Statewide Criteria Pollutants and Toxics Reporting

The Regulation for the Reporting of Criteria Air Pollutants and Toxic Air Contaminants (CTR) implements statewide annual reporting of criteria air pollutant and toxic air contaminant emissions data from facilities. CTR was developed to support the mandates of both Assembly Bill (AB) 617 and AB 197 by establishing new policies to improve air quality, including emissions inventories. Yorke Engineering has completed over 2,000 air emission quantification projects and has reported more than 600 inventories to the California Air Resources Board (CARB) and local air districts. For general information about AB 617, click here.

CTR Reporting Services

• Investigate and evaluate facility applicability;
• Develop recordkeeping and Annual Report generation tools;
• Prepare Annual Report for criteria pollutants and toxics; and
• Negotiate with Air District or other regulatory agencies.

Applicability

Facilities currently required to report under AB 617 include those that:

• Fall under Mandatory Reporting for Greenhouse Gases (GHGs) (approximately 900 facilities in CA);
• Are permitted to emit 250 tons of a criteria pollutant (approximately 30 facilities); or
• Have been designated as High Priority for Toxics by the local Air District (approximately 500 facilities).

In addition, CARB has proposed regulatory revisions that would require many additional facilities to report their criteria and toxics emissions if they meet one of the following criteria for permitted emissions and devices:

• 4 tons per year of any criteria air pollutant (except for Carbon Monoxide);
• 100 tons per year of Carbon Monoxide; or
• Facilities in selected industries that operate permitted equipment exceeding certain “activity levels” published in the CTR regulations.

These facilities will be phased into reporting anytime between 2022 and 2027, depending on the Air District in which they are located and the sector phase defined by the regulation. Several activities under this proposed regulation would be eligible for abbreviated reporting.

Reporting Requirements

Emissions will be quantified at the device/process/permit unit level, and the following will be reported:

• Criteria Pollutants (NO_x, SO_x, PM₁₀, PM_2.5, Carbon Monoxide, Lead, Ozone);
• Toxics (as defined by AB 2588 and CAPCOA Appendix B); and
• Relevant facility data (stack heights, building dimensions, etc.).

Timeline

The phase-in period for GHG and Criteria Pollutant applicable facilities is the 2020 reporting year (2019 data), and the Toxics applicable facilities phase-in period is for reporting years 2020 and 2021 (2019 and 2020 data). During the initial phase-in period, facilities will submit annual emissions reports that include all data and methods for the 12-month timeframe currently specified and required by the local Air District. After the phase-in period, these facilities will be required to submit an annual report with all the information required under the regulation.

Full reporting (after the phase-in period ends) will include:

• Facility information;
• North American Industry Classification System (NAICS) code;
• Facility location;
• Device names and IDs;
• Process names and descriptions;
• Activity level;
• Criteria pollutant and toxic pollutant actual emissions;
• Calculation methods and emission factors;
• Emission limits; and
• Emission release location, as applicable.

These reports are to be submitted to the local Air District by May 1st, unless a facility specifically requests to submit the full report to CARB directly, if CARB has an appropriate online reporting tool available at that time. All reports required to be submitted to the local air districts by May 1st must be submitted to CARB by August 1st. The reporting of emission release information can be deferred until the 2023 reporting year (2022 data).