Coffee roasters are now subject to more stringent emission requirements in Southern California. Find out how this affects your current operation.

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Yes, you read that right: the South Coast Air Quality Management District (“SCAQMD”) has shaken things up for new and existing coffee roasters in Southern California.

In particular, the new-ish amendment (passed August 2023) to SCAQMD Rule 1153.1 requires certain coffee roasters to meet more stringent requirements for NOX (an acronym for NO₂, or “oxides of nitrogen”), and one of the first deadlines is coming up in Summer 2024. As it relates to your coffee roaster, NOX (pronounced like the Knox in Fort Knox) is emitted when a fuel like natural gas is combusted and/or can be generated from the coffee beans during the roasting process.

In the SCAQMD, NOX is a big deal since it contributes to ozone formation (smog). Nonetheless, even though the air quality has been cleared up, the SCAQMD has work to do to clean up the air in Southern California even more. 

One way to do this is to reduce the amount of NOX emitted from various equipment in the area, including coffee roasters.  So, what does that all mean?

Warning: More stringent emissions limits are now in effect for coffee roasters in Southern California

Well, the short of it is that for certain coffee roasters (mainly ones that have a burner rating that is greater than 325,000 BTU/hr and require a permit from the SCAQMD), the changes to Rule 1153.1 include a lower NOX limit compared to the previous version of the Rule.

In particular, the amended Rule requires the NOX emissions from a roaster subject to the rule to be 30 parts per million (“PPM”) or less—25-50% lower than Rule 1153.1 previously allowed. 

We’re leaving out some details, but for roasters subject to the rule, that is the biggest and arguably the most impactful change you’ll need to deal with to stay out of non-compliance with the SCAQMD’s Rules and Regulations.

In terms of compliance pathways, depending on the age and conditions of your existing SCAQMD permit, there are two main options for complying with the Rule. 

What are my options to comply?

Option 1: Administrative Compliance

In certain cases, Rule 1153.1 will allow you to comply administratively with the rule, which means that the SCAQMD will assume that the emissions from your roaster meet the rule limit under certain conditions. For instance, if you’re willing to accept a permit condition limiting the fuel consumption or total operating time for your roaster, then it is assumed that your unit complies with the rule, regardless of the actual emissions from your unit.

To utilize this option, you’ll need to install a fuel or time meter and submit a permit application to add a condition on the face of your existing permit to limit your operation’s fuel or time limits. Before going down this route, you should be sure that the limits that the SCAQMD will impose are ones that your operation can live with (we can help with that if needed).

Option 2: Equipment Retrofit

If Option 1 does not work, then you’ll need to consider retrofitting the roaster with a new burner that will meet the new 30 PPM limit if the age of your burner is seven (7) years old or more. For this, you’ll need to file a permit application before July 1, 2024, to install a new burner, and you will also be subject to source testing requirements. Depending on the configuration of your roaster, this can be a challenge since you’ll only need to measure the NOX emissions from the burner and not the burner and the roasting process.

On the other hand, if your roaster is less than seven (7) years old, you’ll need to plan to retrofit it with a burner that can meet the new 30 PPM limit and file a permit application to do so on or before July 1 of the year that the burner reaches 7 seven years old.

What are key indicators to know if your roaster is impacted by the new Rule 1153.1 Limits?

Key indicators to know if the new Rule impacts your roaster are if:

1. Your current permit does not have a condition limiting the roaster’s NOX concentration to 30 PPM;
2. If your current permit has a condition limiting the roaster’s NOX concentration to 60 PPM; and/or
3. Your permit was issued before 2016 and has a burner rating greater than 325,000 BTU/hr.

Again, we are leaving out other details to save you from boredom. This article only provides a summary of the high-level changes. You can contact us if you have questions or need direction based on your specific situation. 

So, where does this leave things?

In helping folks comply with the new Rule 1153.1, we find folks in two situations: 

1. You are planning to buy a new coffee roaster and are wondering how the new Rule 1153.1 is going to change things; or 
2. You have an existing coffee roaster, and you’re scratching your head on what to do next.

Situation 1

If you’re in the first boat, meaning that you’re planning to buy a new unit, you should ask your vendor about the NOX emissions from their unit. Why? 

If the unit needs a permit from the SCAQMD, you must address the NOX limit in the new Rule 1153.1 during the permitting process, and the Agency will want to see documentation substantiating the emissions from the burner. Now, if the unit you’re planning to buy a unit that cannot meet the NOX emission limit of Rule 1153.1, you’ll need to look into the alternative options for demonstrating compliance with the Rule, like administrative compliance (Option 1) or getting a unit with smaller roast drum or burner.

The amended Rule 1153.1 requires the NOX emissions from a roaster subject to the rule to be 30 parts per million (“PPM”) or less—25-50% lower than previously allowed. 

Situation 2

On the other hand, if you have an existing unit, you’ll have some decisions to make and planning to do. For instance, if your unit is seven (7) years old or older, you’ll likely need to apply for a permit to install a new burner in your roaster by July 1, 2024. But if your burner is less than seven (7) years old, you have time to plan to retrofit it. The key is that you have to plan for this upgrade.

In either case, however, if you have an existing unit and do not utilize Option 1, you’ll likely need to conduct an emissions test of your roaster before August 2025 as required under Rule 1153.1 (g)(2)(A) and again periodically. Again, depending on the configuration of your roaster, this can be challenging.

What about my afterburner?

Rule 1153.1 only applies to coffee roasters. However, in almost all cases, a coffee roaster will have an afterburner connected to it, which begs the question: How does this change affect the afterburner? The short answer is that Rule 1153.1 does not affect the afterburner. 

Here’s why.

In most situations, the afterburner is connected in series to the roaster’s exhaust. That means that the exhaust from the roast drum is sent directly to an afterburner before it is emitted into the atmosphere. In this case, the NOX emissions from the roaster are subject to a 30 PPM limit of Rule 1153.1, and the NOX emissions from the burner in the afterburner are subject to SCAQMD Rule 1147 (a different Rule).

For a roaster in this situation that needs to demonstrate compliance with the 30 PPM NOX limit of Rule 1153.1, you can either test the roaster on its own or test both the afterburner and the roaster together and then determine compliance with a weighted emission limit based on the heat capacities of both the roaster and afterburner.  More on this can be found in Rule 1153.1 (g)(7).

Is there any good news?

So, yes, Rule 1153.1 will (and already has) shake things up for folks who have coffee roasters in Southern California (which can be a major thorn in your side). 

The good news is, however, that we’re very familiar with the SCAQMD’s rules and regulations and challenges when it comes to addressing NOX from coffee roasters, so you can turn to us for help with planning, permitting or getting out of a jam that you may find yourself in because of the new requirements of Rule 1153.1.