Five Things You Need to Know About Changes to the New Hampshire Annual Air Emission Statements

March 15, 2019

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New Hampshire Annual Emission Statements Due April 15th

New Hampshire facilities with air permits should take notice to recent changes made by the New Hampshire Department of Environmental Services (NHDES) to how air pollutant emission fees (emission fees) are calculated and paid. These changes were finalized on October 24, 2018. If you are just hearing this news for the first time, or need a refresher regarding the changes made and what you must submit, here are five things from GeoInsight's team of air compliance experts you need to know to prepare your facility’s Annual Emission Statement for 2018 emissions: 

  1. Only Annual Emission Statements are due by April 15th
  1. Payment for emissions must be submitted to the NHDES by May 15th - This is different from before, as both the Annual Emission Statement and emission fee payment were due previously by April 15th.
  1. The emission fee rate has been reduced - NHDES is charging $283.70 for each ton of air pollution emitted in 2018. This is less than last year’s rate, which was $319.57 per ton of air pollution.
  1. The minimum emission fee rate can be prorated– In cases where the total emissions were less than one ton, the NHDES historically charged the amount of one ton. The NHDES now allows facilities which emitted less than one ton, to pay proportionally less than the amount for one ton. For example, a facility which emitted one half of a ton last year could pay 50% of the dollar per ton rate.
  1.  “Baseline Fees” have been added – While the emission fee rate was reduced and can be prorated, the NHDES is charging an additional “baseline fee” beginning this year.   The base fee varies with the type of facility and can be as little as $500 and as much as $75,000

What is an Air Emission Statement?

In conjunction with paying their emission fee, the NHDES also requires facilities to prepare a short report called an Annual Emission Statement. This report is typically comprised of  the following:

  • compliance report cover sheet;
  • cover letter;
  • relevant NHDES forms;
  • supporting emission calculations;
  • supporting emission fee calculations;
  • and sometimes, supporting operational information (such as the monthly operating hours for a diesel-fueled engine).

In addition, there are forms for combustion sources (facilities that burn a fuel such as a power plant), and process sources (facilities that produce emissions through a production process such as a manufacturing plant).  There are also forms which address specific air pollutants such as nitrogen oxides (NOx), volatile organic
compounds (VOCs) and sulfur dioxide (SO2).

Who is required to pay an emission fee?

Facilities with NHDES air pollution control permits (air permits) are required by the NHDES to account for their contribution of air pollution by paying a fee for their calendar year air pollutant emissions (emission fee).  The emission fee is paid for emissions from equipment and/or processes which are regulated by NHDES air permits.

Who needs an Air Permit?

Air permit applicability depends on a number of factors such as the type and size of equipment producing air pollutant emissions, the type of air pollutant emissions, the type of fuel burned, and the type of facility.  Examples of facilities commonly needing air permits are power plants, manufacturing plants, hospitals, universities, ski areas, rock crushing plants, hot mix asphalt plants.

More Information on NH Air Emissions

You can find more information on the NHDES website here:

https://www.des.nh.gov/organization/divisions/air/pehb/apps/crss/emissions-fees-notice.htm


Need help with your Annual Emissions Statement? – Contact Our Air Compliance Experts:

If you are unsure if this applies to your facility, or how to compile and write your Annual Emission Statement, please reach out to GeoInsight for help!


John Hinckley, Air Compliance Specialist

jahinckley@geoinc.com | (603) 314-0820

Contact John Hinckley

 

Suzanne Pisano, Compliance Director
slpisano@geoinc.com | (978) 679-1600

Contact Suzanne Pisano