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CTR Regulation Update – Fall 2022

September 15, 2022

• Emit 4 tons per year (tpy) of any criteria pollutant [100 tpy of carbon monoxide (CO)] in a Group A air district (see list below);
  

  District Group A:	District Group B:
  SCAQMD	All Other Air Districts
  SJVAPCD
  BAAQMD
  ICAPCD
  SMAQMD
  SDAPCD

• Emit 10 tpy of any criteria pollutant (100 tpy of CO) in a Group B air district (all other smaller districts);
• Exceed the activity level threshold for a specific permitted process (for example, combustion of diesel oil in Tier 0-3 engines, exceeding 30 gallons or 5 hours per year of non-emergency use, except for agricultural and medical industry sectors);
• Report greenhouse gases (GHGs) under the Mandatory Reporting Rule (MRR);
• Hold permit(s) to emit 250 tpy or more of any nonattainment criteria pollutant (“Criteria Facility”); or
• Are classified as “high priority” under Assembly Bill (AB) 2588 (Air Toxics “Hot Spots” Act).

Facilities in the six Group A air districts that are already required to report GHG emissions (under the MRR), criteria pollutants, or air toxics under AB 2588 have begun reporting. Full reporting of stack data will be due in 2023 for 2022 emissions data to the air district in which they reside. Group B districts will begin reporting in 2024.
Required data for reporting under CTR includes:

• Device information;
• Process descriptions and annual activity levels;
• Actual emissions for each pollutant;
• Methodology for calculating emissions; and
• Stack/emissions release location information (e.g., location, temperature, velocity, etc.).

Facilities currently reporting through the MRR and Criteria Facilities will also need to report their portable diesel engine usage for any units greater than 50 brake horsepower (bhp) starting in 2023 for 2022 data.

Abbreviated reporting of throughput data and facility information will be allowed for certain sectors, including:

• Agricultural facilities;
• Facilities only operating natural gas-fired boilers/heaters;
• Facilities only operating diesel emergency generators or fire pumps; and
• Gasoline dispensers.

CARB has released guidance documents to assist facilities with determining the applicability of the regulation, as well as what data is required. Additional information is available on the CARB website at:
https://ww2.arb.ca.gov/our-work/programs/criteria-and-toxics-reporting/guidance-documents-ctr.

Yorke Engineering specializes in air quality consulting and environmental consulting for stationary and mobile sources, including dispersion modeling, health risk assessments, permitting, emission inventories, air quality compliance systems, etc. Yorke Engineering has assisted over 1,800 customers, including a wide variety of industrial facilities and government organizations throughout California. Learn more about how we can help you here: Air Quality | Yorke Engineering, LLC (yorkeengr.com).

Air Quality Tip

Unless otherwise subject to CTR reporting, consider staying below the Reporting Thresholds for Permitted Processes to remain out of reporting, if possible. For example, keep non-emergency use of Tier 0-3 diesel engines below 5 hours. For more information, see Tables A-1 to A-3, starting on page 35 of the currently available regulation text: CTR Unofficial Regulation Text (ww2.arb.ca.gov).

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