On January 29, 2026, the City of Philadelphia’s Air Management System (AMS) released its proposed amendments to Air Management Regulation XI (Reg XI), which outlines the requirements for incinerators located in Philadelphia County, Pennsylvania. Regulation XI was last amended on February 4, 1991. The 2026 proposed amendments to Reg XI include the following:
- Clearly defining “new” and “existing” incinerators;
- Updating visible emission standards for new incinerators;
- Removal of emission standards/limitations for HCL and SO2;
- Addition of fuel restrictions for incinerator burners;
- Outlines design, operational, and maintenance requirements for Type 4 crematory furnaces;
- Restructures and clarifies the construction and operating section of Reg XI; and
- Minor administrative/clerical updates.
In this amended version of Reg XI, “new” incinerators are defined as any incinerator installed after January 29, 2026, or an existing incinerator operating without a permit. “Existing” incinerators are defined as incinerators that have an installation permit or operating permit before January 29, 2026. New incinerators are subject to the new Reg XI visible emission standard, which is listed below.
visible emissions shall not exceed, except uncombined water, for a period of more than thirty (30) consecutive seconds in any one hour or an aggregate of more than three (3) minutes in any calendar day which is equal to or greater than five (5) percent opacity.
Existing incinerators will remain subject to the current Reg XI emissions standard for incinerators.
In addition to the visible emission updates detailed above, there were also updates to some of the pollutant emission limits in the amended Reg XI. The most notable change regarding pollutant emission limits in the new amended version of Reg XI is that there are no longer emission standards/limitations for SO2 or HCL. There were also updates to the operational requirements section of the regulation limiting burner combustion to the following fuels, natural gas, propane, no. fuel oil, or lighter fuels.
The most extensive change of the amendment was the updating, defining, and clarification of requirements for crematory incinerators that exclusively burn Type 4 waste. The updated Reg XI defines the design requirements of these incinerators. Under the proposed Reg XI, crematory incinerators are required to have a burner that operates at least 1600 degrees Fahrenheit, have continuous monitoring, and to be designed so that there is appropriate access to the stack for stack testing. Finally, the amended Reg XI provides a list of materials that can and materials that cannot be incinerated in crematory incinerators.
The final major update to the rule was the restructuring of the construction and operating permit section of the regulation. This amended section clearly outlines the required permits for new and existing incinerators, as well as the specific requirements for each permit. Under the proposed Reg XI, new incinerators are required to submit a construction permit, and modifications to existing incinerators are required to be authorized by an installation permit. The regulation also requires that all existing incinerators have an operating permit. New incinerators have 60 days after conformance by the Department to submit an operating permit application.
The City of Philadelphia is having a Public Hearing for ” Proposed amendments to Air Management Regulation XI – Control of Emissions from Incinerators” on April 28, 2026, 6:00PM – 8:00 PM. During this meeting, the public will have the opportunity to provide testimony. This meeting can be attended by clicking the following link here.
If you would like to discuss the new Reg XI amendments and how they may impact your facility, please contact Trinity’s Philadelphia office or call 610.280.3902.
