New Source Review Fees, the Cost of Getting Permitted
New Source Review, or NSR, fees are the charges most operators recognize. Under Utah Code 19-2-108, UDAQ collects them for the work it performs reviewing a permit application, and they are paid in advance before the review begins.
Each NSR fee includes a set number of base review hours, which is UDAQ’s estimate of the engineering time a typical application of that type should take. A minor source permit, for example, includes up to 20 hours of review in its prepaid fee, while larger major source projects include several hundred base hours. As long as the review fits within those base hours, the prepaid fee is all you pay.
If the review runs longer than the base hours, UDAQ bills the additional time at $125 per hour. Reviews tend to exceed the base hours when an application is complex or incomplete. Common drivers include extensive air dispersion modeling, complicated or unclear control technology or BACT analysis, difficult applicability determinations, and applications that require several additional rounds of review because information was missing or unclear. A complete and well-supported application is the best way to keep the review inside the base hours and avoid the extra charges.
Annual NSR Fees, a Newer Yearly Charge
The Annual NSR Fee is a more recent addition that sometimes catches clients by surprise. In 2020, the Utah Legislature authorized UDAQ to charge an annual fee to every source that holds an NSR Approval Order (AO), the air quality permit issued at the end of the New Source Review process. The authorization came through the state budget bill that session and has been carried forward each year since. Unlike the application fees above, this is a recurring yearly charge for as long as you hold the permit.
The amount is based on your facility’s total potential to emit, adding together the potential emissions of nitrogen oxides, sulfur dioxide, particulate matter, carbon monoxide, and volatile organic compounds. The combined total places the source into one of the following fee tiers.
| Total Source Emissions (tpy) | Annual Fee |
| Less than 20 | $200 |
| 20 to 49 | $400 |
| 50 to 99 | $800 |
| 100 to 250 | $2,000 |
| 250 and above | $3,000 |
Annual Emission Fees for Title V Sources
Operators in the Title V Operating Permit Program pay a separate annual emission fee. In Utah, this fee is set under Utah Code 19-2-109.1, and the current statutory framework for it was established through H.B. 344, passed during the 2024 General Session. H.B. 344 governs how the fee applies across Title V sources and regulated pollutants, ties it to actual emissions, and caps the chargeable amount at 4,000 tons per year for any single pollutant. You can check whether the program applies to your business on the UDAQ Operating Permit Program fact sheet.
The fee is charged per ton of pollutants emitted to the air, and it pays for the administrative cost of running the Operating Permit Program. A helpful point for budgeting is that there is no separate charge to issue the operating permit itself. That cost is folded into the annual emission fee. The rate is adjusted each year. For the fiscal year that runs from July 2025 through June 2026, the rate is $134.72 per ton of emissions. Because the fee scales directly with emissions, accurate emission inventories matter both for compliance and for managing what you owe.
Aggregate Compliance Fees, a Less Common Charge Worth Knowing
The Aggregate Compliance Fee is one that many clients have never encountered, because it applies only to a specific kind of operation. It is an annual fee that UDAQ collects to recover the cost of overseeing emissions from rock crushing, material handling, and aggregate operations. If your facility runs a crushing or aggregate process under an AO, this fee likely applies to you. The amount is set by the permitted annual emissions listed on each AO, measured in tons per year as shown in the table below:
| Total Source Emissions (tpy) | Annual Fee |
| Less than 20 | $207 |
| 20 to 79 | $414 |
| 80 to 99 | $1,035 |
| 100 and above | $1,449 |
The fee is assessed for each AO, so a company running several permitted aggregate operations could see this charge on more than one permit. If you are not sure whether your operation falls into this category, it is worth confirming, because the fee is easy to overlook until the invoice arrives.
Permit By Rule Registrations for Oil and Gas
Utah gives oil and gas operators a streamlined alternative to full New Source Review. Qualifying equipment on lands under state jurisdiction can be covered through a single registration under the state Permit By Rule program, set out in Rule R307-505 and often shortened to PBR. Rather than preparing a full application, an operator registers the equipment one time against a standardized set of requirements.
The registration fee depends on whether the equipment requires emission controls. A registration for uncontrolled equipment is $1,000, and a registration for controlled equipment is $2,000. Because it is a one-time registration rather than a recurring charge, it is one of the easier items on the schedule to plan for.
Temporary Relocation Authorizations
The last item is the Temporary Relocation fee. Oil and gas and other portable sources that need to move equipment to a new location within Utah can apply for a Temporary Relocation Authorization. UDAQ charges a flat processing fee of $875 for each authorization it grants, a rate set by the Utah State Legislature.
If your equipment also generates fugitive dust and will operate in a particulate matter nonattainment or maintenance area, keep in mind that a separate Fugitive Dust Control Plan may be required as part of the relocation. Planning both pieces together helps avoid delays when you are ready to move.
How Trinity Can Help
Air quality fees are rarely the hardest part of a project, but they add up, and an unexpected charge can complicate a budget or a schedule. Trinity Consultants helps clients across Utah understand which fees apply to their facilities, confirm the right fee tiers, and plan for both the upfront and recurring costs of staying permitted and compliant. Since several of these fees scale directly with emissions, getting the numbers right matters. Our team has deep experience formulating and submitting accurate emission inventories for a wide range of industries, from oil and gas and refining to manufacturing and aggregate operations, which means the emissions that drive your fees are calculated correctly the first time.
If you have received a fee from UDAQ that you do not recognize, or you simply want to forecast your air quality costs before your next project, our team can walk you through it. To talk through your specific situation, reach out to our Trinity Consultants Salt Lake City office and we will be glad to help.
