Compliance Reporting

NHDES receives compliance reports, emission data, emission fees and permit deviations from facilities that emit air pollutants.

a smoke stack towers over a buildingFacilities that emit air pollutants may be required to submit compliance reports based on applicable federal and state statutes and rules. If a facility has been issued a permit to operate, it will specify which reports must be submitted to NHDES to demonstrate the facility’s compliance status with the permit’s terms and conditions. In addition, the facility’s permit will require the reporting of the amount of emissions released during the calendar year and the payment of an associated annual emissions fee. In general, the more complex the facility and the more complicated the permit conditions, the more reporting the facility will have to do to meet its obligations under state and federal requirements.
                                                 
What types of air compliance reports are there and when are they due?
Each permit issued by NHDES has a Reporting Section, which lists all of the reporting obligations of the source necessary to comply with the conditions of the permit. The permit also includes a Recordkeeping Section, which lists what records are necessary to retain and include in the reports. Facilities that are required to apply for a permit, but have not done so, or that have applied, but have not yet been issued a permit by NHDES, may still be required to keep records and/or submit reports. Env-A 900 specifies the recordkeeping and reporting requirements for facilities that emit air pollutants. See the Compliance Reporting for Permitted Sources of Air Pollution fact sheet for a list of the most frequently submitted report types and when they are due.

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Did you know?

Did you know?

Reports that are required to be submitted to NHDES must be received by the due date specified in the permit or rule. The due date is not the deadline for mailing it.  

Title V Reporting

In addition to any other reports, a Title V facility is required to submit, all Title V sources must submit an Annual Compliance Certification and two Semi-Annual Permit Deviation and Monitoring Reports each year. NHDES provides recommended reporting templates for the Annual Compliance Certification and Semi-Annual Permit Deviation and Monitoring Report.   

See our Title V Operating Permit Reporting Guidance document  
looking at boilers from the sideEmission statements and data are required annually 

NHDES is authorized by RSA 125-C to collect air emissions data from permitted stationary sources of air pollution. The stationary source emissions data in conjunction with area and mobile source emissions data and ambient air monitoring data makes up NH’s air emission inventory. NHDES requires permitted facilities that emit air pollutants to submit air emissions data and applicable fees. The annual emission statement containing the emission data must be received by NHDES by April 15 and the annual emission fee must be received by May 15. 

See our guidance document on preparing a statement  

stationary source with plume from a distance

A summary of air pollutants emitted in a calendar year 

An emission statement summarizes the amount of air pollutants emitted by permitted devices at a stationary source during the calendar year. Stationary source emissions are generally calculated based on actual fuel usages or process rates multiplied by an emission factor. An emission factor is a value that relates the quantity of a pollutant released to a fuel usage or process rate. NHDES has forms to help facilities calculate their annual emissions. However, these forms are not mandatory and facilities may use their own reporting formats.  

Emission Inventory Forms  

a large tank with pipes coming out of it

Calculating an annual emission fee based on facility type, actual emissions 

The Annual Emission Fee now consists of two components, a Baseline Emission Fee and an Emission-Based Fee. Annual Emission Statements (including NOx and VOC Emission Statements) are due by April 15 following the year of record. For example, calendar year 2023 Emission Statements are due by April 15, 2024. Payment of the Annual Emission Fee must be received by NHDES no later than May 15 following the year of record. For calendar year 2023 emissions, the dollar per ton fee is $286.84. This portion of the Annual Emissions Fee must be submitted with the applicable Baseline Emission Fee.

Read the fact sheet on calculating the annual emission fee  

dark smoke is emitted from a smoke stackPermit Deviations and Control Equipment Parameter Excursions

Facilities are also required to submit reports of permit deviations to NHDES, depending on the circumstances, when they are not operating in compliance.  Sources with air pollution control equipment that operate outside of the parameters required by the permit must keep records of the occurrence and, depending on the duration, may be required to submit a parameter excursion report. If you have an air permit issued by NHDES or you are required to operate air pollution control equipment (APCE), you may be required, under conditions of malfunction or excess emissions, to submit a permit deviation or a report of a monitored APCE parameter excursion. Sources with a Title V permit are subject to more stringent reporting requirements for deviations than are sources operating under a state permit. The requirements specifying under what circumstances a facility is required to submit a permit deviation is in Env-A 911.

How and When Do I Report a Permit Deviation?
NHDES has developed a Permit Deviation guidance document to explain what conditions require a source to report a permit deviation and when to report a parameter excursion for air pollution control equipment. Permit deviations can be reported to NHDES using the permit deviation report form and submitted electronically to pdeviations@des.nh.gov.

Report Submittal
Reports, emission statements and emission fees (to the attention of Emissions Inventory) can be mailed to:
New Hampshire Department of Environmental Services
Air Resources Division – Compliance Bureau
29 Hazen Drive, P.O. Box 95
Concord, NH 03301-0095

The mailing address to send the report to EPA is:
Air Compliance Clerk
US EPA Region I
Air Technical Unit OES04-2
5 Post Office Square, Suite 100
Boston, MA 02109-3912

Some reports are required to be submitted electronically to EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be located at EPA’s Central Data Exchange (CDX).

NHDES encourages facilities to use the Compliance Report Cover Sheet with all report submissions to indicate what report or reports are being submitted. NHDES uses that cover sheet to accurately identify and quickly enter the report submissions into the NHDES database.

Air-Compliance
Senior Compliance Assessment Specialist
Air-Compliance
Inventory Section Supervisor
Air-Compliance
Field Operations Manager