As a reminder, the 2018 control period annual compliance reports for the Mass Emissions Cap and Trade (MECT) and Highly Reactive Volatile Organic Compounds Cap and Trade (HECT) Programs are due to TCEQ by March 31, 2019. Reports for both programs must be submitted through the State of Texas Environmental Electronic Reporting System (STEERS).

Mass Emissions Cap and Trade (MECT) Program

The MECT Program is published in 30 Texas Administrative Code (TAC) Chapter 101, Subchapter H, Division 3. The program is applicable to a site, and each affected facility at that site, in the Houston-Galveston-Brazoria (HGB) ozone nonattainment area that is either:

  1. A major source (i.e., site with a potential to emit of at least 25 tpy NOx in the HGB ozone nonattainment area) with one or more affected facilities subject to §117.310 or §117.1210; or
  2. Not a major source, but has one or more affected facilities subject to §117.1210 with a collective uncontrolled design capacity to emit 10.0 tpy or more of NOx.

It is important to note that any site that was major as of December 31, 2000 or any site that has been major for any period of time since December 31, 2000 is classified as a major source for the purposes of the MECT Program until it is permanently shut down.

The annual report for the MECT Program must contain the following information:

  1. Actual emissions of NOx from the applicable facilities;
  2. The method for determining NOx emissions;
  3. A summary of all final trades from the control period;
  4. Detailed documentation of the activity level and emission factor used; and,
  5. Detailed documentation of any deductions to allowable NOx emissions related to changes made under §101.354(e) (increases in NOx emissions to facilities not subject to §117.310 or §117.1210).

Failure to submit this annual compliance report may result in the withholding of approval of future trades from that site. If your site is subject to the MECT Program but no longer has authorization to operate any affected facilities, you may request a waiver from the reporting requirements. If approved, the annual compliance report is not required until a new affected facility is authorized at the site.

Highly Reactive Volatile Organic Compounds Cap and Trade (HECT) Program

The HECT Program is published in 30 TAC Chapter 101, Subchapter H, Division 6. The Program is applicable to those sites in the HGB ozone nonattainment area that include: vent gas streams, flares, and cooling tower heat exchange systems that emit or have the potential to emit highly reactive volatile organic compounds (HRVOCs). Sites with a potential to emit of greater than 10.0 tpy of HRVOCs are subject to the HECT Program.

The annual report for the HECT program must contain the following information:

  1. Actual HRVOC emissions from each affected facility;
  2. The method(s) used to determine actual HRVOC emissions; and,
  3. A summary of all final transactions from the control period.

Failure to submit this annual compliance report may result in the withholding of approval of future trades from that site. If your site is subject to the HECT Program but no longer has authorization to operate any affected facilities, you may request a waiver from the reporting requirements. If approved, the annual compliance report is not required until a new affected facility is authorized at the site.

How Trinity Can Help

Trinity is well-versed in both the MECT and HECT Programs and can assist with all aspects of the annual compliance reporting discussed. Please reach out to your nearest Trinity office by calling (800) 229-6655 if you have any questions on any aspect of the MECT and HECT Programs or other environmental needs.