Caldwell: Some Regulations Don’t Accomplish Anything

Government exists, so government can exist.  Most actions are to grow government, have government control the population or to pretend why government regulations are needed—to build empires, not help the community.

“The APCD has virtually no authority to regulate mobile sources, like cars, trucks, trains, planes, and marine vessels despite the fact these are the largest sources of air pollution, as these sources are regulated by the state and feds. The APCD does manage emissions from fixed stationary sources, which are relatively puny, such as wineries. Relatedly, the largest wine production facility in the county closed because the APCD would not allow the company to grow by permitting additional tanks used for fermentation. Tellingly, the Miller Family Wine Company is moving operations to two other counties in California, neither of which regulate winery emissions at all. Hence, instead of making the wine here, the grapes will now be trucked to Northern California.

How is that going to reduce emissions overall?”

The APCD regulations are killing jobs and the economy—but must hire more staffers to complete the destruction.

Some Regulations Don’t Accomplish Anything

by Andy Caldwell, Santa Barbara Current, 9/1/24  https://www.sbcurrent.com/p/some-regulations-dont-accomplish

I kicked up a hornet’s nest with my article about the Santa Barbara County Air Pollution Control District’s regulation of Space X and United Launch activities on Vandenberg Space Force Base. The APCD claims my article was full of inaccuracies. For the record, I had a confidential source, who is associated with neither company, who informed me that the APCD was doing what all regulatory agencies do naturally, making projects more cumbersome and expensive than they need to be. Since then, I have obtained official records currently available which corroborate most all the information previously discussed.

The APCD has virtually no authority to regulate mobile sources, like cars, trucks, trains, planes, and marine vessels despite the fact these are the largest sources of air pollution, as these sources are regulated by the state and feds. The APCD does manage emissions from fixed stationary sources, which are relatively puny, such as wineries. Relatedly, the largest wine production facility in the county closed because the APCD would not allow the company to grow by permitting additional tanks used for fermentation. Tellingly, the Miller Family Wine Company is moving operations to two other counties in California, neither of which regulate winery emissions at all. Hence, instead of making the wine here, the grapes will now be trucked to Northern California.

How is that going to reduce emissions overall?

It won’t.

Regardless, decades ago, the APCD cleverly utilized a loophole to regulate marine vessels which serve operators at Vandenberg. The loophole posits that if the equipment being delivered is necessary for the stationary equipment to operate, then the emissions from the marine vessels get added to the stationary source emissions regulated by the district.

One mistake in my piece had to do with the Annual Report of SpaceX operations in 2023 referencing both permits to construct and permits to operate boat trips. Specifically, the Authority to Construct Permit (ATC) 16000 increased the annual boat trips from 12 to 36 per year. The daily hours of operation for the marine vessels were permitted under Permit to Operate (PTO) 15704. However, the district has clarified that the Authority to Construct permits aren’t actually permits for construction projects.

Nonetheless, the Authority to Construct 16000 requires, as part of the emission inventory, an annual written report documenting terms and conditions of the permit verifying compliance with the emission limits and other requirements of the permit to construct. The report must include the daily and annual volume of fuel used by the boats, the daily and annual hours of operation for the boats’ engines, and the billing vouchers or other data certifying the fuel being used for combustion.

The report also requires that a Global Positioning System report the location and time data for the ship’s location in intervals of no greater than every 15 minutes whether the ship is off the Santa Barbara, Ventura, or Los Angeles coastline or in federal waters. The costs to prove compliance, including record keeping and source testing can be extremely expensive. One company I know spent up to $1 million per year proving they were complying with their permits.

The operator’s annual permits are based on a total emission inventory. It behooves the operators to limit emissions so that they don’t get penalized by the district. The permits specify the routes and number of days the marine vessels may take coming and going to Vandenberg, despite the district’s claim that it doesn’t regulate the routes taken or eventually force abandonment of the deliveries. That is, the permits can require the vessels to leave our coastal waters temporarily or permanently if they can’t dock at the base in a timely manner because of weather and tidal circumstances.

My biggest criticism remains. When United Launch moves their shipments 4500 miles through the ocean from Alabama to VSFB via the Panama Canal, why does the APCD bother to track, monitor, and permit the last 18 miles which represents 0.4% of the emissions associated with the trip?

What difference does that make?

One thought on “Caldwell: Some Regulations Don’t Accomplish Anything

  1. The people of California bring on their own problems and headaches. They elect office holders that are totally liberal and total control freaks. These Liberals enact agencies and committees for the good of the people and give them total control over people’s everyday life. Because in theory their policies are great. In reality, they simply don’t work.

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