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Public Comment Period, Public Hearing: Proposed amendments to SRCAA’s Consolidated Fee Schedule

Spokane Regional Clean Air Agency’s (SRCAA) Board of Directors has a long-standing financial goal of full cost recovery for SRCAA’s fee-based programs. Rising costs to administer fee-based programs have prompted SRCAA to propose changes to its Consolidated Fee Schedule, including:

SectionSection TitleAction
10.06(B)Annual Registration FeesInflationary increase 3%
10.06(C)Annual Air Operating Permit FeesIncrease the emissions fee component to redistribute annual fees to be more emissions weighted. This action does not increase AOP fees.
10.07Notice of Construction (NOC) and Portable Source Permit (PSP) Fees; base, filing, investigation and hourly ratesInflationary increase 3%
10.08Miscellaneous Fees; filing and hourly ratesInflationary increase 3%.
9.09.C & 10.09AsbestosIncrease 15%; except fees that are $0
10.13Other Outdoor Burning Waiting Period and Fees; filing and hourly ratesInflationary increase 3%

The public is invited to review and comment on the proposed amendments:

Redline of proposed amendments

Comments: Written comments will be accepted until 8 a.m., August 1, 2024. Written comments may be submitted by mail or email:  SRCAA, Attention Margee Chambers, 1610 S. Technology Blvd., #101, Spokane, WA 99224, or PublicComment@spokanecleanair.org.

Public Hearing: A public hearing will be held during SRCAA’s Board of Directors meeting, 9:30 a.m., Thursday, August 1, 2024, at SRCAA’s office, 1610 S. Technology Blvd. #101, Spokane, WA 99224. A virtual / call-in option for the public hearing will be provided on the board meeting agenda which is posted at SpokaneCleanAir.org, a week prior to the meeting.

Please note that under the Washington State Public Records Act (Chapter 42.56 RCW), your written and oral comments, attachments and associated contact information (e.g. your name, address, email, etc.) become part of the public record and can be released to the public upon request.

Details on the proposed amendments to SRCAAs Consolidated Fee Schedule:

Annual Registration Program, Section 10.06(B). The annual registration program is required under the Washington State Clean Air Act. About 583 commercial and industrial facilities in Spokane County participate in the Spokane Clean Air Registration Program. Registration includes an annual fee and reporting, and periodic inspections. Registration verifies compliance and helps maintain an accurate inventory of air pollutants. Facility data also helps with the evaluation of pollution control strategies which are designed to meet national air quality standards. Compliance verification is integral to achieving and maintaining those standards.

Section 10.06(B)Current FeeProposed Fee
Facility Fee$365$375
Emissions Fee ($/ton)$110$113
Emission Point Fee ($/stack)$110$113
SM Fee$2,400$2,472

For questions on the proposed amendments and the how the annual registration program proposed fees might look for your business, our engineering section can assist you. Call 509-477-4727 and ask to speak with an engineer.

Annual Air Operating Permit (AOP) fees, Section 10.06(C). Spokane Clean Air administers the federal Air Operating Permit (AOP) program in Spokane County. Major emission sources and other sources identified by the Environmental Protection Agency are required to obtain an AOP. There are seven facilities that participate in the agency AOP program. The program is currently at full cost recovery as mandated by the Federal Clean Air Act.

The AOP program fees have three main components:  base fee, emissions fee ($/ton), and time fee (based on number of staff hours spent on facility during most recent fiscal year). The goal of the AOP fees is for the emissions fee and the time fee to be close to equal. Currently, the emissions fee component is approximately $55,000 lower than the time fee. SRCAA is proposing to change the distribution of the three fee components for the AOP annual fee [Section 10.06(C)] by increasing the emissions fees portion by 33%. This will not result in an increase in the total fees charged to the AOP facilities; rather the fee distribution will be more heavily weighted on the emissions fee. 

SRCAA is also proposing to increase the acid deposition hourly fee by the inflationary rate of 3% to keep hourly based rates consistent throughout the Consolidated Fee Schedule

Section 10.06(C)Current FeeProposed Fee
Emissions Fee ($/ton)$75$100
Acid Deposition Fee$108$111

Notice of Construction (NOC) and Portable Source Permit (PSP) Fee, Section 10.07: Prior to constructing, installing, replacing, and/or modifying air contaminant sources, emissions units or air pollution control equipment in Spokane County, the owner/operator must file an application for Notice of Construction (NOC) approval with our agency. If approved, an Order of Approval will be issued that is valid for the life of the equipment at a specific location. NOCs can be issued for a single piece of equipment, or for an entire facility. The NOC program is near full cost recovery. SRCAA is proactively addressing the projected program cost increases and adjusting fees accordingly.

