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
SALLY G. SEYMOUR
Associate Regional Administrator
United States Environmental Protection Agency, Region IX
Signature Date
LOUIS D. VAN MULLEM, Colonel, USAF
Chief, Environmental Management
Vandenberg Air Force Base
Signature Date
DOUGLAS W. ALLARD
Air Pollution Control Officer
Santa Barbara County Air Pollution Control District