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Vandenberg Air Force Base (AFB)

DoD-Vandenberg Interim Project Agreement

Interim Agreement On The Implementation
Of The ENVVEST "Title V" Initiative

This interim agreement is made between the 30th Space Wing at Vandenberg Air Force Base, CA, (hereafter "Vandenberg"), Region IX of the Environmental Protection Agency (hereafter "Region IX"), and the Santa Barbara County Air Pollution Control Officer (hereafter "Control Officer") to facilitate the implementation of the ENVVEST "Memorandum of Agreement" (hereafter "MOA") entered into by the Department of Defense (hereafter "DoD") and the Environmental Protection Agency on November 3, 1995 as applied to the test project to be conducted at Vandenberg.

In the spirit of partnership, all parties agree ENVVEST is a worthwhile program that will provide superior environmental benefits and hereby pledge their best effort to take such actions as are legally available to successfully accomplish this ENVVEST proposal.

Based on a review of the Vandenberg 1994 Air Emissions Comprehensive Inventory Report (CIR) and after applying the relevant federal and state law including 42 U.S.C. 7661-7661f (hereafter "Title V"), 40 C.F.R Part 70, and Regulation XIII of the Santa Barbara County Air Pollution Control District, the parties declare and agree as follows:

1. The Control Officer has determined, and all parties agree, that the District has the discretion and legal authority to designate Vandenberg as a nonmajor source pursuant to authority delegated under Title V. The exercise of this discretion may require amendments to District Rules and Regulations. The Control Officer is prepared to propose such an amendment, if necessary, to exclude Tactical Support Equipment and selected Infrastructure and Building Maintenance equipment from the applicability determination for Title V permitting. In addition, the Control Officer is prepared to exercise his discretion to designate certain groups of emission units to be separate and distinct stationary sources for the purposes of Title V only. These units include, but may not be limited to residential units and other personnel amenities. The Control Officer further anticipates any rule amendment will include requirements that Vandenberg shall reduce actual emissions at the Base through the ENVVEST program. Any rulemaking action is subject to the final review and approval of the Governing Board of the Air Pollution Control District (hereafter "District Board").

2. If amendments to the District Rules and Regulations are necessary in order for the Control Officer to designate Vandenberg as a nonmajor source as discussed in paragraph 1 above, the Control Officer agrees to use his best efforts to submit this matter in the form of a proposed rule amendment to the District Board for consideration at its regularly scheduled meeting in August 1996.

3. If, by July 1, 1996, the Control Officer determines that Vandenberg is not required to obtain a Title V permit, Vandenberg shall implement ENVVEST program emission reduction projects using currently identified Title V compliance funds. This includes actual emission reduction projects valued at $200,000, less the funds expended in the development of a protective filing pursuant to this agreement, for Fiscal Year 1996. If the Control Officer determines subsequent to July 1, 1996, that Vandenberg is not required to obtain a Title V permit, Vandenberg shall implement ENVVEST Program emission reduction projects with any remaining funds for Fiscal Year 1996 identified for Title V compliance. The projected Fiscal Year 1997 commitment is $465,000 for follow-on projects. The amount of such remaining funds, and additional funding for the Fiscal Years of 1997 through 2001 will be outlined in the Final Project Agreement. All funding commitments by Vandenberg shall be in accordance with the Anti-Deficiency Act (31 U.S.C. 1341).

4. The parties agree to exercise best efforts and work in good faith to enter into a Final Project Agreement which reflects any determination by the Control Officer that Vandenberg is a nonmajor source pursuant to Title V and commits Vandenberg to implement the ENVVEST emissions reduction program. The parties also agree to negotiate in good faith performance standards for determining Vandenberg's compliance with the requirements to implement the ENVVEST program as set forth in paragraph 3, above. The parties agree the minimum goal is that annual ozone precursor emissions shall be reduced by a total of 10 tons by the conclusion of the ENVVEST Program.

5. Vandenberg currently believes it is a nonmajor source under Title V. However, Vandenberg and the District will work in good faith to develop a "protective filing" Title V permit application. The District will work in good faith with Vandenberg prior to June 30, 1996, to ensure that the application meets the requirements for a complete Title V permit application. After receiving a determination from the Control Officer that the permit application would be deemed complete if submitted, Vandenberg will promptly inform the Control Officer whether such determination is sufficient for the Air Force to implement the ENVVEST Program as outlined in paragraph 3. If the Air Force concludes that such determination is insufficient, then Vandenberg shall continue to develop a Title V permit application that the Air Force determines meets all applicable regulatory and statutory requirements.

6. This agreement shall be superseded by a final project agreement or terminated by January 1, 1997 unless extended by mutual agreement.

Signature Date
Associate Regional Administrator
United States Environmental Protection Agency, Region IX

Signature Date
Chief, Environmental Management
Vandenberg Air Force Base

Signature Date
Air Pollution Control Officer
Santa Barbara County Air Pollution Control District

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