Proposed oven ruling: Sustainability solution or operational setback?

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Proposed oven ruling: Sustainability solution or operational setback?

1 May 2023

Joanie Spencer

Since 2008, Joanie Spencer has covered the retail and wholesale sides of the baking industry.
Serving associations such as the American Society of Baking (ASB) and BEMA, Joanie is also in demand as an industry presenter on bakery operations and trends. She holds a bachelor’s degree in communication from Rockhurst University and a master’s degree in journalism from the University of Missouri.

When she’s not running or playing soccer, Joanie spends her time with her husband and 11-year-old son.

LOS ANGELES — In cities around the country, air quality is a huge factor in sustainability, and it’s an issue the baking industry consistently keeps on the radar. And in the Los Angeles area, where smog has been a serious issue for decades, the South Coast Air Quality Management District (SCAQMD) has taken steps toward decarbonization with a specific focus on reducing emissions of nitrogen oxides (NOx).

Specifically, in 2014 the district adopted Rule 1153.1: Emissions of Oxides of Nitrogen from Commercial Food Ovens, which established NOx limits applicable to commercial food ovens, roasters and smokehouses. Recently, however, a proposed amendment to the rule has shifted focus from prioritizing low-NOx technology to zero-NOx attainment by 2027. The proposal was based on the 2016 Air Quality Management Plan (AQMP).

“Proposed Amended Rule 1153.1 is a source specific rule that regulates commercial food ovens which has been in the rulemaking public process since 2021,” said Connie Mejia, senior public affairs specialist for SCAQMD, noting that in December2022, governing board adopted the more recent 2022 AQMP that which focuses on widespread deployment of zero-emission technology. This applies “across all sectors and not just commercial food ovens, where feasible.”

However, should the amendment be enacted, this could impact more than 200 commercial food oven units — including direct- and indirect-fired bakery ovens, tortilla and tortilla chip ovens, cooking ovens, drying ovens, spray dryers, smokehouse ovens, and coffee and nut roasters — located in 97 production facilities in the Los Angeles area.

“Commercial food ovens account for 0.2 tons per day of NOx emissions,” Mejia said. “As discussed in the 2022 AQMP, an ambitious emission reduction program is critical to attain both the federal and state criteria pollutant emission standards, which if not met, will result in consequences for the region.”

In recent years, many baking companies have been working toward NOx reduction. Those with operations in the SCAQMD region have also been working toward complying with the original rule requiring NOx reduction to 30 parts per million (ppm) — as opposed to the current 60 ppm — in oven emissions by 2038. This would reduce commercial baking ovens emissions by 50%. Some companies are going a step further by working on NOx reduction in boilers and other natural gas-burning combustibles.

When looking at the basics of oven technology, the standard heat required for proper baking is at about 500 BTU per pound of dough. However, products with higher density could require 600 BTU or more per pound of dough. The challenge then becomes lining up an oven’s BTU capability with the bakery’s needed throughput requirements without sacrificing capacity in the oven.

For bakery lines that can potentially run hundreds of bread loaves or thousands of buns per minute, a progressive emissions reduction over time is a reasonable expectation, even considering the substantial financial investment it could require. Commissioning, testing and installing new oven equipment can run into the millions of dollars. For a low-profit-margin industry like baking, whose purpose is providing affordable food products for consumers and national feeding programs, timing is critical to avoid huge potential financial and logistical setbacks.

“It’s important to consider the full scope of the carbon footprint that’s being created. Otherwise, these efforts contradict what California is trying to accomplish.” — Rasma Zvaners | VP of regulatory and technical services | American Bakers Association

SCAQMD’s goal to reach zero NOx would require food ovens to shift from gas-fired to electric, as hybrid ovens are not zero-NOx emissions.

There are, indeed, versions of electric ovens in use around the world. However, the timing to fully develop the technology does not align with the amendment’s deadline, which states that all new food ovens be zero-NOx by July 2027. Additionally, the amendment would require that any food oven older than 22 years to be scrapped and replaced with net-zero NOx technology, namely, electric ovens. With proper maintenance, commercial bakery ovens can operate for up to 30-40 years.

Considering demand in the supply chain has many oven OEMs working on 18- to 24-month lead times for current orders, the proposed new deadline limits options for bakeries and other food producers to gain compliance.

Currently, the proposed rule applies to one out of six air districts in California. While it directly impacts bakeries operating in that district — including multi-unit companies with South Coast operations — many other baking companies are concerned about a potential slippery slope.

“One big thing we often see is that rules enacted in California tend to spread into Washington, Oregon and Colorado,” said Rasma Zvaners, VP of regulatory and technical services for the American Bakers Association (ABA). “But the bigger concern for the industry is what this can mean for precedent setting. There’s no longer a step-by-step process in lowering emissions; these bakeries are now expected to get emissions to zero in just a few short years.”

During the window for public comment, ABA submitted a letter voicing concern for the feasibility of compliance for the proposed amendment. In the letter, ABA raised concern that the food industry has been “prematurely singled out” in an unprecedented sector-based ruling.

“The baking sector’s NOx emissions footprint represents a small fraction of NOx emissions when compared to other industrial stationary sources and mobile sources in the SCAQMD,” the letter continued. “ABA’s member commercial bakeries are open to adopting electric oven technology when it is truly available, but the transition should be mandated only when feasible.”

While no feasibility studies appear to have been conducted, the SCAQMD office appears to be open to the possibility.

“During rule development South Coast AQMD collaborates with all stakeholders, industry, vendors, environmental and community groups, interested parties and other governmental agencies,” Mejia said. “A number of energy agencies and utilities are working to ensure future energy demand is met by developing zero-emission infrastructure assessment (e.g., California Energy Commission’s Energy Demand Forecast) in order to fully address the expected demand, share information and data needed to expedite planning efforts, and support accelerated deployments of zero-emission infrastructure in advance of the need, wherever feasible.”

ABA indicated that there are limited electric ovens in use for commercial baking purposes, the realistic transition — without wreaking further havoc on an already tenuous supply chain — is a progressive transition from gas-fired to hybrid oven technology before a full shift to electric-only baking technology.

It remains to be seen if the transition to electric oven technology will fully offset NOx emissions or if the increased use of electricity will simply generate more carbon emission, just from a different fuel source.

“It’s important to consider the full scope of the carbon footprint that’s being created,” Zvaners said. “Otherwise, these efforts contradict what California is trying to accomplish.”

It’s true that a shift to electric oven technology will indeed provide a host of environmental benefits. That said, companies facing the operational and financial impacts of stark and immediate regulation could also benefit from regulatory bodies taking time to dig into the implications that come with it.

“We want to educate the industry on what’s happening in California so that bakers can be aware of what’s coming, even if they’re not necessarily located in the South Coast or in that particular district,” Zvaners said. “Rulings like this have a tendency to mushroom.”

For more information on SCAQMD’s proposed amendment to Rule 1153.1, including scheduled dates for public hearings, visit the SCAQMD website.

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