On April 5, 2025, the Pennsylvania Department of Environmental Protection (PADEP) finalized a new General Plan Approval and/or Operating Permit available for owners and operators of gaseous fuel-fired spark ignition internal combustion engines (BAQ-GPA/GP-16). PADEP had announced the proposed BAQ-GPA-GP-16 on October 12, 2024. The BAQ-GPA/GP-16 was developed under the authority of 25 Pa. Code Chapter 127, Subchapter H and is limited to gaseous fuel-fired spark ignition internal combustion engines. The application of the BAQ-GPA/GP-16 is limited to engines proposed at new or existing minor sources, as defined under 25 Pa. Code Chapter 121.1
The BAQ-GPA/GP-16 contains Best Available Technology (BAT) emission limits shown in the table below. Please note that these BAT limits are generally more stringent than the limits in Table 1 of 40 CFR Part 60 Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. The limitations remain consistent with those in the proposal permit.
TABLE 1
| Engine Type | Engine Rating (hp) | Emissions Standards |
| (g/hp-hr) | ppmvd @15%O2 |
| NOx | CO | VOC (as propane) | HCHO | NOx | CO | VOC (as propane) | HCHO |
| Lean-Burn | ≥100 and ≤500 | 1.0 | 0.70 | 0.30 | __ | 82 | 95 | 26 | __ |
| Lean-Burn | >500 and <2,370 | 0.50 | 0.25 | 0.25 | 0.05 | 41 | 34 | 21 | 6 |
| Lean-Burn | ≥2,370 | 0.30
uncontrolled
0.05
with control | >0.25 | >0.25 | >0.05 | 25
uncontrolled
4
with control | >34 | >21 | >6 |
| Rich-Burn | >100 and <500 | 0.25 | 0.30 | 0.20 | __ | 21 | 41 | 17 | __ |
| Rich-Burn | >500 | 0.20 | 0.30 | 0.20 | 76% reduction | 16 | 41 | 17 | 2.7 |
In order to comply with the new BAQ-GPA/GP-16 the owner and/or operator must comply with the above limits set forth for the spark ignition combustion engine(s) they plan to permit. Additionally, as part of the BAQ-GPA/GP-16, there are monitoring, recordkeeping and reporting requirements designed to keep the facility operating within applicable Federal and State air quality requirements. Some of these records include maintenance performed, malfunction reporting and annual facility emissions inventory (AEI) reporting. The required records must be maintained onsite or at the nearest local field office for 5 years and an annual emissions report is required to be submitted to the Department by March 1 of every year.
Prior to this BAQ-GPA/GP-16, sources seeking authorization for spark ignition engines were limited to certain exemption criteria or full Plan Approval permitting was necessary. The permit allows operators and/or owners to more easily navigate obtaining authorization for spark ignition engines at their facilities in Pennsylvania.
Permitting Fees
- Fees are as follows:
- General Plan Approval Application Fee ($2,100)
- General Operating Permit Application/Renewal Fee ($750)
- Annual Operating Permit Maintenance Fee ($500)
- Transfer of Ownership Fee ($500)
- Administrative Amendment Fee ($500)
As with other General Plan Approvals and Operating Permits, the term for this general permit is 5 years and an approved authorization can be renewed before the expiration date.
The PADEP published a notice for the proposed BAQ-GPA/GP-16 in local newspapers and the PA Bulletin. Notice was also sent to nearby states and to the United State Environmental Protection Agency for public review and comment. A comment and response document that summarizes the lone comment received was prepared by the PADEP. This document, long with the full General Permit and related documents may be obtained via the PADEP’s Greenport eLibrary here: DEP eLibrary.
If you would like to discuss this new General Plan Approval and/or General Operating Permit and how they may impact your facility or any upcoming projects you may have, please contact Trinity’s Philadelphia or Pittsburgh office.
