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  • Writer's pictureBen Ellenberger

EPA Annual Emission Reporting Requirements (AERR)

Updated: Oct 25, 2023

The EPA is proposing changes to the existing Air Emissions Reporting Requirements (AERR). The proposed changes would require facility operators of large sources to report emissions and source test results directly to the EPA each year in addition to the data already submitted by the states. This emissions inventory data is essential in the development of regulations and regional air quality modeling. The purpose of requiring large sources to report directly to EPA is to ensure that EPA has access to data relevant to impacted communities to make better informed decisions around air pollution management.


Who would report data under this rule?

Reporting requirements would apply to “Point Sources”, which are defined as facilities with Title V permits, facilities with emissions over the major source thresholds for their area, major Hazardous Air Pollutant (HAP) sources, and certain facilities that emit specific HAPs at lower rates. In general, the majority of facilities subject to this rule are likely to be Title V facilities reporting based on Clean Air Act PTE reporting thresholds for criteria pollutants. However, facilities that emit HAPs such as hexavalent chromium, mercury, dioxins, will be required to report emissions at lower rates appropriate to the level of risk they pose to the environment.


What would be reported under the rule?

Emissions of criteria pollutants and HAPs would need to be reported each year from all stack and fugitive release points at a facility. Emissions from mobile sources that operate primarily within the facility boundaries would also need to be reported each year. In addition, results of source tests would also need to be reported directly to EPA. For each emission point the facility would be required to report throughput rates, release point coordinates, and stack parameters, as well as identifying control equipment and control equipment effectiveness.


How would data be reported?

Emissions data would be reported under the Combined Air Emissions Reporting System (CAERS). Source test results would be reported through the Compliance and Emissions Data Reporting Interface (CEDRI). Both of these online reporting tools require registration with the EPA to allow access.


When would these requirements apply?

These requirements is expected to become mandatory for the 2026 emission inventory year, with data to be submitted by May 31, 2027.


EPA is soliciting written comments through November 17th, 2023. The proposed rule and supporting material can be found here. In addition, EPA is holding a webinar on Wednesday October 25th. If you would like to learn more about this proposed regulation or to explore how ALG can help you update your monitoring and recordkeeping procedures to prepare for these changes, please contact us at:



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