Non-Title V Emission Fee Program
Submittal of emissions information is required by state law, Ohio Revised Code (ORC) 3745.11(D).
A blue, Non-Title V air fee emissions report covering years 2020 and 2021 will be sent on or around February 1, 2022. The facility owner or air permit holder is required to complete this report and submit online via the Ohio EPA Air Services application, or sign it and mail it back to the Ohio EPA by April 15, 2022.
The return address where reports should be mailed is:
OHIO EPA
DAPC - BOSS
P.O. Box 1049
Columbus, OH 43216-1049
What is this report?
The facility owner or air permit holder is required to pay a fee based on the amount of air pollution emitted by the facility annually. We only mail out this form every two years. This form allows you to self-report your facility emissions so Ohio EPA can prepare an invoice for your facility. The payment of this air pollution control is required by Ohio law. This form also allows you to report changes to facility mailing address, facility name, contact person and ownership changes. Giving us this correct information allows us to bill you or the proper owner(s) in a timely manner.
Why am I getting this report?
This report is being sent to owners or operators of all facilities which have obtained at least one air pollution permit or have a registered source by Ohio EPA. If you are unsure what things at your facility have permits or what permits have been issued to you, please call the contact listed at the top, right corner of the blue, emission report form.
What is the reporting period?
We are asking you provide pollution emissions data for one or two reporting years as indicated on form you received.
What are my responsibilities for this report?
You are required to estimate the actual emissions of sulfur dioxide (SO2), nitrogen oxides (NOx), organic compounds (OC), and particulate matter (PM) during the reporting years indicated on the form you received. Emissions should be reported in tons per year (TPY). One ton equals to 2,000 pounds. Total all pollutants to mark the appropriate choice for each year on the report. Sign the report and return it to Ohio EPA using the enclosed envelope by the due date. Make a copy for your records.
- 1. Indicate emissions (select only one option for each report year).
- 2. Update billing contact information if necessary to ensure proper billing.
- 3. Provide change of ownership information if occurred during the time frame.
- 4. Sign report.
- 5. Make a copy for your records, and mail by the due date.
- 6. Pay emission fee upon receipt of invoice.
It is not necessary to submit the calculations and other supporting documents used to calculate your facility'Â’s annual emissions with the emission report. Please be advised, however, that Ohio EPA staff may request the calculations and supporting documentation at any time.
What emissions should be included in the facility-wide total?
ORC section 3745.11(D)(1) establishes that each person who owns or operates an air contaminant source who is required to apply for a permit to operate must pay a fee based on the sum of actual emissions from the facility of the regulated pollutants particulate matter, sulfur dioxide, nitrogen oxides, organic compounds and lead based on a schedule established in the law starting at more than zero emissions and up to 100 or more tons per year of emissions from the facility. There is no lower reporting threshold in the law and the reported amounts are an aggregate amount from "the facility." Reporting is based on "the regulated pollutants," not the regulated source(s). The report format sent to Non-Title V facilities provides a simplified check-mark system. Most small operations fall in the lowest emissions level of 0-to-10 tons per year of potential emissions and so detailed calculations are not needed. According to the legislation, each operation should be evaluated and the actual emissions calculated.
However, in 2001 Ohio EPA developed an Engineering Guide 71 for Title V emissions reporting that allows companies to submit estimated actual emissions that do not include emissions from emissions units that are "de minimis" per Ohio Administrative Code (OAC) rule 3745-15-05 or have estimated actual emissions fewer than 1 ton per year. This guidance recognizes the efforts associated with calculating such emissions relative to the effect of those emissions on the overall calculated fee. Although Ohio EPA has not modified the Engineering Guide to address Non-Title V emissions units (synthetic minor Title V emissions units were addressed in 2003), it is reasonable to apply the same logic to Non-Title V emissions units.
In addition, Ohio EPA developed a list of trivial activities in conjunction with implementing the Title V permitting program. These trivial activities, identified in Engineering Guide 62, include activities such as copiers, facility maintenance equipment such as lawn mowers and welders. Again, as part of guidance in developing Title V emissions reports, such trivial activity emissions are not required to be included in submitted emissions reports. Similar to treatment of emissions from de minimis operations, consistency and logic would dictate that emissions from trivial activities do not need to be included in calculating the estimated actual emissions for Non-Title V air fee emission reporting.
Does the estimate of facility-wide emissions need to include emissions from emissions units that qualify for a permanent air permit exemption pursuant to OAC rule 3745-31-03(B)(1)?
Yes. Emissions from emissions units that qualify for a permanent air permit exemption pursuant to OAC rule 3745-31-03(B)(1) should be considered and accounted for in determining which emissions level a Non-Title V facility falls into unless the emissions from the operation or activity fall under Engineering Guide 71 as described above.
Does the estimate of facility-wide emissions need to include emissions from emissions units that are operating based on a permit-by-rule pursuant to OAC rule 3745-31-03(C)?
Yes.
Does the estimate of facility-wide emissions need to include emissions from de minimis emissions units pursuant to OAC rule 3745-15-05?
No.
Does the estimate of facility-wide emissions need to include emissions from "trivial" emissions units listed in Engineering Guide No. 62?
No.
Is it possible to use the 1.0 TPY exclusion that applies to Title V and Synthetic Minor FERs as an exclusion for the true minor FERs also?
Yes.
