional Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Wastewater Collection Supervisor

$ 100,483

$ 125,567

-17.5%

$ 103,593

2/7/2021

2/6/2022

2-4%

2

County of Fresno

Supervising Water/Wastewater Specialist

$ 81,042

$ 98,514

4.7%

$ 103,144

4/19/2021

unknown

unknown



County of San Diego

Sanitation Regional Supervisor

$ 74,006

$ 90,979



$ 90,979

6/18/2021

unknown

unknown

4

County of San Bernardino

Maintenance and Construction Supervisor II

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%

5

County of Orange

Supervising Waste Inspector

$ 48,797

$ 65,354

-2.0%

$ 64,046

7/2/2021

7/1/2022

3.50%

6

County of Kern

Sewer Collection Systems Supervisor

$ 45,684

$ 55,776

1.2%

$ 56,445

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 78,416

$ 79,906

% County of San Diego Above/Below

13.8%

12.2%

Number of Matches

5

5

N/C - Non Comparator

Page 305 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Section Chief, Revenue & Recovery





















1

County of Contra Costa1

[Collection Enforcement Supervisor I/Auditor - Controller Division Manager]

$ 100,085

$ 121,654

-11.1%

$ 108,151

7/1/2021

unknown

unknown

2

County of San Bernardino

Chief Collections Supervisor

$ 67,579

$93,122

1.9%

$ 94,891

7/31/2021

7/30/2022

3.00%

3

County of Santa Clara

Supervising Revenue Collections Officer

$93,186

$ 113,314

-16.8%

$ 94,277

6/28/2021

6/27/2022

3.00%

4

County of Alameda

Collection Supervisor II

$ 87,277

$ 106,163

-11.4%

$ 94,061

12/27/2020

12/26/2021

3.00%





















6

County of San Mateo

Revenue Collection Supervisor

$ 84,093

$ 105,080

-17.5%

$86,691

10/4/2020

unknown

unknown

7

City and County of San Francisco

Collection Supervisor

$ 82,810

$ 100,646

-17.4%

$83,134

7/1/2021

1/8/2022

.50%

8

County of Orange

Supervising, Collections Officer

$ 55,078

$ 74,235

-2.0%

$ 72,751

7/2/2021

7/1/2022

3.50%

9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 105,080

$ 94,061

% County of San Diego Above/Below

-17.1%

-4.8%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match:
displayed is an average of the matches.

This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary



Page 306 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Account Clerk





















1

County of San Mateo

Fiscal Office Services Supervisor

$ 69,263

$86,568

-17.5%

$ 71,419

10/4/2020

unknown

unknown

2

County of Contra Costa

Account Clerk Supervisor

$ 61,124

$ 78,057

-11.1%

$ 69,393

7/1/2021

unknown

unknown

3

City and County of San Francisco

Senior Account Clerk

$ 68,952

$83,746

-17.4%

$ 69,174

7/1/2021

1/8/2022

.50%

4

County of Ventura1

[Senior Accounting Assistant/ Supervising Accounting Technician]

$ 47,844

$ 66,982

-0.7%

$ 66,514

12/26/2020

12/27/2021

2.00%

5

County of Riverside

Senior Accounting Assistant

$ 39,852

$ 62,232

1.9%

$ 63,414

5/1/2021

5/1/2022

2.00%

6

County of Fresno

Supervising Account Clerk

$ 44,148

$ 56,472

4.7%

$ 59,126

11/2/2020

unknown

unknown

7

County of Santa Clara

Senior Account Clerk

$ 57,267

$ 69,147

-16.8%

$ 57,531

6/14/2021

6/13/2022

3.00%

8

County of Orange

Senior Accounting Assistant

$42,598

$ 56,867

-2.0%

$ 55,730

7/2/2021

7/1/2022

3.50%

9

County of San Bernardino

Supervising Office Assistant

$ 38,584

$ 53,082

1.9%

$ 54,090

7/31/2021

7/30/2022

3.00%

10

County of Sacramento

Senior Account Clerk

$ 44,433

$ 53,996

0.1%

$ 54,050

6/21/2020

unknown

unknown





















12

County of Kern

Fiscal Support Specialist

$ 39,144

$ 47,784

1.2%

$48,357

4/21/2021

unknown

unknown

13

County of Alameda

N/C















14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,232

$ 59,126

% County of San Diego Above/Below

-24.4%

-18.2%

Number of Matches

11

11

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 307 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Accountant





















1

County of Santa Clara

Senior Accountant

$ 105,776

$ 128,577

-16.8%

$ 106,976

6/28/2021

6/27/2022

3.00%

2

City and County of San Francisco

Accountant III

$ 100,646

$ 122,330

-17.4%

$ 101,045

7/1/2021

1/8/2022

.50%

3

County of Sacramento

Senior Accountant

$ 79,114

$ 96,152

0.1%

$ 96,248

6/21/2020

unknown

unknown

4

County of Orange

Senior Accountant/Auditor

$ 71,698

$ 96,512

-2.0%

$ 94,582

7/2/2021

7/1/2022

3.50%





















6

County of Ventura

Senior Accountant

$ 65,038

$ 91,053

-0.7%

$ 90,416

12/27/2020

12/26/2021

2.00%

7

County of Contra Costa1

[Accountant Ill/Supervising Accountant]

$ 82,600

$ 100,401

-11.1%

$ 89,256

7/1/2021

unknown

unknown

8

County of San Mateo2

[Accountant 1 I/Senior Accountant]

$ 84,519

$ 105,662

-17.5%

$ 87,171

10/4/2020

unknown

unknown

9

County of San Bernardino

Accountant III

$ 61,381

$ 84,365

1.9%

$ 85,968

7/31/2021

7/30/2022

3.00%

10

County of Riverside

Senior Accountant

$ 53,292

$ 78,876

1.9%

$ 80,375

5/1/2021

5/1/2022

2.00%

11

County of Alameda

Senior Accountant

$ 75,171

$ 90,168

-11.4%

$ 79,889

12/27/2020

12/26/2021

3.00%

12

County of Los Angeles

Accountant III

$ 61,218

$ 82,490

-3.8%

$ 79,356

1/1/2021

unknown

unknown

13

County of Fresno

Senior Accountant

$ 62,140

$ 75,556

4.7%

$ 79,107

10/17/2019

unknown

unknown

14

County of Kern

Accountant III

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 91,053

$ 87,171

% County of San Diego Above/Below

0.3%

4.6%

Number of Matches

13

13

N/C - Non Comparator

1	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 308 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Admissions Clerk





















1

County of Riverside

Senior Admissions and Collections Clerk

$ 38,616

$ 60,300

1.9%

$ 61,446

5/1/2021

5/1/2022

2.00%

2

County of San Bernardino

Supervising Office Assistant

$ 38,584

$ 53,082

1.9%

$ 54,090

7/31/2021

7/30/2022

3.00%





















4

County of Fresno

Senior Admitting Interviewer

$ 38,610

$ 49,374

4.7%

$ 51,695

11/2/2020

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 53,082

$ 54,090

% County of San Diego Above/Below

-1.4%

-3.4%

Number of Matches

3

3

N/C - Non Comparator

Page 309 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Adult Protective Services Specialist





















1

County of Alameda1

[Adult Protective Services Worker 11/ Adult Protection Supervisor]

$ 90,904

$ 107,282

-11.4%

$95,052

12/27/2020

12/26/2021

3.00%

2

County of San Bernardino

Lead Social Service Practitioner

$ 63,461

$89,419

1.9%

$91,118

3/13/2021

3/26/2022

3.00%

3

County of Contra Costa

Social Worker III

$83,461

$ 101,448

-11.1%

$90,187

7/1/2021

unknown

unknown

4

County of Ventura

HS Adult Protective Services Social Worker IV

$ 64,539

$86,061

-0.7%

$85,458

12/26/2020

12/27/2021

2.00%





















6

County of Fresno

Social Worker III

$ 50,570

$ 64,714

4.7%

$ 67,756

11/2/2020

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$89,419

$90,187

% County of San Diego Above/Below

-10.8%

-11.8%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

Page 310 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Agricultural/Standards Inspector





















1

County of Santa Clara

Senior Biologist/Standards Inspector

$ 104,549

$ 127,065

-16.8%

$ 105,718

6/14/2021

6/13/2022

3.00%

2

County of Orange

Senior Agricultural/Standards Inspector

$ 67,912

$ 91,541

-2.0%

$ 89,710

7/2/2021

7/1/2022

3.50%

3

County of San Mateo

Biologist/Standards Specialist III

$ 86,922

$ 108,636

-17.5%

$ 89,625

10/4/2020

unknown

unknown





















5

County of Los Angeles

Agricultural/Weights & Measures Inspector II

$ 58,848

$ 79,302

-3.8%

$ 76,288

1/1/2021

unknown

unknown

6

County of Alameda

Agricultural and Standards Investigator II

$ 70,083

$ 84,123

-11.4%

$ 74,533

6/27/2021

6/26/2022

3.25%

7

County of San Bernardino

Agricultural/Standards Officer

$ 50,960

$ 71,739

1.9%

$ 73,102

3/13/2021

3/26/2022

3.00%

8

County of Contra Costa

Agricultural Biologist II

$ 67,648

$ 82,226

-11.1%

$ 73,099

7/1/2021

unknown

unknown

9

County of Ventura

Agricultural Inspector/Biologist

$ 51,552

$ 73,075

-0.7%

$ 72,564

12/27/2020

12/26/2021

2.00%

10

County of Sacramento

Agricultural and Standards Inspector II

$ 61,617

$ 71,347

0.1%

$ 71,418

6/30/2021

unknown

unknown

11

County of Fresno

Agricultural/Standards Specialist II

$ 50,206

$ 61,022

4.7%

$ 63,890

4/19/2021

unknown

unknown

12

County of Riverside

Senior Agricultural Inspector

$ 30,624

$ 47,796

1.9%

$ 48,704

5/1/2021

5/1/2022

2.00%

13

City and County of San Francisco

N/C















14

County of Kern

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,302

$ 73,102

% County of San Diego Above/Below

4.1%

11.6%

Number of Matches

11

11

N/C - Non Comparator

Page 311 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Air Pollution Chemist*





















1

South Coast Air Quality Management District

Principal Air Quality Chemist

$ 97,956

$ 131,616

-2.8%

$ 127,931

1/1/2020

unknown

unknown





















3

Bay Area Air Quality Management District

Senior Air Quality Chemist

$ 101,434

$ 123,294

-17.4%

$ 101,841

11/8/2020

unknown

Unknown

4

Sacramento Metropolitan Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 127,455

$ 114,886

% County of San Diego Above/Below

-12.3%

-1.3%

Number of Matches

2

2

N/C - Non Comparator

Page 312 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Air Pollution Control Engineer*





















1

Sacramento Metropolitan Air Quality Management District

Program Supervisor

$ 101,971

$ 136,655

0.1%

$ 136,792

7/1/2021

unknown

unknown





















3

San Luis Obispo County Air Pollution Control District

Air Pollution Control Engineer III

$93,725

$ 113,922

2.9%

$ 117,225

7/1/2020

unknown

unknown

4

South Coast Air Quality Management District

Senior Air Quality Engineer

$ 89,040

$ 119,664

-2.8%

$ 116,313

1/1/2020

unknown

unknown

5

County of Kern

Air Quality Engineer III

$93,216

$ 113,796

1.2%

$ 115,162

4/21/2021

unknown

unknown

6

Bay Area Air Quality Management District

N/C















7

County of Contra Costa

N/C















8

County of Orange

N/C















9

County of Ventura

N/C















10

Imperial County Air Pollution Control District

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Los Angeles

N/C















15

County of Fresno

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 116,793

$ 116,769

% County of San Diego Above/Below

1.6%

1.6%

Number of Matches

4

4

N/C - Non Comparator

Page 313 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Airport Technician

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Airport Operations Supervisor

$ 117,576

$ 142,896

-17.4%

$ 118,032

7/1/2021

1/8/2022

.50%

2

County of Orange

Airport Maintenance Supervisor

$ 72,280

$ 97,365

-2.0%

$ 95,417

7/2/2021

7/1/2022

3.50%

3

County of Santa Clara

Airport Operations Supervisor

$ 82,913

$ 100,768

-16.8%

$ 83,839

6/28/2021

6/27/2022

3.00%

4

County of San Diego

Senior Airport Technician

$ 64,730

$ 79,518



$ 79,518

6/18/2021

unknown

unknown

5

County of Ventura

Airport Maintenance Supervisor

$ 55,592

$ 77,829

-0.7%

$ 77,284

12/26/2020

12/27/2021

2.00%

6

County of San Bernardino

Airport Maintenance Supervisor

$ 52,666

$ 72,241

1.9%

$ 73,613

7/31/2021

7/30/2022

3.00%

7

County of Kern

Airports Maintenance Supervisor

$ 49,236

$60,108

1.2%

$ 60,829

4/21/2021

unknown

unknown

8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,597

$ 80,561

% County of San Diego Above/Below

-10.2%

-1.3%

Number of Matches

6

6

N/C - Non Comparator

Page 314 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Animal Services Representative





















1

County of Santa Clara

Senior Office Specialist

$ 57,034

$ 68,856

-16.8%

$ 57,288

6/14/2021

6/13/2022

3.00%

2

County of Orange

Senior Animal Care Attendant

$ 42,058

$ 56,701

-2.0%

$ 55,567

7/2/2021

7/1/2022

3.50%





















4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,779

$ 56,428

% County of San Diego Above/Below

-18.7%

-6.7%

Number of Matches

2

2

N/C - Non Comparator

Page 315 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Assessment Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Senior AssessmentTechnician

$ 54,974

$ 73,528

-2.0%

$ 72,057

7/2/2021

7/1/2022

3.50%

2

City and County of San Francisco

Senior Clerk

$ 57,538

$ 81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

3

County of San Bernardino

RecordsTechnician Supervisor 1

$ 45,448

$ 62,525

1.9%

$ 63,713

7/31/2021

7/30/2022

3.00%

4

County of Santa Clara

Senior Assessment Clerk

$ 55,638

$67,157

-16.8%

$ 55,874

6/14/2021

6/13/2022

3.00%

5

County of Sacramento

Senior Office Specialist

$ 45,936

$ 55,812

0.1%

$ 55,868

6/21/2020

unknown

unknown

6

County of San Diego

Senior Assessment Clerk

$ 40,414

$ 49,670



$ 49,670

6/18/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$67,157

$ 63,713

% County of San Diego Above/Below

-35.2%

-28.3%

Number of Matches

5

5

N/C - Non Comparator

Page 316 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Cadastral Technician





















1

County of Riverside

Senior EngineeringTechnician - PLS/PE

$ 60,768

$ 100,188

1.9%

$ 102,092

5/1/2021

5/1/2022

2.00%

2

County of San Mateo

GISTechnician III

$ 89,584

$ 105,828

-17.5%

$ 87,308

10/4/2020

unknown

unknown

3

County of Orange

Senior Cadastral Technician

$ 59,384

$ 79,997

-2.0%

$ 78,397

7/2/2021

7/1/2022

3.50%

4

County of Contra Costa

Lead Computer Aided Drafting Operator

$ 69,288

$ 84,219

-11.1%

$ 74,871

7/1/2021

unknown

unknown





















6

County of Ventura

Cadastral Technician III

$ 51,727

$ 72,423

-0.7%

$ 71,916

12/26/2020

12/27/2021

2.00%

7

County of Alameda

MappingTechnician III

$ 66,495

$ 79,463

-11.4%

$ 70,404

6/27/2021

6/26/2022

3.25%

8

County of Santa Clara

Senior Cadastral MappingTechnician

$ 68,370

$ 82,609

-16.8%

$ 68,731

6/14/2021

6/13/2022

3.00%

9

County of Kern

DraftingTechnician III

$ 53,064

$ 64,776

1.2%

$ 65,553

4/21/2021

unknown

unknown

10

County of San Bernardino

Cadastral DraftingTechnician II

$ 46,592

$ 63,960

1.9%

$ 65,175

7/31/2021

7/30/2022

3.00%

11

County of Fresno

Cadastral Technician III

$ 48,516

$ 62,036

4.7%

$ 64,952

11/2/2020

unknown

unknown

12

City and County of San Francisco

N/C















13

County of Los Angeles

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,730

$ 71,160

% County of San Diego Above/Below

-9.3%

2.4%

Number of Matches

10

10

N/C - Non Comparator

Page 317 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Cashier





















1

City and County of San Francisco

Cashier III

$ 69,264

$ 84,216

-17.4%

$ 69,562

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Senior Cashier

$ 64,935

$ 78,969

-16.8%

$ 65,702

6/28/2021

6/27/2022

3.00%

3

County of Los Angeles

Cashiering Services Representative II, Sheriff

$ 43,190

$ 59,725

-3.8%

$ 57,456

1/1/2021

unknown

unknown





















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 78,969

$ 65,702

% County of San Diego Above/Below

-58.1%

-31.6%

Number of Matches

3

3

N/C - Non Comparator

Page 318 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Civil Engineer	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Ventura

Staff Engineer

$ 105,685

$ 147,959

-0.7%

$ 146,923

unknown

unknown

unknown

2

County of Alameda

Supervising Civil Engineer

$ 135,990

$ 165,381

-11.4%

$ 146,527

6/13/2021

6/12/2022

3.50%

3

County of Orange

Senior Civil Engineer

$ 107,619

$ 145,142

-2.0%

$ 142,240

7/2/2021

7/1/2022

3.50%

4

City and County of San Francisco

Engineer

$ 141,622

$ 172,198

-17.4%

$ 142,236

7/1/2021

1/8/2022

.50%

5

County of Sacramento

Senior Civil Engineer

$ 125,718

$ 138,601

0.1%

$ 138,740

6/21/2020

unknown

unknown

6

County of Los Angeles

Civil Engineer

$ 112,548

$ 143,659

-3.8%

$ 138,200

1/1/2021

unknown

unknown

7

County of Riverside

Senior Civil Engineer

$ 91,080

$ 134,928

1.9%

$ 137,492

5/1/2021

5/1/2022

2.00%

8

County of Santa Clara

Senior Civil Engineer

$ 134,549

$ 163,966

-16.8%

$ 136,420

10/21/2020

10/20/2021

3.00%

9

County of San Bernardino

Supervising Engineer

$ 95,222

$ 131,290

1.9%

$ 133,784

7/31/2021

7/30/2022

3.00%

10

County of San Mateo

Senior Civil Engineer

$ 129,582

$ 161,987

-17.5%

$ 133,640

12/13/2020

unknown

unknown

11

County of San Diego

Senior Civil Engineer

$ 105,435

$ 129,605



$ 129,605

6/18/2021

unknown

unknown

12

County of Fresno

Senior Engineer

$ 90,584

$ 110,110

4.7%

$ 115,285

4/19/2021

unknown

unknown

13

County of Kern

Engineer III

$ 82,704

$ 100,968

1.2%

$ 102,180

4/21/2021

unknown

unknown

14

County of Contra Costa

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 144,401

$ 137,846

% County of San Diego Above/Below

-11.4%

-6.4%

Number of Matches

12

12

N/C - Non Comparator

Page 319 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Clinical Psychologist





















1

County of Santa Clara

Senior Psychologist

$ 146,777

$ 177,877

-16.8%

$ 147,994

6/14/2021

6/13/2022

3.00%

2

County of Ventura

Lead Psychologist

$ 100,598

$ 130,778

-0.7%

$ 129,862

12/27/2020

12/26/2021

2.00%

3

County of Fresno

Senior Licensed Psychologist

$ 90,870

$ 109,304

4.7%

$ 114,441

11/2/2020

unknown

unknown

4

County of San Mateo2

[Psychologist ll/Supervising Psychologist]

$ 109,416

$ 136,768

-17.5%

$ 112,833

10/4/2020

unknown

unknown

5

County of Alameda1

[Clinical Psychologist/ Senior Clinical Psychologist]

$ 105,454

$ 122,195

-11.4%

$ 108,265

12/27/2020

12/26/2021

3.00%

6

County of San Bernardino

Clinical Therapist II - Psychologist

$ 73,445

$ 106,101

1.9%

$ 108,117

3/13/2021

3/26/2022

3.00%

7

County of Orange

Clinical Psychologist II

$ 80,538

$ 108,493

-2.0%

$ 106,323

7/2/2021

7/1/2022

3.50%





















9

County of Riverside

Senior Clinical Psychologist

$ 61,154

$ 90,585

1.9%

$92,306

5/1/2021

5/1/2022

2.00%

10

City and County of San Francisco

N/C















11

County of Contra Costa

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 115,749

$ 110,549

% County of San Diego Above/Below

-10.2%

-5.3%

Number of Matches

8

8

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 320 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Communicable Disease Investigator





















1

County of Santa Clara

Senior Communicable Disease Investigator

$81,128

$ 97,995

-16.8%

$81,532

6/14/2021

6/13/2022

3.00%

2

County of San Mateo

Senior Communicable Diseases Investigator

$ 75,253

$ 94,077

-17.5%

$ 77,613

10/4/2020

unknown

unknown





















4

County of Orange

Senior Public Health Investigator

$ 56,597

$ 76,274

-2.0%

$ 74,748

7/2/2021

7/1/2022

3.50%

5

County of Riverside

Senior Communicable Disease Specialist

$ 45,996

$ 71,772

1.9%

$ 73,136

5/1/2021

5/1/2022

2.00%

6

County of Alameda1

[Public Health Investigator/Senior Public Health Investigator]

$ 63,710

$ 76,844

-11.4%

$ 68,084

12/27/2020

unknown

unknown

7

County of Sacramento

Senior Communicable Disease Investigator

$ 55,436

$ 67,380

0.1%

$ 67,447

6/21/2020

unknown

unknown

8

County of San Bernardino

Communicable Disease Investigator II

$ 47,736

$ 65,603

1.9%

$ 66,850

7/31/2021

7/30/2022

3.00%

9

City and County of San Francisco

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,274

$ 73,136

% County of San Diego Above/Below

-0.8%

3.3%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 321 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Construction Inspector





















1

City and County of San Francisco

Senior Construction Inspector

$ 114,790

$ 139,542

-17.4%

$ 115,262

7/1/2021

1/8/2022

.50%

2

County of Alameda

Supervising Construction Inspector

$ 66,206

$ 128,398

-11.4%

$ 113,761

12/27/2020

unknown

unknown

3

County of Riverside

Senior Construction Inspector

$ 69,888

$ 109,248

1.9%

$ 111,324

5/1/2021

5/1/2022

2.00%

4

County of Los Angeles

Senior Construction Inspector

$ 82,285

$ 105,034

-3.8%

$ 101,043

1/1/2021

unknown

unknown

5

County of Santa Clara

Senior Construction Inspector

$ 99,283

$ 120,675

-16.8%

$ 100,402

6/14/2021

6/13/2022

3.00%

6

County of Contra Costa

EngineeringTechnician Supervisor- Construction

$ 87,267

$ 106,073

-11.1%

$ 94,299

7/1/2021

unknown

unknown

7

County of Sacramento

Senior Construction Inspector

$ 84,835

$ 93,522

0.1%

$ 93,616

6/21/2020

unknown

unknown

8

County of Orange

Senior Construction Inspector

$ 69,826

$ 93,995

-2.0%

$ 92,115

7/2/2021

7/1/2022

3.50%

9

County of Ventura

Senior Public Works Inspector

$ 65,098

$ 91,522

-0.7%

$ 90,882

12/26/2020

12/27/2021

2.00%

10

County of San Bernardino

Supervising Building Construction Inspector

$ 64,480

$ 88,608

1.9%

$ 90,292

7/31/2021

7/30/2022

3.00%

11

County of Fresno

Supervising Building Inspector

$ 70,330

$ 85,488

4.7%

$ 89,506

4/19/2021

unknown

unknown

12

County of Kern

Supervising Construction Project Inspector

$ 71,208

$ 86,940

1.2%

$ 87,983

4/21/2021

unknown

unknown





















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 99,515

$ 93,957

% County of San Diego Above/Below

-14.0%

-7.7%

Number of Matches

12

12

N/C - Non Comparator

Page 322 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Cook





















1

City and County of San Francisco

Chef/Production Manager

$ 75,948

$ 92,352

-17.4%

$ 76,283

7/1/2021

1/8/2022

.50%

2

County of Orange

Senior Head Cook

$ 51,938

$ 69,597

-2.0%

$ 68,205

7/2/2021

7/1/2022

3.50%

3

County of San Mateo2

[Cook ll/Supervising Cook]

$ 65,124

$ 72,799

-17.5%

$ 60,059

10/4/2020

unknown

unknown

4

County of Alameda

First Cook

$ 54,744

$ 64,911

-11.4%

$ 57,511

6/27/2021

6/26/2022

3.25%

5

County of Santa Clara

Cook II

$ 55,821

$ 67,419

-16.8%

$ 56,093

6/14/2021

6/13/2022

3.00%

6

County of Kern1

[Cook III/ Juvenile Corrections Senior Cook]

$ 45,228

$ 55,224

1.2%

$ 55,887

4/21/2021

unknown

unknown

7

County of Los Angeles

Senior Cook

$ 41,840

$ 56,289

-3.8%

$ 54,150

1/1/2021

unknown

unknown

8

County of Contra Costa

Lead Cook

$ 54,850

$ 60,472

-11.1%

$ 53,759

7/1/2021

unknown

unknown

9

County of Riverside

Senior Cook

$ 33,480

$ 52,248

1.9%

$ 53,241

5/1/2021

5/1/2022

2.00%

10

County of Sacramento

Senior Food Service Cook

$ 42,407

$ 51,574

0.1%

$ 51,626

6/21/2020

unknown

unknown





















12

County of San Bernardino

Cook III

$ 33,072

$ 45,448

1.9%

$ 46,311

7/31/2021

7/30/2022

3.00%

13

County of Fresno

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 60,472

$ 55,887

% County of San Diego Above/Below

-25.2%

-15.7%

Number of Matches

11

11

N/C - Non Comparator

1	- County of Kern: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator
agency. The salary displayed is the higher of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at
the comparator agency. The salary displayed is an average of the matches. Bottom of range is step 3 for both classes.