Section 10.07Current FeeProposed Fee
Class I Base Fee$1,788$1,842
Class II Base Fee$2,750$2,833
Class III Base Fee$4,510$4,645
Class IV Base Fee$9,900$10,197
Hourly Rate$108/hour$111/hour
Replacement or Substantial Alteration Minimum Fee Hourly rate  $324 $108/hour  $333 $111/hour
Compliance Investigation Fee$385$397

Miscellaneous Fees, Section 10.08:

Adjust hourly rate for consistency throughout the fee schedule. Adjust the filing fee accordingly.

Section 10.08CurrentProposed
Emission Reduction Credit$108/hour$111/hour
Variance Request: Filing fee Hourly rate  $324 $108/hour  $333 $111/hour
Alternate Opacity$108/hour$111/hour

Asbestos, Sections 9.09.C and 10.09. Asbestos is classified as a hazardous air pollutant by the U.S. Environmental Protection Agency and is the reason why demolition and renovation projects must comply with certain asbestos requirements. Homeowners, landlords, contractors, property managers, and any other party involved in renovation, demolition, or altering a structure must follow asbestos regulations. Many projects require an asbestos survey and to file a Notice of Intent (NOI) for asbestos removal with our agency. Spokane Clean Air inspectors enforce the asbestos regulations to reduce asbestos exposure. Currently, Spokane Clean Air has six inspectors spending a portion of their time working on the asbestos program.

The asbestos fees were last increased on July 13, 2006 (Res. 06-09). As a result, revenue did not keep up with program costs. For fiscal year 2024, the asbestos program has a $38,000 deficit. The deficit does not include the additional costs incurred from the Gray Road and Oregon Road wildfires. The special projects fund absorbed the expenses related to the wildfire asbestos work. Spokane Clean Air has reduced program activities to minimize costs and believes additional reductions would compromise program effectiveness and ultimately air quality. After discussions of budget projections and fee options with the Advisory Council and Board of Directors, Spokane Clean Air is proposing to increase the fees by 15%. This will not completely resolve the budget deficit, but staff attrition will help reduce the deficit. Once the deficit is resolved, the Board will consider a smaller, routine annual fee adjustment to minimize the need to burden of larger unanticipated increases.

Asbestos-Containing Waste Material Temporary Storage Permit application fee$65$75
10.09 Owner-occupied, single-family residenceCurrentProposed
All Demolition$30$35
10.09 Not owner-occupied, single-family residenceCurrent FeeProposed Fee
Project consists of < 10 ln ft and/or < 48 sq ft of asbestos removal, but ≥ 10 ln ft and/or ≥ 48 sq ft asbestos has already been removed from structure in calendar year or project WILL exceed threshold of ≥ 10 ln ft and/or ≥ 48 sq ft asbestos removal from structure in calendar year$75$85
10-259 ln ft and/or 48-159 sq ft asbestos$250A$290A
260-999 ln ft and/or 160-4,999 sq ft asbestos$500A$575A
³ 1,000 ln ft and/or ³ 5,000 sq ft asbestos$1,250A, B$1,440A, B
All Demolition$250$290
10.09 Additional categoriesCurrent FeeProposed Fee
EmergencyTwice the Regular FeeTwice the Regular Fee
Annual Notification (£ 259 ln ft and/or £ 159 sq ft)$750$860
Alternate Asbestos Project Work PracticesTwice the Regular FeeTwice the Regular Fee
Demolition with Nonfriable RoofingTwice the Regular FeeTwice the Regular Fee
Exception for Hazardous ConditionsRegular FeeRegular Fee

A  Includes demolition fee, if applicable, provided the asbestos removal project and demolition project are submitted to the Agency on one notification.

B  When removing ³ 2,000 ln ft and/or ³ 10,000 sq ft, an additional fee of $250 $290 shall be paid for each increment of up to 1,000 ln ft beginning at 2,000 ln ft and/or each increment of up to 10,000 sq ft beginning at 10,000 sq ft.

Other Outdoor Burning Permit fee, Section 10.13. Although outdoor burning for disposal has been phased out in most areas of Spokane County, there are a several fee-based outdoor burning permits available. To keep hourly fee rates the same in the Consolidated Fee Schedule, Spokane Clean Air is proposing to increase the “other” outdoor burning hourly rates.

Section 10.13CurrentProposed
Other Outdoor Burning Permit Review Fee Hourly Rate $108/hour  $111/hour

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