Note: These questions and answers pertain to the 2021 Electronic Submission Requirements, Emission Factors Regulations Proposed Revisions. The information was current at the time of posting, but may be outdated after the adoption of regulations.

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Why is DEC updating adoptions by reference?

DEC is adopting a new federal regulation so that applicable requirements for municipal solid waste landfills are included in permits.

Where can I find the updated adoption by reference documents?

The current and proposed updated adoption by reference documents can be found at: 18 AAC 50 Reference Materials

Why is DEC proposing to add electronic submission requirements?

DEC is required by the Environmental Protection Agency (EPA) to report electronically a large majority of the information submitted by permittees. Since the majority of the data received by the Department is in paper form, DEC staff must hand enter the data into its database in order to then electronically submit to EPA. DEC is proposing to add electronic submission requirements in order to streamline processing of data reported to be more efficient, reduce data entry efforts, and prevent data entry errors.

Why is DEC proposing to add requirements regarding emissions factor calculations?

DEC is proposing to add a requirement that there be consistency in how emissions are calculated for all reporting requirements to reduce disparities between reported actual/assessable emissions and potential-to-emit calculations that are conducted by sources using a different calculation methodology for similar types of emission estimation calculations.  By using consistent calculation methodologies, the Department will gain improved accuracy in its data.  This should also help alleviate DEC’s need to contact permittees to verify emission estimates as staff address identified discrepancies between emission estimates reported by a facility.

Will I be able to review new web forms before they become mandatory?

All draft webforms created after September 1, 2021, will be available to review within the Permittee Portal. Permittee Portal users will be able to use their existing access IDs and passwords. Once inside the portal, users just need to go to the report section (after selecting a particular source and permit in most cases) and any new webform will be listed along with existing web forms.  Draft webforms will mimic all elements except electronic signature and saving. Instructions on how to comment specifically on a draft webform will be posted when a draft webform is available for review.

How will I be able to review new web forms before they become mandatory?

The Permittee Portal is just for those that have an Air Quality Permit from DEC, or who have been granted access by those with an Air Quality Permit from DEC. The general public does not have access. If you have a permit, please go to this website for more information and instructions: https://dec.alaska.gov/Applications/Air/airtoolsweb/AosHelpEC

What is the proposed regulatory language in 18 AAC 50.275 intended to achieve?  Specifically please provide clarity for what is meant by the following: "18 AAC 50.275 (b) For the purposes of reporting actual and assessable emissions under any requirement of 18 AAC 50, stationary sources shall use consistent pollutant-specific emissions factors and calculation methods for all reporting requirements."

The underlying purpose of the regulation is to ensure that the permittee uses consistent calculation methods for the various regulatory requirements such as PTE, calculations of actual emissions (assessables), excess emissions, and so forth. If an emission factor was used to calculate PTE, or a new emission factor was obtained by source testing, then the same emission factor should be used to calculate actual emissions for the purpose of fees, as an example.

What exactly are the calculation methodologies that are proposed to be required?

We are not proposing any new methodologies in this regulation revision, nor are we proposing which specific ones are required. We are just proposing a requirement that sources be consistent with using whichever calculation methodology they have used for other purposes.

Additional information:

You may submit written questions relevant to the proposed action to DEC by submitting questions electronically via our public notice site at https://dec.alaska.gov/comment/ by December 3, 2021.  Alternately, you may submit questions to Rebecca Smith at rebecca.smith@alaska.gov.

The department will aggregate its response to substantially similar questions and make the questions and responses available on this page.  The department may, but is not required to, answer written questions received after the December 3, 2021, deadline for submitting questions.

Documents for the proposed regulation changes may be found at: 2021 Electronic Submission Requirements, Emission Factors Regulations Webpage