Page 323 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Electronic Security & Systems Technician





















1

City and County of San Francisco

Electronic Maintenance Technician Assistant Supervisor

$ 119,604

$ 145,416

-17.4%

$ 120,114

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Audio, Video, and Security Systems Technician

$95,261

$95,261

-3.8%

$91,641

1/1/2021

unknown

unknown

3

County of Ventura

Senior Digital Systems Electronics Technician

$ 72,990

$91,896

-0.7%

$91,253

1/10/2021

1/9/2022

2.00%

4

County of Contra Costa

Lead Electronic Systems Specialist

$81,021

$98,481

-11.1%

$87,550

7/1/2021

unknown

unknown





















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$96,871

$91,447

% County of San Diego Above/Below

-16.1%

-9.6%

Number of Matches

4

4

N/C - Non Comparator

Page 324 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Emergency Services Coordinator





















1

County of San Mateo2

[District Coordinator Sheriff's Office of Emergency Services/Director of Emergency Preparedness]

$ 120,627

$ 150,828

-17.5%

$ 124,433

12/13/2020

unknown

unknown

2

County of Santa Clara

Senior Emergency Planning Coordinator

$ 110,639

$ 134,499

-16.8%

$ 111,903

6/28/2021

6/27/2022

3.00%

3

City and County of San Francisco

Emergency Services Coordinator III

$ 108,836

$ 132,288

-17.4%

$ 109,270

7/1/2021

1/8/2022

.50%

4

County of Contra Costa1

[Senior Emergency Planning Coordinator/Emergency Services Manager]

$91,204

$ 117,018

-11.1%

$ 104,029

7/1/2021

unknown

unknown





















6

County of San Bernardino

Senior Emergency Medical Services Specialist

$ 63,502

$91,707

1.9%

$ 93,450

3/13/2021

3/26/2022

3.00%

7

County of Riverside

Senior Emergency Medical Services Specialist

$ 61,500

$91,032

1.9%

$92,762

5/1/2021

5/1/2022

2.00%

8

County of Alameda

Senior Emergency Services Coordinator

$ 80,579

$ 97,968

-11.4%

$ 86,800

11/1/2020

10/31/2021

2.00%

9

County of Kern

Senior Emergency Medical Services Coordinator

$ 64,776

$ 79,080

1.2%

$ 80,029

4/21/2021

unknown

unknown

10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 107,493

$ 98,739

% County of San Diego Above/Below

-6.3%

2.4%

Number of Matches

8

8

N/C - Non Comparator

1	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of
the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of the
matches.

Page 325 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Epidemiologist









































2

County of Santa Clara

Senior Epidemiologist

$ 108,405

$ 131,175

-16.8%

$ 109,138

6/14/2021

6/13/2022

3.00%

3

County of Orange

Senior Epidemiologist

$ 78,374

$ 105,622

-2.0%

$ 103,510

7/2/2021

7/1/2022

3.50%

4

County of Alameda

Epidemiologist III

$ 95,992

$ 116,688

-11.4%

$ 103,386

12/27/2020

12/26/2021

3.00%

5

County of San Mateo1

[Epidemiologist 1 I/Supervising Epidemiologist]

$97,186

$ 121,490

-17.5%

$ 100,230

10/4/2020

unknown

unknown

6

County of Fresno

Senior Epidemiologist

$ 78,338

$95,212

4.7%

$ 99,687

4/19/2021

unknown

unknown

7

County of Contra Costa

Public Health Epidemiologist and Biostatistician

$ 91,333

$ 111,016

-11.1%

$ 98,693

7/1/2021

unknown

unknown

8

County of Kern

Senior Public Health Epidemiologist

$ 73,008

$89,124

1.2%

$90,193

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 111,016

$ 100,230

% County of San Diego Above/Below

3.0%

12.5%

Number of Matches

7

7

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 326 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Forensic Evidence Technician |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Latent Fingerprint Examiner III

$ 103,653

$ 125,409

-16.8%

$ 104,341

6/14/2021

6/13/2022

3.00%

2

County of Orange

Senior Forensic Specialist

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

3

County of San Bernardino

Sheriff's Lead Crime Scene Specialist

$ 64,480

$ 88,608

1.9%

$ 90,292

7/31/2021

7/30/2022

3.00%

4

County of San Diego

Senior Forensic Evidence Technician

$ 70,366

$ 86,507



$ 86,507

6/18/2021

unknown

unknown

5

County of Riverside

Senior Forensic Services Specialist

$ 46,188

$ 72,180

1.9%

$ 73,551

5/1/2021

5/1/2022

2.00%

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 95,711

$ 95,525

% County of San Diego Above/Below

-10.6%

-10.4%

Number of Matches

4

4

N/C - Non Comparator

Page 327 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Geographic Information Systems Analyst





















1

County of Santa Clara

Senior Geographic Information Systems (GIS) Analyst

$ 141,833

$ 172,401

-16.8%

$ 143,437

6/14/2021

6/13/2022

3.00%

2

County of Orange

GIS Supervisor

$91,541

$ 123,282

-2.0%

$ 120,816

7/2/2021

7/1/2022

3.50%

3

County of Los Angeles

Senior Geographic Information Systems Analyst

$93,550

$ 119,403

-3.8%

$ 114,866

1/1/2021

unknown

unknown

4

County of Sacramento

Geographic Information Systems Analyst III

$89,554

$ 114,276

0.1%

$ 114,390

6/21/2020

unknown

unknown





















6

County of Riverside

Senior GIS Specialist

$49,776

$ 77,736

1.9%

$ 79,213

5/1/2021

5/1/2022

2.00%

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 119,403

$ 114,866

% County of San Diego Above/Below

-25.7%

-20.9%

Number of Matches

5

5

N/C - Non Comparator

Page 328 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Health Information Management Technician





















1

County of Contra Costa1

[Medical Records Technician/Registered Health Information Technologist]

$ 55,106

$ 68,492

-11.1%

$ 60,890

7/1/2021

unknown

unknown

2

County of Ventura

Records Technician IV

$ 39,741

$ 55,637

-0.7%

$ 55,247

12/27/2020

12/26/2021

2.00%





















4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,064

$ 58,068

% County of San Diego Above/Below

-17.2%

-9.6%

Number of Matches

2

2

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 329 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Health Physicist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Head Radiation Control

$ 119,988

$ 161,700

-3.8%

$ 155,555

1/1/2021

unknown

unknown



County of San Diego

Senior Health Physicist

$ 96,824

$ 118,934



$ 118,934

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 161,700

$ 155,555

% County of San Diego Above/Below

-36.0%

-30.8%

Number of Matches

1

1

N/C - Non Comparator

Page 330 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior HHSA Contract Auditor

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco1

[Auditor 11/Auditor III]

$ 112,728

$ 137,016

-17.4%

$ 113,175

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Senior Contract Program Auditor

$ 77,748

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown

3

County of Sacramento

Senior Auditor

$79,114

$96,152

0.1%

$ 96,248

6/21/2020

unknown

unknown

4

County of San Diego

Senior HHSA Contract Auditor

$ 78,229

$ 96,179



$ 96,179

6/18/2021

unknown

unknown

5

County of Fresno

Financial Analyst III

$ 62,478

$ 75,920

4.7%

$ 79,488

4/19/2021

unknown

unknown

6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,462

$ 98,519

% County of San Diego Above/Below

-4.5%

-2.4%

Number of Matches

4

4

N/C - Non Comparator

1 - City and County of San Francisco: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and
lower level classification at the comparator agency. The salary displayed is an average of the matches.

Page 331 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Histology Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Senior HistologicTechnician

$ 91,720

$ 129,172

-16.8%

$ 107,471

10/21/2020

10/20/2021

3.00%

2

County of Los Angeles

Tissue AnalysisTechnician II

$ 56,992

$ 76,804

-3.8%

$ 73,886

1/1/2021

unknown

unknown

3

County of San Diego

Senior Histology Technician









6/18/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 102,988

$ 90,679

% County of San Diego Above/Below

-48.6%

-30.8%

Number of Matches

2

2

N/C - Non Comparator

Page 332 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Hydrogeologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Senior Hydrogeologist

$ 92,976

$ 114,317



$ 114,317

6/18/2021

unknown

unknown

2

County of Fresno

Senior Geologist

$ 82,888

$ 100,750

4.7%

$ 105,485

4/19/2021

unknown

unknown

3

County of Kern

Engineer III

$ 82,704

$ 100,968

1.2%

$ 102,180

4/21/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 100,859

$ 103,832

% County of San Diego Above/Below

11.8%

9.2%

Number of Matches

2

2

N/C - Non Comparator

Page 333 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Insect Detection Specialist





















1

City and County of San Francisco

Senior Integrated Pest Management Specialist

$ 88,140

$ 107,146

-17.4%

$ 88,503

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Pest Detection Supervisor

$ 62,212

$ 77,790

-17.5%

$ 64,177

10/4/2020

unknown

unknown





















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,468

$ 76,340

% County of San Diego Above/Below

-59.7%

-31.9%

Number of Matches

2

2

N/C - Non Comparator

Page 334 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Laboratory Assistant





















1

County of Santa Clara

Medical Laboratory Assistant III

$ 64,305

$ 77,671

-16.8%

$ 64,623

6/14/2021

6/13/2022

3.00%

2

County of San Mateo1

[Laboratory Assistant ll/Laboratory Support Services Supervisor]

$ 60,849

$ 76,054

-17.5%

$ 62,744

10/4/2020

unknown

unknown

3

County of Orange

Senior Laboratory Assistant

$ 42,016

$ 56,410

-2.0%

$ 55,281

7/2/2021

7/1/2022

3.50%

4

County of Riverside

Senior Laboratory Assistant

$ 34,200

$ 53,388

1.9%

$ 54,402

5/1/2021

5/1/2022

2.00%





















6

County of Los Angeles

Senior Laboratory Assistant

$ 38,056

$ 51,129

-3.8%

$49,186

1/1/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,410

$ 55,281

% County of San Diego Above/Below

-11.2%

-9.0%

Number of Matches

5

5

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 335 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Land Surveyor





















1

City and County of San Francisco

Chief Surveyor

$ 129,636

$ 169,780

-17.4%

$ 140,238

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Senior Land Surveyor

$ 124,466

$ 137,223

0.1%

$ 137,360

6/21/2020

unknown

unknown

3

County of Riverside

Senior Land Surveyor

$88,152

$ 130,596

1.9%

$ 133,077

5/1/2021

5/1/2022

2.00%

4

County of Santa Clara

County Surveyor, Supervisor Surveying And Mapping

$ 131,146

$ 159,438

-16.8%

$ 132,653

6/28/2021

6/27/2022

3.00%





















6

County of Orange

Senior Land Surveyor

$ 92,248

$ 124,301

-2.0%

$ 121,815

7/2/2021

7/1/2022

3.50%

7

County of Ventura

Surveyor IV

$ 81,564

$ 122,219

-0.7%

$ 121,364

1/10/2021

1/9/2022

2.00%

8

County of Alameda1

[Land Surveyor/Senior Land Surveyor]

$ 115,534

$ 135,106

-11.4%

$ 119,704

6/13/2021

6/12/2022

3.50%

9

County of Contra Costa2

[Engineering Technician Supervisor - Land Surveyor/Senior Land Surveyor]

$ 102,614

$ 118,062

-11.1%

$ 104,958

7/1/2021

unknown

unknown

10

County of Kern

Engineer III

$ 82,704

$ 100,968

1.2%

$ 102,180

4/21/2021

unknown

unknown

11

County of Fresno

Field Survey Supervisor

$ 62,868

$ 76,414

4.7%

$ 80,005

4/19/2021

unknown

unknown

12

County of Los Angeles

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 127,448

$ 121,589

% County of San Diego Above/Below

1.7%

6.2%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 336 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Latent Print Examiner









































2

County of Contra Costa

Supervising Fingerprint Examiner

$ 96,875

$ 120,696

-11.1%

$ 107,299

7/1/2021

7/1/2022

5.00%

3

County of Santa Clara

Latent Fingerprint Examiner III

$ 103,653

$ 125,409

-16.8%

$ 104,341

6/14/2021

6/13/2022

3.00%

4

County of Alameda1

[Latent Fingerprint Examiner/ Identification Supervisor]

$ 74,737

$ 90,085

-11.4%

$79,815

11/1/2020

10/31/2021

2.00%

5

City and County of San Francisco

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 120,696

$ 104,341

% County of San Diego Above/Below

-1.0%

12.7%

Number of Matches

3

3

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 337 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Laundry Worker





















1

County of Alameda1

[Laundry Service Worker/ Laundry Supervisor, Santa Rita Jail]

$ 49,013

$ 58,568

-11.4%

$ 51,891

6/27/2021

6/26/2022

3.25%





















3

County of Riverside

Senior Laundry Worker

$ 29,652

$ 46,296

1.9%

$47,176

5/1/2021

5/1/2022

2.00%

4

County of Fresno

LaundrySupervisor- Branch Jail

$ 33,904

$ 43,394

4.7%

$ 45,434

11/2/2020

unknown

unknown

5

County of Ventura

Laundry Assistant Supervisor

$ 31,985

$ 43,003

-0.7%

$ 42,702

12/26/2020

12/27/2021

2.00%

6

County of Los Angeles

Senior Laundry Worker

$ 32,263

$ 43,295

-3.8%

$ 41,650

1/1/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Kern

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 43,394

$ 45,434

% County of San Diego Above/Below

8.9%

4.6%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 338 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Litigation Investigator





















1

City and County of San Francisco

Senior Claims Investigator, City Attorneys Office

$ 118,716

$ 144,352

-17.4%

$ 119,235

7/1/2021

1/8/2022

.50%



















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 144,352

$ 119,235

% County of San Diego Above/Below

-34.1%

-10.8%

Number of Matches

1

1

N/C - Non Comparator

Page 339 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Mail Carrier

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Lead Mail Services Driver

$ 54,953

$ 68,680

-17.5%

$ 56,661

10/4/2020

unknown

unknown

2

County of San Bernardino

Mail Services Supervisor

$ 37,440

$ 51,376

1.9%

$ 52,352

7/31/2021

7/30/2022

3.00%

3

County of Riverside

Supervising Mail Clerk

$ 32,491

$ 47,981

1.9%

$ 48,893

5/1/2021

5/1/2022

2.00%

4

County of San Diego

Senior Mail Carrier







$ 48,090

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 51,376

$ 52,352

% County of San Diego Above/Below

-6.8%

-8.9%

Number of Matches

3

3

N/C - Non Comparator

Page 340 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Medical Transcriber |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Medical Transcriber Typist

$ 69,992

$ 84,994

-17.4%

$ 70,205

7/1/2021

1/8/2022

.50%

2

County of San Diego

Senior Medical Transcriber

$ 45,448

$ 55,869



$ 55,869

6/18/2021

unknown

unknown

3

County of Ventura

Information Processing Operator IV

$ 38,031

$ 53,219

-0.7%

$ 52,847

12/27/2020

12/26/2021

2.00%

4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,107

$ 61,526

% County of San Diego Above/Below

-23.7%

-10.1%

Number of Matches

2

2

N/C - Non Comparator

Page 341 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Meteorologist









































2

South Coast Air Quality Management District

Senior Meteorologist

$87,108

$ 117,060

-2.8%

$ 113,782

1/1/2020

unknown

unknown

3

Sacramento Metropolitan Air Quality Management District

N/C















4

Bay Area Air Quality Management District

N/C















5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 117,060

$ 113,782

% County of San Diego Above/Below

-2.3%

0.6%

Number of Matches

1

1

N/C - Non Comparator

Page 342 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Occupational/Physical Therapist





















1

City and County of San Francisco1

[Senior Physical Therapist/ Senior Occupational Therapist]

$ 112,008

$ 157,612

-17.4%

$ 130,187

7/1/2021

1/8/2022

.50%

2

County of San Bernardino

Lead Occupational Therapist/Lead Physical Therapist

$ 76,586

$ 110,760

1.9%

$ 112,864

3/13/2021

3/26/2022

3.00%

3

County of Ventura5

[Senior Occupational Therapist/ Senior Physical Therapist]

$ 76,190

$ 112,216

-0.7%

$ 111,430

12/27/2020

12/26/2021

2.00%

4

County of Fresno3

[Occupational Therapist III / Physical Therapist III]

$ 81,224

$ 103,896

4.7%

$ 108,779

11/2/2020

unknown

unknown

5

County of Sacramento

Senior Therapist

$ 88,782

$ 107,908

0.1%

$ 108,016

6/21/2020

unknown

unknown

6

County of Kern

Senior Occupational/Physical Therapist

$ 85,644

$ 104,556

1.2%

$ 105,811

4/21/2021

unknown

unknown

7

County of San Mateo4

[Physical Therapist II - CCS/Supervising Therapist]

$ 100,441

$ 125,557

-17.5%

$ 103,584

10/4/2020

unknown

unknown

8

County of Alameda

Senior Therapist

$ 94,205

$ 114,465

-11.4%

$ 101,416

6/27/2021

6/26/2022

3.25%

9

County of Contra Costa2

[Physical Therapist ll/Supervising Pediatric Therapist]

$ 93,597

$ 113,768

-11.1%

$ 101,140

7/1/2021

unknown

unknown





















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Riverside

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 112,216

$ 108,016

% County of San Diego Above/Below

-11.2%

-7.0%

Number of Matches

9

9

N/C - Non Comparator

1	- City and County of San Francisco: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency.
The salary displayed is the same for both matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

3	- County of Fresno: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the same for both matches.

4	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

5	- County of Ventura: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 343 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Office Assistant





















1

County of Alameda

Supervising Clerk 1

$ 67,454

$ 81,827

-11.4%

$ 72,499

12/27/2020

12/26/2021

3.00%

2

City and County of San Francisco

Senior Clerk

$ 57,538

$ 81,744

-17.4%

$ 67,521

7/1/2021

1/8/2022

.50%

3

County of Ventura

Clerical Supervisor 1

$ 41,469

$ 58,023

-0.7%

$ 57,617

12/26/2020

12/27/2021

2.00%

4

County of Santa Clara

Senior Office Specialist

$ 57,034

$ 68,856

-16.8%

$ 57,288

6/14/2021

6/13/2022

3.00%

5

County of Fresno

Supervising Office Assistant

$ 42,146

$ 53,924

4.7%

$ 56,458

11/2/2020

unknown

unknown

6

County of Contra Costa1

[Clerk - Experienced Level/Clerical Supervisor]

$ 49,494

$ 62,465

-11.1%

$ 55,531

7/1/2021

unknown

unknown

7

County of San Bernardino

Supervising Office Assistant

$ 38,584

$ 53,082

1.9%

$ 54,090

7/31/2021

7/30/2022

3.00%

8

County of Riverside

Supervising Office Assistant 1

$ 33,069

$ 52,944

1.9%

$ 53,950

5/1/2021

5/1/2022

2.00%

9

County of Sacramento

Senior Office Assistant

$ 41,134

$ 50,008

0.1%

$ 50,058

6/21/2020

unknown

unknown





















11

County of Kern

Senior Office Services Specialist

$ 36,684

$ 44,784

1.2%

$ 45,321

4/21/2021

unknown

unknown

12

County of Los Angeles

N/C















13

County of Orange

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,973

$ 55,995

% County of San Diego Above/Below

-15.1%

-15.1%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 344 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Park Ranger	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Senior Park Ranger

$89,103

$ 107,831

-16.8%

$ 89,716

6/14/2021

6/13/2022

3.00%

2

County of San Mateo2

[Park Ranger ll/Park Ranger III]

$ 75,856

$ 94,846

-17.5%

$ 78,248

10/4/2020

unknown

unknown

3

City and County of San Francisco1

[Park Ranger/ Head Park Ranger]

$ 76,079

$ 92,480

-17.4%

$ 76,388

7/1/2021

1/8/2022

.50%

4

County of San Bernardino

Park Ranger III

$ 46,904

$ 64,501

1.9%

$ 65,726

7/31/2021

7/30/2022

3.00%

5

County of Riverside

Senior Park Ranger - Parks

$ 43,224

$ 63,744

1.9%

$ 64,955

5/1/2021

5/1/2022

2.00%

6

County of San Diego

Senior Park Ranger

$ 50,918

$ 62,608



$ 62,608

6/18/2021

unknown

unknown

7

County of Ventura

Park Services Ranger II

$ 42,981

$ 60,201

-0.7%

$ 59,779

10/4/2020

unknown

unknown

8

County of Kern

Senior Park Ranger

$45,912

$ 56,052

1.2%

$ 56,725

4/21/2021

unknown

unknown

9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Los Angeles

N/C















13

County of Orange

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 64,501

$ 65,726

% County of San Diego Above/Below

-3.0%

-5.0%

Number of Matches

7

7

N/C - Non Comparator

1	- City and County of San Francisco: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and
lower level classification at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 345 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Payroll Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Payroll And Personnel Clerk

$ 77,870

$ 94,640

-17.4%

$ 78,173

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Supervising Payroll Clerk II

$ 52,405

$ 72,571

-3.8%

$ 69,813

1/1/2021

unknown

unknown

3

County of San Diego

Senior Payroll Clerk







$ 50,731

6/18/2021

unknown

unknown

4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 83,605

$ 73,993

% County of San Diego Above/Below

-64.8%

-45.9%

Number of Matches

2

2

N/C - Non Comparator

Page 346 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Precinct Planning Technician |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Elections Services Specialist

$ 57,122

$ 69,432

-11.1%

$ 61,725

7/1/2021

unknown

unknown

2

County of San Diego

Senior Precinct Planning Technician







$ 59,405

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,432

$ 61,725

% County of San Diego Above/Below

-16.9%

-3.9%

Number of Matches

1

1

N/C - Non Comparator

Page 347 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Procurement Contracting Officer





















1

City and County of San Francisco

Supervising Purchaser

$ 130,312

$ 170,352

-17.4%

$ 140,711

7/1/2021

1/8/2022

.50%

2

County of Sacramento

Contract Services Manager 1

$ 108,305

$ 119,392

0.1%

$ 119,511

6/21/2020

unknown

unknown





















4

County of Santa Clara

Procurement Contracts Specialist

$ 109,978

$ 133,731

-16.8%

$ 111,265

6/28/2021

6/27/2022

3.00%

5

County of Riverside

Senior Procurement Contract Specialist

$ 62,479

$ 102,875

1.9%

$ 104,830

5/1/2021

5/1/2022

2.00%

6

County of Orange

Supervising Procurement Contract Specialist

$ 78,374

$ 105,622

-2.0%

$ 103,510

7/2/2021

7/1/2022

3.50%

7

County of Contra Costa1

[Senior Buyer/Procurement Services Manager]

$ 92,936

$ 112,964

-11.1%

$ 100,425

7/1/2021

unknown

unknown

8

County of San Bernardino

Supervising Buyer

$ 67,579

$ 93,122

1.9%

$ 94,891

7/31/2021

7/30/2022

3.00%

9

County of Alameda

Procurement and Contracts Supervisor

$ 86,382

$ 105,019

-11.4%

$ 93,047

12/27/2020

12/26/2021

3.00%

10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Los Angeles

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 109,293

$ 104,170

% County of San Diego Above/Below

5.3%

9.7%

Number of Matches

8

8

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 348 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Protective Services Worker





















1

County of Alameda1

[Child Welfare Worker 11/ Child Welfare Supervisor]

$ 92,414

$ 108,932

-11.4%

$ 96,513

9/6/2020

unknown

unknown

2

County of San Mateo

Children's Services Social Worker III

$92,350

$ 115,459

-17.5%

$95,253

10/4/2020

unknown

unknown

3

County of San Bernardino

Lead Social Service Practitioner

$ 63,461

$ 89,419

1.9%

$91,118

3/13/2021

3/26/2022

3.00%

4

County of Contra Costa

Social Worker III

$ 83,461

$ 101,448

-11.1%

$90,187

7/1/2021

unknown

unknown

5

County of Ventura

HS Child Welfare Social Worker IV

$ 55,143

$ 87,933

-0.7%

$ 87,318

12/26/2020

12/27/2021

2.00%

6

County of Riverside

Social Services Practitioner III

$ 53,476

$ 83,439

1.9%

$ 85,024

5/1/2021

5/1/2022

2.00%





















8

County of Fresno

Social Worker III

$ 50,570

$ 64,714

4.7%

$ 67,756

11/2/2020

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Sacramento

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 89,419

$90,187

% County of San Diego Above/Below

-10.9%

-11.8%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 349 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Public Health Microbiologist





















1

County of Santa Clara

Senior Public Health Microbiologist

$ 117,765

$ 165,926

-16.8%

$ 138,050

10/21/2020

10/20/2021

3.00%

2

City and County of San Francisco

Microbiologist II

$ 122,330

$ 148,668

-17.4%

$ 122,800

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Public Health Microbiologist II

$ 82,080

$ 110,616

-3.8%

$ 106,413

1/1/2021

unknown

unknown

4

County of San Mateo1

[Public Health Microbiologist ll/Supervising Public Health Microbiologist]

$ 99,526

$ 124,413

-17.5%

$ 102,641

10/4/2020

unknown

unknown

5

County of Contra Costa

Senior Public Health Microbiologist

$ 89,324

$ 108,574

-11.1%

$96,522

7/1/2021

unknown

Unknown

6

County of Ventura

Microbiologist III

$ 67,988

$95,355

-0.7%

$ 94,687

12/26/2020

12/27/2021

2.00%





















8

County of San Bernardino

Public Health Microbiologist III

$ 63,502

$ 91,707

1.9%

$ 93,450

3/13/2021

3/26/2022

3.00%

9

County of Sacramento

Senior Public Health Microbiologist

$ 75,043

$91,225

0.1%

$91,316

6/21/2020

unknown

unknown

10

County of Alameda

Senior Microbiologist

$ 83,696

$ 100,447

-11.4%

$ 88,996

6/27/2021

6/26/2022

3.25%

11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Orange

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 108,574

$ 96,522

% County of San Diego Above/Below

-15.1%

-2.3%

Number of Matches

9

9

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 350 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Pu

blic Health Nurse





















1

County of Santa Clara

Public Health Nurse III

$ 138,324

$ 167,656

-16.8%

$ 139,490

6/14/2021

6/13/2022

3.00%

2

County of San Mateo1

[Public Health Nurse/Senior Public Health Nurse]

$ 126,462

$ 153,771

-17.5%

$ 126,861

2/7/2021

unknown

unknown

3

County of Alameda

Registered Nurse III (PHN Designation)

$ 115,670

$ 142,407

-11.4%

$ 126,173

6/27/2021

6/26/2022

3.25%

4

County of Sacramento

SeniorPublic Health Nurse

$ 92,164

$ 112,042

0.1%

$ 112,154

8/2/2020

unknown

unknown

5

County of Riverside

Registered Nurse III

$ 82,380

$ 106,776

1.9%

$ 108,805

5/1/2021

5/1/2022

2.00%

6

County of Orange

SeniorPublic Health Nurse

$ 82,181

$ 110,490

-2.0%

$ 108,280

7/2/2021

7/1/2022

3.50%

7

County of Ventura

Senior Registered Nurse - Public Health

$ 90,678

$ 108,405

-0.7%

$ 107,647

4/4/2021

4/17/2022

3.25%





















9

City and County of San Francisco

N/C















10

County of Contra Costa

N/C















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Los Angeles

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 112,042

$ 112,154

% County of San Diego Above/Below

-12.4%

-12.5%

Number of Matches

7

7

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches. Bottom of range is step 2 for PHN, step 1 for Senior.

