New Hampshire's New Annual Air Emission Fee Structure

NH's Air Emission Fee Structure Explained

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

where
    BF = baseline fee in dollars
    EF = actual annual emissions[1] in tons per year multiplied by the dollar per ton fee established annually by NHDES

 The flat-rate baseline fee is determined by the type of emission source as follows:

  • For each permitted facility with emission source(s) that emit regulated toxic air pollutants (RTAPs) from non-combustion sources, the baseline fee is $750 for the first RTAP emission unit plus $500 for each additional RTAP emission unit up to 10 emission units. For example, if you are a printer that emit RTAPs from five printing devices identified as emission units EU01 through EU05 on your permit, your baseline emission fee will be $750 for EU01 plus $500 each for EU02, EU03, EU04, and EU05 for a total baseline fee of $2,750.
  • For each Title V landfill, the baseline emission fee is $25,000.
  • For each electric generating unit capable of generating between 10 and 25 megawatts (MW) electrical power, including municipal waste combustors that are subject to Env-A 3300, but excluding stand-alone simple cycle gas turbines, the baseline fee is $20,000.
  • For each non-nuclear electric generating unit that is capable of generating greater than or equal to 25 MW electrical output, the baseline emission fee is $75,000.
  • For each Title V source not included above, the baseline emission fee $1,500.
  • For all other sources not listed above including combustion-only sources, the baseline fee is $500.

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. 

[1] Adjustments can be made if actual annual emissions exceed 250 tons per year; see Env-A 705.04(c)

April 3, 2019

Key Points

  • Effective October 24, 2018, NHDES revised the annual air emission fee structure.
  • The total annual emission fee is equal to the sum of the baseline fee and the emission-based fee.
  • The baseline fee is determined by the type of emission source.
  • The emission-based fee is the actual annual emissions multiplied by the dollar-per-ton fee established by NHDES.  

Contact

Katy Ward, P.E.
Principal Engineer
kward@aries-eng.com

Environmental Consultants in Concord, New Hampshire

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