In late September 2023, all users registered in the U.S. Environmental Protection Agency’s (EPA’s) Combined Air Emission Reporting System (CAERS) under a facility in the District received an automated email regarding monthly fuel reporting. This sparked a lot of questions as to whether this was a new reporting requirement for Title V and synthetic minor sources and following a training on October 16th, we now have an answer. The short answer is “No” or at least “Not at this time”. During a training on October 16 held jointly with EPA and the Department of Energy and Environment (DOEE), it has been clarified that while this is not required for 2024, it is strongly encouraged and will likely be required at some point in the future.
So, what is monthly fuel reporting? Title V and synthetic minor permits issued by the DOEE require facilities to submit a report of monthly fuel and hours on the fuel burning equipment form as part of semiannual compliance reports. The monthly reporting within CAERS is essentially a replacement for that form which allows monthly input of fuel, hours, and emissions for all fuel-burning sources and is certified and submitted to DOEE and EPA semiannually.
This monthly option is not yet available to CAERS users but will be available in early 2024 to be used for the 2024 calendar year. If a facility chooses to do the optional monthly reporting, the semiannual deadlines will match the semiannual/annual compliance reporting deadlines (i.e., March 1 and September 1 for most permits) and the fuel burning equipment forms will no longer be required starting with the first half of 2024 semiannual report.
When deciding whether to switch to this new reporting option, here are some things to consider:
- Pros to submitting monthly reports in CAERS:
- DOEE is strongly encouraging it and as such, your compliance inspector is likely to want to see it submitted that way. DOEE even said during the October 16 training that paper forms would be “highly discouraged” by DOEE.
- This is not actually an extra report, facilities are already required to submit this monthly data, it is just a different way to submit it. Therefore, you are replacing a report (not created a new report), and most submitted data is already submitted anyway.
- The monthly data automatically transfers into your annual emissions report that is required to be in CAERS. In theory, this will make your annual report easier. In addition, it ensures consistency between the monthly and annual data.
- This is likely to be required in a year or two. There may be a benefit to being an early adopter while they are still figuring it out.
- Cons to submitting monthly reports in CAERS:
- Entering data into the CAERS system appears to be significantly more time-intensive than completing the traditional fuel burning equipment forms.
- While the majority of the data is already submitted on the fuel burning equipment forms, there is some additional information that is not currently required to be submitted for most sources on a monthly basis including emissions and more detailed operating schedule (hours per day, days per week, and weeks per month).
- The biggest issue seems to be if you find an error in the monthly data. If the monthly information was submitted in your semiannual or annual report of monthly data, the only way to fix it is to contact DOEE and have them reject the report and resubmit it. For example, if in preparing your annual emission report in CAERS you were to find a mistake in the April fuel usage for one unit, instead of just using the correct number, you would need to contact DOEE, have them reject your semiannual report, update and resubmit the semiannual report, and then finish and complete your annual emission report. It is unclear if this would be required if you change an emission factor mid-year for something like a new stack test.
The monthly reporting option will be available to all users, whether or not your facility decides to submit the monthly data. If you opt to stick with annual emissions in CAERS only, you can ignore the new monthly report section of CAERS and enter data annually as done in prior years. If you are switching to the electronic reporting, you do not need to notify DOEE.
The October 16 training was recorded and can be found on EPA’s website (under CAERS V4 Trainings and Reference Data > User Interface > District of Columbia).
Trinity Consultants’ Washington, D.C. Office assists several facilities in the District with preparing annual emission reports in CAERS. Please contact our office at 240.379.7490 if you have any questions about CAERS reporting or want to discuss whether monthly reporting may be right for your facility.
