Envera Consulting: Can A Facility Be Exempt From Filing A SCAQMD AER? Generally speaking, applicability to the annual emission reporting (AER) program is based on three criteria:

  1. Your facility is notified by the SCAQMD to submit an AER.
  2. Your facility’s emissions of criteria and/or toxic air pollutants exceed the reporting thresholds found in Rule 301.
  3. Your facility is part of the AB 2588 reporting program for air toxics.

Now, if your facility does not fit into one of those categories, then yes, you can be exempt from the AER program, however, you will need to request this exemption from the SCAQMD, and the SCAQMD needs to grant your request. Exemption requests are typically good for a three-year period, after which you will need to re-apply for the exemption. If your exemption request is granted, you will want to continue to track your emissions to demonstrate the applicability of your exemption. In closing, it’s important to note that your facility is still required to file an AER in the case where a notification letter is received, but your emissions are below the reporting threshold and/or the fees amount to zero.

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Topics Assembly Bill 2588
Grant T. Aguinaldo, PhD

About Grant T. Aguinaldo, PhD

Grant provides techno-economic-regulatory modeling, analysis, and decision support on §45Z, the Low Carbon Fuel Standard (LCFS), and the decarbonization of the economy. He also leads air permitting projects across all of California's major air districts and in other states across the U.S. He is a Lead Verifier for California GHG and LCFS, and Washington GHG.