US EPA has proposed changes to the existing emission inventory reporting requirements on state, local, and tribal agencies in the 2008 Air Emissions Reporting Requirements rule. The proposed amendments would lower the current threshold for reporting Pb sources as point sources; eliminate the requirement for reporting emissions from wildfires and prescribed fires; and replace a requirement for reporting mobile source emissions with a requirement for reporting the input parameters that can be used to run the EPA models that generate the emissions estimates. In addition, the proposed amendments would reduce the reporting burden on state, local, and tribal agencies by removing the requirements to report daily and seasonal emissions associated with carbon monoxide (CO), ozone (O3), and particulate matter up to 10 micrometers in size (PM10) nonattainment areas and nitrogen oxides (NOX) State Implementation Plan (SIP) call areas. Comments must be received on or before August 19, 2013.
The EPA promulgated the Air Emissions Reporting Requirements (AERR) in 2008, in order to consolidate and harmonize the emissions reporting requirements of the NOX SIP Call and the Consolidated Emissions Reporting Rule with the Clean Air Interstate Rule (CAIR). The amendments are being proposed to align the AERR with the National Ambient Air Quality Standard for Lead. The amendments would lower the current threshold for reporting stationary Pb sources as point sources.
The current AERR threshold for determining if a stationary source of Pb emissions must be reported as an individual point source rather than as part of a county-aggregate nonpoint source, is 5 tons per year (tpy). As with the other required pollutants, that threshold determination is based on potential to emit, although the emissions reported are the actual emissions. In 2010, the EPA finalized the Revisions to Lead Ambient Air Monitoring Requirements, which required monitoring agencies to install and operate source-oriented ambient monitors near Pb sources emitting 0.5 tpy or more by December 27, 2011. The EPA is proposing to lower the AERR emissions threshold for reporting Pb emitters to match the 0.5 tpy threshold in the revised ambient air monitoring requirements. EPA expects that only about 30 additional facilities nationwide would be required to be reported as point sources due to this change, since most of the sources emitting Pb greater than 0.5 tpy are already reported as point sources due to their emissions of other criteria pollutants. The current AERR already requires all criteria pollutants (including Pb) to be reported for a facility that emits any one criteria pollutant greater than the relevant threshold.