Pennsylvania is Requiring Minor Facilities to Submit Air Emissions Inventories

In July 2020, the Pennsylvania Department of Environmental Protection (PADEP) revised the instructions for completing annual air emissions inventories for regulated facilities with air permits.  The Pennsylvania annual air emissions inventories are more commonly referred to as Air Information Management System (AIMS) reports and for affected facilities, are due annually by March 1.  While minor updates and clarifications are routine, there is one noteworthy revision in the July 2020 version.

The requirement to annually report emissions through AIMS is addressed in section two of the AIMS instructions.  Historically, facilities subject to Title V operating permit requirements were required to submit an annual AIMS report and that has not changed.  However, the not so obvious update is that PADEP is now requiring facilities operating under synthetic minor operating permits to report actual annual emissions through the AIMS system.  A synthetic minor permit includes enforceable conditions (e.g., annual emissions limit, production cap, operating hours restrictions) that restricts emissions to prevent the facility from exceeding major stationary source emissions rate thresholds.  Keep in mind that PADEP also reserves the right, at its discretion, to request that a facility submit emissions inventory reports.

Facilities are being notified, typically by a letter from their regional PADEP office, indicating that their facility will be required to complete and submit an annual air emissions inventory.  There are two mechanisms to submit the annual air emissions inventory:  the AESonline system or AESxml.  If your facility receives such a letter and you are interested in discussing what this could mean for you and/or the many other Pennsylvania environmental regulatory actions that I have been tracking, contact me at nleone@all4inc.com or 610-422-1121.