IEPA Updates CAAPP Forms: 2026 Changes Explained

When are CAAPP Forms Needed?

The IEPA 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 IEPA website¹: 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.

The number of required forms depends on the scope of the submittal. For medium- to large-sized facilities, populating these forms can be one of the most time-intensive aspects of the permitting or amendment process. This is largely due to the volume of manufacturing, emissions, and regulatory data required for each operation, 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 IEPA’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 IEPA 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 lengthy and complex sections for testing, monitoring, recordkeeping, and reporting, while Procedural Forms lacked centralized instructions. These issues frequently resulted in submission errors, increased revisions during IEPA review, and post-submittal amendments.

In response, the IEPA 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

Procedural CAAPP Forms

Emission Unit & Air Pollution Control Equipment CAAPP Forms

If you need assistance navigating these recent updates or populating the updated CAAPP Forms for new sources, amendments, renewals, etc., please contact Trinity’s Chicago Office at 630.495.1470, email Rebecca Collins at [email protected], or submit your information at Contact Us – Trinity Consultants.