Moving to Canada if a “certain” candidate wins the presidential election has been a recent topic of conversation.
On the other hand, businesses move all the time, and they move for various reasons.
In an article in Entrepreneur Magazine, Mark Henricks referenced the five reasons Sharon K. Ward gave for why businesses move:
- Labor and workforce issues
- The desire to reach new market
- The need to upgrade facilities or equipment
- The desire to lower costs or increase cash flow
- Considerations about quality of life
As it relates to South Coast Air Quality Management District (AQMD) air permits, there is one thing everyone must know about when moving:
Under AQMD Rule 206, air permits expire when the equipment moves from one location to another.
Therefore, if your business has equipment that holds air permits from the AQMD, those permits will expire when you move your business.
In addition, in order to properly operate your equipment at your new facility location, each piece of your equipment must have a permit issued to the new location prior to construction, operation or relocation of the equipment.
Therefore, you’ll need to reapply for your permits at your new location.
Because of this, there are five things to consider prior to going through the moving process, which you should keep in mind … even if Donald Trump doesn’t become president.
1. You should have all of your permits in hand before moving or before starting construction on equipment at your new location.
The AQMD’s rules require you to have a permit to both construct and to operate a piece of equipment.
In our experience, there has always been some confusion as to what it means to have constructed a piece of equipment.
- Is building the foundation for a new engine considered to be construction of the engine?
- Is having an engine on-site still in the crate considered to be construction of the engine?
- Is moving an existing engine from the old to the new location considered to be construction of the engine?
Due to the different interpretations, in order to avoid any confusion about what or when a piece of equipment is constructed, it is best to not move a piece of equipment or start any work on one that needs a permit until you have all of your permits in hand from the AQMD.
2. You may need to notify the public that you are moving to the area.
Under AQMD Rule 212, any facility that’s located within 1,000 feet of the outer boundary of a school must provide a notice to the parents or legal guardians of children who attend that school.
The applicant must distribute the notice to each address within a 1,000-foot radius from the outer property line of the proposed new or modified facility.
3. You may be subject to new emission requirements and need to purchase a new burner or equipment.
Depending on the rules that pertain to your equipment and to your facility, moving may sometimes cause you to be subject to new emission requirements.
For example, in AQMD Rule 1147, a piece of equipment can be exempt from the emission requirements of the rule if the piece of equipment was installed between 2007 and 2012.
Therefore, if this piece of equipment moves to a new location, it no longer qualifies for this exemption and will need to meet the requirements of Rule 1147.
In practice, and depending on the type of equipment, this may mean retrofitting a piece of equipment with a new burner in order to meet the emission requirements of Rule 1147.
4. You may need to implement a plan to lower the health risk of the new location.
Each facility that emits air contaminants will have a certain health risk due to its operation. This health risk is due to a combination of factors, including types of air contaminants, the emission rates, and the distance from the equipment to an off-site receptor.
In practice, the health risk from a given facility will increase if there are off-site receptors closer to the equipment.
In addition, if the health risk from the operation of a piece of equipment exceeds certain levels, additional controls may be needed in order to comply with the AQMD permitting rules.
Therefore, when you move to a new location, it’s best to know the types of receptors in the area as well as their distance to your facility so that you can know the impacts of the operation of your facility.
5. You may be required to secure emission reduction credits in order to operate your equipment at the new location.
Emission reduction credits (ERC) are credits issued by the AQMD that symbolize real and quantifiable emission reductions due to the shut-down of older pieces of equipment or facilities.
During the new source review process, a piece of equipment will need to be assessed to determine if it requires emission reduction credits.
If these credits are needed, you’ll need to purchase these credits from the open market in order to get your permits from the AQMD (there are exemptions for certain cases).
The bottom line about moving and AQMD permits
Moving may be a smart decision depending on the reason or combination of reasons for the move.
But a smart move is one that considers the AQMD permits your facility currently has.
If you’re planning to move your facility to another location within the AQMD, knowing these five items can reduce some of the unknown bogies that can arise during the moving process.
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Image Credit: Pugo Design Studio
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