Page 351 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Real Property Agent	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Senior Real Property Officer

$ 124,878

$ 151,762

-17.4%

$ 125,355

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Senior Real Estate Agent

$ 116,624

$ 141,762

-16.8%

$ 117,946

6/28/2021

6/27/2022

3.00%

3

County of Orange

Senior Real Property Agent

$ 82,181

$ 110,490

-2.0%

$ 108,280

7/2/2021

7/1/2022

3.50%

4

County of Los Angeles

Senior Real Property Agent

$ 86,020

$ 109,808

-3.8%

$ 105,635

1/1/2021

unknown

unknown

5

County of Contra Costa

Senior Real Property Agent

$ 87,386

$ 108,874

-11.1%

$ 96,789

7/1/2021

unknown

unknown

6

County of Riverside

Senior Real Property Agent

$ 63,144

$ 93,468

1.9%

$ 95,244

5/1/2021

5/1/2022

2.00%

7

County of San Bernardino

Real Property Agent III

$ 67,579

$ 93,122

1.9%

$ 94,891

7/31/2021

7/30/2022

3.00%

8

County of San Diego

Senior Real Property Agent

$ 84,656

$ 94,328



$ 94,328

6/18/2021

unknown

unknown

9

County of Ventura

Senior Real Property Agent

$ 69,896

$ 93,446

-0.7%

$ 92,792

12/27/2020

12/26/2021

2.00%

10

County of Kern

Real Property Agent III

$ 56,892

$ 69,456

1.2%

$ 70,289

4/21/2021

unknown

unknown

11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 108,874

$ 96,789

% County of San Diego Above/Below

-15.4%

-2.6%

Number of Matches

9

9

N/C - Non Comparator

Page 352 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Revenue & Recovery Officer





















1

City and County of San Francisco

Collection Supervisor

$ 82,810

$ 100,646

-17.4%

$83,134

7/1/2021

1/8/2022

.50%

2

County of Alameda

Collection Supervisor 1

$ 76,918

$ 93,475

-11.4%

$ 82,819

12/27/2020

12/26/2021

3.00%

3

County of San Mateo1

[Lead Revenue Collector/Revenue Collection Supervisor]

$ 77,728

$97,134

-17.5%

$80,136

10/4/2020

unknown

unknown

4

County of Sacramento

Collection Services Supervisor

$ 60,531

$ 73,581

0.1%

$ 73,655

6/21/2020

unknown

unknown

5

County of Contra Costa

Collection Enforcement Supervisor 1

$ 68,064

$ 82,732

-11.1%

$ 73,549

7/1/2021

unknown

unknown

6

County of Santa Clara

Senior Revenue Collections Officer

$ 72,238

$ 87,360

-16.8%

$ 72,684

6/14/2021

6/13/2022

3.00%

7

County of San Bernardino

Supervising Collections Officer

$ 50,440

$ 69,389

1.9%

$ 70,707

7/31/2021

7/30/2022

3.00%





















9

County of Los Angeles

Supervising Delinquent Accounts Investigator

$ 49,887

$ 67,225

-3.8%

$ 64,671

1/1/2021

unknown

unknown

10

County of Fresno

Collections Supervisor

$ 47,710

$ 57,980

4.7%

$ 60,705

4/19/2021

unknown

unknown

11

County of Kern

N/C















12

County of Orange

N/C















13

County of Riverside

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,732

$ 73,549

% County of San Diego Above/Below

-19.3%

-6.0%

Number of Matches

9

9

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 353 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Storekeeper





















1

County of Santa Clara

Supervising Materials Supply Specialist

$ 76,685

$ 93,186

-16.8%

$ 77,531

6/28/2021

6/27/2022

3.00%

2

County of Contra Costa

Supply and Distribution Supervisor

$ 67,527

$ 82,079

-11.1%

$ 72,968

7/1/2021

unknown

unknown

3

County of San Mateo

Storekeeping Supervisor

$ 64,271

$ 80,370

-17.5%

$ 66,305

10/4/2020

unknown

unknown

4

County of Orange

Senior Storekeeper

$ 49,650

$ 66,518

-2.0%

$ 65,188

7/2/2021

7/1/2022

3.50%

5

City and County of San Francisco

Senior Storekeeper

$ 64,662

$ 78,650

-17.4%

$ 64,965

7/1/2021

1/8/2022

.50%

6

County of Los Angeles

Warehouse Worker III

$ 47,724

$ 64,308

-3.8%

$ 61,864

1/1/2021

unknown

unknown

7

County of Ventura

Warehouse Supervisor

$ 43,975

$ 61,570

-0.7%

$ 61,139

12/26/2020

12/27/2021

2.00%

8

County of Sacramento

Storekeeper II

$49,193

$ 59,800

0.1%

$ 59,860

6/21/2020

unknown

unknown





















10

County of Alameda

Storekeeper 1

$ 51,623

$ 61,770

-11.4%

$ 54,728

6/27/2021

6/26/2022

3.25%

11

County of Fresno

Supervising Stock Clerk

$ 39,260

$ 50,232

4.7%

$ 52,593

11/2/2020

unknown

unknown

12

County of San Bernardino

Stores Supervisor 1

$ 34,133

$ 46,966

1.9%

$ 47,859

7/31/2021

7/30/2022

3.00%

13

County of Kern

Storekeeper II

$ 34,212

$ 41,760

1.2%

$ 42,261

4/21/2021

unknown

unknown

14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 63,039

$ 61,502

% County of San Diego Above/Below

-12.0%

-9.2%

Number of Matches

12

12

N/C - Non Comparator

Page 354 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Structural Engineer





















1

City and County of San Francisco

Senior Structural Engineer

$ 180,804

$ 219,726

-17.4%

$ 181,494

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Senior Structural Engineer

$ 132,440

$ 169,062

-3.8%

$ 162,637

1/1/2021

unknown

unknown

3

County of Orange

Senior Civil Engineer

$ 107,619

$ 145,142

-2.0%

$ 142,240

7/2/2021

7/1/2022

3.50%

4

County of Sacramento

Senior Civil Engineer

$ 125,718

$ 138,601

0.1%

$ 138,740

6/21/2020

unknown

unknown

5

County of Ventura

Senior Plan Check Engineer

$ 98,614

$ 138,059

-0.7%

$ 137,093

unknown

unknown

unknown

6

County of Santa Clara

Senior Plan Check Engineer

$ 114,887

$ 163,966

-16.8%

$ 136,420

10/21/2020

10/20/2021

3.00%





















8

County of San Bernardino

Supervising Engineer

$ 95,222

$ 131,290

1.9%

$ 133,784

7/31/2021

7/30/2022

3.00%

9

County of Contra Costa

Principal Structural Engineer

$ 113,449

$ 137,898

-11.1%

$ 122,591

7/1/2021

unknown

unknown

10

County of Fresno1

[Building Plans Engineer/ Supervising Engineer]

$ 90,935

$ 110,526

4.7%

$ 115,721

4/19/2021

unknown

unknown

11

County of Alameda

N/C















12

County of Kern

N/C















13

County of Riverside

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 138,601

$ 137,093

% County of San Diego Above/Below

-2.1%

-1.0%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Fresno: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 355 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Tax Payment Enforcement Officer





















1

City and County of San Francisco

Senior Investigator, Tax Collector

$ 96,512

$ 117,364

-17.4%

$ 96,943

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Revenue Collection Supervisor

$ 84,093

$ 105,080

-17.5%

$ 86,691

10/4/2020

unknown

unknown

3

County of Alameda

Collection Supervisor 1

$ 76,918

$ 93,475

-11.4%

$ 82,819

12/27/2020

12/26/2021

3.00%



















5

County of Riverside

SeniorTax Enforcement Investigator

$ 51,912

$ 76,824

1.9%

$ 78,284

5/1/2021

5/1/2022

2.00%

6

County of Sacramento

Collection Services Supervisor

$ 60,531

$ 73,581

0.1%

$ 73,655

6/21/2020

unknown

unknown

7

County of Contra Costa

Tax Compliance Officer - Advanced

$ 58,892

$ 71,583

-11.1%

$ 63,637

7/1/2021

unknown

unknown

8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 85,150

$ 80,551

% County of San Diego Above/Below

-7.6%

-1.8%

Number of Matches

6

6

N/C - Non Comparator

Page 356 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|SeniorTax Payment Processor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Senior Tax Payment Processor

$ 43,722

$ 53,747

$ 53,747

6/18/2021

unknown

unknown

2

County of Kern

Fiscal Support Specialist

$ 39,144

$ 47,784

1.2%

$ 48,357

4/21/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 47,784

$ 48,357

% County of San Diego Above/Below

11.1%

10.0%

Number of Matches

1

1

N/C - Non Comparator

Page 357 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Treasurer-Tax Collector Specialist





















1

County of San Mateo

Senior Cash Management Specialist

$ 65,144

$ 81,430

-17.5%

$ 67,180

10/4/2020

unknown

unknown

2

County of Alameda

Treasurer-Tax Collector's Specialist III

$ 60,039

$ 71,052

-11.4%

$ 62,952

6/27/2021

6/26/2022

3.25%

3

County of Los Angeles

Tax Services Specialist

$ 44,799

$ 61,981

-3.8%

$ 59,626

1/1/2021

unknown

unknown

4

County of Contra Costa

Account Clerk - Advanced Level

$ 49,796

$ 63,592

-11.1%

$ 56,533

7/1/2021

unknown

unknown





















6

City and County of San Francisco

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,322

$ 61,289

% County of San Diego Above/Below

-25.9%

-14.7%

Number of Matches

4

4

N/C - Non Comparator

Page 358 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Senior Vector Control Technician	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Vector Control Technician III

$ 75,504

$ 91,266

-16.8%

$ 75,934

6/14/2021

6/13/2022

3.00%

2

County of Alameda

Senior Vector Control Officer

$ 70,506

$ 84,036

-11.4%

$ 74,455

6/27/2021

6/26/2022

3.25%

3

County of San Diego

Senior Vector Control Technician

$ 55,266





$ 67,954

6/18/2021

unknown

unknown

4

County of San Bernardino

Vector Control Technician II

$ 46,904

$ 64,501

1.9%

$ 65,726

7/31/2021

7/30/2022

3.00%

5

County of Riverside

Environmental Health Technician II

$ 38,982

$ 60,876

1.9%

$ 62,032

5/1/2021

5/1/2022

2.00%

6

City and County of San Francisco

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 74,268

$ 70,091

% County of San Diego Above/Below

-9.3%

-3.1%

Number of Matches

4

4

N/C - Non Comparator

Page 359 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Vector Ecologist









































2

County of Santa Clara

Vector Control Ecologist

$ 92,991

$ 112,522

-16.8%

$ 93,618

6/14/2021

6/13/2022

3.00%

3

County of Alameda

Senior Vector Control Biologist

$ 82,446

$ 100,250

-11.4%

$ 88,821

6/27/2021

6/26/2022

3.25%

4

City and County of San Francisco

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,386

$ 91,220

% County of San Diego Above/Below

-6.1%

9.1%

Number of Matches

2

2

N/C - Non Comparator

Page 360 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Senior Veteran Services Representative





















1

City and County of San Francisco1

[Veterans Claims Representative/ Veterans Claims Representative Supervisor]

$ 92,832

$ 112,854

-17.4%

$ 93,217

7/1/2021

1/8/2022

.50%

2

County of Contra Costa2

[Veterans Service Representative ll/Veterans' Services Manager]

$ 75,559

$ 91,842

-11.1%

$ 81,648

7/1/2021

unknown

unknown

3

County of Riverside

Senior Veteran Services Representative

$ 54,696

$ 73,296

1.9%

$ 74,689

5/1/2021

5/1/2022

2.00%





















5

County of Los Angeles

Veterans Claims Assistant III

$ 55,057

$ 74,197

-3.8%

$ 71,378

1/1/2021

unknown

unknown

6

County of Sacramento

Senior Veterans Claims Representative

$ 52,597

$ 63,935

0.1%

$ 63,999

6/21/2020

unknown

unknown

7

County of Kern

Veterans Service Representative II

$ 45,456

$ 55,500

1.2%

$ 56,166

4/21/2021

unknown

unknown

8

County of Alameda

N/C















9

County of Fresno

N/C















10

County of Orange

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,747

$ 73,033

% County of San Diego Above/Below

0.2%

1.1%

Number of Matches

6

6

N/C - Non Comparator

1	- City and County of San Francisco: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is an average of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 361 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sewing Room Supervisor

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Head Sewing Worker

$ 40,448

$ 54,382

-3.8%

$ 52,315

1/1/2021

unknown

unknown

2

County of San Diego

Sewing Room Supervisor

$ 34,403





$ 38,397

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 54,382

$ 52,315

% County of San Diego Above/Below

-41.6%

-36.2%

Number of Matches

1

1

N/C - Non Comparator

Page 362 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Commissary Stores Supervisor









































2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 363 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Communications Dispatcher	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Communications Dispatcher II

$ 67,990

$ 82,602

-17.4%

$ 68,229

7/1/2021

1/8/2022

.50%

2

County of San Mateo

911 Communications Calltaker

$ 60,652

$ 75,794

-17.5%

$ 62,530

10/4/2020

unknown

unknown

3

County of San Bernardino

Sheriff's Communication Dispatcher 1

$ 40,082

$ 55,016

1.9%

$ 56,061

7/31/2021

7/30/2022

3.00%

4

County of Los Angeles

Dispatcher II

$ 40,350

$ 54,249

-3.8%

$ 52,187

1/1/2021

unknown

unknown

5

County of Kern

Sheriff's Dispatcher 1

$ 42,180

$ 51,492

1.2%

$ 52,110

4/21/2021

unknown

unknown

6

County of San Diego

Sheriffs Communications Dispatcher



$ 50,232



$ 50,232

6/18/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,016

$ 56,061

% County of San Diego Above/Below

-9.5%

-11.6%

Number of Matches

5

5

N/C - Non Comparator

Page 364 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Detentions Licensed Vocational Nurse





















1

County of San Mateo1

Licensed Vocational Nurse

$ 71,114

$ 84,093

-17.5%

$ 69,377

10/4/2020

unknown

unknown

2

County of Contra Costa

Licensed Vocational Nurse

$ 57,999

$ 74,067

-11.1%

$ 65,845

7/1/2021

unknown

unknown

3

County of Sacramento

Licensed Vocational Nurse D/CF

$ 50,718

$ 61,638

0.1%

$ 61,700

6/21/2020

unknown

unknown





















5

County of San Bernardino

Licensed Vocational Nurse II - Corrections

$ 41,454

$ 57,075

1.9%

$ 58,160

7/31/2021

7/30/2022

3.00%

6

County of Fresno

Licensed Vocational Nurse II

$ 42,822

$ 54,756

4.7%

$ 57,330

11/2/2020

unknown

unknown

7

County of Riverside

Licensed Vocational Nurse - Adult Detention

$ 36,465

$ 53,882

1.9%

$ 54,906

5/1/2021

5/1/2022

2.00%

8

County of Orange

Licensed Vocational Nurse

$ 41,080

$ 54,974

-2.0%

$ 53,875

7/2/2021

7/1/2022

3.50%

9

County of Kern

Correctional Vocational Nurse II

$ 42,180

$ 51,492

1.2%

$ 52,110

4/21/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Los Angeles

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,025

$ 57,745

% County of San Diego Above/Below

7.4%

4.6%

Number of Matches

8

8

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 365 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Detentions Nurse	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Registered Nurse

$ 124,777

$ 155,829

-11.1%

$ 138,532

1/1/2021

unknown

unknown

2

County of Los Angeles

Registered Nurse II, Sheriff

$ 85,408

$ 127,845

-3.8%

$ 122,987

1/1/2021

unknown

unknown

3

County of San Mateo1

Correctional Health Nurse

$ 123,737

$ 146,242

-17.5%

$ 120,650

2/7/2021

unknown

unknown

4

County of Riverside

Institutional Nurse

$ 81,677

$ 113,970

1.9%

$ 116,135

5/1/2021

5/1/2022

2.00%

5

County of San Diego

Sheriffs Detentions Nurse

$ 83,616

$ 113,360



$ 113,360

6/18/2021

unknown

unknown

6

County of San Bernardino

Correctional Nurse II

$ 80,766

$ 109,928

1.9%

$ 112,017

8/15/2020

unknown

unknown

7

County of Sacramento

Registered Nurse D/CF II

$ 80,659

$ 98,052

0.1%

$ 98,150

8/2/2020

unknown

unknown

8

County of Kern

Correctional Staff Nurse II

$ 78,684

$ 96,060

1.2%

$ 97,213

4/21/2021

unknown

unknown

9

County of Orange

Staff Nurse

$ 62,712

$ 84,469

-2.0%

$ 82,779

7/2/2021

7/1/2022

3.50%

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 111,949

$ 114,076

% County of San Diego Above/Below

1.2%

-0.6%

Number of Matches

8

8

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 366 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Detentions Supervising Nurse





















1

County of Riverside

Supervising Institutional Nurse

$ 96,579

$ 135,870

1.9%

$ 138,452

5/1/2021

5/1/2022

2.00%

2

County of Los Angeles

Supervising Staff Nurses 1, Sheriff

$ 96,127

$ 143,891

-3.8%

$ 138,423

1/1/2021

unknown

unknown





















4

County of San Bernardino

Supervising Correctional Nurse 1

$ 89,710

$ 123,510

1.9%

$ 125,857

7/31/2021

7/30/2022

3.00%

5

County of Sacramento

Supervising Registered Nurse D/CF

$ 90,348

$ 109,787

0.1%

$ 109,897

6/21/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 129,690

$ 132,140

% County of San Diego Above/Below

3.1%

1.2%

Number of Matches

4

4

N/C - Non Comparator

Page 367 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Detentions, Chief Mental Health Clinician





















1

County of Riverside

Behavioral HeaIth Services Supervisor - Detention

$ 73,631

$ 106,214

1.9%

$ 108,232

5/1/2021

5/1/2022

2.00%





















3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 106,214

$ 108,232

% County of San Diego Above/Below

-0.2%

-2.1%

Number of Matches

1

1

N/C - Non Comparator

Page 368 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Detentions, Mental Health Clinician





















1

County of Kern

Clinical Psychologist II

$ 88,248

$ 107,724

1.2%

$ 109,017

4/21/2021

unknown

unknown





















3

County of Los Angeles

Mental Health Clinician II

$ 98,758

$ 98,758

-3.8%

$ 95,005

1/1/2021

unknown

unknown

4

County of Riverside

Clinical Therapist II - Detention

$ 58,002

$ 92,993

1.9%

$ 94,760

5/1/2021

5/1/2022

2.00%

5

County of Alameda

Behavioral Health Clinician II

$ 88,729

$ 102,259

-11.4%

$ 90,602

6/27/2021

6/26/2022

3.25%

6

County of Orange

Behavioral Health Clinician II

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,758

$ 94,760

% County of San Diego Above/Below

0.3%

4.3%

Number of Matches

5

5

N/C - Non Comparator

Page 369 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Detentions, Processing Assistant Manager









































2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 370 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Emergency Services Dispatcher





















1

County of Santa Clara

Communications Dispatcher III

$ 99,461

$ 120,338

-16.8%

$ 100,122

6/14/2021

6/13/2022

3.00%

2

City and County of San Francisco

Public Safety Communications Dispatcher

$ 95,992

$ 116,688

-17.4%

$ 96,384

7/1/2021

1/8/2022

.50%

3

County of Ventura

Sheriff's Technical Communications Specialist II

$ 63,974

$ 89,563

-0.7%

$ 88,936

8/9/2020

unknown

unknown

4

County of Sacramento

Sheriff's Communication Dispatcher II

$ 72,391

$ 87,988

0.1%

$ 88,076

6/20/2021

1/2/2022

1.00%

5

County of Riverside

Sheriff's 911 Communications Officer II B

$ 52,146

$ 85,940

1.9%

$ 87,573

5/1/2021

5/1/2022

2.00%

6

County of San Mateo

Communications Dispatcher II

$ 83,760

$ 104,768

-17.5%

$ 86,433

10/4/2020

unknown

unknown

7

County of Orange

Radio Dispatcher

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

8

County of Alameda

Emergency Services Dispatcher II

$ 79,955

$ 96,170

-11.4%

$ 85,206

6/27/2021

6/26/2022

3.25%

9

County of Contra Costa

Sheriff's Dispatcher II

$ 78,922

$ 93,646

-11.1%

$ 83,252

7/1/2021

7/1/2022

5.00%





















11

County of Los Angeles

Public Response Dispatcher II

$ 57,133

$ 76,993

-3.8%

$ 74,067

1/1/2021

unknown

unknown

12

County of San Bernardino

Sheriff's Communication Dispatcher II

$ 52,666

$ 72,301

1.9%

$ 73,675

7/31/2021

7/30/2022

3.00%

13

County of Fresno

Communications Dispatcher II

$ 47,606

$ 60,918

4.7%

$ 63,781

7/1/2019

unknown

unknown

14

County of Kern

Sheriff's Dispatcher II

$ 46,608

$ 56,892

1.2%

$ 57,575

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,988

$ 85,633

% County of San Diego Above/Below

-14.3%

-11.3%

Number of Matches

13

13

N/C - Non Comparator

Page 371 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Emergency Services Dispatcher Trainee





















1

County of Ventura

Sheriff's Technical Communications Specialist 1

$ 61,040

$ 85,456

-0.7%

$ 84,858

8/9/2020

unknown

unknown

2

County of Sacramento

Sheriff's Communication Dispatcher 1

$ 65,814

$ 79,991

0.1%

$ 80,071

6/20/2021

1/2/2022

1.00%

3

County of Santa Clara

Communications Dispatcher 1

$ 79,088

$ 95,634

-16.8%

$ 79,568

6/14/2021

6/13/2022

3.00%

4

County of Alameda

Emergency Services Dispatcher 1

$ 67,069

$ 80,234

-11.4%

$ 71,088

6/27/2021

6/26/2022

3.25%

5

County of Orange

Radio DispatcherTrainee

$ 53,622

$ 72,280

-2.0%

$ 70,834

7/2/2021

7/1/2022

3.50%

6

County of Contra Costa

Sheriff's Dispatcher 1

$ 72,051

$ 79,436

-11.1%

$ 70,619

7/1/2021

7/1/2022

5.00%

7

County of San Mateo1

Communications Dispatcher 1

$ 75,794

$ 84,717

-17.5%

$ 69,891

10/4/2020

unknown

unknown

8

County of Riverside

Sheriff's 911 Communications Officer 1

$ 40,909

$ 67,399

1.9%

$ 68,679

5/1/2021

5/1/2022

2.00%

9

County of Los Angeles

Public Response Dispatcher 1

$ 48,556

$ 65,431

-3.8%

$ 62,944

1/1/2021

unknown

unknown

10

County of Fresno

Communications Dispatcher 1

$ 44,148

$ 56,472

4.7%

$ 59,126

7/1/2019

unknown

unknown

11

County of San Bernardino

Sheriff's Communication Dispatcher II Trainee

$ 41,454

$ 55,640

1.9%

$ 56,697

7/31/2021

7/30/2022

3.00%

12

County of Kern

Sheriff's Dispatch Assistant

$40,128

$ 48,984

1.2%

$49,572

4/21/2021

unknown

unknown





















14

City and County of San Francisco

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,858

$ 70,255

% County of San Diego Above/Below

-61.0%

-49.1%

Number of Matches

12

12

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 372 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriffs Fingerprint Examiner





















1

County of Riverside

Fingerprint Examiner II

$ 58,320

$91,164

1.9%

$ 92,896

5/1/2021

5/1/2022

2.00%

2

County of Santa Clara

Latent Fingerprint Examiner II

$92,115

$ 111,457

-16.8%

$ 92,732

6/14/2021

6/13/2022

3.00%

3

County of Contra Costa

Fingerprint Technician II

$ 73,856

$ 92,017

-11.1%

$ 81,803

7/1/2021

7/1/2022

5.00%

4

County of Orange

Forensic Specialist

$ 61,402

$ 82,763

-2.0%

$81,108

7/2/2021

7/1/2022

3.50%

5

County of San Bernardino

Fingerprint Examiner II

$ 53,914

$ 74,090

1.9%

$ 75,497

7/31/2021

7/30/2022

3.00%

6

County of Los Angeles

Automated Fingerprint Identification System Technician II

$ 55,057

$ 74,197

-3.8%

$ 71,378

1/1/2021

unknown

unknown

7

City and County of San Francisco

Fingerprint Technician II

$ 68,952

$ 83,746

-17.4%

$ 69,174

7/1/2021

1/8/2022

.50%

8

County of San Mateo

Sheriff's Identification Technician

$ 66,184

$ 82,762

-17.5%

$ 68,278

12/13/2020

12/12/2021

2-4%

9

County of Alameda

Fingerprint Examiner

$ 58,715

$ 69,830

-11.4%

$ 61,869

6/27/2021

6/26/2022

3.25%





















11

County of Fresno

N/C















12

County of Kern

N/C















13

County of Sacramento

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,763

$ 75,497

% County of San Diego Above/Below

-54.6%

-41.0%

Number of Matches

9

9

N/C - Non Comparator

Page 373 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Investigative Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Civilian Investigator

