Executive Summary: In early 2026, the Illinois Environmental Protection Agency (Illinois EPA) released updated versions of several Clean Air Act Permit Program (CAAPP) forms. These revisions focus primarily on improved formatting and streamlined data entry across the forms. In addition, the Illinois EPA made select content changes, including consolidation of sections related to insignificant activity identification, pollutant emissions reporting, and monitoring requirements.
When are CAAPP Forms Needed?
The Illinois EPA requires all owners and operators of CAAPP sources to submit CAAPP forms as part of any permit application, revision, or amendment. Forms may also accompany mandatory periodic reports, including semiannual monitoring reports and annual compliance certifications.
CAAPP forms are generally organized into the following categories, which are available on the Illinois EPA website: General Application Forms (required with all CAAPP Permit Applications), Construction Permit Forms for CAAPP Sources, Procedural Forms, Emission Unit Forms, Air Pollution Control Equipment Forms, and Compliance Forms. (Federal Enforceable State Operating (FESOP) and Lifetime Permit forms can also be found on the same Illinois EPA webpage. However, these documents were last updated in January 2025 and were not part of the recent formatting and content updates made to the CAAPP forms.)
The number of required forms depends on the scope of the submittal. For medium- to large-sized facilities, populating these forms can be a very time-intensive aspect of the permitting process. This is largely due to the volume of process, emissions, and regulatory data required for each emission unit and control device. In some cases, applicants must also provide supplemental exhibits to support form entries, such as calculations and technical justifications. Exhibit requirements are typically outlined within each form but may also be added when additional space or clarification is needed.
The Illinois EPA’s General Instructions for CAAPP Applications provide guidance on CAAPP form selection and completion. Additionally, guidance on permit revisions, permit renewals, and Semi-Annual Monitoring Report submissions is available on the Illinois EPA website.
When and Why Were the Forms Updated?
Prior to the 2026 updates, CAAPP applicants reported challenges with form accessibility, formatting inconsistencies, and redundant content. Many form fields were not editable, requiring tedious troubleshooting. In addition, Emission Unit forms contained separate sections for testing, monitoring, recordkeeping, and reporting, some of which were redundant or rarely used by the Illinois EPA permit writer. Additionally, Procedural Forms lacked centralized instructions.
In response, the Illinois EPA released updated Procedural forms in April 2026, followed by updated Emission Unit and Air Pollution Control Equipment forms in May 2026. These updates significantly improve formatting and usability by introducing editable fields and a more streamlined structure.
Across the revised forms, field numbering was removed, section names were standardized, and the ‘Date Prepared’ field was eliminated. New fields for CAAPP permit numbers and environmental contact information were also added to create consistency and reduce repetitive data entry. Collectively, these changes should simplify form completion, improve data quality, expedite permit issuance, and reduce the need for revisions.
Unfortunately, General Application Forms (required with all CAAPP permit applications), Construction Permit forms for CAAPP Sources, and Compliance Forms have not yet been updated, and many of the original issues persist for these forms. Also, keep in mind that facilities may need to work with both updated and outdated forms, requiring careful attention to formatting and submission requirements.
2026 Updates to CAAPP Forms
The following two tables summarize the forms that Illinois EPA has updated at this time.
Updated Procedural CAAPP Forms
| Form Identification | Updates |
285-CAAPP
Withdrawal of Source, Permit, or Permit Application | 1. Certification statement was revised and expanded |
297-CAAPP
Listing of Insignificant Activities | 1. Question 5 (identification of insignificant activities under 35 IAC 201.210(a)) has been removed
2. All insignificant activities (IAs) must now be listed directly in the table
3. The “Basis for Determination” column has been removed
4. Exhibit 297-1 (additional operating/emissions information) is required for IAs under 201.210(a)(1)-(3)
5. There is no longer a separate table to complete for IAs under 201.211(a) |
Updated Emission Unit & Air Pollution Control Equipment CAAPP Forms
| Form Identification | Updates |
| All | 1. Removed “hours/year” operating data fields (maximum and typical)
2. Eliminated redundant checkboxes
3. Consolidated the “Applicable Rules” section into a single table covering:
> Emission standards
> Recordkeeping
> Reporting
> Monitoring
> Testing requirements
4. Condensed the “Testing, Monitoring, Recordkeeping, and Reporting” section into two tables.
> Reduced the number of discrete questions
> Expanded the parameters table for clarity
> Removed contact and responsible persons columns
5. Reformatted the “Emission Information” table and “Hazardous Air Pollutant Emission Information” table |
220-CAAPP
Process Emission Unit | 1. Removed questions related to startup emissions exceedances* |
* The Illinois startup, malfunction, and breakdown provisions (Title 35 of the Illinois Administrative Code, Part 201, Subpart I) were repealed in 2023. Emissions exceedances during these events are no longer permitted and must be reported the same as any other emissions exceedance.
If you need assistance navigating these recent updates or populating the updated CAAPP forms for any construction or CAAPP permit applications, please contact Trinity’s Chicago Office at 630.495.1470, email Rebecca Collins at [email protected] or Chloe Reece at [email protected], or submit your information at Contact Us – Trinity Consultants.
