This article summarizes some of the first quarter 2026 environmental reporting requirements for facilities located in Wisconsin. While not all of these reports may be applicable to every facility – and there may be other environmental reports that are not listed here – environmental professionals should be aware of the reporting requirements and the potential applicability for the facility (or facilities) they are responsible for.
Wisconsin and Federal Reporting Timeline
With all of the environmental reports that are required, it can be difficult to keep track of what report is due and when. The list below provides some of the common environmental reports and their due dates:
- Air Permit Annual Compliance Certification – March 1
- Note that certain permits – especially older ones – may have different due dates such as January 30 or February 14
- Air Permit Semiannual Monitoring and Deviation Report – March 1
- Note that certain permits – especially older ones – may have different due dates such as January 30 or February 14
- Annual Air Emission Inventory – March 1
- Note that an extension to March 15 may be requested and granted by WDNR
- Also note that certification of the report is not due when submitted, but rather by June 30
- Annual Hazardous Waste Report – March 1
- Tier II Chemical Inventory Report – March 1
While the list above provides common environmental reports due in the first quarter, the list is not fully comprehensive. There may be other reports that are required for a given facility, such as those required by certain rules and/or permits.
Specific Environmental Reports – Things to Know
Below are some things to know about these specific environmental reports as well as some tips for successful reporting in the first quarter of the year.
Air Permit Annual Compliance Certification
This report is an annual certification of compliance against all the terms and conditions listed in your air permit and covers the previous reporting year. While information related to each permit condition does not need to be submitted, documentation of the compliance status for each condition should be maintained. Additionally, any permit deviations previously reported should be included in the report as well. Also, do not forget to review the general requirements in Part II of the permit.
Air Permit Semiannual Monitoring and Deviation Report
This report requires that a summary of monitoring – which may include things like testing and inspections – as well as a report of the deviations that occurred during the reporting period. For facilities with Title V permits, this report must be submitted semiannually. For facilities with non-Title V permits (including ROPA, ROPB, and general permits), this report is submitted annually in conjunction with the Annual Compliance Certification. Also, with the updates to NR 439 that became effective on July 1, 2025, this may be the first time certain deviations that don’t result in the exceedance of an emission limit need to be reported. And as with the Annual Compliance Certification, do not forget to review the general requirements in Part II of the permit.
Annual Air Emission Inventory
This report provides air emissions information from the facility for the previous calendar year. In general, facilities with actual emissions above pollutant-specific thresholds listed in NR 438 are required to report. Even with emissions below these thresholds, certain facilities are required to report or submit an Under Threshold Notification (UTN). Additionally, WDNR has made some updates to the reporting system, called Air Reporting System (ARS), for this year’s report. Refer to the WDNR website for more information.
Annual Hazardous Waste Report
This report is an annual report for facilities in Wisconsin that are either a Large Quantity Generator (LQG) or Small Quantity Generator (SQG) for any single month of the reporting year. This is different from many other states where only LQGs need to report and reports may not be annual. Additionally, starting with reporting year 2025, reporting for facilities in Wisconsin is no longer done in WDNR’s Switchboard, but rather is done through RCRAInfo. As RY2025 is the first year that RCRAInfo reporting is required, both the preparer and responsible official (RO) will need to have RCRAInfo logins, as well as Login.gov logins to access the United States Environmental Protection Agency (USEPA) Central Data Exchange (CDX) system that houses RCRAInfo. RCRAInfo reporting requires that the RO sign and submit an Electronic Signature Agreement (ESA), which can be done online, or via paper forms if the identification of the RO cannot be verified. Paper processing of the ESA can take up to two weeks, so facilities are encouraged to set up the account and ESA as soon as practicable.
Tier II Chemical Inventory Report
This report is required for facilities that store hazardous substances above certain thresholds. The report identifies the hazardous substances including where they are stored and the specific hazardous. The report is submitted to the State Emergency Response Commission, Local Emergency Response Commission, and local fire department. In Wisconsin, the submittal to all of these entities is done via the Wisconsin Hazmat Online Planning and Reporting System (WHOPRS) system.
Conclusion
With a significant number of environmental reports due in the first quarter of the year, it can be challenging to keep them all straight and stay organized. Starting early and documenting the source of data and information can help make your reporting season go smoothly. Trinity also has significant experience in assisting clients with a wide variety of environmental reports. Contact Trinity’s Wisconsin Office to discuss how Trinity can assist with environmental reporting for your facility.