$ 67,884

$ 91,488

-3.8%

$ 88,011

1/1/2021

unknown

unknown

2

County of Orange

Investigative Assistant - Sheriff

$ 49,358

$ 65,936

-2.0%

$ 64,617

7/2/2021

7/1/2022

3.50%

3

County of San Diego

Sheriff's Investigative Specialist

$ 49,899

$ 61,339



$ 61,339

6/18/2021

unknown

unknown

4

County of Ventura

Investigative Assistant II

$ 38,366

$ 53,899

-0.7%

$ 53,521

12/26/2020

12/27/2021

2.00%

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,936

$ 64,617

% County of San Diego Above/Below

-7.5%

-5.3%

Number of Matches

3

3

N/C - Non Comparator

Page 374 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Licensing Clerk I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Permit Technician Trainee

$ 44,366

$ 59,738

-2.0%

$ 58,543

7/2/2021

7/1/2022

3.50%

2

County of Los Angeles

Sheriff Station Clerk 1

$ 42,462

$ 52,665

-3.8%

$ 50,664

1/1/2021

unknown

unknown

3

County of San Diego

Sheriffs Licensing Clerk 1

$ 35,173





$ 43,160

6/18/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 56,201

$ 54,603

% County of San Diego Above/Below

-30.2%

-26.5%

Number of Matches

2

2

N/C - Non Comparator

Page 375 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Licensing Clerk II

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Permit Technician

$ 56,597

$ 76,274

-2.0%

$ 74,748

7/2/2021

7/1/2022

3.50%

2

County of Los Angeles

Sheriff Station Clerk II

$43,190

$ 59,725

-3.8%

$ 57,456

1/1/2021

unknown

unknown

3

County of Santa Clara

Law Enforcement Clerk

$ 54,207

$ 65,453

-16.8%

$ 54,457

6/14/2021

6/13/2022

3.00%

4

County of San Diego

Sheriffs Licensing Clerk II







$ 48,714

6/18/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 65,453

$ 57,456

% County of San Diego Above/Below

-34.4%

-17.9%

Number of Matches

3

3

N/C - Non Comparator

Page 376 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Licensing Specialist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Senior PermitTechnician

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%



County of San Diego

Sheriff's Licensing Specialist

$ 42,890

$ 52,686



$ 52,686

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,381

$ 85,633

% County of San Diego Above/Below

-65.9%

-62.5%

Number of Matches

1

1

N/C - Non Comparator

Page 377 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Licensing Supervisor |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Supervising Sheriff Station Clerk

$52,146

$ 72,213

-3.8%

$ 69,469

1/1/2021

unknown

unknown

2

County of San Diego

Sheriff's Licensing Supervisor

$ 44,304

$ 54,538



$ 54,538

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,213

$ 69,469

% County of San Diego Above/Below

-32.4%

-27.4%

Number of Matches

1

1

N/C - Non Comparator

Page 378 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Operations Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Sheriff's Operations Supervisor

$ 59,800

$ 73,445

$ 73,445

6/18/2021

unknown

unknown

2

County of Los Angeles

Supervising Sheriff Station Clerk

$ 52,146

$ 72,213

-3.8%

$ 69,469

1/1/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 72,213

$ 69,469

% County of San Diego Above/Below

1.7%

5.4%

Number of Matches

1

1

N/C - Non Comparator

Page 379 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Property & Evidence Custodian





















1

County of San Mateo

Sheriff's Property Officer II

$ 69,970

$ 87,462

-17.5%

$ 72,156

12/13/2020

12/12/2021

2-4%





















3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,462

$ 72,156

% County of San Diego Above/Below

-48.1%

-22.1%

Number of Matches

1

1

N/C - Non Comparator

Page 380 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriffs Property & Evidence Manager





















1

County of San Mateo

Sheriffs Property Manager

$ 109,926

$ 137,444

-17.5%

$ 113,391

12/13/2020

unknown

unknown

2

County of Contra Costa1

[Sheriff's Specialist/Sheriffs Director of Property and Evidence]

$80,123

$ 98,380

-11.1%

$ 87,460

7/1/2021

unknown

unknown





















4

County of Los Angeles

Supervising Evidence and Property Custodian, Sheriff

$ 54,515

$ 75,488

-3.8%

$ 72,619

1/1/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,380

$ 87,460

% County of San Diego Above/Below

-34.1%

-19.2%

Number of Matches

3

3

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 381 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Property & Evidence Specialist I





















1

County of Contra Costa

Sheriffs Aide

$ 55,258

$ 68,846

-11.1%

$ 61,204

7/1/2021

7/1/2022

5.00%

2

County of San Mateo

Sheriff's Property Officer 1

$ 58,405

$ 73,007

-17.5%

$ 60,230

12/13/2020

12/12/2021

2-4%

3

County of Fresno

Property&EvidenceTechnician 1

$ 43,238

$ 55,354

4.7%

$ 57,956

7/1/2019

unknown

unknown

4

County of Los Angeles

Evidence and Property Custodian 1, Sheriff

$ 39,469

$ 54,515

-3.8%

$ 52,443

1/1/2021

unknown

unknown





















6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 62,100

$ 59,093

% County of San Diego Above/Below

-44.4%

-37.4%

Number of Matches

4

4

N/C - Non Comparator

Page 382 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Property & Evidence Specialist II





















1

County of Contra Costa

Sheriffs Specialist

$ 65,129

$ 81,144

-11.1%

$ 72,137

7/1/2021

7/1/2022

5.00%

2

County of Orange

Sheriff's Correctional Services Assistant

$ 52,250

$ 69,971

-2.0%

$ 68,572

7/2/2021

7/1/2022

3.50%

3

County of Fresno

Property&EvidenceTechnician II

$ 50,024

$ 63,986

4.7%

$ 66,993

7/1/2019

unknown

unknown

4

County of Alameda

Sheriffs Technician

$ 59,854

$ 71,429

-11.4%

$ 63,286

6/27/2021

6/26/2022

3.25%

5

City and County of San Francisco

Sheriffs Property Keeper

$ 62,192

$ 75,634

-17.4%

$ 62,474

7/1/2021

1/8/2022

.50%

6

County of Los Angeles

Evidence and Property Custodian II, Sheriff

$ 46,353

$ 64,152

-3.8%

$ 61,714

1/1/2021

unknown

unknown

7

County of Santa Clara

Sheriffs Technician

$ 54,991

$ 66,425

-16.8%

$ 55,265

6/14/2021

6/13/2022

3.00%





















9

County of Kern

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 69,971

$ 63,286

% County of San Diego Above/Below

-41.3%

-27.8%

Number of Matches

7

7

N/C - Non Comparator

Page 383 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Property Investigator









































2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 384 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Sheriff's Range Guard	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Sheriff's Range Master

$ 36,068

$53,120

1.9%

$ 54,129

5/1/2021

5/1/2022

2.00%



County of San Diego

Sheriff s Range Guard

$ 37,419

$ 45,947



$ 45,947

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$53,120

$ 54,129

% County of San Diego Above/Below

-15.6%

-17.8%

Number of Matches

1

1

N/C - Non Comparator

Page 385 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Records & Identification Clerk I





















1

County of San Mateo

Sheriff's Criminal Records Technician 1

$ 52,727

$ 65,893

-17.5%

$ 54,362

10/4/2020

unknown

unknown

2

County of Fresno

Identification Technician 1

$ 38,428

$ 49,166

4.7%

$ 51,477

7/1/2019

unknown

unknown

3

County of Orange

Sheriff's Record Trainee

$ 38,771

$ 51,064

-2.0%

$ 50,043

7/2/2021

7/1/2022

3.50%

4

County of Los Angeles

Records System Clerk 1, Sheriff

$ 37,593

$ 51,886

-3.8%

$ 49,914

1/1/2021

unknown

unknown

5

County of Ventura

Sheriff's Records Technician 1

$ 35,851

$ 50,191

-0.7%

$ 49,840

12/27/2020

12/26/2021

2.00%

6

County of Riverside

Sheriff's Records/Warrants Assistant 1

$ 30,838

$ 48,156

1.9%

$ 49,071

5/1/2021

5/1/2022

2.00%

7

County of San Bernardino

Sheriff's Records Clerk

$ 33,779

$ 46,363

1.9%

$ 47,244

7/31/2021

7/30/2022

3.00%

8

County of Sacramento

Sheriff's Records Specialist 1

$ 37,438

$45,518

0.1%

$ 45,564

6/21/2020

unknown

unknown

9

County of Kern

Identification Technician 1

$ 36,324

$ 44,340

1.2%

$ 44,872

4/21/2021

unknown

unknown





















11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Contra Costa

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 49,166

$ 49,840

% County of San Diego Above/Below

-13.9%

-15.5%

Number of Matches

9

9

N/C - Non Comparator

Page 386 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Records & Identification Clerk II





















1

County of Santa Clara

Law Enforcement RecordsTechnician

$ 63,180

$ 76,336

-16.8%

$ 63,512

6/14/2021

6/13/2022

3.00%

2

County of Fresno

Identification Technician II

$ 43,238

$ 55,345

4.7%

$ 57,946

7/1/2019

unknown

unknown

3

County of San Mateo

Sheriffs Criminal RecordsTechnician II

$ 55,785

$ 69,762

-17.5%

$ 57,554

10/4/2020

unknown

unknown

4

County of Los Angeles

Records System Clerk II, Sheriff

$ 42,981

$ 59,428

-3.8%

$ 57,170

1/1/2021

unknown

unknown

5

County of Ventura

Sheriffs RecordsTechnician II

$ 40,584

$ 56,818

-0.7%

$ 56,420

12/27/2020

12/26/2021

2.00%

6

County of Riverside

Sheriffs Records/Warrants Assistant II

$ 34,272

$ 53,529

1.9%

$ 54,547

5/1/2021

5/1/2022

2.00%

7

County of Orange

Sheriff's Record Technician

$ 40,581

$ 53,768

-2.0%

$ 52,693

7/2/2021

7/1/2022

3.50%

8

County of Sacramento

Sheriff's Records Specialist II

$ 42,031

$ 51,114

0.1%

$ 51,165

6/21/2020

unknown

unknown





















10

County of Kern

Identification Technician 1

$ 36,324

$ 44,340

1.2%

$ 44,872

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Alameda

N/C















13

County of Contra Costa

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 55,345

$ 56,420

% County of San Diego Above/Below

-13.6%

-15.8%

Number of Matches

9

9

N/C - Non Comparator

Page 387 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's F

iecords & Identification Supervisor





















1

County of Santa Clara

Law Enforcement Records Supervisor

$ 96,427

$ 117,254

-16.8%

$ 97,555

6/28/2021

6/27/2022

3.00%

2

County of San Mateo

Sheriff's Criminal Records Supervisor

$ 73,131

$ 91,435

-17.5%

$ 75,434

10/4/2020

unknown

unknown

3

County of Riverside

Sheriff's Records/Warrants Supervisor A

$ 43,487

$ 67,836

1.9%

$ 69,125

5/1/2021

5/1/2022

2.00%

4

County of Los Angeles

Supervising Records System Clerk, Sheriff

$ 50,502

$ 69,931

-3.8%

$ 67,273

1/1/2021

unknown

unknown

5

County of Ventura

Sheriff's Records Supervisor 1

$ 46,900

$ 65,660

-0.7%

$ 65,200

12/26/2020

12/27/2021

2.00%

6

County of Sacramento

Sheriff's Records Supervisor

$ 52,325

$ 63,600

0.1%

$ 63,664

6/20/2021

1/2/2022

1.00%

7

County of San Bernardino

Sheriff's Records Supervisor

$ 44,658

$ 61,464

1.9%

$ 62,632

7/31/2021

7/30/2022

3.00%





















9

City and County of San Francisco

N/C















10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Kern

N/C















14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,836

$ 67,273

% County of San Diego Above/Below

-22.4%

-21.4%

Number of Matches

7

7

N/C - Non Comparator

Page 388 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriffs Senior Fingerprint Examiner





















1

County of Santa Clara

Latent Fingerprint Examiner III

$ 103,653

$ 125,409

-16.8%

$ 104,341

6/14/2021

6/13/2022

3.00%

2

County of Orange

Senior Forensic Specialist

$ 76,274

$ 102,814

-2.0%

$ 100,758

7/2/2021

7/1/2022

3.50%

3

County of Riverside

Supervising Fingerprint Examiner

$ 59,968

$ 98,777

1.9%

$ 100,654

5/1/2021

5/1/2022

2.00%

4

County of Contra Costa

Supervising Fingerprint Technician

$ 83,836

$ 104,451

-11.1%

$92,857

7/1/2021

7/1/2022

5.00%

5

County of Alameda

Identification Supervisor

$ 80,288

$ 97,178

-11.4%

$ 86,099

11/1/2020

10/31/2021

2.00%

6

County of San Mateo

Supervising Sheriff's Identification Technician

$ 76,210

$95,221

-17.5%

$ 78,557

12/13/2020

12/12/2021

2-4%

7

County of Los Angeles

Automated Fingerprint Identification System Operations Supervisor

$ 58,128

$ 78,331

-3.8%

$ 75,354

1/1/2021

unknown

unknown

8

City and County of San Francisco

Fingerprint Technician III

$ 74,152

$ 90,142

-17.4%

$ 74,457

7/1/2021

1/8/2022

.50%





















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 97,977

$ 89,478

% County of San Diego Above/Below

-53.9%

-40.6%

Number of Matches

8

8

N/C - Non Comparator

Page 389 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Sheriff's Supervisor Helicopter/Airplane Mechanic





















1

County of Ventura

Chief Flelicopter Maintenance Technician

$ 102,290

$ 107,416

-0.7%

$ 106,664

1/10/2021

1/9/2022

2.00%





















3

County of Orange

Sheriff's Flelicopter Mechanic - Inspector

$ 72,301

$ 97,469

-2.0%

$ 95,519

7/2/2021

7/1/2022

3.50%

4

County of San Bernardino

Sheriff's Aviation Mechanic

$ 64,480

$ 88,608

1.9%

$ 90,292

7/31/2021

7/30/2022

3.00%

5

County of Sacramento

Supervising Flelicopter Mechanic

$ 74,145

$ 81,745

0.1%

$ 81,827

6/21/2020

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 93,038

$92,905

% County of San Diego Above/Below

10.7%

10.8%

Number of Matches

4

4

N/C - Non Comparator

Page 390 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Social Services Aide





















1

County of Santa Clara

Program Services Aide

$ 67,469

$81,559

-16.8%

$ 67,857

6/14/2021

6/13/2022

3.00%

2

County of Alameda1

[Community Outreach Worker 1/ Community Outreach Worker II]

$ 53,801

$ 64,672

-11.4%

$ 57,299

6/27/2021

6/26/2022

3.25%

3

County of Los Angeles

Human Services Aide

$41,041

$ 55,194

-3.8%

$ 53,096

1/1/2021

unknown

unknown

4

County of Ventura

HS Case Aide II

$ 38,517

$ 51,362

-0.7%

$ 51,002

12/27/2020

12/26/2021

2.00%

5

County of Orange

Social Worker Assistant

$ 38,626

$ 51,397

-2.0%

$ 50,369

7/2/2021

7/1/2022

3.50%

6

County of San Bernardino

Social Service Aide

$ 33,322

$ 45,802

1.9%

$46,672

7/31/2021

7/30/2022

3.00%

7

County of Riverside

Social Service Assistant

$ 30,028

$ 44,364

1.9%

$45,207

5/1/2021

5/1/2022

2.00%

8

County of Sacramento

Human Services Assistant

$ 36,477

$ 44,328

0.1%

$44,372

6/21/2020

unknown

unknown





















10

County of Fresno

Social Worker Aide II

$ 29,692

$ 36,842

4.7%

$ 38,574

11/2/2020

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Contra Costa

N/C















13

County of Kern

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 51,362

$ 50,369

% County of San Diego Above/Below

-22.7%

-20.4%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The
salary displayed is the same for both matches.

Page 391 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Social Work Supervisor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Supervising Children's Social Workers

$ 83,516

$ 112,548

-3.8%

$ 108,271

1/1/2021

unknown

unknown

2

County of Alameda

Social Work Supervisor

$ 97,032

$ 116,771

-11.4%

$ 103,459

12/27/2020

12/26/2021

3.00%

3

County of Santa Clara

Social Work Supervisor

$ 102,667

$ 124,326

-16.8%

$ 103,439

6/14/2021

6/13/2022

3.00%

4

County of San Mateo

Social Work Supervisor

$ 99,110

$ 123,862

-17.5%

$ 102,186

10/4/2020

unknown

unknown

5

County of Riverside

Social Services Supervisor II

$ 60,713

$ 94,788

1.9%

$ 96,589

5/1/2021

5/1/2022

2.00%

6

City and County of San Francisco

Social Work Supervisor

$ 91,442

$ 111,150

-17.4%

$ 91,810

7/1/2021

1/8/2022

.50%

7

County of Contra Costa

Social Work Supervisor 1

$ 80,548

$ 97,895

-11.1%

$ 87,029

7/1/2021

unknown

unknown

8

County of Fresno

Social Work Supervisor

$ 64,350

$ 82,290

4.7%

$ 86,158

11/2/2020

unknown

unknown

9

County of Sacramento

Human Services Supervisor

$ 69,468

$ 84,439

0.1%

$ 84,523

6/21/2020

unknown

unknown

10

County of Orange

Social Services Supervisor 1

$ 63,440

$ 85,613

-2.0%

$ 83,901

7/2/2021

7/1/2022

3.50%

11

County of San Bernardino

Supervising Social Worker

$ 58,427

$ 80,309

1.9%

$ 81,835

7/31/2021

7/30/2022

3.00%

12

County of San Diego

Social Work Supervisor

$ 63,606

$ 78,146



$ 78,146

6/18/2021

unknown

unknown

13

County of Kern

Social Service Supervisor 1

$ 58,332

$ 71,208

1.2%

$ 72,062

4/21/2021

unknown

unknown

14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 96,342

$ 89,419

% County of San Diego Above/Below

-23.3%

-14.4%

Number of Matches

12

12

N/C - Non Comparator

Page 392 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Social Worker I





















1

County of Contra Costa

Social Worker

$ 69,561

$ 84,551

-11.1%

$ 75,166

7/1/2021

unknown

unknown

2

County of Santa Clara

Social Worker 1

$ 74,310

$ 89,796

-16.8%

$ 74,710

6/14/2021

6/13/2022

3.00%

3

County of Orange

Social Worker 1

$ 51,397

$ 68,827

-2.0%

$ 67,451

7/2/2021

7/1/2022

3.50%

4

County of Alameda

Social Worker 1

$ 63,522

$ 75,743

-11.4%

$ 67,108

6/27/2021

6/26/2022

3.25%

5

County of San Mateo1

Social Worker 1

$ 70,656

$ 78,997

-17.5%

$ 65,172

10/4/2020

unknown

unknown

6

County of Los Angeles

Children's Social Worker 1

$ 52,275

$ 66,731

-3.8%

$ 64,195

1/1/2021

unknown

unknown

7

County of San Bernardino

Social Worker II Trainee

$ 42,536

$ 57,075

1.9%

$ 58,160

7/31/2021

7/30/2022

3.00%

8

County of Riverside

Social Services Practitioner 1

$ 37,842

$ 55,944

1.9%

$ 57,007

5/1/2021

5/1/2022

2.00%

9

County of Fresno

Social Worker 1

$ 40,820

$ 52,234

4.7%

$ 54,689

11/2/2020

unknown

unknown





















11

County of Ventura

Social Worker 1

$ 36,887

$ 51,622

-0.7%

$ 51,260

12/26/2020

12/27/2021

2.00%

12

County of Kern

Social Service Worker 1

$ 39,924

$ 48,744

1.2%

$ 49,329

4/21/2021

unknown

unknown

13

City and County of San Francisco

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,731

$ 64,195

% County of San Diego Above/Below

-22.1%

-17.4%

Number of Matches

11

11

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 3.

Page 393 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Social Worker II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Social Worker II

$ 81,827

$ 99,045

-16.8%

$ 82,406

6/14/2021

6/13/2022

3.00%

2

County of Contra Costa

Social Worker II

$ 78,259

$ 86,280

-11.1%

$ 76,703

7/1/2021

unknown

unknown

3

County of Los Angeles

Children's Social Worker II

$ 61,218

$ 78,136

-3.8%

$ 75,167

1/1/2021

unknown

unknown

4

County of San Mateo

Social Worker II

$ 71,384

$ 89,230

-17.5%

$ 73,615

10/4/2020

unknown

unknown

5

County of Orange

Social Worker II

$ 55,578

$ 74,651

-2.0%

$ 73,158

7/2/2021

7/1/2022

3.50%

6

County of Alameda

Social Worker II

$ 69,159

$ 82,307

-11.4%

$ 72,924

6/27/2021

6/26/2022

3.25%

7

City and County of San Francisco

Social Worker

$ 70,980

$ 86,268

-17.4%

$ 71,257

7/1/2021

1/8/2022

.50%

8

County of San Bernardino

Social Worker II

$ 49,317

$ 67,662

1.9%

$ 68,948

7/31/2021

7/30/2022

3.00%

9

County of Riverside

Social Services Practitioner II

$ 43,379

$ 64,160

1.9%

$ 65,379

5/1/2021

5/1/2022

2.00%

10

County of Fresno

Social Worker II

$ 44,980

$ 57,538

4.7%

$ 60,242

11/2/2020

unknown

unknown

11

County of Ventura

Social Worker II

$ 46,548

$ 59,376

-0.7%

$ 58,961

12/26/2020

12/27/2021

2.00%

12

County of San Diego

Social Worker II

$ 46,717

$ 57,491



$ 57,491

6/18/2021

unknown

unknown

13

County of Kern

Social Service Worker II

$ 41,976

$ 51,240

1.2%

$ 51,855

4/21/2021

unknown

unknown

14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,394

$ 72,091

% County of San Diego Above/Below

-32.9%

-25.4%

Number of Matches

12

12

N/C - Non Comparator

Page 394 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Social Worker III





















1

County of Los Angeles

Children's Social Worker III

$ 66,896

$ 100,478

-3.8%

$ 96,660

1/1/2021

unknown

unknown

2

County of Santa Clara

Social Worker III

$ 90,293

$ 109,252

-16.8%

$ 90,898

6/14/2021

6/13/2022

3.00%

3

County of Alameda1

[Social Worker III/ Social Work Supervisor]

$ 84,776

$ 101,666

-11.4%

$ 90,076

12/27/2020

12/26/2021

3.00%

4

City and County of San Francisco

Social Work Specialist

$ 87,540

$ 106,416

-17.4%

$ 87,900

7/1/2021

1/8/2022

.50%

5

County of San Mateo

Social Worker III

$ 84,197

$ 105,204

-17.5%

$ 86,794

10/4/2020

unknown

unknown

6

County of Riverside

Social Services Practitioner III

$ 53,476

$ 83,439

1.9%

$ 85,024

5/1/2021

5/1/2022

2.00%

7

County of Contra Costa2

[Social Worker ll/Social Work Supervisor 1]

$ 79,399

$ 92,088

-11.1%

$ 81,866

7/1/2021

unknown

unknown

8

County of Sacramento

Human Services Social Worker

$ 60,322

$ 73,310

0.1%

$ 73,383

6/21/2020

unknown

unknown

9

County of Ventura

Social Worker IV

$ 50,856

$ 71,280

-0.7%

$ 70,781

12/26/2020

12/27/2021

2.00%

10

County of Fresno

Social Worker III

$ 50,570

$ 64,714

4.7%

$ 67,756

11/2/2020

unknown

unknown





















12

County of Kern

Social Service Worker III

$ 48,744

$ 59,508

1.2%

$ 60,222

4/21/2021

unknown

unknown

13

County of Orange

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 92,088

$ 85,024

% County of San Diego Above/Below

-38.4%

-27.8%

Number of Matches

11

11

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at
the comparator agency. The salary displayed is an average of the matches.

