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Based on the 2018 designation of Bexar County as marginal nonattainment for the 2015 eight-hour ozone National Ambient Air Quality Standard (NAAQS), the Texas Commission on Environmental Quality (TCEQ) is now accepting valid revisions to the previously submitted Reporting Year (RY) RY2017 Emissions Inventory (EI) point source data for facilities in Bexar County. Facilities may use the revised data to generate Emission Reduction Credits (ERCs). More information is included below.

On October 1, 2015, the U.S. Environmental Protection Agency (EPA) revised the primary and secondary NAAQS for ozone to an eight-hour standard of 0.070 parts per million (ppm). Effective September 24, 2018, the EPA designated Bexar County as marginal nonattainment for the 2015 eight-hour ozone NAAQS.

The Federal Clean Air Act requires states to submit a comprehensive, accurate, current inventory of actual emissions from all sources in a nonattainment area, within two years of the effective date of nonattainment designations. To meet this requirement, the TCEQ is in the process of preparing an EI state implementation plan (SIP) revision for the Bexar County 2015 eight-hour ozone nonattainment area. If these SIP revisions are adopted, a RY2017 SIP emissions year for credit generation projects will be established for the Bexar County 2015 eight-hour ozone nonattainment area.

The TCEQ is now accepting valid revisions to the previously submitted RY2017 EI point source data for facilities in Bexar County. Facilities may use the revised data to generate ERCs, which are otherwise generated by implementing potentially expensive control devices or shutting down existing equipment. ERCs may be required to offset emissions increases caused by major modifications under TCEQ Nonattainment New Source Review (NNSR) regulations. SIP emissions may not exceed any applicable local, state, or federal requirement.

Note that this is not an opportunity for sites to submit overdue RY2017 EIs. EIs not received by the original deadline are subject to enforcement, and may not be processed or included in the upcoming EI SIP revisions.

To revise previously-submitted RY2017 EIs in Bexar County:

  • Submit the revisions on paper EI forms with supporting documentation prepared according to the 2018 Emissions Inventory Guidance, which can be found here.
  • Revisions must be postmarked July 31, 2019, and submitted to the TCEQ in Austin.

Please contact your local Trinity Consultants office at (800) 229-6655 if you require assistance with your Bexar County RY2017 EI revisions or if you have any other questions.