What’s Changing and Why It Matters for EHS Managers
Delaware’s Department of Natural Resources and Environmental Control (DNREC) has officially transitioned Natural Minor air construction permits and amendments into the digital DNREC ePermitting platform. This represents a significant change for manufacturing sites because the method of submitting applications (not the technical requirements) has changed.
As of January 1, 2026, all Natural Minor construction-related air permit applications must be submitted online. For now, Synthetic Minor, Title V renewals, and other federally enforceable permits will remain paper‑based. For many EHS teams, this means managing two parallel permitting workflows for the foreseeable future.
Key access points:
Start Here: Personal Accounts Are Mandatory
If your facility has never used the digital DNREC portal, every user must create a Personal account first. This is each user’s access key to the portal, which can then be associated with an Enterprise (business) profile.
Creating a Personal account involves entering basic contact information, address details, and verifying email. While simple, this step often becomes a last‑minute bottleneck. EHS managers should ensure internal staff and external consultants are registered ahead of time to avoid delays at submittal (Tip: sites may designate at least one “primary submitter” plus one backup (Note: the primary does not need to be a “Responsible Official (RO)” but does need to be an authorized CROMERR electronic signatory). This prevents schedule slips when the primary submitter is out on PTO or unavailable during a critical permitting window).
What the Digital Workflow Looks Like
Online application and supporting files. Complete required fields in the portal, then upload emissions calculations, equipment descriptions, and other supporting documents. The technical content itself has not changed – modeling, process narratives, and engineering details are still an important part of the application. Note: any supplemental files and figures must be uploaded in PDF format (.pdf) – editable file formats (e.g. .docx or .xlsx) are not suitable for attachment in the system.
Online payment. Pay fees directly through the system, eliminating checks and mailing delays.
Paper forms as preparation tools. DNREC will continue to publish paper forms online as templates to help EHS teams prepare complete digital packages before entering them into the portal (these templates will also be available for use in preparation of synthetic minor and major source applications for paper-based submittal.
Training and resources. The digital DNREC portal includes training materials, portal walkthroughs, and example applications to help new users understand the flow before their first submittal.
Recommendations for Manufacturing Facilities and EHS Leaders
- Build digital readiness into your process: Set up Personal accounts early. Confirm who will upload documents, who will review, and who will act as the digital signatory.
- Standardize a “digital‑ready” permit package: Organize emission calculations, engineering drawings, modeling files, and narratives into clearly labeled PDFs. Good file hygiene saves time during upload and review.
- Expect a mixed paper/digital environment: If you manage Natural Minor and Synthetic Minor/Title V requirements, maintain parallel Regulation 1102 permits and add a simple “permit type check” at project kickoff.
- Protect your schedule: Digital intake reduces administrative delays, but first‑time users may encounter learning curves or role‑assignment issues. Build a small buffer into timelines.
- Monitor future expansion: DNREC plans to bring additional air permit categories into the digital system over time. Check air permitting pages periodically to stay ahead of changes.
Bottom Line
For EHS managers, the move to the digital DNREC portal is less about regulatory change and more about process modernization. Facilities that set up accounts early, standardize digital‑ready application packages, and clearly define roles will see smoother, more predictable permitting cycles.
Next Steps
Need support with preparing for an air quality permit application in Delaware? Trinity Consultants helps facilities assess project details, identify permitting requirements, and can support with account setup, preparation of digital‑ready permit packages, and coordinate Natural Minor, Synthetic Minor, and Title V strategies during DNREC’s transition period.
If you would like to discuss DNREC’s ePermitting program and how it may impact your facility, please contact Trinity’s Philadelphia Office.
For the latest updates in federal and state requirements, consider attending our Air Quality Permitting in Delaware class which provides an overview of federal requirements and detailed information on state/local regulations which are needed to prepare or manage the air permit application process for new or modified sources.