2	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 395 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Solid Waste Site Supervisor |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Landfill Operations Superintendent

$ 77,958

$ 104,749

-2.0%

$ 102,654

7/2/2021

7/1/2022

3.50%

2

County of San Diego

Solid Waste Site Supervisor

$ 66,165

$ 81,266



$ 81,266

6/18/2021

unknown

unknown

3

County of Riverside

Solid Waste Landfill Supervisor

$ 48,439

$ 71,710

1.9%

$ 73,072

5/1/2021

5/1/2022

2.00%

4

County of Fresno

Disposal Site Lead Supervisor

$ 48,204

$ 61,724

4.7%

$ 64,625

11/2/2020

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 71,710

$ 73,072

% County of San Diego Above/Below

11.8%

10.1%

Number of Matches

3

3

N/C - Non Comparator

Page 396 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Staff Accountant	|

_ „	_	..	Annual _ „ „ Geographic Adjusted	*	Next Salary

Rank	Comparator Agency	Classification Title	... .	Top Annual	.. „	„ Effective „	Percentage

Minimum	Differential Top Annual „ ^	Increase

Date	Increase

1

County of Sacramento

Accountant

$ 65,960

$ 80,179

0.1%

$ 80,259

6/21/2020

unknown

unknown

2

County of Orange

Accountant/Auditor 1

$ 62,712

$ 77,958

-2.0%

$ 76,399

7/2/2021

7/1/2022

3.50%

3

City and County of San Francisco

Accountant 1

$ 75,084

$ 91,260

-17.4%

$ 75,381

7/1/2021

1/8/2022

.50%

4

County of Ventura

Accountant 1

$ 53,213

$ 74,498

-0.7%

$ 73,976

12/27/2020

12/26/2021

2.00%

5

County of Riverside

Accountant 1

$46,717

$ 69,077

1.9%

$ 70,390

5/1/2021

5/1/2022

2.00%

6

County of Alameda1

[Accounting Technician/ Accountant]

$ 67,954

$ 77,957

-11.4%

$ 69,070

6/27/2021

6/26/2022

3.25%

7

County of San Diego

Staff Accountant

$ 49,712

$ 67,350



$ 67,350

6/18/2021

unknown

unknown

8

County of Santa Clara

Accountant 1

$ 66,810

$ 80,714

-16.8%

$ 67,154

6/14/2021

6/13/2022

3.00%

9

County of San Mateo

Accountant 1

$ 64,936

$ 81,181

-17.5%

$ 66,974

10/4/2020

unknown

unknown

10

County of Contra Costa

Accountant 1

$ 60,799

$ 73,901

-11.1%

$ 65,698

7/1/2021

unknown

unknown

11

County of Los Angeles

Accountant 1

$ 56,289

$ 64,468

-3.8%

$ 62,019

1/1/2021

unknown

unknown

12

County of Fresno

Accountant 1

$ 46,462

$ 56,472

4.7%

$ 59,126

10/17/2019

unknown

unknown

13

County of San Bernardino

Accountant 1

$ 40,539

$ 54,392

1.9%

$ 55,425

7/31/2021

7/30/2022

3.00%

14

County of Kern

Accountant 1

$ 43,248

$ 52,800

1.2%

$ 53,434

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 74,498

$ 67,154

% County of San Diego Above/Below

-10.6%

0.3%

Number of Matches

13

13

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 397 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Staff Nurse





















1

City and County of San Francisco

Registered Nurse

$ 141,518

$ 185,848

-17.4%

$ 153,510

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Registered Nurse

$ 124,777

$ 155,829

-11.1%

$ 138,532

1/1/2021

unknown

unknown

3

County of Los Angeles

Public Health Nurse

$ 90,609

$ 135,631

-3.8%

$ 130,477

1/1/2021

unknown

unknown

4

County of Santa Clara

Public Health Nurse II

$ 128,509

$ 155,780

-16.8%

$ 129,609

6/14/2021

6/13/2022

3.00%

5

County of San Mateo3

[Ambulatory Care Nurse/Community Mental Health Nurse]

$ 133,679

$ 149,445

-17.5%

$ 123,292

2/7/2021

unknown

unknown

6

County of Alameda1

[Registered Nurse 1/ Registered Nurse II]

$ 104,655

$ 118,966

-11.4%

$ 105,404

6/27/2021

6/26/2022

3.25%

7

County of San Bernardino

Registered Nurse ll-ARMC/Mental Health Nurse II

$ 75,858

$ 101,982

1.9%

$ 103,920

8/15/2020

unknown

unknown

8

County of Ventura

Registered Nurse II

$86,194

$ 103,076

-0.7%

$ 102,354

4/4/2021

4/17/2022

3.25%

9

County of Sacramento

Registered Nurse II

$ 80,659

$ 98,052

0.1%

$98,150

8/2/2020

unknown

unknown

10

County of Fresno2

[Staff Nurse II / Mental Health Nurse II]

$ 76,414

$ 92,872

4.7%

$ 97,237

11/2/2020

unknown

unknown

11

County of Riverside

Registered Nurse II

$ 76,023

$ 93,416

1.9%

$95,190

5/1/2021

5/1/2022

2.00%





















13

County of Orange

Staff Nurse

$ 62,712

$ 84,469

-2.0%

$ 82,779

7/2/2021

7/1/2022

3.50%

14

County of Kern

Staff Nurse

$ 59,808

$ 73,008

1.2%

$ 73,884

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,076

$ 103,920

% County of San Diego Above/Below

-15.0%

-16.0%

Number of Matches

13

13

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

2	- County of Fresno: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

3	- County of San Mateo: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches. Bottom of range is step 3 for higher paid class.

Page 398 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Statistician





















1

County of Los Angeles

Data Scientist

$ 100,478

$ 135,409

-3.8%

$ 130,264

1/1/2021

unknown

unknown

2

County of San Bernardino

Statistical Analyst

$ 62,421

$ 85,842

1.9%

$87,473

7/31/2021

7/30/2022

3.00%

3

County of Orange

Research Analyst III

$ 65,354

$ 88,088

-2.0%

$86,326

7/2/2021

7/1/2022

3.50%

4

City and County of San Francisco

Statistician

$82,810

$ 100,646

-17.4%

$83,134

7/1/2021

1/8/2022

.50%





















6

County of Alameda1

[Management Analyst Assistant/ Management Analyst]

$ 68,734

$ 88,494

-11.4%

$ 78,405

12/27/2020

12/26/2021

3.00%

7

County of Riverside

Statistician

$40,730

$ 60,226

1.9%

$ 61,370

5/1/2021

5/1/2022

2.00%

8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$88,291

$84,730

% County of San Diego Above/Below

-7.8%

-3.5%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 399 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Stock Clerk	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Assistant Storekeeper

$ 55,354

$ 67,288

-17.4%

$ 55,580

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Warehouse Worker 1

$ 40,644

$ 54,648

-3.8%

$ 52,571

1/1/2021

unknown

unknown

3

County of Santa Clara

Warehouse Materials Handler

$ 50,885

$ 61,320

-16.8%

$ 51,019

6/14/2021

6/13/2022

3.00%

4

County of Alameda

Supply Clerk 1

$ 46,254

$ 55,049

-11.4%

$ 48,773

6/27/2021

6/26/2022

3.25%

5

County of Orange

Store Clerk

$ 37,606

$ 49,650

-2.0%

$ 48,657

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Stock Clerk

$30,138

$ 47,007

1.9%

$ 47,901

5/1/2021

5/1/2022

2.00%

7

County of Sacramento

Stock Clerk

$ 38,252

$ 46,500

0.1%

$ 46,547

6/21/2020

unknown

unknown

8

County of Ventura

Inventory Management Assistant II

$ 32,481

$ 45,406

-0.7%

$ 45,089

12/27/2020

12/26/2021

2.00%

9

County of San Mateo

Storekeeper 1

$ 43,284

$ 54,079

-17.5%

$ 44,615

10/4/2020

unknown

unknown

10

County of Contra Costa

Storeroom Clerk

$ 40,272

$ 48,952

-11.1%

$ 43,518

7/1/2021

unknown

unknown

11

County of San Bernardino

Storekeeper

$ 30,243

$ 41,205

1.9%

$ 41,988

7/31/2021

7/30/2022

3.00%

12

County of San Diego

Stock Clerk

$ 31,554

$ 38,834



$ 38,834

6/18/2021

unknown

unknown

13

County of Kern

Stock Clerk

$ 29,304

$ 35,784

1.2%

$ 36,213

4/21/2021

unknown

unknown

14

County of Fresno

Stock Clerk

$ 30,264

$ 33,358

4.7%

$ 34,926

11/2/2020

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 48,952

$ 46,547

% County of San Diego Above/Below

-26.1%

-19.9%

Number of Matches

13

13

N/C - Non Comparator

Page 400 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Storekeeper	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Storekeeper

$ 60,736

$ 73,788

-17.4%

$ 60,949

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Materials Supply Specialist

$ 58,916

$ 71,610

-16.8%

$ 59,580

6/14/2021

6/13/2022

3.00%

3

County of Los Angeles

Warehouse Worker II

$ 45,240

$ 60,912

-3.8%

$ 58,597

1/1/2021

unknown

unknown

4

County of Contra Costa

Storekeeper

$ 51,942

$ 63,136

-11.1%

$ 56,128

7/1/2021

unknown

unknown

5

County of Orange

Storekeeper 1

$ 42,224

$ 56,597

-2.0%

$ 55,465

7/2/2021

7/1/2022

3.50%

6

County of Sacramento

Storekeeper 1

$ 44,725

$ 54,351

0.1%

$ 54,405

6/21/2020

unknown

unknown

7

County of San Mateo

Storekeeper II

$ 52,727

$ 65,914

-17.5%

$ 54,379

10/4/2020

unknown

unknown

8

County of Riverside

Storekeeper

$ 33,828

$ 52,818

1.9%

$ 53,822

5/1/2021

5/1/2022

2.00%

9

County of Alameda1

[Supply Clerk 11/ Storekeeper 1]

$ 50,544

$ 60,489

-11.4%

$ 53,593

6/27/2021

6/26/2022

3.25%

10

County of San Bernardino

Stores Specialist

$ 34,778

$ 47,798

1.9%

$ 48,707

7/31/2021

7/30/2022

3.00%

11

County of Ventura

Inventory Management Assistant III

$ 34,900

$ 48,805

-0.7%

$ 48,463

12/27/2020

12/26/2021

2.00%

12

County of San Diego

Storekeeper

$ 35,797

$ 44,054



$ 44,054

6/18/2021

unknown

unknown

13

County of Kern

Storekeeper 1

$ 29,460

$ 35,964

1.2%

$ 36,396

4/21/2021

unknown

unknown

14

County of Fresno

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 58,543

$ 54,392

% County of San Diego Above/Below

-32.9%

-23.5%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 401 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Storekeeper II (T)	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Orange

Storekeeper II

$ 47,154

$ 62,899

-2.0%

$ 61,641

7/2/2021

7/1/2022

3.50%

2

City and County of San Francisco

Storekeeper

$ 60,736

$ 73,788

-17.4%

$ 60,949

7/1/2021

1/8/2022

.50%

3

County of Los Angeles

Warehouse Worker II

$ 45,240

$ 60,912

-3.8%

$ 58,597

1/1/2021

unknown

unknown

4

County of Contra Costa

Storekeeper

$ 51,942

$ 63,136

-11.1%

$ 56,128

7/1/2021

unknown

unknown

5

County of San Mateo

Storekeeper II

$ 52,727

$ 65,914

-17.5%

$ 54,379

10/4/2020

unknown

unknown

6

County of Riverside

Storekeeper

$ 33,828

$ 52,818

1.9%

$ 53,822

5/1/2021

5/1/2022

2.00%

7

County of Alameda1

[Supply Clerk 11/ Storekeeper 1]

$ 50,544

$ 60,489

-11.4%

$ 53,593

6/27/2021

6/26/2022

3.25%

8

County of San Diego

Storekeeper II (T)

$ 39,645

$ 48,693



$ 48,693

6/18/2021

unknown

unknown

9

County of Ventura

Inventory Management Assistant III

$ 34,900

$ 48,805

-0.7%

$ 48,463

12/27/2020

12/26/2021

2.00%

10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Sacramento

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 61,906

$ 55,254

% County of San Diego Above/Below

-27.1%

-13.5%

Number of Matches

8

8

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 402 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Substance Abuse Assessor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Public Defender Client Services Specialist

$ 73,327

$ 89,130

-11.1%

$ 79,237

7/1/2021

unknown

unknown



County of San Diego

Substance Abuse Assessor







$ 76,378

6/18/2021

unknown

unknown

3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 89,130

$ 79,237

% County of San Diego Above/Below

-16.7%

-3.7%

Number of Matches

1

1

N/C - Non Comparator

Page 403 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Agricultural/Standards Inspector





















1

County of San Mateo2

[Biologist/Standards Specialist Ill/Deputy Director Of Agricultural Services]

$ 98,424

$ 123,040

-17.5%

$ 101,508

12/13/2020

unknown

unknown





















3

County of Contra Costa

Deputy Agriculture Commissioner

$ 89,631

$ 108,947

-11.1%

$ 96,854

7/1/2021

unknown

unknown

4

County of Alameda1

[Agricultural and Standards Investigator III/ Deputy Agricultural Commissioner/ Sealer of Weights and Measures]

$ 88,362

$ 106,278

-11.4%

$ 94,163

12/27/2020

unknown

unknown

5

County of Santa Clara

Supervising Agricultural Biologist

$ 91,327

$ 111,060

-16.8%

$ 92,402

6/28/2021

6/27/2022

3.00%

6

County of Ventura

Supervising Agricultural Inspector/Biologist

$ 62,884

$ 88,038

-0.7%

$ 87,422

12/26/2020

12/27/2021

2.00%

7

County of Riverside

Supervising Agricultural & Standards Investigator

$ 57,392

$ 84,970

1.9%

$ 86,584

5/1/2021

5/1/2022

2.00%

8

County of San Bernardino

Supervising Agricultural/Standards Officer

$ 59,883

$ 82,326

1.9%

$ 83,891

7/31/2021

7/30/2022

3.00%

9

County of Fresno

Supervising Agricultural/Standards Specialist

$ 64,870

$ 78,858

4.7%

$ 82,564

4/19/2021

unknown

unknown

10

County of Kern

Supervising Agricultural Biologist/Weights and Measures Inspector

$ 58,620

$71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

11

City and County of San Francisco

N/C















12

County of Los Angeles

N/C















13

County of Orange

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,038

$ 87,422

% County of San Diego Above/Below

9.2%

9.9%

Number of Matches

9

9

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary displayed is an average of the matches.

Page 404 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Air Quality Inspector*





















1

Sacramento Metropolitan Air Quality Management District

Program Supervisor

$ 101,971

$ 136,655

0.1%

$ 136,792

7/1/2021

unknown

unknown

2

Bay Area Air Quality Management District

Supervising Air Quality Inspector

$ 103,939

$ 126,339

-17.4%

$ 104,356

11/8/2020

unknown

Unknown





















4

South Coast Air Quality Management District

Supervising Air Quality Inspector

$ 78,768

$ 106,644

-2.8%

$ 103,658

1/1/2020

unknown

unknown

5

County of Contra Costa

N/C















6

County of Orange

N/C















7

County of Ventura

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 126,339

$ 104,356

% County of San Diego Above/Below

-21.4%

-0.2%

Number of Matches

3

3

N/C - Non Comparator

Page 405 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Air Resources Specialist* |





















1

Sacramento Metropolitan Air Quality Management District

Program Supervisor

$ 101,971

$ 136,655

0.1%

$ 136,792

7/1/2021

unknown

unknown

2

South Coast Air Quality Management District

Supervising Air Quality Engineer

$ 97,944

$ 131,628

-2.8%

$ 127,942

1/1/2020

unknown

unknown

3

Bay Area Air Quality Management District

Supervising Staff Specialist

$ 120,322

$ 146,253

-17.4%

$ 120,805

11/8/2020

unknown

Unknown













S 120,037

6/18/2021

unknown

unknown

5

County of Orange

N/C















6

County of Ventura

N/C















7

County of Contra Costa

N/C















8

San Luis Obispo County Air Pollution Control District

N/C















9

Imperial County Air Pollution Control District

N/C















10

County of Sacramento

N/C















11

City and County of San Francisco

N/C















12

County of Santa Clara

N/C















13

County of Los Angeles

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Alameda

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 136,655

$ 127,942

% County of San Diego Above/Below

-13.8%

-6.6%

Number of Matches

3

3

N/C - Non Comparator

Page 406 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Animal Care Attendant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Contra Costa

Animal Center Operations Supervisor

$ 68,615

$ 83,402

-11.1%

$ 74,144

7/1/2021

unknown

unknown

2

County of Riverside

Animal Services Supervisor

$ 43,102

$ 67,259

1.9%

$ 68,537

5/1/2021

5/1/2022

2.00%

3

City and County of San Francisco

Animal Care Assistant Supervisor

$ 63,752

$ 77,506

-17.4%

$ 64,020

7/1/2021

1/8/2022

.50%

4

County of Orange

Supervising Animal Care Attendant

$ 48,090

$ 64,813

-2.0%

$ 63,517

7/2/2021

7/1/2022

3.50%

5

County of San Diego

Supervising Animal Care Attendant

$ 49,317

$ 60,653



$ 60,653

6/18/2021

unknown

unknown

6

County of Kern

Senior Animal Care Worker

$ 31,896

$ 38,940

1.2%

$ 39,407

4/21/2021

unknown

unknown

7

County of Alameda

N/C















8

County of Fresno

N/C















9

County of Los Angeles

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,259

$ 64,020

% County of San Diego Above/Below

-10.9%

-5.6%

Number of Matches

5

5

N/C - Non Comparator

Page 407 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Animal Control Officer





















1

County of Santa Clara

Animal Services Field Manager

$ 105,756

$ 128,602

-16.8%

$ 106,997

6/28/2021

6/27/2022

3.00%

2

County of Orange

Supervising Animal Control Officer

$ 68,432

$ 92,248

-2.0%

$ 90,403

7/2/2021

7/1/2022

3.50%

3

County of Sacramento

Supervising Animal Control Officer

$ 69,050

$ 83,917

0.1%

$ 84,001

6/22/2020

unknown

unknown

4

City and County of San Francisco

Animal Control Supervisor

$ 80,210

$ 97,500

-17.4%

$ 80,535

7/1/2021

1/8/2022

.50%

5

County of Los Angeles

Animal Control Officer IV

$ 60,319

$ 81,282

-3.8%

$ 78,193

1/1/2021

unknown

unknown





















7

County of Ventura

Supervising Animal Control Officer

$ 47,267

$ 66,113

-0.7%

$ 65,650

12/26/2020

12/27/2021

2.00%

8

County of San Bernardino

Supervising Animal Control Officer 1

$ 42,037

$ 57,762

1.9%

$ 58,859

7/31/2021

7/30/2022

3.00%

9

County of Kern

Senior Animal Control Officer

$ 38,364

$ 46,836

1.2%

$ 47,398

4/21/2021

unknown

unknown

10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Riverside

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,599

$ 79,364

% County of San Diego Above/Below

-16.3%

-11.7%

Number of Matches

8

8

N/C - Non Comparator

Page 408 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Appraiser I	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Supervising Appraiser

$ 87,086

$ 117,357

-3.8%

$ 112,897

1/1/2021

unknown

unknown

2

County of San Diego

Supervising Appraiser 1

$ 89,398

$ 109,907



$ 109,907

6/18/2021

unknown

unknown

3

County of Orange

Senior Appraiser

$ 83,408

$ 112,091

-2.0%

$ 109,849

7/2/2021

7/1/2022

3.50%

4

County of Contra Costa

Supervising Appraiser

$ 96,099

$ 123,015

-11.1%

$ 109,360

7/1/2021

unknown

unknown

5

County of Sacramento

Supervising Real Property Appraiser

$ 89,471

$ 108,743

0.1%

$ 108,852

6/21/2020

unknown

unknown

6

County of San Mateo2

[Senior Appraiser/Principal Appraiser]

$ 97,737

$ 122,218

-17.5%

$ 100,830

10/4/2020

unknown

unknown

7

County of Fresno

Senior Appraiser

$ 72,072

$ 92,170

4.7%

$ 96,502

11/2/2020

unknown

unknown

8

County of Alameda1

[Appraiser III/ Supervising Appraiser 1]

$ 87,604

$ 105,929

-11.4%

$ 93,853

12/27/2020

6/27/2021

3.00%

9

County of Kern

Senior Appraiser

$ 62,244

$ 75,984

1.2%

$ 76,896

4/21/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 110,417

$ 104,841

% County of San Diego Above/Below

-0.5%

4.6%

Number of Matches

8

8

N/C - Non Comparator

1	- County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 409 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Appraiser II





















1

City and County of San Francisco

Principal Real Property Appraiser

$ 119,288

$ 156,078

-17.4%

$ 128,920

7/1/2021

1/8/2022

.50%

2

County of Orange

Managing Appraiser

$ 92,893

$ 125,070

-2.0%

$ 122,569

7/2/2021

7/1/2022

3.50%

3

County of Santa Clara

Supervising Appraiser

$ 120,709

$ 146,723

-16.8%

$ 122,074

6/28/2021

6/27/2022

3.00%

4

County of Contra Costa1

[Supervising Appraiser/Principal Appraiser]

$ 107,263

$ 137,312

-11.1%

$ 122,071

7/1/2021

unknown

unknown





















6

County of Ventura

Supervising Appraiser

$ 80,443

$ 118,263

-0.7%

$ 117,435

12/26/2020

12/27/2021

2.00%

7

County of Riverside

Supervising Appraiser

$ 65,675

$ 97,250

1.9%

$ 99,098

5/1/2021

5/1/2022

2.00%

8

County of San Bernardino

Supervising District Appraiser

$ 70,512

$ 96,990

1.9%

$ 98,833

7/31/2021

7/30/2022

3.00%

9

County of Fresno

Senior Appraiser

$ 72,072

$ 92,170

4.7%

$ 96,502

11/2/2020

unknown

unknown

10

County of Alameda

Supervising Appraiser 1

$ 83,117

$ 100,963

-11.4%

$ 89,453

12/27/2020

12/26/2021

3.00%

11

County of Kern

Supervising Appraiser

$ 67,752

$ 82,704

1.2%

$ 83,696

4/21/2021

unknown

unknown

12

County of Los Angeles

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 109,613

$ 108,266

% County of San Diego Above/Below

9.4%

10.5%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification
at the comparator agency. The salary displayed is an average of the matches.

Page 410 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Assessment Clerk





















1

County of Santa Clara

Supervising Assessment Clerk

$ 78,919

$ 95,901

-16.8%

$ 79,789

6/28/2021

6/27/2022

3.00%

2

City and County of San Francisco

Principal Clerk

$ 75,946

$92,352

-17.4%

$ 76,283

7/1/2021

1/8/2022

.50%

3

County of Fresno

Supervising Assessment Technician

$ 59,800

$ 72,696

4.7%

$ 76,113

4/19/2021

unknown

unknown

4

County of Orange

Principal Assessment Technician

$ 54,974

$ 73,528

-2.0%

$ 72,057

7/2/2021

7/1/2022

3.50%

5

County of San Bernardino

Records Technician Supervisor II

$ 49,317

$ 67,662

1.9%

$ 68,948

7/31/2021

7/30/2022

3.00%

6

County of Contra Costa1

[Supervising Assessment Clerk/Clerk-Recorder Services Supervisor]

$ 61,566

$ 76,610

-11.1%

$ 68,106

7/1/2021

unknown

unknown





















8

County of Alameda

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 75,069

$ 74,085

% County of San Diego Above/Below

-28.3%

-26.7%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Contra Costa: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary
displayed is the higher of the matches.

