The Northern Nevada Public Health Air Quality Management District (NNPH AQMD) has announced updates to the District Board of Health Regulations Governing Air Quality (AQMR), specifically Section 030.00 – Source Permitting. These updates aim to incorporate best practices for air quality source permitting developed over the last 20-30 years. The revisions seek to enhance the delineation between air programs, provide a clearer and more transparent structure for air permitting, and address outdated or inaccurate regulations.
Major Changes to AQMR Section 030 – Source Permitting
- Minimum Permitting Thresholds– AQMD is proposing to increase the minimum threshold for permitting from 0.365 tons per year (2 lb/day) to 5 tpy, reflecting current state thresholds. NNPH research has not identified contributing impacts to the districts’ air quality caused by sources under 5 tpy and is therefore increasing the threshold.
- Permit Renewal Timeframe: AQMD is proposing to increase the timeframe for permit renewals from annually to every 5 years. Currently permits are reprinted annually but are not seriously reviewed by AQMD. AQMD is proposing to switch the annual renewal process for a thorough permit renewal process that undergoes more serious review every 5 years.
- Exemptions: AQMD is proposing to clarify and provide a transparent, longer list of examples of activities that may be considered insignificant.
- Best System of Control: AQMD is proposing to clearly define when projects require additional air pollution controls.
- Structure: AQMD is proposing to separate and more clearly lay out different permitting programs into different parts of Section 030 as seen below:
Chapter 030 Source Permitting (Proposed Revision) Structure
| Part 030.000 – General Provisions | Part 030.100 – General Permitting | Part 030.200 – Minor Sources | Part 030.300 – Nonattainment New Source Review | Part 030.400 – Prevention of Significant Deterioration | Part 030.500 – Part 70 |
| Provides general guidance on the air quality permitting program. | Establishes requirements for the permitting of general sources. | Establishes requirements for the permitting of minor sources. | Establishes requirements for the permitting of major stationary sources in nonattainment areas. | Establishes requirements for the permitting of major stationary sources in attainment areas. | Establishes requirements for the permitting of major sources. |
- General Permitting: AQMD is proposing to update and correct definitions listed in Section 030.
- Definitions: AQMD is proposing to update Part 030.100 to allow for the issuance of general permits for similar sources (ex: dry cleaners, gas stations, etc. that have similar emissions from one source to another).
- Fee Structure: AQMR is proposing to update the Source Permitting Fees listed in Section 030 as seen below. This includes:
- Creating a General Permit and Portable Equipment application fee for the similar sources discussed above;
- Updating Minor Sources Annual Emissions Fees to tiered categories defined by Maximum Allowable Emissions. Currently, annual emissions fees are per pound of actual emissions and the proposal changes the structure to be based on flat fees in relation to tpy of allowable emissions.
- Similarly, Updating Annual Emissions Fee for Air Toxics to be based on Allowable Emission greater rather than per pound of actual emissions.
- Adding an Annual Maintenance Fee for General Permits.
Proposed Fee Schedule
| Description | Proposed FY24-25 Fee Effective 7/1/2024 | Proposed FY24-25 Fee Effective 1/1/2025 |
| Application – General Permit | | $500.00 |
| Application – Portable Move Notification (Per Emission Unit) | | $100.00 |
| Annual Emissions Reporting | | |
| Annual Maintenance Fee – Minor Source (PTC/PTO) | $696.00 | $696.00 |
| Annual Emission Fee – Minor Source (Per Pound) | $24.00 | |
| Annual Emission Fee – Minor Source (Allowable Emissions < 20 tpy) | | $250.00 |
| Annual Emission Fee – Minor Source (Allowable Emissions ≥ 20 and < 40 tpy) | | $500.00 |
| Annual Emission Fee – Minor Source (Allowable Emissions ≥ 40 and < 60 tpy) | | $1,000.00 |
| Annual Emission Fee – Minor Source (Allowable Emissions ≥ 60 and < 80 tpy) | | $2,000.00 |
| Annual Emission Fee – Minor Source (Allowable Emissions ≥ 80 and < 100 tpy) | | $4,000.00 |
| Annual Maintenance Fee – Major Source (PTC/PTO) | $12,344.00 | $12,344.00 |
| Annual Emission Fee – Major Source | $10,401.00 | $10,401.00 |
| Annual Maintenance Fee – Air Toxics Source | $208.00 | $208.00 |
| Annual Emission Fee – Air Toxics Source (Per Pound) | $11.00 | $11.00 |
| Annual Emission Fee – Air Toxics Source (Allowable ≥ 1 tpy) | | $2,000.00 |
| Annual Maintenance Fee – General Permit | | $250.00 |
| Annual Equipment Fee – Gasoline Dispensing Source (Per Nozzle) | $95.00 | $95.00 |
| Air Quality Permit to Operate Late Fee (% of Total Fee Due) | 25% | 25% |
Changes to AQMR Section 030 – Timeline:
As seen below, the timeline for the revisions includes a 30-day public comment period, a presentation of the Business Impact Statement to the District Board of Health, and a Public Hearing and Rule Adoption presentation to the District Board of Health by September 26, 2024. The Implementation date for the proposed revisions to Section 030 will be January 1, 2025.
Chapter 030 Source Permitting (Proposed Revision) Timeline
| July 8, 2024 | August 8, 2024 | August 22, 2024 | September 26, 2024 |
| Start of the 30-Day Public Comment Period and Public Workshop. | Close of 30-Day Public Comment Period and Public Workshop. | Business Impact Statement presented to District Board of Health. | Public Hearing and Rule Adoption presented to District Board of Health. |
*Implementation date for the proposed revisions will be January 1, 2025
Impact on Stationary Sources: With the updated fee schedule, stationary sources (especially minor sources) may want to re-evaluate annual emissions costs based on tons of allowable emissions. The updates will also allow all sources under 5 tpy to operate without an air quality permit. The updates propose to extend the allowable time for permit renewal to 5 years which will decrease annual permit renewal requirements. Sources may also look for a more comprehensive list of insignificant activities.
The complete updated regulations can be found at the Washoe County DAQ Website.
If you have questions regarding the updates to AQMR Section 030 and how they may affect your facility, please reach out to Trinity’s Reno office or call 775.242.3200.
