EPA alert

October 18, 2023

epa air emissions reporting rule

USEPA published its proposed revisions to Air Emissions Reporting Requirements (AERR) in August. AERR is a regulation that requires states, local agencies, and some tribes (SLTs) to report annual air emissions to EPA. The comment period has been extended until November, 17, 2023.

EPA is holding a webinar on the proposed rule on October 25, 2023, from 2 pm to 5pm (Eastern Time).

Click HERE to register.


The current regulation allows voluntary reporting of air toxics emissions. EPA uses the data collected and other resources to create the National Emissions Inventory (NEI). NEI supports programs and activities such as Modeling (Air Quality Standards, Risk Analysis, etc.), Trends (Air Quality Trends Report), and Public Information.

AERR currently requires reporting of:

  1. Criteria Air Pollutants (CAP – CO, SO2, PM10, PM2.5 and Lead).
  2. Precursors (VOC and NOx for Ozone and Ammonia for PM).
  3. Point source emissions must be reported as emissions within the facility.
  4. States report other emissions (residential wood combustion and mobile sources) as county-wide emission totals.
  5. CAP emissions report to SLTs, and SLTs report to EPA. SLTs also accept optional HAP reporting responsibility.


Proposed AERR revisions:

  1. No changes to CAP emissions reporting (i.e., SLTs report to EPA).
  2. Source test data and Hazardous Air Pollutants to report directly to EPA.
  3. Major sources to report all Hazardous Air Pollutants to EPA.
  4. Non-major sources with listed industry codes and > HAP thresholds to report HAPs to EPA.
  5. Report all point sources every year, starting with 2026 in the year 2027.
  6. Report geographic coordinates of release points for point sources.
  7. Include emissions from mobile sources operating within the facility.
  8. Reporting of Title V Operating Permit Number is required.
  9. Report emissions from Small Generating Units: boilers, turbines, IC engines, or other units combusting fuel to generate electricity for grid or on-site use (other than emergency use).
  10. Emission data will no longer qualify as confidential information.


Proposed Phase-in of Stationary Point Source Reporting for owners and operators:

  1. For years 2026-2029 – 5 months from the end of the inventory year.
  2. For the years 2030 and beyond – 3 months from the end of the inventory year.
  3. Owners/Operators must report to EPA using CARES – Combined Air Reporting System.


Comments due:

  1. November 17, 2023. Send comments via regulations.gov docket ID EPA-HQ-OAR-2004-0489.
  2. Find additional information on the proposed rule here.
  3. EPA is holding a webinar on the proposed rule on October 25, 2023, from 2 pm to 5pm (Eastern Time). Click HERE to register.


Please direct questions about your facility to your SCS project manager or .



Posted by Diane Samuels at 3:07 pm

August 31, 2019


The updates to air regulations intend to remove redundant requirements and reduce compliance burdens where environmentally appropriate.

The U.S. Environmental Protection Agency (EPA) proposed updates to the oil and natural gas industry national standards. The proposal intends to remove regulatory duplication while maintaining health and environmental regulations on oil and gas sources that the agency considers appropriate. The proposal is the result of EPA’s review of the 2016 New Source Performance Standards (NSPS) for the oil and natural gas (O&G) industry conducted in response to Executive Order 13783 – Promoting Energy Independence and Economic Growth. The goal was to review existing regulations that could potentially “burden the development or use of domestically produced energy resources,” including oil and natural gas.

The resulting regulatory impact analysis from EPA estimates that the proposed amendments could save the O&G industry $17-$19 million a year, for a total of $97-$123 million from 2019 through 2025.

“EPA’s proposal delivers on President Trump’s executive order and removes unnecessary and duplicative regulatory burdens from the oil and gas industry,” said EPA Administrator Andrew Wheeler. “The Trump Administration recognizes that methane is valuable, and the industry has an incentive to minimize leaks and maximize its use. Since 1990, natural gas production in the United States has almost doubled while methane emissions across the natural gas industry have fallen by nearly 15%. Our regulations should not stifle this innovation and progress.”

In its primary proposal, the agency is proposing to remove sources in the transmission and storage segment of the O&G industry from regulation. These sources include transmission compressor stations, pneumatic controllers, and underground storage vessels. The agency is proposing that the addition of these sources to the 2016 rule was not appropriate, noting that the agency did not make a separate finding to determine that the emissions from the transmission and storage segment of the industry cause or significantly contribute to air pollution that may endanger public health or welfare.

The primary proposal also would rescind emissions limits for methane, from the production and processing segments of the industry; keeping emissions limits for ozone-forming volatile organic compounds (VOCs). These sources include well completions, pneumatic pumps, pneumatic controllers, gathering and boosting compressors, natural gas processing plants and storage tanks. The controls to reduce VOCs emissions also reduce methane at the same time, so separate methane limitations for that segment of the industry are redundant.

In an alternative proposal, EPA would rescind the methane emissions limitations without removing from regulation any sources from the transmission and storage segment of the industry.

The agency also is seeking comment on alternative interpretations of EPA’s legal authority to regulate pollutants under section 111(b)(1)(A) of the Clean Air Act.

This proposal is in addition to a September 2018 technical action that proposed targeted improvements to help streamline implementation, reduce duplication of EPA and state requirements, and significantly decrease unnecessary burdens on domestic energy producers. EPA is currently reviewing comments received on that technical package and expects to issue a final rule in the upcoming months.

EPA will take comment on the proposal for 60 days after its publication in the Federal Register, and will hold a public hearing. EPA will announce details of the hearing shortly.

More information, including a pre-publication version of the Federal Register notice and a fact sheet, is available at https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry

Link to the proposal: https://www.epa.gov/sites/production/files/2019-08/documents/frn_oil_and_gas_review_2060-at90_nprm_20190828revised_d.pdf

Link to fact sheet: 


Air Monitoring at SCS Engineers / O&G Services





Posted by Diane Samuels at 6:00 am

August 1, 2016

Do you have NSPS or EG sites per the new definitions of “new” and “existing”?

Does your EG site have any upcoming planned or permitted expansions, or will it be commencing construction on an expansion permitted after July 17, 2014?

Will you need to submit/resubmit Design Capacity and NMOC reports to establish your sites status as subject to the new NSPS? Over, or under 34 Mg/year of NMOCs?

Are you a candidate for Tier 4? In the closed landfill subcategory?

For EG sites contact the SCS state representative by sending a request to

SCS Engineers will be publishing Pat Sullivan’s Technical Bulletin Summary of Final NSPS/EG Rules for Landfills as soon as it is published in the federal register. Meanwhile, please contact your SCS Project Manager or for answers to your questions or advice.  Follow SCS Engineers on your favorite social media site or check our events for new presentations, publications, and webinars explaining the rules in more detail.


Posted by Diane Samuels at 6:00 am