How do I estimate my emissions? How do I get assistance completing this report?
You can use estimates to determine your emissions. You may use emission factors, other engineering calculations or test data. A good starting point for determining your actual emissions is the permit application that was originally filed with the Ohio EPA. If you have questions and need assistance, please call the contact given for assistance. This phone number is provided for you at the top right corner of the blue emission reporting form. Have available your facility name, Ohio EPA 10-digit facility ID and phone number. (Your facility ID is provided at the upper left hand corner of the emissions report.) This information will help staff assist you more effectively.
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Fuel Burning Equipment Emission Calculator (Excel). This Excel spreadsheet quickly calculates the total emissions of particulate matter, nitrogen oxides, sulfur dioxide and organic compounds based on the type and amount of fuel burned in equipment such as boilers, heaters and stationary internal combustion engines such as diesel electric generators. This spreadsheet can be used if:
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The maximum heat input rating, in million Btu per hour, of each boiler, heater, furnace, etc. is less than 100 million Btu per hour;
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Fuels burned include only natural gas, gasoline, propane (LPG), diesel fuel, or # 2 oil.
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The spreadsheet can not be used to calculate emissions from combustion turbines or individual pieces of equipment rated in excess of 100 million Btu per hour or for other fuels. The spreadsheet calculates emissions due to fuel combustion and does not account for additional emissions, such as from a paint-curing oven, chemical reaction tank, or product dryer, etc. used to process materials which contribute other emissions.
How much will my bill be?
No payment is due at this time. The fee schedule is provided in ORC 3745.11(D) and can be obtained below. The fee increases as emissions increase. There is a fee assessed per year. Therefore, if there was a change in ownership, Ohio EPA will bill each owner separately as long as complete ownership information is provided.
What is the fee?
The amount of fee you pay depends on how many tons of air pollution your company emits per year. Every two years, Non-Title V facilities will receive a blue card which requests an estimation of the total amount emitted annually of the following pollutants: particulate matter (PM), sulfur dioxide (SO2), nitrogen oxides (NOx) and organic compounds (OC). The fee schedule is as follows:
- More than 0, but less than 10 tons per year (TPY) - $100 per year
- 10 or more, but less than 50 TPY - $200 per year
- Greater than or equal to 50 TPY but less than 100 TPY - $300 per year
- Greater than or equal to 100 TPY - $700 per year
Note: The annual fee is per facility, not per emissions unit or source.
When will I get my invoice?
An invoice will be sent to you upon confirmation of your emissions data. Do not send a check or try to pay online before you receive your invoice. The emission data provided on your report will be used by Ohio EPA to calculate a fee based on tons of pollution emitted by the facility. Fees can be paid by or check, or online via the Ohio EPA eBusiness Center.
Am I required to complete the Emission Statement?
If this facility is located in a county that has not attained the ozone standard set by U.S. EPA, the Emissions Statement information must be completed. Emissions Statements are required by the Clean Air Act section 182(a)(3)(B) for those that emit greater than or equal to 25 tons per year (TPY) of volatile organic compounds (VOCs) or nitrogen oxides (NOx) during the reporting year. To complete this requirement, give the total TPY where indicated.
I thought I already paid this fee?
Ohio EPA sends these reports and invoices every two years. Due to many factors and the decentralized review process of the reports, invoicing can take place at any time during the two-year review period.
If you have questions about the last time this fee was paid for a previous billing cycle, please contact the Office of Fiscal Administration at (614) 644-2897. Please have your check and payment information ready.
Do I have to file this report?
Submittal of emissions information and payment of emission fees is required by state law ORC 3745.11(D). Failure to pay the invoice within 30 days of the invoice date will result in assessment of a 10 percent late penalty. Failure to pay the invoice will result in collections actions by the Collections Enforcement Section of the State of Ohio Attorney General.
How can I find out what my regulated sources are?
You can get information on your regulated air contaminant sources by contacting the appropriate District Office or Local Air Agency where your facility is located.
How can I get copies of issued air permits/registrations for this facility?
You can get copies of issued permits/registrations and/or information on the status of permit applications that you've applied for by contacting the appropriate District Office or Local Air Agency where your facility is located.
All stages of issued permits are available on our Issued Air Permits search page.
Additional Important Changes for Non-Title V facilities
Once you have completed the Non-Title V report requirement, you may want to review information listed below to see if your facility will be impacted. Please visit the web sites listed for additional information and instructions.
Changes to Reporting Categories/Fee Increase
Beginning Jan. 1, 2004, Ohio EPA implemented an increase to the annual air emission fees for Non-Title V facilities. These changes are reflected in ORC 3745.11(D)(2) and became effective July 1, 2003. Ohio EPA has not increased its fees since inception of the fee reporting program. A copy of the fee schedule can be obtained from our web site below.
Facility Exemptions
Effective July 2005, Ohio EPA adopted a permit exemption option for low-emitting types of facilities, called Permit by Rule (PBR). Not all sources are eligible. For a copy of the fact sheet and application information, please visitor call the contact given at the top right corner of the blue report form.
Office of Compliance Assistance and Pollution Prevention
If your company is independently owned, and has fewer than 100 employees, the Ohio EPA's Office of Compliance Assistance and Pollution Prevention (OCAPP) at (800) 329-7518 or (614) 644-3469 is also available to provide free and confidential assistance.