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BOARD MEETING DATE: February 1, 2008
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PROPOSAL:
SYNOPSIS:
COMMITTEE:
RECOMMENDED ACTION:
Barry R. Wallerstein, D.Env. Background Field Implementation of Enhanced PERP Program In 1995, the California state legislature directed CARB to establish a program allowing the operation of portable equipment in any air district throughout the state without individual local district permits. The regulation implementing CARB’s Statewide Portable Equipment Registration Program (“PERP,” §§ 2450-2465, Title 13, California Code of Regulations) became effective September 17, 1997. Joint CAPCOA and industry recommendations led CARB to amend the PERP regulation on June 22, 2006, December 7, 2006, and March 22, 2007. These amendments enhanced enforceability and expanded CARB’s requirements for portable engines and equipment units, creating a more comprehensive and inclusive statewide registration program that now provides for triennial renewal of PERP registrations. Statewide inspection fees collected and disbursed to AQMD and other local “home districts” responsible for implementing the regulation were increased to offset the cost of additional compliance activities. Expected annual revenues from compliance activities and registration renewals for each type of PERP equipment are shown in the table below:
* Collected by CARB at time of equipment registration and triennial renewal and disbursed to “home district” for field enforcement activities. These revenues are expected to increase over the next few years as enhanced statewide field implementation, combined with outreach by CARB and home districts, enables inspectors to take appropriate enforcement action upon location of unregistered or unpermitted portable equipment subject to program requirements. Five additional compliance staff (a Supervising Air Quality Inspector and four Air Quality Inspector IIs) are required to implement field enforcement of the enhanced PERP program, which includes the timely completion of approximately 3,000 (75% retention of 3,800 total equipment inventory) portable equipment inspections each year and the identification of non-permitted, non-registered equipment. In addition, one Senior Office Assistant is needed to restore existing clerical resources reassigned to the PERP program. Revenues generated from this program are expected to fully offset the cost of these compliance activities and will replenish this funding request. Adjusted Resources for RECLAIM Administration A Senior Air Quality Engineer is required to supervise audit review activities in the RECLAIM Administration group. Significant engineering resources are being invested in assisting field inspectors in technical facility-specific emissions calculations and in reviewing proposed RECLAIM Trading Credit (RTC) trades. The technical complexity and financial implications of these activities continue to increase, and section supervision is required. Proposal
A request for quotations (RFQ) will be subsequently submitted to the Board to seek bids for five new inspector vehicles. Resource Impacts The annual top step salary and benefits cost of proposed staffing changes is approximately $616,819. The FY 2007-08 cost, including start-up costs of $150,000 for inspector vehicles and $9,000 for laptop computers for new PERP compliance positions, is approximately $336,517. While it is anticipated that not all of the positions will initially require top step, all figures were calculated using the highest salary step to demonstrate maximum costs fall below minimum expected program revenue from CARB. Inspection fees assessed for equipment currently registered in PERP program will generate annual revenues of approximately $834,000 fully offsetting these expected costs. Attachments Exhibit A – Recommendations to Add/Delete Positions Exhibit A Recommendations to Add/Delete Positions
Approximate FY 2007-08 Impact (Staffing and Equipment): $336,517 * FOOTNOTES:
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