In the June 17, 2017 Pennsylvania Bulletin, the Pennsylvania Department of Environmental Protection (PADEP) published a notice that it will begin requiring all sources subject to the air emission inventory provisions under 25 PA Code § 135.3 to submit the inventory electronically. PADEP cites benefits to electronic reporting including eliminating unnecessary paper forms and improving the review process. The Department will evaluate exceptions at the regional office level on a case-by-case basis. Approximately two-thirds of facilities already report emissions electronically.
The Department's action is effective with the 2018 emissions reporting year data to be submitted by March 1, 2019. While the emissions submittal process will change, those facilities that pay emissions fees by September 1 of each year are not expected to see a difference in the fee submittal process.
Many facilities have submitted data through Greenport for emission inventory or for other programs. For those not currently submitting electronically there are a few preparation steps. The steps include:
- Set up an account by sending Robert Bihl, the form titled Request for Security Access-Portal Account at the "Registration Form" hyperlink located at DEP's Emission Inventory page
- Using the form, establish the facility preparers and submitter. Though the access form is simple, the process to add personnel can be lengthy so we recommend starting the process no later than October to be ready by January 1. There can be up to 5 preparers and 1 submitter per facility and the submitter will be the facility Responsible Official.
- View the online presentation at the same page.
- Facilities will have the option to submit electronic reports using the AES*Online application (manual data entry), or the AES*XML option (via direct upload in XML format). The PADEP regional office will need to configure the facility in AES according to the option selected. Once configured, you will need to go to your Greenport home screen and log in with the credentials provided by PADEP.
The electronic emissions submittal system does not require a facility to change the methods it uses to calculate emissions, although the change in submittal process may be a good opportunity for facilities to review and verify historical emission factors and calculation methodologies. Ultimately, it may mean that facilities (and PADEP) spend less time copying data to and from paper forms and may avoid transcription errors.
What can facilities do now to prepare?
- Evaluate the two electronic submittal options, AES*Online and AES*XML and determine the best method for your site. Facilities with many emission sources and pollutants may find the AES*Online submittal process to be tedious and very time-consuming. However, the AES*XML option does require a certain amount of up-front work to "map" data into the required format for upload. In either option, there is a learning curve, so companies should expect to spend extra time during the first submittal.
- Consider transitioning to the electronic submittal process early, i.e., for the calendar year 2017 emissions report (due March 1, 2018). This strategy may mean that you have more PADEP resources available to assist with configuration of your facility and for troubleshooting, since most will likely wait until 2018 to transition to electronic reporting.
- Use this change in reporting to your advantage by taking some extra time to thoroughly review and validate historic emission factors, calculation methods, and underlying assumptions/data.
Trinity has been assisting facilities in Pennsylvania with preparation and submittal of emissions inventory reports for more than a decade. We can assist you with manual data entry, development of XML tools/templates, training on the use of AES, and critical review/auditing of emission factors and calculations. If you have any questions concerning Pennsylvania's Greenport system or the electronic emission inventory process, please contact Wendy Merz, Manager of Trinity's Exton office at (610) 280-3902, or Tom Muscenti, Manager of Trinity's Wexford office at (724) 935-2611.