Page 236 - Sustainable On-Site CHP Systems Design, Construction, and Operations

Obtaining a Construction Permit 209

Local permitting standards are typically specified in policy or guidance documents
that the permitting agency may issue. This is especially true when the agency encoun-
ters multiple applications for similar projects. In cases where the permitting authority
requires the use of BACT, but does not have significant experience with CHP systems,
the applicant may be required to take on the burden of demonstrating that the proposed
technology is appropriate for the project. In these cases there are various resources and
tools that are available to the applicant to assist in the equipment selection process
such as technology clearinghouses, vendor technical data, and technology analysis
tools and models.
Technology Clearinghouses
Several environmental agencies maintain clearinghouses and technology guidelines
that a project engineer or developer may find useful, even if the proposed project is not
within the jurisdiction of those agencies. The U.S. EPA manages BACT/LAER clearing-
house into which local permitting agencies submit information about recent projects.
Through this clearinghouse one can see what various agencies perceive to be achievable
emission rates for a variety of applications, including CHP. U.S. EPA maintains this
clearinghouse on its Web site www.epa.gov. The California Air pollution Control
Officers Association maintains a similar clearinghouse that contains recent permitting
data from the 34 local air districts within the state (www.arb.ca.gov).
Some agencies offer technology guidance documents. The South Coast Air Quality
Management District, which regulates air emissions in Los Angeles, California, main-
tains a BACT guidance document that reflects periodic evaluations of current tech-
nology. Private and public sector representatives participate in the guidance development
process through the review and debate of technological advancements in the United
States and elsewhere. The broad-based participation by technology manufacturers,
project engineer or developers, and system operators and regulators helps to ensure
that the resulting technology guidance is assertive, and also that the resulting standards
are achievable (www.aqmd.gov).

Vendor Technology Data
Vendor specification sheets, emission guarantees, and price data are also useful in iden-
tifying the appropriate technology and emissions standards to be applied to a CHP
project. Specification sheets can show differences in the performance of various
emission control options that may be applied to the base combustion technology. It is
important to note that the lack of a vendor emissions guarantee (or a vendor emissions
guarantee at levels that are higher than what is typically achievable) will not necessarily
justify the application of less stringent emissions or technology standards than the
permitting agency would otherwise apply to a CHP project.

Technology Analysis Tools and Models
The combination of specification sheets and price data will help both the applicant and
the permitting agency understand the cost-effectiveness of optional technology that
could be utilized for a CHP project. In many cases, but not all cases, the cost-effective-
ness of alternative emission control technologies can be considered as a factor in select-
ing the final project design. Generally, cost-effectiveness analyses consider discounted
cash flow or an annualized cost over an assumed project life, relative to the emission
reductions that can be achieved. The resulting cost-effectiveness factor is compared to a