Annual Emission Reports (AER)s are due to IEPA on May 1st for all permitted sources. Paper forms are still required, and facilities should have received forms in the mail from IEPA. In 2011 the IL Environmental Protection Act was revised to add Greenhouse Gasses (GHGs) to the definition of regulated pollutants. Therefore, GHG emissions are now required to be reported. Note that even if you plan on registering your small sources under the Registration of Smaller Sources (ROSS) rule, you must still complete an AER for reporting year 2011.
Some facilities are required to submit forms for each emission unit in addition to facility-wide emissions (e.g., 'long' report). These sources include: (1) facilities with potential to emit 25 tons/year or more of any combination of regulated air pollutants, (2) facilities required to have a Clean Air Act Permit Program (CAAPP), and (3) facilities in ozone nonattainment areas that have potential to emit 25 ton/year or more of either Volatile Organic Material (VOM) or Nitrogen Oxide (NOx). IEPA clarified that GHG's are not included when determining whether a facility submits the 'long' or 'short' (e.g., only facility-wide emissions) report. Additionally, GHG's are required to be reported even if the facility is subject to report under the Miscellaneous Reporting Rule (40 CFR Part 98). More information regarding AERs can be found here.
Annual Compliance Certifications (ACCs) are required for sources holding CAAPP permits and are due to IEPA on May 1st. Both Table 1 on the 401-CAAPP form detailing compliance status of each permit condition AND Table 2 detailing any deviations and corrective actions are required. Be sure to include all conditions from your CAAPP permit in the ACC. Also, construction permits issued since the last update to the CAAPP permit should be reviewed as part of the compliance certification. Instructions for completing the ACC can be found here.
2012 Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR) Reporting Requirements
The Environmental Protection Agency (EPA) released a fact sheet for Mandatory GHG Reporting Rule Special Provisions last year which explains the multiple deadlines for reporting in 2012. There is a list of 12 new subparts which are required to be reported on for the first time in 2012. The reporting deadlines are dictated by which subpart, or combination of subparts, your facility must report under. If your facility is not reporting under one of these 12 new subparts, the reporting deadline is April 2, 2012. If your facility is reporting under any of the "new" subparts, the reporting deadline is extended to September 28, 2012 for all subparts under which you must report.
Also, if your facility is reporting under any of the "new" subparts and submitted a GHG annual report for reporting year 2010 under another subpart (e.g., stationary fuel combustion), then by April 2, 2012 you must notify EPA through e-GGRT that you are not required to submit the second annual report until September 28, 2012. The reporting deadline extension applies to all subparts being reported by the facility or supplier. More information regarding these reporting deadlines can be found here.