Costs Associated With SCAQMD NOVs

We've covered the most common reasons facilities get a notice of violation (NOV) from the SCAQMD. The next question is what it costs to resolve one. There are penalty fees, but resolution often costs more than the settlement you pay the Air District. The answer is: it depends. The penalty fee alone turns on the length of the violation, how often you've been cited before, the economic advantage you gained by operating out of compliance, and what you did to mitigate it. (For more on that, see what happens after you get an SCAQMD notice of violation.) The range is wide. For Rule 203, settlements run from $50 to $8.1 million. (Yes, fifty dollars, not fifty million.) The SCAQMD also tends to settle multiple violations as a single case with a single cost, which makes the per-rule average hard to pin down. And that's only the penalty. Getting back into compliance often costs more than the settlement itself. You may have to buy equipment, which brings installation, commissioning, and permitting fees. A difficult case can mean bringing in consultants or attorneys; they add cost, but they often cut your total exposure by enough to pay for themselves. Add it up and the final cost to resolve an NOV varies too much to put a clean range on it. Or, as the data puts it: $50 to $8.1 million.   Need help resolving an NOV? Contact us and we'll get you to the most cost-effective resolution the case allows.

About Grant T. Aguinaldo, PhD

Grant provides techno-economic-regulatory modeling, analysis, and decision support on §45Z, the Low Carbon Fuel Standard (LCFS), and the decarbonization of the economy. He also leads air permitting projects across all of California's major air districts and in other states across the U.S. He is a Lead Verifier for California GHG and LCFS, and Washington GHG.