Synthetic Minor Title V Facility Fee Emission Reporting Program
April 15, 2012 is the SMTV report deadline for calendar year 2011. Companies will be required to file electronically using Air Services. To learn more about Air Services please visit the Air Services web site. For information on how to gain Access to Air Services please read Air Services Transition Guide (PDF)
What is the Synthetic Minor Title V Emissions Fee Program?
In 1999, the State legislature passed a revision to the fee schedule for facilities that are required to apply for and obtain air pollution control operating permits. This change in Ohio law effects facilities that are considered a synthetic minor Title V facility. All facilities permitted in Ohio that are considered a SMTV facility are required by Ohio Revised Code (ORC) Section, to report annual actual emissions of particulate matter (PM), sulfur dioxide (SO2), nitrogen dioxide (NOx), organic compounds (OC) , and lead (Pb). Also pursuant to ORC Section 3745.11, facilities that have obtained synthetic minor status to avoid Title V permitting must pay an annual SMTV fee based upon the reported annual actual emissions. The fee is required by ORC Section 3745.11 was implemented for the first time in the year 2000 for calendar year 1999 emissions.
All SMTV facilities will receive a letter in January 2012 to complete reporting via Air Services for calendar year 2011 emissions. The completed emissions report is due (April 16th, 2012). The completed report form will be reviewed by Ohio EPA district office or a local air agency staff after which an invoice will be mailed to the facility. Payment is due 30 days after the invoice is received.
What is a Synthetic Minor Title V Facility?
Facilities for which one or more permits to install or permits to operate have been issued for the air contaminant sources at the facility that include terms and conditions that lower the facility's potential to emit air contaminants below the major source thresholds for Title V facilities described in Ohio Administrative Code (OAC) 3745-77-02. Basically, if your facility has been issued a federally enforceable state operation permit (FESOP) or a synthetic minor PTI in order to opt out of the Title V permitting requirements, your facility is required to report and pay for actual annual emissions in accordance with the SMTV emissions fee program.
Emissions Statement Requirement
In Ohio counties for the 2011 reporting year there are none designated as non-attainment for the 8-hour ozone National Ambient Air Quality Standard. (see listing of counties on the Emissions Statement Web Site). For facilities located in these counties, Emissions Statements are required by the Clean Air Act section 182(a)(3)(B) for those that emit greater than or equal to 25 TPY of volatile organic compounds (VOC) or nitrogen oxides (NOx) during the reporting year. Ohio Administrative Code (OAC) Chapter 3745-24 addresses Emissions Statements. This requirement is for all facilities whether they are subject to Title V permitting (OAC 3745-77) or state permitting (OAC 3745-35). In general, facilities subject to this requirement must submit actual emissions for NOx and VOC. Your can easily submit the Emissions Statement concurrently with the SMTV FER Air Services.
Will my facility have to continue submitting an Emissions Statement each year?
The requirement to file an emissions statement is based on actual emissions of VOC or NOx each reporting year. For example, in 2006 a facility may have emitted 28 TPY of VOC or NOx and is required to submit an Emissions Statement. However in 2007, if the facility emits less than 25 TPY of either VOC or NOx they would not be required to submit an emissions statement for that year.
What is the fee?
The amount assessed by Ohio EPA for your operations depends on how many tons of air pollution your company emits per year. Ohio EPA determines this based on your completed fee emission report . Air Services form requests emissions calculations data and summary totals of annual emissions of the following pollutants: particulate matter, sulfur dioxide, nitrogen dioxide, organic compounds, and lead. The fee schedule is as follows:
Combined total ton per year of all regulated pollutants emitted Annual fee per facility
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LESS THAN 10
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$170
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10 OR MORE, BUT LESS THAN 20
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$340
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20 OR MORE, BUT LESS THAN 30
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$670
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30 OR MORE, BUT LESS THAN 40
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$1,010
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40 OR MORE, BUT LESS THAN 50
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$1,340
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50 OR MORE, BUT LESS THAN 60
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$1,680
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60 OR MORE, BUT LESS THAN 70
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$2,010
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70 OR MORE, BUT LESS THAN 80
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$2,350
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80 OR MORE, BUT LESS THAN 90
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$2,680
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90 OR MORE, BUT LESS THAN 100
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$3,020
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100 OR MORE
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$3,350
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When are the fee emissions report and payment due?
OAC Rule 3745-78-02 provides the manner and time frame to report these emissions. Calendar year 2011 reports are due April 15th, 2012. Once we receive the reported emissions, the information goes through a review/verification process. Invoices will generally be issued 30 days after we received your complete fee emissions report. The invoice will have a detachable stub which must be sent in with the payment to insure proper crediting. Ohio EPA does not have the ability to accept credit card payments at this time. Your payment, accompanied with the detached stub, should be mailed to:
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Ohio EPA
Dept. L-2711
Columbus, OH 43260-2711
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What is the Fee used for?
The Ohio EPA will use the fees for air pollution monitoring, inspections, permit processing and issuance and for providing technical assistance to the regulated community. These fees will be directed to the local air agencies and district offices. None of the SMTV facility fees are expected to be directed to Ohio EPA's Central Office air pollution control activities.
How can I determine my emissions?
You may use emission factors, engineering calculations or test data to determine your emissions.
Use the Most Accurate Methods for Emissions Calculations
Emissions calculations for FER purposes must use the most accurate method available for each reporting period. For example, if your facility has used AP-42 emission factors in the past and a more accurate emissions factor is developed, or emissions testing has been conducted which gives your facility a more accurate emissions factor, the updated or test-based factor should be used.
Report Submission Options:
Ohio EPA no longer accepts hard copy report forms.
Any hard copy reports received will be returned to the company. You are required to file via Air Services.
If you have any questions about this program or would like further information, please contact the Synthetic Minor Title V Facilities Fee Group at (614) 644-3621 or e-mail Elisa Thomas.
Additional Resources:
DO/LAA - Contact your district office or local air agency to obtain additional facility-specific information or copies of your permit(s). If you need to determine which district office or local air agency has jurisdiction with your company/organization, the information can be found at: http://www.epa.state.oh.us/dapc/general/dolaa.aspx
www.epa.ohio.gov/dapc/regs/regs.aspx - to obtain a copy of OAC Chapter 3745-31 (Permit to Install), OAC Chapter 3745-35 (State Permit to Operate), or OAC Chapter 3745-77 (Title V Permit to Operate), or OAC Chapter 3745-78 (Permit to Operate Fees)..