Southern California is a hotbed for specialty coffee, but there are a few things that you need to know if you’re planning to install a coffee roaster in the area.
According to South Coast Air Quality Management District (AQMD) Rules 201 and 203, a permit is needed to both construct and operate a coffee roaster. In the definitions of the permitting rules, this can include new construction, bringing an old unit to the area and firing it up, or modifying an existing coffee roaster.
To get a permit from the AQMD, you need to prepare an application that includes permitting forms, permit processing fees, and a detailed engineering evaluation. You will then submit these three components to the AQMD for processing.
Getting a permit from the AQMD usually takes between three and six months, but it can take longer depending on the complexity of the project and where the roaster will be located within the AQMD. Once you get your permit, additional requirements such as source testing will need to be met.
It’s important to keep a few things in mind when you permit a roaster with the AQMD, some of which have the ability to impact an overall installation project.
1. Your coffee roaster may be exempt from needing an AQMD permit.
According to AQMD Rule 219, there are specific situations where a piece of equipment does not need a permit to construct or operate. The AQMD provides such exemptions because the construction and operation of these pieces of equipment have a de minimis level of emissions (defined by the EPA as “the minimum threshold for which a conformity determination must be performed”).
As it relates to coffee roasters, Rule 219 exempts units that have a roast capacity of fewer than 10 lbs/batch from requiring a permit before construction and operation. The AQMD currently has a proposal that may be adopted by the end of 2016 to increase the 10 lbs/batch limit to 15 kg (33 lbs)/batch. In this case, roasters that have a roast capacity of 15 kg or less will not need a permit from the AQMD.
2. Stringent NOx limits can be a real challenge.
The AQMD has very stringent rules and limits on the oxides of nitrogen (NOx) emissions from a coffee roaster.
Typically, the burner of a new coffee roaster needs to meet the requirements of Rule 1147, which states that the NOx emission limits are either 30 ppm or 60 ppm, depending on the process temperature of the roaster.
It’s also important to remember that, according to Rule 1147, these NOx limits are for the burner itself, not the burner and the roasting of the beans. The roasting of the beans can add between 50 and 70 percent NOx to the process.
3. Existing coffee roasters that relocate are treated as new units and are subject to more stringent NOx limits.
In the AQMD, permits are issued to a single piece of equipment at a specific location. Therefore, when a piece of equipment moves from one location to another, the existing permit becomes void.
This presents an interesting case for coffee roasters because of Rule 1147 and Rule 1153.1. For example, new coffee roasters are covered under Rule 1147, but existing coffee roasters that were installed before November 7, 2014 are instead covered under Rule 1153.1.
Rule 1153.1 provides the same NOx requirements for Rule 1147. However, the timelines that are allowed under Rule 1153.1 are extended.
For example, under Rule 1153.1, an existing coffee roaster that was built after 1998 and installed before November 7, 2014 has until July 1 of the year the unit is 20 years old to meet the NOx emission limits in the rule. On the other hand, a new unit must meet the 30/60 ppm NOx emission limit within the timelines of Rule 1147 — which is basically as soon as possible.
If a unit is installed and is an existing unit under Rule 1153.1, the roaster can benefit from the extended timelines of Rule 1153.1. However, if the same unit that meets the requirements of Rule 1153.1 moves to a new location, the unit is no longer classified as an existing unit and must therefore meet the requirements of Rule 1147.
Depending on the configuration and age of the unit, it may not be possible for the existing roaster to meet the NOx requirements of Rule 1147 due to the lack of burners that are available. Therefore, if you’re considering relocating your unit, it’s best to see if the unit can meet the requirements of Rule 1147 before you do so — or you may end up needing to buy a new unit altogether.
4. Your coffee roaster may need to go through a public notification process as part of the permitting process.
According to the AQMD, if a facility is located within 1,000 feet from the outer boundary of a school, the facility must undergo a public notification process as part of the permitting process. The notification process requires that you notify all parents of the children who attend the nearby school as well as all of the home and businesses owners within 1,000 feet of the facility.
Once these notifications go out, the public has 45 days to respond and comment on the project. If no comments are received in this time, the AQMD can issue the permit to the facility.
5. All construction related to the installation of the coffee roaster cannot occur until the AQMD permit is in hand.
This has always been a thorny issue because of the many interpretations of what “installation” means.
For context, Rule 201 notes:
A person shall not build, erect, install, alter or replace any equipment or agricultural permit unit, the use of which may cause the issuance of air contaminants or the use of which may eliminate, reduce or control the issuance of air contaminants, without first obtaining written authorization for such construction from the Executive Officer.
The problem is that “not build” is not defined in the AQMD’s rules, and the phrase is up to the interpretation of the inspector. Some interpret this to mean not installing the equipment. Others interpret this to mean the ability to install “dead piping” related to the equipment.
Therefore, it’s best to not start any construction that is related to the coffee roaster regardless if it’s electrical, water, or otherwise. Put another way, if the construction activity would not otherwise be taking place (i.e., you’re doing work to prepare for other equipment, not just the roaster), it would be best if the construction did not take place at all since any construction could be construed as a violation of the phrase “not build.”
6. Due to all of the moving parts, it’s best to start the permitting process sooner rather than later.
There’s a little more work to permitting a coffee roaster in Southern California than simply installing it. That’s because of the area’s stringent air pollution requirements, which can add scope, cost, and time if not properly addressed.