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The requirement that states if you choose to use your own N20 from
your source test,instead of the default,then you must source test
annually,is very unfair for the following reasons

1.Local air districts like the SJVAPCD already have N20 limits
that have to be proven by source testing already.The default for
N20 in this case should be what you have to make in that
district.In this district the Nox ppm limit is already set at
9ppm.So the default for N20 should be set at what the highest
limit is in that district.

2.Saying that if you choose your District's limit,that you must
then subject your self to annual source testing is going to cost
more,the reason being that in this district if you make the limits
two years in a row then you can go 36 months before having to test
again.

3.What is the purpose of the local air district if you are
basically saying we will not accept what your district has
mandated,and we don't trust your source test data that you paid
for.

4.Source testing boilers is not cheap,and to require more,when you
already have documented results that were approved by the district
is beyond me

5.Also using a default for N20 or Nox is basically telling
industry that all that money you spent on Nox control to get to
9ppm,is null and void unless you submit to the States annual
source testing program.

6.Bottom line is don't the State have any confidence in the local
air districts?and if not then do away with them and just have one
agency to report to.

I have attached the section of this bill I'm talking about
below.So all interested parties can read into it,maybe I'm
misinterpeting this but using the default N20 has got to give you
a higher total,than what you'd get using 9ppm district imposed
limit that is already in place.

   Copied from the lastest version of the GHG reporting req

The operator may elect to calculate CH4 and N2O emissions using
ARB
approved source specific emission factors derived from source
tests
conducted at least annually under the supervision of ARB or the
local air
pollution control district or air quality management district.
Upon approval of
a source test plan by ARB, the source test procedures in that plan
shall be
repeated in future years to update the source specific emission
factors
A-84
annually. In the absence of source specific emission factors
approved by
ARB, the operator shall use the default emission factors provided
in
Appendix A.
(c) Method for Calculating CO2 Emissions from Fuel Combustion
Using