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On March 11, 2019, The New Mexico Environment Department (NMED) announced that the Air Quality Bureau (AQB) will be conducting a minor source emission inventory for all sources located in the state of New Mexico for reporting year 2020 (per 20.2.73.300 NMAC). Minor source emission inventory recordkeeping will be required from January 1, 2020 - December 31, 2020 for all minor sources.

There is currently no minimum reporting threshold by pollutant. Emissions of the following pollutants will be required to be reported to the NMED by April 1, 2021:

  • Criteria Pollutants: Carbon Monoxide (CO), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Particulate Matter less than 10 microns in diameter (PM10), Particulate Matter less than 2.5 microns in diameter (PM2.5), and Lead (Pb)
  • Greenhouse Gas Pollutants: Methane, Carbon Dioxide (CO2), and Nitrous Oxide (N2O), etc
  • Regulated Pollutants: Volatile Organic Compounds (VOC), Hazardous Air Pollutants (HAPs), and Toxic Air Pollutants (TAPs)

Minor sources pulled into this action include all sources permitted under the following mechanisms:

  • Notice of Intent (NOI)
  • General Construction Permit (GCP)
  • New Source Review (NSR)
  • Streamline Permits

Emissions from portable equipment will also need to be reported for this minor source emission inventory. Title V and No Permit Required (NPR) facilities are not included in the minor source emission inventory; however, Title V sources will also need to submit a major source emission inventory by April 1, 2020. In addition, sources exempt from permitting are exempt from the minor source emission inventory. According to the NMED, there are approximately 5,000 minor sources in the state that will be subject.

This inventory will involve quantifying all actual emissions from each minor source in reporting year 2020; therefore, sources will need to start maintaining records of the data needed to calculate actual emissions from each permitted unit starting January 1, 2020 through December 31, 2020. It is vital that recordkeeping systems are in place by the start of 2020 to ensure the necessary data is collected.

In general, the information that will need to be gathered for each permitted source is as follows:

  • Actual hours of operation for each piece of equipment
  • The type and quantity of fuel combusted
  • Facility-wide production
  • Materials processed

Reporting will be completed using the NMED's web-based Air Emission Inventory Reporting (AEIR) tool. Information in the submittals for each unit may include the hours of operation, fuel consumed, and fuel heating value, as well as the quantity of each pollutant released, and method used to calculate the emissions. Submittals will be inputted into AEIR individually by facility or en masse by uploading an XML file with all facilities that will auto-populate the system. The submittals will still need to be individually certified for each source. If there are multiple permits for the same source, an emission inventory submittal will need to be entered for each permit and will be split up based on the equipment that is permitted under each authorization. There will be no fees associated with the minor source emission inventory. Annual fees will not be affected.

Some acceptable methods of calculation include using emission factors from AP-42, manufacturer's data, or stack testing. Emission monitoring (such as CEMS data) and gas analyses may also be applied. If used, stack test data should be from the past five (5) years and gas analyses from the last year. Please note that these are not definitive time restrictions; the NMED is still discussing these requirements and have not yet released guidance regarding this.

For any questions regarding the New Mexico minor source emission inventory, please contact the Trinity Consultants Albuquerque office at (505) 266-6611.