The AERR Proposed Rule: What You Need to KnowThe AERR proposed rule aims to tighten reporting requirements for businesses concerning their emissions of Hazardous Air Pollutants (HAPs). While the rule might seem complex, its essence can be understood quite simply. The EPA is looking to mandate that businesses, with a few possible exceptions, report each individual HAP emission that surpasses a specific threshold unique to that particular HAP. To illustrate this, let’s consider a couple of examples. For a substance like styrene, businesses would need to report any emissions exceeding 10 tons per year. On the other hand, substances like Chromium (VI) and Chromium Trioxide have a much lower reporting threshold – only emissions surpassing 0.24 lbs per year would need to be reported.
Varied Reporting Thresholds and ImpactsFor common HAPs like toluene, the reporting threshold might align closely with that of styrene – meaning that emissions need to be substantial before reporting is required. However, this is not the case across the board. The disparity between reporting levels for substances like styrene and chromium highlights a significant aspect of the rule – certain businesses might now need to report emissions at extremely low levels. This represents a major shift for some small businesses that have never encountered such stringent requirements.
Challenges for Small BusinessesThe implications for small businesses could be considerable. Many small businesses may find themselves in the position of having to report emissions for the first time. This could be due to the fact that their emission levels, which were previously considered negligible, now require reporting. This shift poses potential challenges, as some of these businesses might not have the necessary recordkeeping systems in place to facilitate the reporting process. It’s important to note that, in many cases, permits for these businesses might already require a certain level of recordkeeping, especially if they are subject to National Emission Standards for Hazardous Air Pollutants (NESHAP). However, the enhanced reporting requirements of the AERR rule could demand a higher level of precision and documentation than what these businesses are accustomed to.
Navigating the Way ForwardThankfully, the EPA is aware of the complexities these changes might introduce, especially for small businesses. In response, they are offering support through a series of webinars designed to provide businesses with a clear understanding of the AERR proposal and its potential impacts. These webinars could prove invaluable for small business owners seeking clarity on the new reporting requirements and how best to adapt to them.
In SummaryThe AERR proposed rule might appear complex and distant, but its potential impact on small businesses should not be underestimated. As reporting thresholds for Hazardous Air Pollutant emissions tighten, businesses – both large and small – need to be prepared for the changes ahead. The EPA’s efforts to provide resources through webinars is a step in the right direction, offering businesses the guidance they need to navigate the shifting regulatory landscape. Small businesses should take advantage of these resources to ensure that they can adapt effectively to the new reporting requirements and continue to thrive in a compliant manner. To find out more about the AERR proposal and the upcoming webinars, visit the official EPA website: https://www.epa.gov/air-emissions-inventories/air-emissions-reporting-requirements-aerr.
Comments on this proposed rule must be received on or before October 18, 2023.