EPA Looks to Add Air Emissions Reporting Items
EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent...
EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent from state to state, add electronic reporting of stack tests, decrease and standardize emissions thresholds, create earlier reporting deadlines, and add new point sources to reporting requirements.
⚡ TL;DR: EPA is standardizing HAP reporting across all states starting in 2027, moving state inventory deadlines to September 30, and implementing consistent emissions thresholds that will trigger reporting obligations for more facilities annually.
⚠️ What’s at stake: Facilities failing to meet the accelerated 2027 and 2030 reporting deadlines face EPCRA enforcement actions, civil penalties starting at $25,000 per day, and state regulatory scrutiny that can delay permit renewals and facility modifications.
All of the changes EPA is considering making is to help the agency comply with the presidential commitment to enhance environmental justice by gathering more detailed location-specific information.
HAP Reporting Per the AERR
Industry is already required to report emissions of common or criteria pollutants and the pollutants that form them, called precursors. Right now, the federal rule doesn’t require HAP reporting, but some states require reporting and voluntarily give this information to EPA. The new rule would make HAP reporting standard for all facilities in all states.
Shorter Deadlines
The proposed rule looks to make states work faster to get this data to EPA. Starting in 2027, state inventory data would be due to EPA by September 30 and starting in 2030, data would be due by May 31.
If your facility is subject to state-level emissions reporting in Kansas, Oklahoma, Texas, or Missouri, the 2027 deadline changes directly affect your compliance calendar. iSi Environmental conducts AERR readiness assessments and builds facility-specific reporting timelines. Start your readiness review →
Standardized Emissions Thresholds
Under the current AERR rule, states report data on criteria pollutants and precursors that exceed certain thresholds. The new rule would make the threshold the same each year causing more facilities to need to report every year.
💰 The cost of non-compliance: Late or inaccurate AERR submissions can trigger state penalties ranging from $15,000 to $75,000 per missed deadline, plus federal EPCRA enforcement escalation. Facilities in environmental justice communities face heightened scrutiny.
Frequently Asked Questions
Q: What is EPA’s Air Emissions Reporting Rule (AERR) and what must facilities report?
EPA’s AERR requires facilities to report emissions of criteria air pollutants (PM2.5, ozone precursors, SO2, NOx, etc.) and precursor pollutants to EPA through state agencies. Current AERR does not mandate federal reporting of hazardous air pollutants (HAPs), though some states require HAP reporting. EPA’s proposed rule changes would standardize HAP reporting requirements nationally so all facilities report HAPs regardless of state location. The standardization aims to create consistent environmental justice data and emissions transparency across all states and regions. iSi Environmental helps facilities understand AERR reporting obligations and state-specific requirements.
Q: What changes is EPA proposing for air emissions reporting deadlines?
EPA’s proposed rule would accelerate state air emissions inventory data submission deadlines to EPA. Starting in 2027, state inventory data would be due by September 30 (moving the deadline earlier than current practice). Beginning in 2030, data would be due by May 31 (even earlier). Earlier deadlines require facilities to compile and submit emissions data faster. States must subsequently submit data to EPA within the new compressed timelines. iSi Environmental helps facilities prepare for accelerated reporting deadlines and ensures timely data submission.
Q: What is changing regarding emissions reporting thresholds under the proposed AERR revisions?
Current AERR rules use variable emissions thresholds that differ from year to year, causing different facilities to report in different years. EPA’s proposed rule would standardize emissions thresholds to be constant each year. Standardization would mean more facilities consistently exceed reporting thresholds and would be required to report annually rather than in sporadic years. Facilities currently below thresholds in some years but above in others would need to establish consistent annual reporting processes. iSi Environmental helps facilities determine which emissions exceed standard thresholds and establish compliant reporting systems.
Q: Why is EPA expanding air emissions reporting requirements?
EPA’s proposed air emissions reporting rule changes are intended to enhance environmental justice by gathering location-specific, detailed emissions data across all facilities in all states. Consistent HAP reporting nationwide and standardized thresholds provide EPA and regulators with more complete emissions inventories for environmental assessment and enforcement. The data helps identify communities experiencing disproportionate air pollution exposure. Expanded reporting increases regulatory scrutiny of emissions sources. iSi Environmental helps facilities conduct emissions assessments and demonstrate compliance.
AERR compliance complexity grows as EPA standardizes thresholds and tightens deadlines. The 2027 September 30 deadline and 2030 May 31 deadline are closer than most facilities realize. iSi Environmental helps manufacturing, chemical, and energy facilities navigate standardized AERR reporting in Kansas, Oklahoma, Texas, and Missouri.
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