Vanguard helps facilities nationwide meet complex emissions reporting obligations under the EPA’s Air Emissions Reporting Rule (AERR) and state-specific regulations.
If your facility emits hazardous air pollutants (HAPs), volatile organic compounds (VOCs), particulate matter (PM), or other regulated substances, you may be subject to annual emissions inventory reporting (aka air emissions reporting or emissions inventory questionnaire in some states). Vanguard provides comprehensive reporting solutions that ensure accurate emissions quantification and compliance with state and federal air quality programs.
What Is Emissions Inventory Reporting?
Emissions Inventory Reporting is the annual submission of detailed data about air pollutants emitted from a facility’s processes, equipment, and activities. It is required by most states and federally under the EPA’s Air Emissions Reporting Rule (AERR), codified at 40 CFR Part 51, Subpart A.
This reporting supports:
- EPA’s National Emissions Inventory (NEI)
- State and local air quality planning
- Public health and environmental risk assessments
- Permitting, rulemaking, and control strategy development
What’s Changing Under the Updated AERR Rule?
The EPA’s proposed update to the AERR (published August 9, 2023) was expected to take effect in 2024 (delayed until 2027). Key changes include:
- Expanded reporting of Hazardous Air Pollutants (HAPs)
- More frequent data submissions for larger facilities
- Tighter alignment with state-specific inventory systems
- Greater use of Continuous Emissions Monitoring Systems (CEMS) and source testing data
- Enhanced electronic reporting requirements through the Emissions Inventory System (EIS)
- Inclusive of Per- and Poly-Fluoro-Alkyl Substances
Vanguard stays on top of these updates and ensures your facility is fully prepared as new rules take effect.
Who Needs to Report?
Most states require emissions inventory submissions from:
- Major and Minor Sources
- Facilities emitting Hazardous Air Pollutants (HAPs); aka 187 air toxics under Title III of the Clean Air Act Amendments of 1990. Note: State requirements vary significantly. California, Texas, Illinois, Ohio, Georgia, Oklahoma, and Washington have some of the strictest and most detailed reporting programs in the U.S.
- Facilities operating under Synthetic Minor permits
- Sources subject to New Source Performance Standards (NSPS) or National Emissions Standards for Hazardous Air Pollutants (NESHAP)
Some states also require reporting from:
- Smaller sources in ozone non-attainment areas
- Facilities with potential-to-emit (PTE) values near regulatory thresholds
- Facilities emitting greenhouse gases (GHGs)