Major facilities permitted under Title V of the 1990 Clean Air Act (CAA) Amendment (42 U.S.C. 7401) are required to submit annual compliance certifications (40 CFR § 70.4) detailing efforts to maintain facility compliance with the CAA to the US Environmental Protection Agency (EPA) and state regulators. The District Department of Energy and Environment (DOEE), the regulatory authority over air quality programs in the District of Columbia, reviews annual compliance certifications for Title V facilities.
As part of the annual certification process, Title V facilities are required to calculate emissions generated by facility equipment. DOEE charges emission fees in accordance with 40 CFR § 70.9(b)(2) and 20 DCMR 305 (updated June 5, 2020) and sends invoices for those fees to the responsible officials on-file for each operating Title V facility. Facilities that do not send DOEE emission calculations will be charged by the total tonnage calculated in their potential to emit.
Questions regarding compliance and reporting for Title V facilities can be sent to [email protected]. Please reference Title V emissions invoice in the subject line.
Title V Emissions Fee Billing
As of June 2020, DOEE has updated its emission fee billing structure for Title V facilities. Per 20 DCMR § 305.6, emission fees will be updated annually based on the Consumer Price Index (CPI) over the most recent contiguous 12 month period from September through August. The emission fee schedule for CY2020 is as follows:
Fee Schedule for CY2020
Total actual emissions less than 10 tons per year
Total actual emissions equal to or greater than 10 tons per year, but less than 25 tons per year
Total actual emissions equal to or greater than 25 tons per year, but less than 100 tons per year
Total actual emissions equal to or greater than 100 tons per year
DOEE calculates the annual CPI using the Bureau of Labor Statistics’ monthly CPI-U “for all items.” The CPI calculated for CY 2020 (September 2019 through August 2020) is 257.959.
Questions regarding emissions fee billing can be sent to [email protected].
Title V Reporting
District and federal regulations require Title V major source facilities to submit compliance reports and notifications, and testing results to DOEE and to EPA.
As DOEE is moving towards going paperless, DOEE will be implementing electronic reporting through EPA's Compliance and Emissions Data Reporting Interface (CEDRI) and Combined Air Emissions Reporting System (CAERS), both housed in EPA's Central Data Exchange (CDX).
Combined Air Emission Reporting System (CAERS)
Beginning for reporting year 2020, DOEE began implementation of EPA’s Combined Emissions Air Reporting System (CAERS) for annual reporting of emissions for Title V facilities. This tool will improve data quality, accessibility, and usability of air emissions data and reduce industry burden for point source reporting. For more background information on the CAERS project, see EPA’s website.
CAERS was first implemented by Georgia Department of Natural Resources in 2020 for CY2019. DOEE will become one of the first jurisdictions to move onto this new platform, which is still undergoing development and testing, and therefore will require some flexibility in onboarding to the system for CY2020.
DOEE is excited to move towards online reporting as our preferred method of submittal for annual emissions, while offering facilities a more streamlined method for reporting going forward.
Facilities should note that submittal of emissions through CAERS is not intended to be a substitute for Annual Compliance Certification reports, which are due to DOEE annually on March 1st for all Title V facilities in the District. Submittal through CAERS will only be used to replace hard copy submittal of annual emissions to DOEE, which are typically included as an attachment to Annual Compliance Certification reports.
- Read the memorandum sent to major facilities regarding CAERS in February 2021.
Compliance and Emissions Data Reporting Interface (CEDRI)
CEDRI supports the submittal of reports, notifications, and applications under the District's Title V program with certification by a responsible official. DOEE encourages all Title V facilities to submit electronic reports via CEDRI beginning with semi-annual compliance reports due on September 1, 2021.