Page 411 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Audit-Appraiser	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Supervising Audit Appraiser

$ 98,384

$ 120,952



$ 120,952

6/18/2021

unknown

unknown

2

City and County of San Francisco

Principal Tax Auditor-Appraiser

$ 119,292

$ 144,972

-17.4%

$ 119,747

7/1/2021

1/8/2022

.50%

3

County of Santa Clara

Supervising Auditor-Appraiser

$ 117,193

$ 142,451

-16.8%

$ 118,519

6/28/2021

6/27/2022

3.00%

4

County of Ventura

Supervising Auditor-Appraiser

$ 70,443

$ 118,263

-0.7%

$ 117,435

12/26/2020

12/27/2021

2.00%

5

County of Orange

Senior Auditor-Appraiser

$ 83,408

$ 112,091

-2.0%

$ 109,849

7/2/2021

7/1/2022

3.50%

6

County of Contra Costa

Supervising Auditor-Appraiser

$ 96,099

$ 123,015

-11.1%

$ 109,360

7/1/2021

unknown

unknown

7

County of San Mateo

Principal Auditor-Appraiser

$ 105,932

$ 132,493

-17.5%

$ 109,307

10/4/2020

unknown

unknown

8

County of Sacramento

Supervising Auditor Appraiser

$ 89,471

$ 108,743

0.1%

$ 108,852

6/21/2020

unknown

unknown

9

County of Alameda

Supervising Auditor-Appraiser II

$ 95,680

$ 116,230

-11.4%

$ 102,980

12/27/2020

12/26/2021

3.00%

10

County of Riverside

Supervising Auditor/Appraiser

$66,319

$ 98,203

1.9%

$ 100,069

5/1/2021

5/1/2022

2.00%

11

County of San Bernardino

Supervising Auditor Appraiser

$ 70,512

$ 96,990

1.9%

$ 98,833

7/31/2021

7/30/2022

3.00%

12

County of Fresno

Senior Audit-Appraiser

$ 72,072

$ 92,170

4.7%

$ 96,502

11/2/2020

unknown

unknown

13

County of Kern

Supervising Auditor-Appraiser

$ 67,752

$ 82,704

1.2%

$ 83,696

4/21/2021

unknown

unknown

14

County of Los Angeles

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 114,161

$ 109,079

% County of San Diego Above/Below

5.6%

9.8%

Number of Matches

12

12

N/C - Non Comparator

Page 412 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Child Support Officer





















1

County of Santa Clara

Supervising Child Support Officer

$ 95,909

$ 116,624

-16.8%

$ 97,031

6/28/2021

6/27/2022

3.00%

2

City and County of San Francisco

Child Support Officer III

$ 95,676

$ 116,244

-17.4%

$ 96,018

7/1/2021

1/8/2022

.50%

3

County of San Mateo

Child Support Supervisor

$ 85,798

$ 107,201

-17.5%

$ 88,441

10/4/2020

unknown

unknown

4

County of Los Angeles

Supervising Child Support Specialist

$ 67,060

$ 90,375

-3.8%

$ 86,941

1/1/2021

unknown

unknown

5

County of Riverside

Child Support Services Supervisor

$ 56,466

$ 83,606

1.9%

$ 85,195

5/1/2021

5/1/2022

2.00%

6

County of Alameda

Child Support Supervisor 1

$ 76,918

$ 93,475

-11.4%

$ 82,819

12/27/2020

12/26/2021

3.00%

7

County of Ventura

Supervising Child Support Services Specialist

$ 57,584

$ 82,524

-0.7%

$ 81,947

12/26/2020

12/27/2021

2.00%

8

County of Sacramento

Supervising Child Support Officer

$ 66,962

$ 81,390

0.1%

$ 81,471

6/21/2021

unknown

unknown

9

County of Contra Costa

Child Support Supervisor

$ 75,148

$ 91,343

-11.1%

$ 81,204

7/1/2021

unknown

unknown

10

County of Orange

Supervising Child Support Specialist

$ 59,738

$ 80,538

-2.0%

$ 78,927

7/2/2021

7/1/2022

3.50%

11

County of Fresno

Supervising Child Support Specialist

$ 57,902

$ 74,074

4.7%

$ 77,555

11/2/2020

unknown

unknown





















13

County of San Bernardino

Supervising Child Support Officer

$ 51,334

$ 70,658

1.9%

$ 72,000

7/31/2021

7/30/2022

3.00%

14

County of Kern

Supervising Child Support Specialist

$ 51,492

$ 62,868

1.2%

$ 63,622

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 83,606

$ 81,947

% County of San Diego Above/Below

-7.8%

-5.7%

Number of Matches

13

13

N/C - Non Comparator

Page 413 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Communicable Disease Investigator





















1

County of Los Angeles

Supervising Public Health Investigator

$ 69,586

$ 93,779

-3.8%

$ 90,215

1/1/2021

unknown

unknown





















3

City and County of San Francisco

Senior Disease Control Investigator

$ 80,990

$ 98,436

-17.4%

$ 81,308

7/1/2021

1/8/2022

.50%

4

County of San Bernardino

Supervising Communicable Disease Investigator

$ 52,666

$ 72,301

1.9%

$ 73,675

7/31/2021

7/30/2022

3.00%

5

County of Alameda

Senior Public Health Investigator

$ 68,141

$ 82,805

-11.4%

$ 73,365

12/27/2020

unknown

unknown

6

County of Fresno

Supervising Communicable Disease Specialist

$ 48,542

$ 62,062

4.7%

$ 64,979

11/2/2020

unknown

unknown

7

County of Contra Costa

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 82,805

$ 73,675

% County of San Diego Above/Below

1.5%

12.3%

Number of Matches

5

5

N/C - Non Comparator

Page 414 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Community Health Promotion Specialist





















1

County of Alameda

Supervising Program Specialist

$88,733

$ 118,810

-11.4%

$ 105,265

12/27/2020

12/26/2021

3.00%

2

City and County of San Francisco

Senior Health Educator

$ 103,636

$ 125,970

-17.4%

$ 104,051

7/1/2021

1/8/2022

.50%

3

County of San Mateo

Chief Public Flealth Education

$91,165

$ 114,003

-17.5%

$ 94,052

10/4/2020

unknown

unknown





















5

County of San Bernardino

Supervising Flealth Education Specialist

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%

6

County of Fresno

Flealth Educator

$ 52,234

$ 66,846

4.7%

$ 69,988

11/2/2020

unknown

unknown

7

County of Kern

Senior Flealth Educator

$ 50,724

$ 61,932

1.2%

$ 62,675

4/21/2021

unknown

unknown

8

County of Contra Costa

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$96,209

$86,979

% County of San Diego Above/Below

-14.2%

-3.3%

Number of Matches

6

6

N/C - Non Comparator

Page 415 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Correctional Counselor





















1

County of Santa Clara

Supervising Probation Counselor

$ 123,727

$ 150,401

-16.8%

$ 125,133

6/28/2021

6/27/2022

3.00%

2

County of Riverside

Supervising Correctional Counselor

$ 72,182

$ 95,848

1.9%

$ 97,669

7/1/2021

7/1/2022

3-4%





















4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 123,124

$ 111,401

% County of San Diego Above/Below

-33.9%

-21.1%

Number of Matches

2

2

N/C - Non Comparator

Page 416 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Criminalist





















1

City and County of San Francisco

Criminalist III

$ 148,668

$ 180,696

-17.4%

$ 149,255

7/1/2021

1/8/2022

.50%

2

County of Contra Costa

Forensic Supervisor

$ 131,158

$ 163,409

-11.1%

$ 145,270

7/1/2021

7/1/2022

5.00%





















4

County of Sacramento

Supervising Criminalist

$ 114,569

$ 139,249

0.1%

$ 139,388

6/21/2021

unknown

unknown

5

County of Santa Clara

Supervising Criminalist

$ 134,418

$ 163,394

-16.8%

$ 135,944

6/28/2021

6/27/2022

3.00%

6

County of Alameda

Supervising Criminalist

$ 123,635

$ 150,342

-11.4%

$ 133,203

11/1/2020

10/31/2021

2.00%

7

County of San Bernardino

Supervising Criminalist

$ 94,598

$ 130,374

1.9%

$ 132,851

7/31/2021

7/30/2022

3.00%

8

County of Ventura

Supervising Forensic Scientist

$ 90,088

$ 132,730

-0.7%

$ 131,801

12/26/2020

12/27/2021

2.00%

9

County of Los Angeles

Supervising Criminalist 1

$ 106,605

$ 136,077

-3.8%

$ 130,906

1/1/2021

unknown

unknown

10

County of San Mateo

Supervising Criminalist

$ 120,076

$ 150,069

-17.5%

$ 123,807

12/13/2020

12/12/2021

2-4%

11

County of Kern

Supervising Criminalist

$ 90,924

$ 111,000

1.2%

$ 112,332

4/21/2021

unknown

unknown

12

County of Orange

Supervising Forensic Specialist

$ 85,030

$ 114,587

-2.0%

$ 112,295

7/2/2021

7/1/2022

3.50%

13

County of Fresno

N/C















14

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 139,249

$ 132,851

% County of San Diego Above/Below

1.4%

5.9%

Number of Matches

11

11

N/C - Non Comparator

Page 417 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Deputy Public Administrator-Guardian





















1

County of Santa Clara

Supervising Deputy Public Guardian

$ 108,948

$ 132,434

-16.8%

$ 110,185

6/28/2021

6/27/2022

3.00%

2

County of Contra Costa

Conservatorship and Guardianship Program Supervisor

$ 93,622

$ 113,798

-11.1%

$ 101,167

7/1/2021

unknown

unknown

3

County of Los Angeles

Supervising Deputy Public Guardian/Sup Deputy Public Conservator-Administrator 1

$ 75,119

$ 101,221

-3.8%

$ 97,375

1/1/2021

unknown

unknown

4

County of Ala meda

Supervising Assistant Public Guardian-Conservator

$ 89,274

$ 108,451

-11.4%

$ 96,088

12/27/2020

12/26/2021

3.00%

5

County of Orange1

[Sup Deputy PA/Sup PG]

$ 69,597

$ 93,766

-2.0%

$ 91,891

7/2/2021

7/1/2022

3.50%

6

County of Riverside2

[Supervising Deputy Public Administrator/ Supervising Deputy Public Guardian]

$ 54,452

$ 80,559

1.9%

$ 82,090

5/1/2021

5/1/2022

2.00%

7

County of San Bernardino

Supervising Deputy Public Guardian

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%





















9

County of Sacramento

Supervising Deputy Public Guardian/Conservator

$ 62,243

$ 75,627

0.1%

$ 75,703

6/21/2020

unknown

unknown

10

County of Kern

Supervising Deputy Public Administrator

$ 58,620

$ 71,568

1.2%

$ 72,427

4/21/2021

unknown

unknown

11

County of Ventura

Senior Deputy Public Administrator-Guardian-Conservator

$ 52,004

$ 72,758

-0.7%

$ 72,248

12/26/2020

12/27/2021

2.00%

12

City and County of San Francisco

N/C















13

County of Fresno

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,163

$ 86,990

% County of San Diego Above/Below

-9.2%

-9.0%

Number of Matches

10

10

N/C - Non Comparator

1	- County of Orange: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the higher of the
matches.

2	- County of Riverside: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is the same for both
matches.

Page 418 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Electronic Instrument Technician





















1

Sacramento Metropolitan Air Quality Management District

Program Supervisor

$ 101,971

$ 136,655

0.1%

$ 136,792

7/1/2021

unknown

unknown

2

Bay Area Air Quality Management District

Supervising Air Quality Instrument Specialist

$ 103,939

$ 126,339

-17.4%

$ 104,356

11/8/2020

unknown

Unknown

3

South Coast Air Quality Management District

Principal Air Quality Instrument Specialist

$ 78,768

$ 106,644

-2.8%

$ 103,658

1/1/2020

unknown

unknown

4

County of Los Angeles

Head Instrument Technician

$ 77,748

$ 104,772

-3.8%

$ 100,791

1/1/2021

unknown

unknown





















6

County of Orange

N/C















7

County of Ventura

N/C















8

County of Contra Costa

N/C















9

San Luis Obispo County Air Pollution Control District

N/C















10

Imperial County Air Pollution Control District

N/C















11

County of Alameda

N/C















12

City and County of San Francisco

N/C















13

County of Santa Clara

N/C















14

County of Fresno

N/C















15

County of Kern

N/C















16

County of Sacramento

N/C















17

County of San Mateo

N/C















18

County of San Bernardino

N/C















19

County of Riverside

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 116,491

$ 104,007

% County of San Diego Above/Below

-33.1%

-18.9%

Number of Matches

4

4

N/C - Non Comparator

Page 419 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Environmental Health Specialist





















1

City and County of San Francisco

Principal Environmental Health Inspector

$ 127,426

$ 154,856

-17.4%

$ 127,911

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Supervising Environmental Health Specialist

$ 126,152

$ 153,348

-16.8%

$ 127,586

6/28/2021

6/27/2022

3.00%

3

County of San Mateo

Environmental Health Program Supervisor

$ 118,266

$ 147,802

-17.5%

$ 121,937

10/4/2020

unknown

unknown

4

County of Alameda

Supervising Environmental Health Specialist

$ 113,776

$ 136,136

-11.4%

$ 120,617

12/27/2020

12/26/2021

3.00%

5

County of Sacramento

Environmental Specialist IV

$ 107,574

$ 117,998

0.1%

$ 118,116

6/30/2021

unknown

unknown

6

County of Contra Costa

Supervising Environmental Health Specialist

$ 99,648

$ 121,124

-11.1%

$ 107,679

7/1/2021

unknown

unknown

7

County of Los Angeles

Chief Environmental Health Specialist

$ 82,285

$ 110,892

-3.8%

$ 106,678

1/1/2021

unknown

unknown

8

County of Riverside

Supervising Environmental Health Specialist

$ 69,534

$ 102,933

1.9%

$ 104,888

5/1/2021

5/1/2022

2.00%

9

County of Ventura

Supervising Environmental Health Specialist

$ 75,082

$ 105,378

-0.7%

$ 104,640

12/26/2020

12/27/2021

2.00%

10

County of Orange

Supervising Environmental Health Specialist

$ 78,374

$ 105,622

-2.0%

$ 103,510

7/2/2021

7/1/2022

3.50%





















12

County of San Bernardino

Supervising Environmental Health Specialist

$ 70,990

$ 97,781

1.9%

$ 99,639

7/31/2021

7/30/2022

3.00%

13

County of Fresno

Supervising Environmental Health Specialist

$ 71,760

$ 91,832

4.7%

$ 96,148

11/2/2020

unknown

unknown

14

County of Kern

Environmental Health Specialist IV

$ 69,456

$ 84,792

1.2%

$ 85,810

4/21/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 110,892

$ 106,678

% County of San Diego Above/Below

-9.9%

-5.8%

Number of Matches

13

13

N/C - Non Comparator

Page 420 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Health Information Specialist





















1

County of San Mateo

Senior Community Health Planner

$ 94,430

$ 117,996

-17.5%

$ 97,347

10/4/2020

unknown

unknown





















3

County of Riverside

Senior Health Educator

$ 55,591

$ 82,276

1.9%

$ 83,840

5/1/2021

5/1/2022

2.00%

4

County of San Bernardino

Supervising Health Education Specialist

$ 57,096

$ 78,416

1.9%

$ 79,906

7/31/2021

7/30/2022

3.00%

5

County of Orange

Health Educator

$ 57,762

$ 77,605

-2.0%

$ 76,053

7/2/2021

7/1/2022

3.50%

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Sacramento

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 80,346

$ 81,873

% County of San Diego Above/Below

4.6%

2.8%

Number of Matches

4

4

N/C - Non Comparator

Page 421 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Human Services Control Specialist





















1

City and County of San Francisco

Program Specialist Supervisor

$ 101,322

$ 123,214

-17.4%

$ 101,775

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Eligibility Work Supervisor

$91,780

$ 111,076

-16.8%

$92,415

6/14/2021

6/13/2022

3.00%

3

County of Alameda

Supervising Eligibility Technician

$ 80,205

$ 97,219

-11.4%

$ 86,136

9/6/2020

unknown

unknown





















5

County of San Bernardino

Fluman Services System Quality Review Supervisor 1

$ 46,592

$ 63,960

1.9%

$ 65,175

7/31/2021

7/30/2022

3.00%

6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 104,148

$89,276

% County of San Diego Above/Below

-46.7%

-25.8%

Number of Matches

4

4

N/C - Non Comparator

Page 422 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Human Services Specialist





















1

City and County of San Francisco

Program Specialist Supervisor

$ 101,322

$ 123,214

-17.4%

$ 101,775

7/1/2021

1/8/2022

.50%

2

County of Orange

Social Services Supervisor II

$ 70,658

$ 95,139

-2.0%

$ 93,236

7/2/2021

7/1/2022

3.50%

3

County of San Mateo

Human Services Supervisor

$ 88,585

$ 110,758

-17.5%

$ 91,375

10/4/2020

unknown

unknown

4

County of Alameda

Supervising Eligibility Technician

$ 80,205

$ 97,219

-11.4%

$ 86,136

9/6/2020

unknown

unknown

5

County of Sacramento

Human Services Supervisor

$ 69,468

$ 84,439

0.1%

$ 84,523

6/21/2020

unknown

unknown

6

County of Contra Costa

Eligibility Work Supervisor

$ 72,043

$ 92,002

-11.1%

$ 81,789

7/1/2021

unknown

unknown

7

County of Ventura

HS Client Benefit Supervisor

$ 65,020

$ 73,629

-0.7%

$ 73,113

12/26/2020

12/27/2021

2.00%

8

County of Riverside

Eligibility Supervisor

$ 42,902

$ 66,982

1.9%

$ 68,254

5/1/2021

5/1/2022

2.00%





















10

County of San Bernardino

Eligibility Worker Supervisor 1

$ 44,658

$ 61,464

1.9%

$ 62,632

7/31/2021

7/30/2022

3.00%

11

County of Kern

Human Services Supervisor

$ 47,304

$ 57,756

1.2%

$ 58,449

4/21/2021

unknown

unknown

12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 88,220

$ 83,156

% County of San Diego Above/Below

-30.4%

-22.9%

Number of Matches

10

10

N/C - Non Comparator

Page 423 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Industrial Hygienist





















1

City and County of San Francisco

Senior Industrial Hygienist

$ 134,186

$ 175,396

-17.4%

$ 144,877

7/1/2021

1/8/2022

.50%

2

County of Los Angeles

Head, Industrial Hygienist

$ 99,488

$ 134,074

-3.8%

$ 128,979

1/1/2021

unknown

unknown

3

County of Alameda

Supervising Industrial Hygiene Engineer

$ 109,346

$ 130,853

-11.4%

$ 115,936

12/27/2020

unknown

unknown





















5

County of Fresno

Supervising Environmental Health Specialist

$ 71,760

$ 91,832

4.7%

$ 96,148

11/2/2020

unknown

unknown

6

County of Kern

Hazardous Materials Specialist IV

$ 59,808

$ 73,008

1.2%

$ 73,884

4/21/2021

unknown

unknown

7

County of Contra Costa

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 130,853

$ 115,936

% County of San Diego Above/Below

-23.3%

-9.2%

Number of Matches

5

5

N/C - Non Comparator

Page 424 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Nurse	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Assistant Nurse Manager

$ 164,299

$ 220,401

-16.8%

$ 183,374

10/19/2020

11/1/2021

3.00%

2

County of San Mateo

Clinical Services Manager II - Nursing

$ 154,707

$ 193,395

-17.5%

$ 159,551

12/13/2020

unknown

unknown

3

County of Los Angeles

Supervising Clinic Nurse 1

$ 96,127

$ 143,891

-3.8%

$ 138,423

1/1/2021

unknown

unknown

4

County of Fresno

Head Nurse

$ 94,822

$ 121,290

4.7%

$ 126,991

11/2/2020

unknown

unknown

5

County of San Bernardino

Assistant Unit Manager II

$ 85,384

$ 117,458

1.9%

$ 119,689

7/31/2021

7/30/2022

3.00%

6

County of Orange

Supervising Public Health Nurse 1

$ 86,840

$ 116,584

-2.0%

$ 114,252

7/2/2021

7/1/2022

3.50%

7

County of Sacramento

Supervising Registered Nurse

$ 90,348

$ 109,787

0.1%

$ 109,897

6/21/2020

unknown

unknown

8

County of San Diego

Supervising Nurse

$ 87,755

$ 107,806



$ 107,806

6/18/2021

unknown

unknown

9

County of Kern

Supervising Nurse

$ 78,684

$ 96,060

1.2%

$ 97,213

4/21/2021

unknown

unknown

10

City and County of San Francisco

N/C















11

County of Alameda

N/C















12

County of Contra Costa

N/C















13

County of Riverside

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 119,374

$ 123,340

% County of San Diego Above/Below

-10.7%

-14.4%

Number of Matches

8

8

N/C - Non Comparator

Page 425 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Occupational/Physical Therapist





















1

County of Santa Clara

Occupational Therapist Ill/Physical Therapist III

$ 128,856

$ 155,961

-16.8%

$ 129,759

6/14/2021

6/13/2022

3.00%

2

County of Los Angeles

Occupational Therapist Supervisor I/Physical Therapist Supervisor 1

$ 96,354

$ 129,848

-3.8%

$ 124,913

1/1/2021

unknown

unknown

3

County of Ventura

Supervising Therapist 1

$ 82,927

$ 122,039

-0.7%

$ 121,184

12/26/2020

12/27/2021

2.00%

4

County of Riverside1

[Supervising Occupational Therapist/ Supervising Physical Therapist]

$ 72,837

$ 116,851

1.9%

$ 119,071

5/1/2021

5/1/2022

2.00%

5

County of Sacramento

Supervising Therapist

$ 97,698

$ 118,765

0.1%

$ 118,884

6/21/2020

unknown

unknown

6

County of San Bernardino

Supervising Rehabilitation Therapist

$ 83,720

$ 115,232

1.9%

$ 117,421

7/31/2021

7/30/2022

3.00%

7

County of Kern

Supervising Therapist

$ 94,632

$ 115,572

1.2%

$ 116,959

4/21/2021

unknown

unknown

8

County of Alameda

Supervising Therapist

$ 103,771

$ 125,819

-11.4%

$ 111,476

12/27/2020

12/26/2021

3.00%





















10

County of San Mateo

Supervising Therapist

$ 104,518

$ 130,663

-17.5%

$ 107,797

10/4/2020

unknown

unknown

11

County of Contra Costa

Supervising Pediatric Therapist

$ 95,589

$ 116,189

-11.1%

$ 103,292

7/1/2021

unknown

unknown

12

City and County of San Francisco

N/C















13

County of Fresno

N/C















14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 120,402

$ 118,153

% County of San Diego Above/Below

-10.7%

-8.6%

Number of Matches

10

10

N/C - Non Comparator

1 - County of Riverside: Functional Match: This hybrid match represents that the duties of the class are performed by more than one class at the comparator agency. The salary displayed is
the same for both matches.

Page 426 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Office Assistant	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Alameda

Supervising Clerk III

$ 77,189

$ 93,517

-11.4%

$ 82,856

12/27/2020

12/26/2021

3.00%

2

City and County of San Francisco

Principal Clerk

$ 75,946

$ 92,352

-17.4%

$ 76,283

7/1/2021

1/8/2022

.50%

3

County of Ventura

Clerical Supervisor III

$ 50,221

$ 70,345

-0.7%

$ 69,853

12/26/2020

12/27/2021

2.00%

4

County of Contra Costa1

[Clerical Supervisor/Office Manager]

$ 60,538

$ 77,309

-11.1%

$ 68,728

7/1/2021

unknown

unknown

5

County of Orange

Senior Office Supervisor A/B

$ 50,918

$ 68,162

-2.0%

$ 66,798

7/2/2021

7/1/2022

3.50%

6

County of Riverside

Supervising Office Assistant II

$ 36,711

$ 57,244

1.9%

$ 58,331

5/1/2021

5/1/2022

2.00%

7

County of San Diego

Supervising Office Assistant







$ 55,515

6/18/2021

unknown

unknown

8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 73,827

$ 69,290

% County of San Diego Above/Below

-33.0%

-24.8%

Number of Matches

6

6

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 427 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Park Ranger





















1

County of Santa Clara

Park Ranger Supervisor

$ 109,458

$ 133,078

-16.8%

$ 110,721

6/28/2021

6/27/2022

3.00%

2

County of San Mateo

Park Ranger IV

$ 91,789

$ 114,751

-17.5%

$ 94,670

10/4/2020

unknown

unknown

3

City and County of San Francisco

Head Park Ranger

$ 84,214

$ 102,388

-17.4%

$ 84,572

7/1/2021

1/8/2022

.50%

4

County of Orange

Supervising Park Ranger II

$ 62,442

$ 84,074

-2.0%

$ 82,392

7/2/2021

7/1/2022

3.50%

5

County of Kern

Supervising Park Ranger

$ 61,320

$ 74,856

1.2%

$ 75,754

4/21/2021

unknown

unknown

6

County of San Bernardino

Assistant Park Superintendent

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

7

County of Riverside

Park Ranger Supervisor - Parks

$ 46,743

$ 68,982

1.9%

$ 70,292

5/1/2021

5/1/2022

2.00%





















9

County of Ventura

Supervising Park Ranger

$ 44,408

$62,199

-0.7%

$ 61,763

12/26/2020

12/27/2021

2.00%

10

County of Alameda

N/C















11

County of Contra Costa

N/C















12

County of Fresno

N/C















13

County of Los Angeles

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 79,465

$ 79,073

% County of San Diego Above/Below

-16.2%

-15.6%

Number of Matches

8

8

N/C - Non Comparator

Page 428 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Pest Management Technician





















1

City and County of San Francisco

Senior Integrated Pest Management Specialist

$88,140

$ 107,146

-17.4%

$ 88,503

7/1/2021

1/8/2022

.50%

2

County of Alameda1

[Vegetation Technician/ Weed and Pest Control Supervisor]

$ 96,013

$ 97,760

-11.4%

$ 86,615

12/27/2020

12/26/2021

3.00%





















4

County of Los Angeles

Pest Exterminator Working Supervisor

$ 50,878

$ 68,565

-3.8%

$ 65,959

1/1/2021

unknown

unknown

5

County of Kern

Pest Control Advisor/Applicator

$ 37,236

$ 45,456

1.2%

$ 46,001

4/21/2021

unknown

unknown

6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$83,162

$ 76,287

% County of San Diego Above/Below

-11.0%

-1.9%

Number of Matches

4

4

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency.
The salary displayed is an average of the matches.

Page 429 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Public Health Microbiologist





















1

City and County of San Francisco

Microbiologist II

$ 122,330

$ 148,668

-17.4%

$ 122,800

7/1/2021

1/8/2022

.50%

2

County of Ventura1

[Microbiologist III/ Public Health Lab Director]

$ 82,838

$ 116,066

-0.7%

$ 115,253

unknown

unknown

unknown

3

County of Los Angeles

Public Health Microbiology Supervisor 1

$ 87,303

$ 117,649

-3.8%

$ 113,179

1/1/2021

unknown

unknown

4

County of Contra Costa

Public Health Laboratory Manager

$ 101,039

$ 122,814

-11.1%

$ 109,181

7/1/2021

unknown

unknown

5

County of San Mateo

Supervising Public Health Microbiologist

$ 104,289

$ 130,393

-17.5%

$ 107,574

10/4/2020

unknown

unknown





















7

County of Orange

Supervising Public Health Microbiologist

$ 78,374

$ 105,622

-2.0%

$ 103,510

7/2/2021

7/1/2022

3.50%

8

County of Riverside

Supervising Public Health Microbiologist

$ 68,571

$ 101,568

1.9%

$ 103,497

5/1/2021

5/1/2022

2.00%

9

County of Kern

Supervising Microbiologist

$ 83,532

$ 101,976

1.2%

$ 103,200

4/21/2021

unknown

unknown

10

County of Sacramento

Supervising Public Health Microbiologist

$ 82,539

$ 100,349

0.1%

$ 100,449

6/21/2020

unknown

unknown

11

County of San Bernardino

Supervising Public Health Microbiologist

$ 70,990

$ 97,781

1.9%

$ 99,639

7/31/2021

7/30/2022

3.00%

12

County of Alameda

Supervising Microbiologist

$ 90,022

$ 108,930

-11.4%

$ 96,512

12/27/2020

unknown

unknown

13

County of Fresno

Senior Public Health Microbiologist

$ 75,452

$ 91,702

4.7%

$ 96,012

4/19/2021

unknown

unknown

14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 107,276

$ 103,504

% County of San Diego Above/Below

-3.1%

0.6%

Number of Matches

12

12

N/C - Non Comparator

1 - County of Ventura: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the
comparator agency. The salary displayed is an average of the matches.

