Welcome to this edition of Envera at the Board (E@TB). Today we’re going to talk about annual emission reports (AERs). More specifically, we’ll talk about who, what, when, where, and why when it comes to these reports. Personally, I like to start any discussion about annual emission reports with a quote from Benjamin Franklin: “In this world, nothing can be said to be certain except death and taxes.” As a practicing air quality professional, I would like to add a third thing to that list: annual emission reports.
[00:50] What is an annual emission report (AER)?
An annual emission report is an emission inventory of your facility. It is an accounting exercise to determine the types and amounts of air pollutants emitted by all of the pieces of equipment at your facility. Within the AQMD, you’ll not only have to identify and quantify these emissions, you’ll also have to pay fees for these emissions. We’ll talk about the fees in Section 5 [06:31].
[01:45] Exempt emission types
Within the AQMD, not all emission types need to be accounted for on the AER. Three examples are:
- On-road and off-road vehicles (e.g. passenger cars, tractors, cranes, etc.), the emissions of which are considered to be mobile source emissions and therefore don’t need to be reported on your AER.
- State registered equipment, or more specifically, portable equipment that is registered under the California Air Resources Board’s Portable Equipment Registration Program (PERP).
- Certain types of architectural coatings, the types of which will dictate whether or not that material needs to be reported on your AER. For example, architectural coatings that are used to paint buildings, walls, and sidewalks don’t need to be reported. However, if those paints and architectural coatings are used within the manufacturing process, they need to be reported.
It’s important when you’re preparing your annual emission report to know what types of equipment you have on site and, more specifically, of those types of equipment, which are exempt from being reported. That requires a little research, and at the end, we’ve included links to presentations made by the air district that discuss the specific types of emission sources that need to be reported on your AER.
[03:37] Who needs to file an AER?
Who needs to file an AER? Generally speaking, the applicability to the AER program follows three criteria:
First, if you receive a notification from the air district asking you to prepare an AER, you have to prepare one. This applies to any facility that receives a notification from the air district.
Some people have received notifications, but their emissions are below the reporting thresholds, which we’ll discuss later. When this happens, they’ll say, “I received a notification, but my emission levels are below the thresholds, therefore I don’t have to report.”
If you receive a notification, you have to report regardless of your emission levels.
Second, any facility that is subject to California’s AB 2588 program for air toxics must file an AER.
Third, and more commonly, we see that people become subject to the AER reporting simply because they have emissions that are higher than the thresholds of the program, which are four tons for NOx, or nitrogen oxides; SOx, or sulfur oxides; VOCs, which are volatile organic compounds; or PM, particulate matter, or there emissions are over 100 tons per year for carbon monoxide.
[05:33] When does an AER need to be filed by?
When does an AER need to be filed? An AER needs to be filed sixty days after the first day of each calendar year. Now, since the sixtieth day can fall on weekends or on a Monday, on which days the AQMD is closed, you’ll need to check the AQMD’s website to know the exact deadline of the AER. Sometimes it will not be on the sixtieth day, it will be a day or a few days later. If you submit a report after the deadline, you’ll be subjected to penalties, which will continue to rise the longer you take to submit the report.
[06:31] Where does the AER need to be submitted?
Where does the AER need to be submitted? The AER is an electronic report, so you’ll use the AQMD’s software to submit it. Most times you’ll prepare your report on a spreadsheet, transfer the numbers from the spreadsheet to the reporting tool, and then click ‘submit’ on the reporting tool to submit it. Although the AER is electronic, there’s also a hard-copy component to it, which must be included in the full submission. The hard-copy submission is where you’ll include your check, if you had fees due, and you’ll need to add a signature on the forms that are generated by the reporting tool. You’ll enter your data into the reporting tool and click ‘submit’, and the reporting tool will generate a set of forms. You’ll print the forms, get your responsible official to produce a wet signature, and then you’ll mail those wet signature copies, plus your check, to the AQMD. Submitting electronically is only half of the submission. You also need to complete a hard-copy submission.
