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Construction Air Permit Elm a. For the LFG IC engines, Ameresco will maintain records of actual VOC and CO emissions calculated using the actual bhp, which can be determined from the kilowatt output multiplied by the measured operating time (hours) and further multiplied by the emission factor calculated from the most recent source test data for that pollutant(g/bhp- hr). b. For the waste gas flare, Ameresco will maintain records of actual VOC and CO emissions by calculating the actual heat input to the flare (MMBtu)multiplied by the emission factor calculated from the most recent source test data for that pollutant(lb/MMBtu). c. Ameresco will maintain records of the actual VOC and CO emissions on a 12-month rolling period and the emissions will be updated at least monthly 3. Ambient Air Quality Standards Section 4.14.1 of this Rule requires that an ambient air quality analysis (AAAA)be conducted for the purpose of determining whether a new or modified Stationary Source will cause or make worse a violation of a State or National ambient air quality standard (AAQS). The Air Pollution Control Officer(APCO) shall make this determination by taking into account the increases in minor and secondary source emissions as well as the mitigation of emissions through offsets obtained pursuant to this rule. Ameresco can conduct an AAQA if requested by the APCO; however, we understand from the Foothill application that the SJVAPCD will undertake this analysis. 4. Public Notification and Publication Requirements: Per Section 5.4,the APCO shall provide public notification and publication for the following types of applications: 5.4.1 New Major Sources and Major Modifications. A new mayor source is a new source that exceeds the thresholds of Section 3.24.1 of this rule. As shown above, there are no pollutants that will exceed the thresholds of Section 3.24.1 with the addition of the CO and VOC cap. Therefore, a new major source public notice is not required. 5.4.2 Applications which include a new emissions unit with a Potential to Emit greater than 100 pounds during any one day for any one affected pollutant; During normal operation, each engine will have potential CO emissions in excess of 100 pounds per day of CO. Therefore,a potential to emit public notice is required. 5.4.3 Modifications that increase the SSPE1 from a level below the emissions offset threshold level to a level exceeding the emissions offset threshold level for one or more pollutants; This is a new facility. Therefore,an existing facility offsets threshold exceedance public notice is not relevant. 5.4.4 New Stationary Sources with post-project SSPE2 exceeding the emissions offset threshold level for one or more pollutants; 12