1. Instructions: BWP AQ 30-CO2 doc format of CO2 Budget Emission Control Plan Instructions
pdf format of CO2 Budget Emission Control Plan Form & Instructions

  2. Form: BWP AQ 30-CO2 doc format of CO2 Budget Emission Control Plan Form
pdf format of CO2 Budget Emission Control Plan Form & Instructions

  3. Transmittal Form & Number for Permit Application & Payment


Permit Fact Sheet

  1. What is the purpose of the Emission Control Plan?

    The purpose of MassDEP regulation 310 CMR 7.70 is to establish the Massachusetts CO2 Budget Trading Program, which is designed to stabilize and then reduce anthropogenic emissions of CO2, a greenhouse gas, from CO2 Budget sources in an economically efficient manner.  The CO2 Budget Trading Program will regulate CO2 emissions beginning on January 1, 2009.  310 CMR 7.70(8) requires all affected units to determine and report CO2 mass emissions from certified systems beginning January 1, 2009.  To ensure that the CO2 mass emissions are determined accurately and consistently, 310 CMR 7.70 requires submission of a CO2 Budget Emission Control Plan (ECP), which contains an emissions and an energy output monitoring plan.
  2. Who must apply?

    All facilities subject to 310 CMR 7.70(1)(d) must apply for a CO2 Budget ECP approval.  Facilities subject to 310 CMR 7.70 (1) (d) include any fossil fuel-fired stationary boiler, combustion turbine, or combined cycle system that, at any time on or after January 1, 2005, serves an electricity generator with a nameplate capacity equal to or greater than 25 MWe.  Any source that includes one or more such units shall be a CO2 Budget source.
  3. What category should I apply under?

    The CO2 Budget ECP category is BWP AQ 30.  BWP AQ 30 is intended for all CO2 Budget sources subject to 310 CMR 7.70.
  4. What are the application deadlines?

    See: Permit Application Timelines and Fees Schedule pdf format of Permit Application Timelines and Fees Schedule

    As required by 310 CMR 7.70(2)(a)4., no CO2 Budget ECP approval shall be issued, and no CO2 Allowance Tracking System account shall be established for a CO2 Budget source until MassDEP has received a complete account certificate of representation under 310 CMR 7.70(2)(d) for a CO2 authorized account representative of the source and the CO2 Budget units at the source.  The CO2 Budget Trading Program certificate of representation form has been included in the CO2 Budget ECP application form.

    If the CO2 Budget source is required to have an Operating Permit under 310 CMR 7.00: Appendix C, such Operating permit shall be modified in accordance with the procedures in 310 CMR 7.00: Appendix C(8).
  5. What are the application fees and timelines?

    See: Permit Application Timelines and Fees Schedule pdf format of Permit Application Timelines and Fees Schedule
  6. How do I find my Facility AQ ID number, my ORIS ID number, and my CO2 Budget Trading Program Compliance Account number?

    The Facility AQ ID number can be found on your MassDEP Source Registration Form.

    The Office of Regulatory Information Systems Identification (ORIS ID) number is issued by the Energy Information Agency (EIA).

    CO2 Budget Trading Program Compliance Account numbers may not be available by August 1, 2008 and therefore CO2 Budget Trading Program Compliance Account numbers do not need to be submitted with the CO2 Budget ECP applications submitted by August 1, 2008.  Please note that submission of this CO2 Budget ECP application is not considered to be an application to open a compliance account.  A process for establishing a compliance account is being developed and will be made available as soon as possible.
  7. How do I submit a complete plan application?

    For a complete CO2 Budget ECP, an applicant must submit the MassDEP Transmittal form (available from http://mass.gov/dep/service/online/trasmfrm.shtml), the BWP AQ 30 CO2 Budget Emission Control Plan Application form, and all applicable additional requirements stated in Sections E (CO2 Budget Program Emissions Control Plans), F (Requirements for Energy Output Monitoring Plans), and H (Requirements for Eligible Biomass Monitoring Plans) of the Application form.  As there is no application fee for this permit, do not check a box in section F of the MassDEP Transmittal form.  All hardcopy submittals should be sent to the primary permit and reserve copy locations provided in Question 20 below.  An electronic copy of the application must be submitted as a Word file, and may also be submitted as an Adobe pdf file, to MassDEP via email to: sue.ann.richardson@state.ma.us.

    The completed CO2 Budget ECP must be submitted by the source’s CO2 authorized account representative.  Note that for sources subject to the Clean Air Interstate Rule (CAIR) NOx Ozone Season program under 310 CMR 7.32 and/or the federal Acid Rain Program (ARP) under 40 CFR Part 72, the CO2 authorized account representative must be the same person as the CAIR and/or ARP designated representative; the alternate CO2 authorized account representative must be the same person as the alternate CAIR and/or ARP designated representative.
  8. How do I decide which monitoring plan option applies to each CO2 Budget unit?

    Please see Tables 1 and 2 below, and also the explanation in Options A through D in the application, to determine which type(s) of monitoring plans must be submitted with this ECP application.  Use Table 2 only if you are revising an existing CO2 Budget ECP approval.  Ensure that each CO2 Budget unit is listed only once under Options A through D in the application.