To use the reporting tool, you’ll have to create an account. The AQMD changed its reporting tool last year, so the way you now register and get access to the reporting tool is different. At the end, we’ve included links to the guidance documents put out by the AQMD for this new system. Once you have an account and you have access to the reporting tool, you’ll submit facility-specific information, including the operating time, what you do, where your facility is located, who the responsible official is, who the local contact is, etc.
You’ll then input the facility-specific data that will be used to calculate emissions from your facility. The reporting tool will calculate these emissions in real time, and then you’ll want to verify that the amount of emissions calculated by the reporting tool equal to the amount of emissions you calculated on the spreadsheet. That check is a good way to know that you’re submitting accurate emissions to the AQMD that can be backed up with documentation. You should be preparing these calculations outside of the reporting tool, and keeping all of your documents, in case you’re asked to submit them.
You’ll then have to verify that everything is correct and that all of the required fields have been filled, and then you’ll have to submit your report online. Again, the online report submission is only one piece; there’s also a hard-copy submission that includes a web signature and a check if you have to pay fees to the AQMD.
[10:19] Why are AER’s needed?
Why are AERs needed? Aside from the fact that AERs are required under Rule 301, the AERs provide the AQMD with the data needed to develop rules and/or to control strategies to lower, reduce, or improve air quality within the area. The only way they can do that is by having data from all the facilities within their jurisdiction, which they can slice and dice to see where more regulation is needed or where new controls are needed to reduce air pollution.
Another reason is that it generates revenue, since you have to pay fees based on the emissions from your facility. If you have a high amount of emissions, you can expect high fees. The more you emit, the more you pay, so it’s a revenue stream for the air district. They use this to make projections on their operating budget.
The AER data is also used to track progress to the National Ambient Air Quality Standard (NAAQS), which measures how much the air quality in Southern California is improving. Right now, our levels are higher than the National Ambient Air Quality Standard, but they’re lower than they were twenty years ago. Again, the levels of emissions reported by these facilities are used by the AQMD to determine their progress to achieving that National Ambient Air Quality Standard.
AERs are also needed to allow the AQMD to verify compliance with certain rules and regulations that require facilities to stay below a certain emission level. If you have one of these conditions on your permit, and more specifically, if you have a condition on your permit that lowers the emissions from your facility to a certain level, when you submit your AER, you’ll want to be sure that the number you’re going to report to the district is below the number in your permit. That way you won’t inadvertently give yourself a violation for exceeding your emissions limit.
Again, AERs are needed to verify compliance with rules and to determine rule applicability. Namely, AERs are for Title V and RECLAIM applicability. These are two large programs in the South Coast Air Quality Management District, and applicability to those programs are based on data submitted on your AERs. For example, for reclaim applicability, if you report NOX or SOX emissions in excess of four tons per year, you’d be subject to the RECLAIM program, which would trigger a series of requirements you would need to comply with. If you report VOC emissions greater than ten tons per year, you will be subject to Title V.
There are the basics of the annual emission reports in regards to who, what, when, where, and why. You should also now know there are three things in life that are certain: death, taxes, and annual emission reports.
Thank you for tuning into this episode of E@TB. We’ll see you soon.
Let’s take this over to you
Before we end, I’ve got three things for you.
Thing 1. Do you know of a colleague who is new to the AER program?
If so, please share this E@TB video with them so that they’ll understand the basics of the 2016 AER.
Thing 2. If you enjoyed this video, sign up for the Envera Consulting newsletter so you won’t miss the next video. No SPAM, just content that guides you through all of the SCAQMD’s air quality rules and regulations that your business needs to deal with in order to comply.
Thing 3. Preparing AERs or our clients is one of the ways that we are able to free up their time so that they can focus on higher level priorities within their business.
Do you need help preparing your 2016 AER? Contact us and consider it done.
Do you see a typo or anything that’s incorrect? If so, please contact us and we’ll get it fixed.