Effective October 24, 2018, the New Hampshire Department of Environmental Services (NHDES) Air Resources Division finalized revisions to Env-A 700, Permit Fee System. The October 24, 2018 rule revision changed the way total annual emission fees are calculated by adding a flat-rate baseline fee to the existing emission-based fee.
Prior to the October 24, 2018 rule revision, total annual emission fees were equal to the emission-based fee calculated by multiplying the total actual annual emissions in tons by the dollar-per-ton fee established by NHDES. Historically, the dollar-per-ton fee exponentially increased each year from $90.95 in 2006 to $377.85 in 2016, which was largely due to the decrease in stationary source emissions over the same time period. In an effort to stabilize the total annual emission fees for emission sources, NHDES established a flat-rate baseline fee. Now, the total annual emission fees are calculated by adding the applicable baseline fee to the emission-based fee:
Total Annual Emission Fee = BF + EF
The flat-rate baseline fee is determined by the type of emission source as follows:
The new baseline fee has increased the total annual emission fee for many permitted facilities. Permitted facilities with emission sources that emit RTAPs may be able to reduce their baseline fee by requesting a permit amendment. Contact Aries to discuss ways to reduce your baseline emission fees.
Two positive changes to the rule include a delay in the due date for the total annual emission fee and earlier publication of the dollar-per-ton fee. Total annual emission fees are due on or before May 15 for the previous calendar year’s emissions (annual emission reports are still due April 15). Also, NHDES will publish the dollar-per-ton fee in the third quarter of the reporting year, which will allow facilities more time to plan for the total annual emission fee payment.
 Adjustments can be made if actual annual emissions exceed 250 tons per year; see Env-A 705.04(c)
April 3, 2019
|Katy Ward, P.E.