Page 430 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Sheriff's Emergency Services Dispatcher





















1

County of Santa Clara

Supervising Communications Dispatcher

$ 133,078

$ 161,772

-16.8%

$ 134,594

6/28/2021

6/27/2022

3.00%

2

County of Riverside

Sheriff's Communications Supervisor B

$ 66,091

$ 117,907

1.9%

$ 120,147

5/1/2021

5/1/2022

2.00%

3

County of Ventura

Supervising Sheriff's Technical Communications Specialist

$ 81,559

$ 114,195

-0.7%

$ 113,396

12/26/2020

12/27/2021

2.00%

4

City and County of San Francisco

Public Safety Communications Supervisor

$ 107,926

$ 131,118

-17.4%

$ 108,303

7/1/2021

1/8/2022

.50%

5

County of San Mateo

Supervising Communications Dispatcher

$ 104,747

$ 130,913

-17.5%

$ 108,003

12/13/2020

unknown

unknown

6

County of Orange

Supervising Radio Dispatcher

$ 74,235

$ 100,027

-2.0%

$ 98,027

7/2/2021

7/1/2022

3.50%





















8

County of Alameda

Emergency Services Dispatch Supervisor

$ 90,646

$ 108,805

-11.4%

$ 96,401

11/1/2020

10/31/2021

2.00%

9

County of Contra Costa

Supervising Sheriff's Dispatcher

$ 86,449

$ 107,706

-11.1%

$95,751

7/1/2021

7/1/2022

5.00%

10

County of San Bernardino

Sheriff's Supervising Communications Dispatcher

$ 62,130

$ 85,426

1.9%

$ 87,049

7/31/2021

7/30/2022

3.00%

11

County of Los Angeles

Supervising Public Response Dispatcher

$ 63,684

$ 85,810

-3.8%

$ 82,549

1/1/2021

unknown

unknown

12

County of Fresno

Supervising Communications Dispatcher

$ 64,012

$ 77,818

4.7%

$ 81,475

4/19/2021

unknown

unknown

13

County of Kern

Sheriff's Dispatch Supervisor

$ 56,892

$ 69,456

1.2%

$ 70,289

4/21/2021

unknown

unknown

14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 108,256

$ 97,214

% County of San Diego Above/Below

-12.0%

-0.5%

Number of Matches

12

12

N/C - Non Comparator

Page 431 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Stores & Mail System Specialist, Auditor & Controller









































2

County of Ventura

Warehouse Coordinator

$39,310

$ 55,039

-0.7%

$ 54,654

12/26/2020

12/27/2021

2.00%

3

County of Kern

Supervising Mail Clerk

$ 31,896

$ 38,940

1.2%

$ 39,407

4/21/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 46,989

$ 47,030

% County of San Diego Above/Below

22.9%

22.8%

Number of Matches

2

2

N/C - Non Comparator

Page 432 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising Treasurer-Tax Collector Specialist





















1

County of Alameda1

[Treasurer-Tax Collector's Specialist III/ Treasurer-Tax Collector Supervisor]

$ 73,399

$ 87,612

-11.4%

$ 77,624

12/27/2020

12/26/2021

3.00%

2

County of Santa Clara

Supervising Tax Collection Clerk

$ 76,685

$93,186

-16.8%

$ 77,531

6/28/2021

6/27/2022

3.00%

3

County of San Mateo

Supervising Cash Management Specialist

$ 73,235

$91,539

-17.5%

$ 75,520

10/4/2020

unknown

unknown

4

County of Los Angeles

Tax Services Supervisor 1

$ 49,887

$ 69,075

-3.8%

$ 66,450

1/1/2021

unknown

unknown

5

County of Sacramento

Accounting Technician

$ 53,495

$ 65,020

0.1%

$ 65,085

6/21/2020

unknown

unknown





















7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 87,612

$ 75,520

% County of San Diego Above/Below

-45.2%

-25.2%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 433 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Supervising Vector Ecologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Supervising Vector Ecologist

$ 87,360

$ 107,390



$ 107,390

6/18/2021

unknown

unknown

2

County of Santa Clara

Vector Control Operations Supervisor

$ 99,083

$ 120,444

-16.8%

$ 100,210

6/28/2021

6/27/2022

3.00%

3

County of Alameda

Vector Control Biologist Supervisor

$ 85,842

$ 104,333

-11.4%

$ 92,439

12/27/2020

12/26/2021

3.00%

4

City and County of San Francisco

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 112,389

$ 96,324

% County of San Diego Above/Below

-4.7%

10.3%

Number of Matches

2

2

N/C - Non Comparator

Page 434 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising, Trial Support Unit





















1

County of Sacramento

Supervising Forensic Multimedia Examiner

$ 79,031

$ 96,069

0.1%

$ 96,165

6/21/2021

unknown

unknown





















3

City and County of San Francisco

N/C















4

County of Alameda

N/C















5

County of Contra Costa

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 96,069

$ 96,165

% County of San Diego Above/Below

0.1%

-0.0%

Number of Matches

1

1

N/C - Non Comparator

Page 435 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Supervising, Vector Control Technician





















1

County of Riverside

Supervising Environmental Health Specialist

$ 69,534

$ 102,933

1.9%

$ 104,888

5/1/2021

5/1/2022

2.00%





















3

County of San Bernardino

Supervising Vector Control Technician

$ 51,771

$ 71,032

1.9%

$ 72,382

7/31/2021

7/30/2022

3.00%

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 86,982

$ 88,635

% County of San Diego Above/Below

-16.1%

-18.3%

Number of Matches

2

2

N/C - Non Comparator

Page 436 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Tax Payment Enforcement Officer |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Investigator, Tax Collector

$ 92,352

$ 112,216

-17.4%

$ 92,690

7/1/2021

1/8/2022

.50%

2

County of Kern

Tax Collector's Investigator II

$ 62,244

$ 75,984

1.2%

$ 76,896

4/21/2021

unknown

unknown

3

County of Alameda

Collection Enforcement Deputy II

$ 63,083

$ 76,733

-11.4%

$ 67,985

6/27/2021

6/26/2022

3.25%

4

County of San Mateo

Revenue Collector II

$ 65,768

$82,179

-17.5%

$ 67,798

10/4/2020

unknown

unknown

5

County of Santa Clara

Revenue Collections Officer

$ 65,859

$ 79,535

-16.8%

$ 66,173

6/14/2021

6/13/2022

3.00%

6

County of Orange

Collection Officer II

$ 49,442

$ 66,602

-2.0%

$ 65,270

7/2/2021

7/1/2022

3.50%

7

County of San Diego

Tax Payment Enforcement Officer

$ 52,790

$ 64,834



$ 64,834

6/18/2021

unknown

unknown

8

County of Contra Costa

Tax Compliance Officer

$ 53,024

$ 64,451

-11.1%

$ 57,297

7/1/2021

unknown

unknown

9

County of Sacramento

Collection Services Agent II

$ 46,354

$ 56,355

0.1%

$ 56,411

6/21/2020

unknown

unknown

10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 76,358

$ 66,986

% County of San Diego Above/Below

-17.8%

-3.3%

Number of Matches

8

8

N/C - Non Comparator

Page 437 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Tax Payment Processor	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Los Angeles

Tax Services Clerk II

$ 40,251

$ 55,603

-3.8%

$ 53,490

1/1/2021

unknown

unknown

2

County of Sacramento

Account Clerk II

$ 41,969

$ 51,010

0.1%

$ 51,061

6/21/2020

unknown

unknown

3

County of San Diego

Tax Payment Processor

$ 39,603

$ 48,693



$ 48,693

6/18/2021

unknown

unknown

4

County of Orange

Property Tax Technician

$ 36,858

$ 48,485

-2.0%

$ 47,515

7/2/2021

7/1/2022

3.50%

5

County of Kern

Fiscal Support Technician

$ 32,868

$40,128

1.2%

$ 40,610

4/21/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Riverside

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 49,747

$ 49,288

% County of San Diego Above/Below

-2.2%

-1.2%

Number of Matches

4

4

N/C - Non Comparator

Page 438 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Technical Writer	|

Rank

Comparator Agency

Classification
Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Technical Writer

$ 125,222

$ 152,212

-16.8%

$ 126,641

6/14/2021

6/13/2022

3.00%

2

County of San Diego

Technical Writer

$73,133

$89,918



$89,918

6/18/2021

unknown

unknown

3

County of Riverside

Staff Writer

$ 63,565

$79,991

1.9%

$81,511

7/1/2021

7/14/2022

2.00%

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 116,102

$ 104,076

% County of San Diego Above/Below

-29.1%

-15.7%

Number of Matches

2

2

N/C - Non Comparator

Page 439 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Telecommunications Technician III





















1

County of San Mateo

IS Communications Specialist - Senior

$ 114,377

$ 142,956

-17.5%

$ 117,938

10/4/2020

unknown

unknown

2

County of Alameda

Senior Telecommunications Technician

$ 93,600

$ 114,130

-11.4%

$ 101,119

12/27/2020

unknown

unknown

3

County of Santa Clara

Senior Telecommunications Technician

$ 92,082

$ 111,413

-16.8%

$ 92,696

6/14/2021

6/13/2022

3.00%

4

County of Ventura

Telecommunications Network Specialist III

$ 72,990

$ 91,905

-0.7%

$ 91,262

1/10/2021

1/9/2022

2.00%

5

County of Contra Costa

Senior Communications Equipment Specialist

$ 83,772

$ 101,826

-11.1%

$ 90,523

7/1/2021

unknown

unknown





















7

County of Orange

Senior Communications Technician

$ 64,418

$ 86,840

-2.0%

$ 85,103

7/2/2021

7/1/2022

3.50%

8

County of Kern

Communications Technician III

$ 57,756

$ 70,500

1.2%

$ 71,346

4/21/2021

unknown

unknown

9

City and County of San Francisco

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of Sacramento

N/C















14

County of San Bernardino

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 101,826

$ 91,262

% County of San Diego Above/Below

-13.0%

-1.3%

Number of Matches

7

7

N/C - Non Comparator

Page 440 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Telecommunications Technician IV	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

IS Communications Supervisor

S 121,802

S 152,232

-17.5%

$ 125,592

10/4/2020

unknown

unknown

2

City and County of San Francisco

Telecommunications Technician Supervisor

S 119,600

S 145,418

-17.4%

$ 120,115

7/1/2021

1/8/2022

.50%

3

County of Contra Costa1

[Senior Communications Equipment Specialist/Telecommunications Manager]

$98,163

S 119,318

-11.1%

$ 106,074

7/1/2021

unknown

unknown

4

County of Sacramento

Telecommunications Systems Supervisor

S 84,230

S 102,375

0.1%

$ 102,477

6/21/2020

unknown

unknown

5

County of Orange

Supervising Communications Technician

S 75,691

S 101,837

-2.0%

$ 99,800

7/2/2021

7/1/2022

3.50%

6

County of San Diego

Telecommunications Technician IV

$80,621

S 99,050



$ 99,050

6/18/2021

unknown

unknown

7

County of Ventura

Telecommunications Network Supervisor

S 63,527

$89,151

-0.7%

$88,527

12/26/2020

12/27/2021

2.00%

8

County of Kern

Telecommunications Engineer

S 65,424

$ 79,872

1.2%

$ 80,830

4/21/2021

unknown

unknown

9

County of Alameda

N/C















10

County of Fresno

N/C















11

County of Los Angeles

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 102,375

$ 102,477

% County of San Diego Above/Below

-3.4%

-3.5%

Number of Matches

7

7

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 441 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Toxicologist I

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo

Criminalist 1

$ 86,859

$ 108,532

-17.5%

$ 89,539

12/13/2020

12/12/2021

2-4%

2

County of San Diego

Toxicologist 1

$ 66,726

$ 82,014



$ 82,014

6/18/2021

unknown

unknown

3

County of Contra Costa

Forensic Toxicologist 1

$ 79,827

$ 88,009

-11.1%

$ 78,240

7/1/2021

unknown

unknown

4

City and County of San Francisco

N/C















5

County of Alameda

N/C















6

County of Fresno

N/C















7

County of Kern

N/C















8

County of Los Angeles

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 98,271

$ 83,889

% County of San Diego Above/Below

-19.8%

-2.3%

Number of Matches

2

2

N/C - Non Comparator

Page 442 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Toxicologist II	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

City and County of San Francisco

Forensic Toxicologist

$ 113,074

$ 137,462

-17.4%

$ 113,544

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Criminalist II

$ 108,158

$ 135,197

-17.5%

$ 111,538

12/13/2020

12/12/2021

2-4%



County of San Diego

Toxicologist II

$ 81,453

$ 100,152



$ 100,152

6/18/2021

unknown

unknown

4

County of Contra Costa

Forensic Toxicologist II

$ 86,922

$ 105,654

-11.1%

$ 93,926

7/1/2021

unknown

unknown

5

County of Los Angeles

Toxicologist

$ 57,555

$ 77,559

-3.8%

$ 74,612

1/1/2021

unknown

unknown

6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 120,426

$ 102,732

% County of San Diego Above/Below

-20.2%

-2.6%

Number of Matches

4

4

N/C - Non Comparator

Page 443 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Toxicologist III |

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Mateo1

[Criminalist 1 I/Supervising Criminalist]

$ 114,117

$ 142,633

-17.5%

$ 117,672

12/13/2020

12/12/2021

2-4%

2

County of San Diego

Toxicologist III

$ 92,914

$ 114,234



$ 114,234

6/18/2021

unknown

unknown

3

County of Contra Costa

Forensic Toxicologist III

$ 100,640

$ 122,328

-11.1%

$ 108,750

7/1/2021

unknown

unknown

4

County of Los Angeles

Senior Toxicologist

$ 63,840

$ 86,020

-3.8%

$ 82,752

1/1/2021

unknown

unknown

5

City and County of San Francisco

N/C















6

County of Alameda

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Orange

N/C















10

County of Riverside

N/C















11

County of Sacramento

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 122,328

$ 108,750

% County of San Diego Above/Below

-7.1%

4.8%

Number of Matches

3

3

N/C - Non Comparator

1 - County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level
classification at the comparator agency. The salary displayed is an average of the matches.

Page 444 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Treasurer-Tax Collector Specialist





















1

County of Alameda1

[Treasurer-Tax Collector's Specialist 11/ Deferred Compensation Technician]

$ 64,428

$ 78,216

-11.4%

$ 69,299

6/27/2021

6/26/2022

3.25%

2

County of San Mateo

Cash Management Specialist

$ 61,608

$ 77,021

-17.5%

$ 63,542

10/4/2020

unknown

unknown

3

County of Santa Clara

Revenue Collections Clerk

$ 53,781

$ 64,908

-16.8%

$ 54,004

6/14/2021

6/13/2022

3.00%

4

County of Los Angeles

Tax Services Clerk II

$ 40,251

$ 55,603

-3.8%

$ 53,490

1/1/2021

unknown

unknown

5

County of Sacramento

Account Clerk II

$ 41,969

$ 51,010

0.1%

$ 51,061

6/21/2020

unknown

unknown





















7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 64,908

$ 54,004

% County of San Diego Above/Below

-39.4%

-16.0%

Number of Matches

5

5

N/C - Non Comparator

1 - County of Alameda: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary
displayed is an average of the matches.

Page 445 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Trial Support Specialist









































2

County of Orange

Video Producer

$ 64,813

$ 87,381

-2.0%

$ 85,633

7/2/2021

7/1/2022

3.50%

3

County of Sacramento

Forensic Multimedia Examiner II

$ 65,354

$ 79,407

0.1%

$ 79,486

6/21/2021

unknown

unknown

4

County of Santa Clara

Investigative Graphic/Media Specialist

$ 72,355

$ 87,454

-16.8%

$ 72,761

6/14/2021

6/13/2022

3.00%

5

County of Kern

Investigative Technician II

$ 46,608

$ 56,892

1.2%

$ 57,575

4/21/2021

unknown

unknown

6

City and County of San Francisco

N/C















7

County of Alameda

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Los Angeles

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 83,394

$ 76,124

% County of San Diego Above/Below

8.9%

16.9%

Number of Matches

4

4

N/C - Non Comparator

Page 446 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Utilization Review Quality Improvement Specialist





















1

County of Santa Clara

Quality Improvement Coordinator - SCVMC

$ 153,762

$ 196,298

-16.8%

$ 163,320

6/28/2021

6/27/2022

3.00%

2

County of Contra Costa

Utilization Review Coordinator

$ 135,348

$ 164,517

-11.1%

$ 146,256

7/1/2021

unknown

unknown

3

County of San Mateo1

Clinical Nurse

$ 135,905

$ 160,635

-17.5%

$ 132,524

2/7/2021

unknown

unknown

4

County of Alameda

Clinical Review Specialist

$ 102,259

$ 120,541

-11.4%

$ 106,799

6/27/2021

6/26/2022

3.25%

5

County of Sacramento

Medical Case Management Nurse

$ 85,817

$ 104,337

0.1%

$ 104,441

8/2/2020

unknown

unknown

6

County of Fresno

Utilization Review Specialist

$ 81,458

$ 97,968

4.7%

$ 102,572

11/2/2020

unknown

unknown





















8

City and County of San Francisco

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Bernardino

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 140,588

$ 119,662

% County of San Diego Above/Below

-41.3%

-20.3%

Number of Matches

6

6

N/C - Non Comparator

1 - County of San Mateo: Bottom of range is step 2.

Page 447 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Utilization Review Quality Improvement Supervisor





















1

County of Contra Costa1

[Utilization Review Coordinator/Utilization Review Manager]

$ 143,806

$ 174,798

-11.1%

$ 155,395

7/1/2021

unknown

unknown

2

County of San Mateo2

[Clinical Nurse/Quality Assurance Manager]

$ 127,294

$ 159,887

-17.5%

$ 131,906

2/7/2021

unknown

unknown

3

County of Alameda

Clinical Review Specialist Supervisor

$ 109,803

$ 134,805

-11.4%

$ 119,437

12/27/2020

unknown

unknown

4

County of Sacramento

Supervising Medical Case Management Nurse

$ 96,319

$ 117,074

0.1%

$ 117,191

6/21/2020

unknown

unknown





















6

City and County of San Francisco

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of San Bernardino

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 147,346

$ 125,672

% County of San Diego Above/Below

-41.1%

-20.3%

Number of Matches

4

4

N/C - Non Comparator

1	- County of Contra Costa: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

2	- County of San Mateo: Span of Responsibility Match: This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator
agency. The salary displayed is an average of the matches.

Page 448 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Vector Control Technician





















1

County of Alameda

Vector Control Officer

$ 67,069

$ 80,041

-11.4%

$ 70,916

6/27/2021

6/26/2022

3.25%

2

County of Santa Clara

Vector Control Technician II

$ 69,688

$ 84,198

-16.8%

$ 70,053

6/14/2021

6/13/2022

3.00%

3

County of Ventura

Resource Management Agency Technician II - Environmental Health

$ 48,265

$ 67,402

-0.7%

$ 66,930

12/26/2020

12/27/2021

2.00%

4

County of Riverside

Environmental Health Technician II

$ 38,982

$ 60,876

1.9%

$ 62,032

5/1/2021

5/1/2022

2.00%





















6

County of San Bernardino

Vector Control Technician 1

$ 43,597

$ 59,925

1.9%

$ 61,063

7/31/2021

7/30/2022

3.00%

7

City and County of San Francisco

N/C















8

County of Contra Costa

N/C















9

County of Fresno

N/C















10

County of Kern

N/C















11

County of Los Angeles

N/C















12

County of Orange

N/C















13

County of Sacramento

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 67,402

$ 66,930

% County of San Diego Above/Below

-9.1%

-8.4%

Number of Matches

5

5

N/C - Non Comparator

Page 449 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

|Vector Control Technician Aide	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Santa Clara

Vector Control Technician 1

$ 60,411

$ 72,956

-16.8%

$ 60,699

6/14/2021

6/13/2022

3.00%

2

County of Riverside

Environmental Health Technician 1

$ 36,977

$ 57,710

1.9%

$ 58,807

5/1/2021

5/1/2022

2.00%

3

County of Alameda

Vector Control Officer, Trainee

$ 61,958

$ 64,965

-11.4%

$ 57,559

6/27/2021

6/26/2022

3.25%

4

County of San Bernardino

Vector Control Technician Trainee

$ 37,710

$ 50,502

1.9%

$ 51,462

7/31/2021

7/30/2022

3.00%

5

County of Contra Costa

Vector Control Technician

$ 42,780

$ 51,999

-11.1%

$ 46,227

7/1/2021

unknown

unknown

6

County of San Diego

Vector Control Technician Aide

$ 40,602

$ 43,118



$ 43,118

6/18/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Fresno

N/C















9

County of Kern

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 57,710

$ 57,559

% County of San Diego Above/Below

-33.8%

-33.5%

Number of Matches

5

5

N/C - Non Comparator

Page 450 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Vector Ecologist	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Bernardino

Vector Ecologist

$ 68,245

$ 96,262

1.9%

$ 98,091

3/13/2021

3/26/2022

3.00%



County of San Diego

Vector Ecologist

$ 77,667

$ 95,493



$ 95,493

6/18/2021

unknown

unknown

3

County of Santa Clara

Vector Control Ecologist

$92,991

$ 112,522

-16.8%

$93,618

6/14/2021

6/13/2022

3.00%

4

County of Alameda

Vector Control Biologist

$ 77,808

$ 94,559

-11.4%

$ 83,779

6/27/2021

6/26/2022

3.25%

5

City and County of San Francisco

N/C















6

County of Contra Costa

N/C















7

County of Fresno

N/C















8

County of Kern

N/C















9

County of Los Angeles

N/C















10

County of Orange

N/C















11

County of Riverside

N/C















12

County of Sacramento

N/C















13

County of San Mateo

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 96,262

$ 93,618

% County of San Diego Above/Below

-0.8%

2.0%

Number of Matches

3

3

N/C - Non Comparator

Page 451 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Veterans Services Representative





















1

City and County of San Francisco

Veterans Claims Representative

$ 87,542

$ 106,418

-17.4%

$ 87,901

7/1/2021

1/8/2022

.50%

2

County of San Mateo

Veterans Services Representative II

$ 79,413

$ 99,256

-17.5%

$ 81,886

10/4/2020

unknown

unknown

3

County of Contra Costa

Veterans Service Representative II

$ 69,328

$ 84,269

-11.1%

$ 74,915

7/1/2021

unknown

unknown

4

County of Santa Clara

Veteran Services Representative II

$ 72,933

$ 88,207

-16.8%

$ 73,388

6/14/2021

6/13/2022

3.00%





















6

County of San Bernardino

Veterans Service Officer II

$ 46,904

$ 64,501

1.9%

$ 65,726

7/31/2021

7/30/2022

3.00%

7

County of Orange

Veterans Claims Representative

$ 49,442

$ 66,602

-2.0%

$ 65,270

7/2/2021

7/1/2022

3.50%

8

County of Riverside

Veterans Services Representative II

$ 46,959

$ 63,058

1.9%

$ 64,256

5/1/2021

5/1/2022

2.00%

9

County of Los Angeles

Veterans Claims Assistant II

$ 49,399

$ 66,566

-3.8%

$ 64,037

1/1/2021

unknown

unknown

10

County of Ventura

HS Veterans Claims Officer II

$ 45,030

$ 60,046

-0.7%

$ 59,626

12/26/2020

12/27/2021

2.00%

11

County of Alameda

Veterans Service Representative

$ 56,676

$ 67,227

-11.4%

$ 59,563

6/27/2021

6/26/2022

3.25%

12

County of Sacramento

Veterans Claims Representative

$ 45,727

$ 55,603

0.1%

$ 55,659

6/21/2020

unknown

unknown

13

County of Kern

Veterans Service Representative 1

$ 43,248

$ 52,800

1.2%

$ 53,434

4/21/2021

unknown

unknown

14

County of Fresno

Veterans Services Representative II

$41,626

$ 50,596

4.7%

$ 52,974

4/19/2021

unknown

unknown

Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 66,566

$ 64,256

% County of San Diego Above/Below

-0.9%

2.6%

Number of Matches

13

13

N/C - Non Comparator

Page 452 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

[Veterinarian	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of Riverside

Chief Veterinarian

$ 119,076

$ 201,223

1.9%

$ 205,046

7/1/2021

7/14/2022

2.00%

2

County of Orange

Veterinarian

$ 120,931

$ 163,072

-2.0%

$ 159,811

7/2/2021

7/1/2022

3.50%

3

County of Los Angeles

Veterinarian

$ 116,205

$ 165,343

-3.8%

$ 159,060

1/1/2021

unknown

unknown

4

County of Kern

Veterinarian

$ 113,232

$ 138,300

1.2%

$ 139,960

4/21/2021

unknown

unknown

5

County of Ventura

Veterinarian

$ 98,009

$ 137,213

-0.7%

$ 136,253

unknown

unknown

unknown

6

City and County of San Francisco

Shelter Veterinarian

$ 119,990

$ 156,832

-17.4%

$ 129,543

7/1/2021

1/8/2022

.50%

7

County of Sacramento

Veterinarian

$ 102,771

$ 124,904

0.1%

$ 125,029

6/21/2020

unknown

unknown

8

County of San Diego

Veterinarian

$ 100,901

$ 124,051



$ 124,051

6/18/2021

unknown

unknown

9

County of Contra Costa

Animal Shelter Veterinarian

$ 112,960

$ 133,304

-11.1%

$ 118,507

7/1/2021

unknown

unknown

10

County of Santa Clara

Veterinarian

$ 111,833

$ 135,972

-16.8%

$ 113,128

6/14/2021

6/13/2022

3.00%

11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of San Bernardino

N/C















14

County of San Mateo

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 138,300

$ 136,253

% County of San Diego Above/Below

-11.5%

-9.8%

Number of Matches

9

9

N/C - Non Comparator

Page 453 of 459	Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Victim Advocate









































