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Policy DAR-11: Electronic Reporting for Air Facilities

Department ID: DAR-11
Title: Electronic Reporting for Air Facilities
Issuing Authority: David J. Shaw, Director, Division of Air Resources
Originating Unit: Bureau of Stationary Sources
Signature: David J. Shaw
Date: 27 July 2010
Phone: (518) 402-8403
Issuance Date: 19 August 2009

Printable version (PDF) (38kb, 3 pgs)
Attachment #1 Application Form for the Department's Electronic Reporting System (PDF) (154 kb, 10 pgs)
Attachment #2 Format for the paper submission of Annual Certifications for Title V Facilities (PDF) (199 kb, 5 pgs)

I. Summary

This policy establishes the methods and procedures to be used by the owners and/or operators of facilities when submitting reports, certifications, emissions statements or other items required in their air permits. This information may be submitted either electronically or on paper, in a format specified by the Department. Electronic data may be submitted in a spreadsheet format or by direct entry through a dedicated electronic reporting Department web site.

II. Policy

Items required to be submitted on an annual basis (such as annual compliance certifications or emission statements for Title V permitted facilities) shall be submitted in one of the following formats:

  1. Electronic spreadsheet;
  2. Direct data entry through a Department web site; or
  3. On paper, using the format specified by the Department.

To submit data through the electronic reporting website, the responsible official (as defined below) must apply to access the electronic reporting website. The application (Attachment #1) will identify the responsible official who has the authority to sign the item (i.e., annual compliance certifications or emission statements) and other individuals who may enter, update or review the data (but cannot sign the item). Separate user IDs and passwords will be given to those individuals identified as the responsible official, reporting editors or reporting reviewers.

Facility owners may opt to continue to submit their required items on paper. The format to be used for the annual compliance certifications is included in this policy (Attachment #2). The format for the paper submittal of the annual emission statements will remain the same. When paper forms are submitted, the data will be entered into the air facility system database by personnel from the appropriate NYSDEC regional office or bureau.

III. Purpose and Background

Owners and/or operators of facilities with an air permit must meet various reporting requirements. The information that must be submitted is specified in the permit. The purpose of this policy is to reduce the amount of paper generated by multiple submittals for the following documents:

Annual Compliance Certifications

Facility owners and/or operators with Title V permits must submit an annual compliance certification, as required under 6 NYCRR 201-6.5(e). The reason for this certification is to verify the compliance status of each condition in the Title V permit. A copy of this certification is sent to the NYSDEC Regional Office where the permit was issued, the NYSDEC Central Office and the USEPA Region II Office.

Under this policy, the facility owner may make one electronic compliance certification submission in place of the three paper submissions sent to the parties cited above. The electronic submission methods provide for control of data quality by direct entry and validation of the certification data. Implementation of this policy will reduce the data entry burden by pre-filling appropriate data fields with data from prior submissions.

Emission Statements

Facility owners and/or operators with Title V permits must submit an annual emission inventory statement, as required by 6 NYCRR 202. The intent of this reporting requirement is to document the actual annual emissions from the facility. The information from the statement is used to determine the fee the Title V facility owner/operator will pay for the facility's emissions. This information is also submitted to the U.S. EPA as part of the National Emissions Inventory.

Other Required Reports

Facility owners with air permits are sometimes required to submit other types of reports. These can include semi-annual monitoring reports and capping certifications. These types of reports may also be submitted electronically.

IV. Responsibility

The Bureau of Stationary Sources' Enforcement Section shall have primary responsibility for ensuring that this policy remains up-to-date for facilities submitting annual compliance certifications and semi-annual monitoring reports. They will also provide any additional interpretation of this policy that may be needed for compliance purposes. Staff from both this Section and Air Resources staff in the DEC Regional Offices are responsible for ensuring that the Title V permit holders follow these policies and procedures. The Bureau of Air Quality Planning's Stationary Source Planning Section shall have primary responsibility for ensuring that this policy remains up-to-date for facilities submitting emission statements. The staff from this section will be responsible for ensuring that the Title V permit holders follow these policies and procedures. The Bureau of Quality Assurance (BQA) will mail application forms and information packages to the facility representatives. Additionally, staff from the BQA will coordinate distribution of the user IDs and passwords to the people submitting the certifications electronically.

V. Procedure

An information package regarding the electronic reporting program will be sent to the responsible parties of Title V facilities by the BQA. The package will contain an application form to be completed by the responsible parties. On this form, the responsible parties will indicate the type of format they will use (i.e., spreadsheet, data entry or paper), who will be authorized to enter and edit data, and will identify the responsible official who will sign the item as required (eg, for an annual compliance certification or emission statement).

The roles of different facility personnel involved with the various submittals are defined as follows:

  • Responsible Official: Responsible Official is defined by paragraph 6 NYCRR 201-2(b)(28) as "A president, vice president, secretary, treasurer, general partner, proprietor, principal executive officer, ranking elected official, or any other person who performs policy or decision making functions and is authorized to legally bind a corporation, partnership, sole proprietorship, or government entity which operates a facility that is subject to the provisions of this Part. Whenever the term responsible official is used in this Part or in any other regulations implementing Title V of the act, it shall be deemed to refer to the 'designated representative' with regard to all matters under Title IV of the act."
    The Responsible Official will complete the E-Sign page on the website to submit the item. Only the Responsible Official for each facility will have access to this page. The Responsible Official will also be able to enter data; this person will have access to all pages on the electronic reporting website.
  • Reporting Editors: The reporting editor is an individual who can enter data on the website. Persons in this role will not have access to the E-Sign page of the website and will not be able to formally submit the item.
  • Reporting Reviewers: The reporting reviewer is an individual who has read-only access to the electronic reporting website. This person can review the information entered on the website, but cannot change or revise this information.

Facilities that intend to utilize electronic reporting must complete the application attached to this policy (Attachment #1). The following information must be provided for each person who will have access to the website:

  • Name and address
  • Title
  • Role indicator (responsible official, certification editor, reviewer)
  • Business telephone number
  • Email address

The facility Responsible Official will review and complete the application with a notarized signature, before returning the application form (Attachment #1) to the BQA, along with documentation supporting their authority. Each Responsible Official named on the application will have to supply a notarized signature. The individuals identified will be given appropriate access, a user ID and a password. The electronic reporting system will be able to differentiate a responsible official, a reporting editor and a reporting reviewer and provide access to the website according to their respective role.

The facility representative(s) may enter data via the website at any time during the reporting period. Any information entered during this time will ONLY be available to the facility representative(s). This information will NOT be accessible to either the Department or the U.S. EPA until the item has been signed by the facility's responsible official and formally submitted to the Department.

VI. Related References

AFS Compliance Manual

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