Office of Air Quality, Permitting & Enforcement Division

               Mechanical Section Policy Memorandum

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Date:  March 8, 1994                           No.: 1    

From:  Skip Clark, P.E. 

Approved by:  Gary Wallin, P.E. 

Subject:  Grandfathered Standard Exemptions

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Policy:   

Once a standard exemption has been claimed, the company can
keep the exemption for as long as they continue to meet the
conditions of that exemption that were in effect at the time
the exemption was claimed.  Even if the exemption went through
major or minor changes, the company does not have to upgrade
its facility to meet the newer conditions if they continue to
meet the conditions that were in effect when the exemption was
first granted. 

Background:   

If an exemption did, or did not, require registration at the
time it was being claimed, it makes no difference.  The most
important part of the exemption processis the listed
conditions of the exemption at that time.  If the company
complied with all of the conditions that were listed at the
time the exemption was claimed, then they are legally entitled
to claim that exemption.  If they continue to maintain
compliance with all conditions of that exemption all the time,
then they are entitled to keep that exemption. 

Necessary Action:  None.

cc:  All Mechanical Section