2

County of Santa Clara

Victim/Witness Advocate

$ 60,773

$ 73,867

-16.8%

$ 61,457

6/14/2021

6/13/2022

3.00%

3

County of Los Angeles

Victim Services Representative II

$ 46,922

$63,216

-3.8%

$60,814

1/1/2021

unknown

unknown

4

County of Riverside

Victim Services Advocate 1

$ 40,280

$ 59,560

1.9%

$ 60,692

5/1/2021

5/1/2022

2.00%

5

County of San Bernardino

Victim Advocate 1

$ 42,536

$ 58,489

1.9%

$ 59,601

7/31/2021

7/30/2022

3.00%

6

County of Contra Costa

Victim and Witness Assistance Program Specialist

$ 52,867

$ 64,260

-11.1%

$57,127

7/1/2021

unknown

unknown

7

County of San Mateo

District Attorney's Office Victim Advocate 1

$ 54,557

$68,160

-17.5%

$ 56,232

10/4/2020

unknown

unknown

8

County of Kern

Victim/Witness Services Specialist II

$ 45,456

$ 55,500

1.2%

$56,166

4/21/2021

unknown

unknown

9

County of Ventura

Victim Advocate II

$39,141

$ 54,890

-0.7%

$ 54,506

12/26/2020

12/27/2021

2.00%

10

County of Sacramento

Victim Witness Claims Specialist

$ 44,057

$ 53,557

0.1%

$53,611

6/21/2020

unknown

unknown

11

County of Fresno

Victim-Witness Advocate

$ 40,898

$ 49,738

4.7%

$ 52,076

4/19/2021

unknown

unknown

12

City and County of San Francisco

N/C















13

County of Alameda

N/C















14

County of Orange

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 59,025

$ 56,680

% County of San Diego Above/Below

17.6%

20.9%

Number of Matches

10

10

N/C - Non Comparator

Page 454 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Victim/Witness Assist Program Manager





















1

County of Los Angeles

Program Administrator, Victim-Witness Assistance

$92,863

$ 125,140

-3.8%

$ 120,385

1/1/2021

unknown

unknown

2

County of Riverside

Victim Services Assistant Director

$ 70,620

$ 106,963

1.9%

$ 108,995

7/1/2021

7/14/2022

2.00%

3

County of San Mateo

Victim Programs Services Manager

$ 104,747

$ 130,913

-17.5%

$ 108,003

12/13/2020

unknown

unknown

4

City and County of San Francisco

Assistant Chief Victim/Witness Investigator

$ 104,806

$ 127,426

-17.4%

$ 105,254

7/1/2021

1/8/2022

.50%

5

County of Sacramento

Victim and Witness Assistance Program Coordinator

$ 95,234

$ 104,985

0.1%

$ 105,090

6/21/2020

unknown

unknown

6

County of Contra Costa

Victim and Witness Assistance Program Manager

$ 95,310

$ 115,850

-11.1%

$ 102,991

7/1/2021

unknown

unknown

7

County of San Bernardino

Victim Services Assistant Chief

$ 64,480

$ 88,608

1.9%

$ 90,292

7/31/2021

7/30/2022

3.00%





















9

County of Alameda

N/C















10

County of Fresno

N/C















11

County of Kern

N/C















12

County of Orange

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 115,850

$ 105,254

% County of San Diego Above/Below

-31.8%

-19.7%

Number of Matches

7

7

N/C - Non Comparator

Page 455 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Victim/Witness Assistance Program Supervisor





















1

City and County of San Francisco

Victim/Witness Investigator III

$ 96,512

$ 117,364

-17.4%

$ 96,943

7/1/2021

1/8/2022

.50%

2

County of Santa Clara

Supervising Victim/Witness Advocate

$ 91,495

$ 111,209

-16.8%

$92,526

6/28/2021

6/27/2022

3.00%

3

County of San Bernardino

Supervising Victim Advocate

$ 58,427

$ 80,309

1.9%

$ 81,835

7/31/2021

7/30/2022

3.00%





















5

County of Contra Costa1

[Victim and Witness Program Specialist/Victim and Witness Program Manager]

$ 74,088

$ 90,055

-11.1%

$ 80,059

7/1/2021

unknown

unknown

6

County of San Mateo

District Attorney's Office Supervising Victim Advocate

$ 75,024

$ 93,806

-17.5%

$ 77,390

10/4/2020

unknown

unknown

7

County of Los Angeles

Supervising Victim Services Representative

$ 55,194

$ 74,382

-3.8%

$ 71,555

1/1/2021

unknown

unknown

8

County of Riverside

Victim Services Supervisor

$ 47,291

$ 69,928

1.9%

$ 71,257

5/1/2021

5/1/2022

2.00%

9

County of Kern

Program Supervisor

$ 50,988

$ 62,244

1.2%

$ 62,991

4/21/2021

unknown

unknown

10

County of Ventura

Victim Advocate III

$ 43,644

$ 61,374

-0.7%

$ 60,945

12/26/2020

12/27/2021

2.00%

11

County of Alameda

N/C















12

County of Fresno

N/C















13

County of Orange

N/C















14

County of Sacramento

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 80,309

$ 77,390

% County of San Diego Above/Below

0.1%

3.8%

Number of Matches

9

9

N/C - Non Comparator

1 - County of Contra Costa: Span of Responsibility Match:
displayed is an average of the matches.

This hybrid match represents that the duties are bridged by a higher and lower level classification at the comparator agency. The salary



Page 456 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Wastewater Facilities Supervisor





















1

County of Sacramento

WastewaterTreatment Plant Operations Supervisor

$ 116,991

$ 128,976

0.1%

$ 129,105

6/21/2020

unknown

unknown

2

County of Ventura

Water/Wastewater Services Supervisor

$ 79,783

$ 107,707

-0.7%

$ 106,953

12/26/2020

12/27/2021

2.00%

3

County of Los Angeles

WastewaterTreatment Plant Supervisor

$ 108,361

$ 108,361

-3.8%

$ 104,243

1/1/2021

unknown

unknown

4

County of Fresno

Supervising Water/Wastewater Specialist

$ 81,042

$ 98,514

4.7%

$ 103,144

4/19/2021

unknown

unknown

5

County of San Bernardino

Water and Sanitation Supervisor (SD)

$ 69,389

$ 95,638

1.9%

$97,456

7/18/2020

unknown

unknown





















7

County of Kern

Wastewater Specialist 1

$ 54,396

$ 66,408

1.2%

$ 67,205

4/21/2021

unknown

unknown

8

City and County of San Francisco

N/C















9

County of Alameda

N/C















10

County of Contra Costa

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 103,111

$ 103,694

% County of San Diego Above/Below

-8.0%

-8.6%

Number of Matches

6

6

N/C - Non Comparator

Page 457 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

Wastewater Plant Operator III





















1

County of Sacramento

Senior Wastewater Treatment Plant Operator

$ 97,489

$ 107,469

0.1%

$ 107,576

6/21/2020

unknown

unknown

2

County of Fresno

Water/Wastewater Specialist III

$ 70,512

$ 85,722

4.7%

$ 89,751

4/19/2021

unknown

unknown

3

County of Ventura

Senior Water/Wastewater Services Worker

$ 66,486

$ 89,756

-0.7%

$ 89,128

12/26/2020

12/27/2021

2.00%

4

County of San Bernardino

Treatment Plant Operator IV (SD)

$ 60,923

$ 81,952

1.9%

$ 83,509

9/26/2020

10/9/2021

2.50%





















6

County of Kern

Wastewater Treatment Plant Operator III

$ 50,472

$ 61,620

1.2%

$ 62,359

4/21/2021

unknown

unknown

7

City and County of San Francisco

N/C















8

County of Alameda

N/C















9

County of Contra Costa

N/C















10

County of Los Angeles

N/C















11

County of Orange

N/C















12

County of Riverside

N/C















13

County of San Mateo

N/C















14

County of Santa Clara

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

$ 85,722

$ 89,128

% County of San Diego Above/Below

-3.8%

-7.9%

Number of Matches

5

5

N/C - Non Comparator

Page 458 of 459

Appendix II: San Diego Market Findings

-------
County of San Diego
Appendix II: Market Compensation Findings
July 2021

| Watershed Manager	|

Rank

Comparator Agency

Classification Title

Annual
Minimum

Top Annual

Geographic
Differential

Adjusted
Top Annual

Salary
Effective
Date

Next Salary
Increase

Next
Percentage
Increase

1

County of San Diego

Watershed Manager

$ 77,917

$ 95,805

$ 95,805

6/18/2021

unknown

unknown

2

City and County of San Francisco

N/C















3

County of Alameda

N/C















4

County of Contra Costa

N/C















5

County of Fresno

N/C















6

County of Kern

N/C















7

County of Los Angeles

N/C















8

County of Orange

N/C















9

County of Riverside

N/C















10

County of Sacramento

N/C















11

County of San Bernardino

N/C















12

County of San Mateo

N/C















13

County of Santa Clara

N/C















14

County of Ventura

N/C















Summary Results

Top Annual

Adjusted
Top Annual

Median of Comparators

N/A

N/A

% County of San Diego Above/Below

N/A

N/A

Number of Matches

0

0

N/C - Non Comparator

Page 459 of 459

Appendix II: San Diego Market Findings

-------
lose Salary Compensation Study - final Report

County of San Diego

>loqy for	>r

-------
Methodology
The Geographic Assessor® & Pay Survey

ERi Economic Research Institute was founded over 25 years ago to provide compensation applications
for private and public organizations. ERi's applications are available to management, analysts and
consultants and are now widely used by client organizations. Subscribers include corporate
compensation, relocation, human resources, and other professionals, as well as independent consultants
and counselors, and US and Canadian public sector administrators (including military, law enforcement,
city/county, state/provincial, and federal government pay administrators).

ERi compiles the most robust salary, cost-of-living, and executive compensation survey data available,
with current market data for more than 1,000 industry sectors. The majority of the Fortune 500 and
thousands of other small and medium sized organizations rely on ERi data and analytics for
compensation and salary planning, relocations, disability determinations, board presentations, and setting
branch office salary structures in the United States, Canada, and worldwide.

ERi is a leader in the collection, and analysis of compensation, occupation, and cost-of-living data. All
data are employer-provided and come from a variety of sources. Survey data are collected through
internally conducted salary surveys and the purchase of third party salary surveys. Additional data are
gathered through the digitization of Proxy and 10-K data and Freedom of Information Requests in the US.
Compensation data are compiled in terms of mean and median salaries for jobs of similar duties,
responsibilities, skills, and functions through an extensive job matching process. ERi produces surveys
and application analyses by which managers, advisors, and Boards of Directors may make
recommendations and/or decisions. ERi does not provide fee-for-service consulting; our sole focus is
providing valid and reliable information to our subscribers.

Overview

The Geographic Assessor & Pay Survey application and databases present in-depth time series
regression analyses of base salary and wage differences among and between different cities and areas.
ERi researchers have utilized these regression techniques for decades, the difference from the original
publication being the extent and quality of survey data that are available today. Geographic cost of labor
regressions represent analyses of the demand and supply of labor (as opposed to cost-of-living's
reflection of the demand and supply of goods and services). ERi has been collecting and analyzing salary
surveys since its founding; over 20 million position incumbents' data are now included in ERi's survey
databases. For those interested, we refer the reader to ERi's founder's original published article on this
subject:

Thomsen, D. J. (1974). Geographic Differentials in Salaries Within The United States, Personnel
Journal, 53, 9, 670-4.

Salary/Wage Differentials

The Geographic Assessor & Pay Survey application is an easy-to-use program that aids with the
assessment of branch location wage and salary competitiveness and the setting of salary structures.
ERi's Geographic Assessor & Pay Survey application calculates wage and salary differentials between
any of over 7,300 North American cities and almost 1,300 European cities.

Cost-of-Living Analyses

The Geographic Assessor & Pay Survey application and databases presents cursory cost-of-living
information. This information is limited to renters' spending patterns and is intended to provide only a first
look at the relative buying power of wages/salaries in different areas. ERi recommends using salary
differentials for salary structure adjustments; however, the Geographic Assessor does report summary
cost-of-living differentials to develop a more comprehensive picture of a location (or potentially for use in
conjunction with the salary differentials).

Statistical Methodology

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The Geographic Assessor & Pay Survey application consists of linear regression analyses programs.
Eight trend lines are created for any area. Local area salary data are compared to the corresponding
national salary by job or job family to create a series of differentials per area. A sample of these
differentials by job or job family is displayed on the Graphs tab. To create a single differential across
jobs (one that can vary by salary level), the average, conditional on salary level, is computed via a simple
linear regression (the regression line is also displayed on the Graphs tab). Since these differentials vary
both by salary and salary structure, a separate regression is performed for each salary structure. The
user only needs to input the salary level for the base location; the program automatically assigns the
structure based on the ranges below and returns the corresponding differential.

Structures

These regression equations are expressed in terms of "structures," as follows:

Wage Earner Structure	Min - 24,000

Low Salary Structure	24,000 -36,000

Mid Salary Structure	36,000 - 48,000

High Salary Structure	48,000 - 72,000
Management Salary Structure 72,000 - 108,000

Executive-1 Structure	108,000 - 144,000

Executive-2 Structure	144,000 - 192,000

Executive-3 Structure	192,000+

The Wage/Salary area structures are the formulae resulting from ERi's regression analyses of all
available data for the area. The program will automatically assign the correct structures by city on the
Two City Comparison table, the Comparison List table, and the Graphs table.

Sources

Data used in the cost-of-labor calculations come from salary survey sources. ERi collects available
salary survey data for jobs and areas; evaluates survey data for validity and reliability; and compiles
mean and median salaries for positions with similar duties, responsibilities, skills, and functions.

Because ERi has decades of experience collecting and evaluating salary data, we have refined methods
for validating both the source data and results.

Selected FAQs

Who uses the Geographic Assessor application and databases? How do they use it and how
should I?

Companies setting salary structures, who pay different rates in different locations, use it. Branch pay
differentials allow you to take advantage of the differing labor markets to minimize operating costs while
maintaining the ability to attract, retain, and motivate employees in each area. Most often, companies
use the labor cost differentials reported by the Geographic Assessor to make data-based decisions and
manage complexity by adjusting existing structures based on local labor cost differentials or, when the
differentials are sufficiently large, to develop new structures. Companies also use the labor cost
differentials to research general overall labor cost differences associated with opening new branch
offices. In addition to using the Geographic Assessor with salary structures, there are other uses of
labor cost differentials, such as to adjust salary survey results directly, say from state or region to the
national equivalent (or the inverse) when data at the desired geographic level or area is not directly
available.

While these are all valid uses of labor cost differentials per se, each planning situation is different. So it
is important to keep in mind the current planning context such as consistency with prior methods,
compensation philosophy, and organizational culture, and so on when deciding how to best leverage the
differentials reported. We at ERi are happy to answer questions on the data and general uses, but we
do not do consulting.

-------
In terms of specific users, a number of voluntary subscriber disetoiure* about reliance on ERi data are
cited in customer testimonials (see http./.'www.erieri. com/testimonials) and corporate proxies
(http://www,erieri.com/ExecuMveCom[>ef)sa[ionProxvDala } and periodically appear in other authorized
releases or public declarations. While ERI does not release listings of the names of its subscribers ERi
has thousands of subscribers, including flw majjorfty iflftttn®	several large government

Agencies.	tftecsliwii, human resources specialists,

plus other professional®, as well a®	e.
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A more complete differentiation can be found in Help under Assessor Series FAQ #3, but this question
arises often enough that an abbreviated response should be included here. Put simply, wage and salary
differentials reflect the local demand for and supply of labor, whereas cost of living is dictated by the local
demand for and supply of goods and services. Because different factors affect the supply and demand of
labor than affect the market basket of goods (the basis of cost of living), these two differentials will not, in
most cases, be the same. Research has shown they often do move in the same direction, but not
always. Take the case where there is a net increase in workers due to migration. The increase in labor
supply could put downward pressure on the labor differential while putting upward pressure on housing
costs, thereby increasing cost of living. Even when the differentials are in the same direction, the
magnitudes can be very different. In urban centers, for example, both types of differentials are often
higher; but, since workers can commute from areas with less expensive housing, the COL differentials
tend to be much higher than the labor differentials in these cases.

Besides the underlying difference in the supply and demand, another reason why users focus on cost of
labor differentials is that cost-of-labor differentials often more closely correspond to the labor market
scope of the salary structure. In other words, COL can vary greatly from neighborhood to neighborhood
within the same city, but companies would not restrict the recruitment labor market to a single
neighborhood.

While employees may find it more desirable for their pay to be adjusted for local cost-of-living variances,
this is an extremely unusual practice, and in many cases will not be cost effective for the employer. That
is, in many cases, the employer would be competing against organizations with relatively lower
compensation costs and, thus, be at a competitive disadvantage. Most compensation professionals
agree that, when a company is hiring from the local work force (that is, when no transfer or relocation
occurs), wages and salaries are set according to market pricing of wages and salaries only. In a recent
informal polling of webinar attendees, most used salary differentials when adjusting salary structures,
while a much smaller subset used both types in conjunction (perhaps where required). None used cost
of living exclusively. While the cost-of-labor differentials are best utilized when adjusting pay structures
(as the underlying data are congruent), in practice, there may be other contextual factors such as
compensation philosophy or contractual requirements that need to be considered.

The program allows me to easily compute cross-country comparisons, but are such comparisons
valid?

The cross-country comparisons are statistically valid; however, it is not advisable to take a pay system
from, say, the United States and try to adjust it for a Canadian branch office using the general geographic
differentials because U.S. and Canadian economies value jobs quite differently (as do most international
economies). It is important to review pay by job and job description, rather than by general salary level.
Cross-country comparisons, however, can give some general insight into labor cost differences where
such information may be difficult to obtain otherwise.

Reliability Statistics - A Note for Expert Witnesses

In 1975, the US Congress passed Federal Rule of Evidence 702 so that a threshold standard for the
admission of expert witness testimony might exist in federal courts. Based on the concept that experts
should use methodologies that are "generally accepted" by a discipline's practitioners, the rule states: "If
scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence
or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training,
or education, may testify thereto in the form of an opinion or otherwise." Following this, the Supreme
Court issued an opinion in Daubert v. Merrill-Dow Pharmaceuticals, 509 U.S. 579, 113 S. Ct. 2786, 125
L.Ed.2d 469 (1993) that has become the standard for the admission of "general acceptance". In this Case
(which standard is now adopted by federal and most state courts), the admittance of expert witness
testimony and evidence required a two-step analysis: A) Evidence must be relevant, and B) Evidence
must be reliable. The "relevance" is a subjective judgment, but simple logic may be applied (salary survey
data for use in labor cost differentials, proxy compensation data for use in maximum reasonable
compensation cases, etc.) For the latter, "reliability", the Supreme Court established four separate,
non-exclusive tests: 1) it can be illustrated that the theory or technique can be tested, 2) the data has

-------
been subjected to peer review and publication, 3) there is a known or potential rate of error, and (4) there
a level of general acceptance in that particular discipline's community.

ERi Statement as to the Relevance and Reliability of Data

Relevance is totally determinable by the circumstances and situation presented. ERi provides outsourced
analyses and presentations of salary, executive compensation, benefit, and cost-of-living survey data.
Reliability is described in a four part, non-exclusive summary to match the Daubert challenge:

Testable

To illustrate how the technique can be tested is straightforward. The technique and data sources are
described in this methodology, and replicating the results is a matter of performing similar regressions
through similar salary data. Using smaller data samples will likely give similar, albeit less robust and
comprehensive, results.

Subject to Publication and Peer Review

Assessor Series application databases are published on a quarterly basis. Unique monthly Internet visits
now exceed 500,000 to http://www.erieri.com and related sites, with approximately five million unique
visitors each year. ERi's peers are its competitors, those firms that also provide data analyses to their
clients. Unlike ERi, that solicits an annual subscription, most compensation and benefits consulting firms
charge an hourly rate for their research services. Suffice it to say, all the major consulting firms have
purchased subscriptions so that their consultants could utilize ERi analyses. ERi data are used by these
firms when consulting with their clients.. ERi data and analyzes are under constant review and critique by
its competitors. ERi, unlike these firms, provides no fee-for-service/time consulting.

Known or Potential Rate of Error

Each Assessor Series application database illustrates, via a "Reliability Statistics" link, the beginning of
a statistical overview of ERi data. Statistics are reported as derived from just one survey source for all
salary and compensation presentations (so that copyright restrictions are not violated). ERi accumulates
many survey sources to compile its analyses. Hence the data illustrated may be, in ERi's estimate,
considered to be the highest possible standard error that might exist with each analysis. Assessor
Series application database results are, by logic, more robust than the standard error displayed and
reported.

General Level of Acceptance within the Discipline's Community

ERi has thousands of subscribers, including the majority of the Fortune 500 and several large
government agencies. Many of these organizations are entering their third decade of being subscribers.
ERi exhibits at major tradeshows. ERi data are used as source data by major publications and job
boards. WorldatWork, NASBA, and HRCI accept ERi Distance Learning Center courses for professional
maintenance and recertification continuing education credit. Major US employers rely upon ERi data as
cited in corporate proxy filings (see http://www.erieri.com/ExecutiveCompensationProxvData).

ERi Economic Research Institute is a licensed user of postal code and latitude and longitude data from
the United States Postal Service (USPS). Canadian Postal Codes are adapted from Statistics Canada
Postal Code°M Conversion (2013) which is based on data licensed from Canada Post Corporation.
Contains data adapted from Statistics Canada, National Household Survey, 2011. This does not
constitute an endorsement by Statistics Canada of this product. Contains Ordnance Survey data ©
Crown copyright and database right 2017. Contains Royal Mail data © Royal Mail copyright and
database right 2017. Contains National Statistics data© Crown copyright and database right 2017.

ERi Economic Research Institute

111 Academy Drive, Suite 270, Irvine, CA, 92617 USA
Telephone (800) 627-3697
Email info.eri@erieri.com
http://www.erieri.com

5

-------
Assessor Series application and database access by license agreement only.

Copyright © 1989-2017 ERi Economic Research Institute, Inc.

Patent Nos. 6,862,596 and 7,647,322

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Assessor Seri

Frequently Asked Questions

QUESTION: What is the difference between cost-of-living and geographic pay
differentials

Wage and salary differentials reflect the local demand for and supply of labor.

Cost of living is dictated by the local demand for and supply of goods and services.

ERI subscribers may also come across the term "buying power," which is the inverse of cost
of living. Cost of living is the cost of purchasing goods and services, as determined by the
demand and supply of goods, services, and property. For example, if the cost of living is
10% higher in an area, the buying power is approximately 10% less in that area.

This demand for and supply of goods and services are defined in terms of the data ERI
surveys for Assessor Series cost-of-living databases. This data is downloaded from existing
sources and includes: rental rates, housing prices, income taxes, property taxes, gasoline
prices, medical costs/services, major retail grocery and drug store prices, etc. Cost-of-living
differentials, as reported by ERI, reflect cost models at different income levels (e.g., an auto
of "x" value driven "x" miles/kilometers, home rental with no mortgage income tax
deductions, home ownership with income tax mortgage deductions, etc.). Local wages and
salaries do not indicate the local cost of living. Cost of living indicates the comparable local
buying power for any given salary.

Most compensation professionals agree that when a company is hiring from the local work
force (that is, when no transfer or relocation occurs), wages and salaries are set according
to market pricing of wages and salaries only. In general, branch pay should be dictated by
market pricing of wage/salary differentials only.

While employees may find it more desirable for their pay to be adjusted for local cost-of-
living variances, this is an extremely unusual practice, and in many cases will not be cost
effective for the employer. That is, in many cases the employer would be competing against
organizations with relatively lower compensation costs and, thus, be at a competitive
disadvantage.

In most cases, cost-of-living is considered only when an employee incurs new expenses due
to an "internal" move from one branch office to another. In this situation, the new salary
would be set according to the destination market (local wage and salary level). Then, any
cost-of-living allowance would be awarded separately from salary and for a finite period of
time.

It is undesirable to build a cost-of-living adjustment into salary, as the integrity of the current
salary administration program will be compromised. For instance, the transfer of personnel
into an office where locally hired employees would be earning lower salaries than the
transferee's "cost-of-living adjusted salary" is an undesirable and avoidable situation. The
transfer of personnel into an area where local competitors' employees would be earning
higher salaries than the transferee's "cost-of-living adjusted salary" is an equally undesirable
and avoidable situation. Better solutions would include the award of a one-time (lump sum)

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moving bonus or a gradually decreasing three-year cost-of-living allowance, which is
awarded separately from the new locally adjusted competitive salary. Each organization's
unique situation (tax considerations, cash-flow, etc.) will dictate the best method for handling
cost-of-living allowances.

A random telephone survey by ERI's Director found that only 2% of ERI subscribers pay "the
same for all jobs nationally, but vary levels by the cost of living." All other surveyed
subscribers stated that they ignore cost of living and concentrate on the demand and supply/
local market pricing to administer geographic pay differentials.

Cost of Living v Market Pay Rates

There are many reasons why employers decide to pay the local market pay rate (what it
takes to attract, retain and motivate a competent worker) instead of paying according to local
costs:

No two employees have the same living costs. Even if they hold the same job and earn the
same money, their family circumstances and spending practices vary.

The cost of living depends on family lifestyle and the total budget available from all income
earners in the family. Family expenses differ according to many variables, such as the
number of income earners, the total budget available, size of home, whether renting or
buying, how many dependents, number and value of automobiles, and more. Every cost-
of-living statistical model uses a different standard market basket of goods and services.

It is quite difficult to come up with only one cost figure that properly fits every employee
lifestyle, but it is quite simple to determine what other employers pay for the job you do.

Pay is usually set once a year according to local salary levels, corporate pay strategy, and
budget, but costs change constantly. Prices go up and down all the time, and employees
would be quite upset if their wages were cut because the price of bread dropped this
week, for example.

Companies pay for you to do work, at a competitive rate, rather than give you amounts
based on your expenses. Employers are not even legally allowed to question job
applicants about their family circumstances, so they are not about to set pay according to
your spending pattern.

People don't usually live where they work. Most employees live in a town where the costs
fit their family budget and where the prices are lowest for their lifestyle. They work where
their employer is located, and that usually is not within walking distance of home. Basing
pay on home location and family expenses would require different pay scales for every
worker and even different rates for the same job done by people in the same community,
if, for example, one was a single renter and the other was a homeowner with five
dependents.

Relevant living costs are already covered by pay surveys. If wages and salaries are
influenced by living costs, then the competitive market pay surveys reflect those costs. If

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you wish to research livings costs, see ERI's Relocation Assessor, which calculates cost-
of-living levels based on earnings level, family size, home size, and automobile usage. The
application reports the cost-of-living differential between a base city and destination city to
determine the amount an employee must earn in the new location to "remain whole" (not
lose buying power).

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