 Table 1:  Submission of Monitoring Plans with ECP due on or before August 1, 2008, or 12 months before a new CO2 Budget unit commences operation, whichever is later

 

Monitoring Plan Options for CO2 Budget unit’s Initial BWP AQ30 ECP Application

Energy Output Monitoring

Acid Rain Program Units

Non-Acid Rain Program Units

New unit, or proposing changes to 310 CMR 7.28 or 7.32 ECP Approval?

No

Yes

No

Yes

CO2 Emissions Monitoring per 40 CFR Part 75 excluding equation G-1

Certified CO2 monitoring system or long-term cold storage or new unit

Option A

Option B

N/A

N/A

Adding CO2 monitoring system or new unit

N/A 

N/A 

Option C

Option D

Note:  N/A in Table 1 indicate situations that do not exist in Massachusetts.

 

Table 2:  Submission of Monitoring Plans to amend an existing CO2 Budget ECP approval

 

Monitoring Plan Options to amend CO2 Budget unit’s BWP AQ30 ECP Approval

Energy Output Monitoring

Acid Rain Program Units

Non-Acid Rain Program Units

Changes to 310 CMR 7.70 ECP Approval?

No

Yes

No

Yes

CO2 Emissions Monitoring per 40 CFR Part 75 excluding equation G-1

Certified CO2 monitoring system

 N/A

Option B

  N/A

Option B

Changing CO2 monitoring methodology

 N/A

Option B

Option C

Option D

Note:  N/A in Table 2 indicate situations that do not require submission of an ECP application.

 

  1.  What other information should be considered when applying?

    Emissions monitoring – ARP units do not need to submit emissions monitoring plans or emissions certification documents.

    Petitions for Emissions Monitoring Plans – A CO2 authorized account representative who proposes to submit a petition for any variance to 40 CFR Part 75, or whose CO2 Budget unit has already received a petition approval from US EPA under 40 CFR Part 75, but that has not received an approval pursuant to 310 CMR 7.70, must submit the petition, and any approval received.  Option E must be completed in the application.

    Long-term Cold Storage[1] – You must have a certified emissions monitoring system that meets the requirements of 310 CMR 7.70(8)(a)1.a through 1.c (that does not use equation G-1 to calculate CO2 emissions) by January 1, 2009.  However, a unit is considered to meet these requirements if the monitoring system is uncertified, the unit is not going to operate before January 1, 2009, and notification has been provided to US EPA that the unit is a ‘long-term cold storage unit’ (shut down for at least two years) in accordance with 40 CFR 75.61(a)(7).  In addition, under 40 CFR 75.64, no quarterly reports will need to be submitted for these units until they recommence operation.

    Energy Output Monitoring – Documentation does not need to be submitted with the application if no changes are being proposed to the energy output monitoring documentation that was:

        a. submitted with the CO2 Budget unit’s CAIR ECP application; or
        b. approved under the CO2 Budget unit’s 310 CMR 7.28 ECP approval net output tables I (and II for cogenerators), and no changes were proposed in a CAIR ECP application.

    Eligible Biomass – A CO2 authorized account representative of a CO2 Budget unit that co-fires eligible biomass as a compliance mechanism under 310 CMR 7.70 must submit documentation pursuant to 310 CMR 7.70(8)(g) and the requirements of Section H of the Application.  Option F must be completed in the application.  See also Question 18 below.
  2. Who should I send my CO2 emissions monitoring and testing data and electronic monitoring plans to?

    The US EPA is the Department’s agent for these purposes. You can find the appropriate contact here: Clean Air Markets Business Contacts
  3. Do I need to send the CO2 account certificate of representation to US EPA?

    No.  The CO2 authorized account certificate of representation form has been included in the ECP application in Section B.  This form must be signed by the CO2 authorized account representative (CO2 AAR) and, if any, the alternate CO2 authorized account representative (CO2 AAAR).  Note that for sources subject to the Clean Air Interstate Rule (CAIR) NOx Ozone Season program under 310 CMR 7.32 and/or the federal Acid Rain Program (ARP) under 40 CFR Part 72, the CO2 authorized account representative must be the same person as the CAIR and/or ARP designated representative; the alternate CO2 authorized account representative must be the same person as the alternate CAIR and/or ARP designated representative.  No additional account certificate of representation form needs to be submitted to US EPA for the purposes of 310 CMR 7.70.  Please contact the MassDEP if you wish to change either the CO2 AAR or CO2 AAAR.  Any changes made to either the CO2 AAR or the CO2 AAAR, must correspond to respective changes made with US EPA to the ARP and CAIR designated representatives.
  4. When do I submit my electronic monitoring plan to US EPA?

    40 CFR 75.62(a)(1) states that the authorized account representative for an affected unit “shall submit a complete electronic, up to date monitoring plan file… no later than 21 days prior to the initial certification tests; at the time of each certification or recertification application submission; and (prior to or concurrent with) the submittal of the electronic quarterly report where an update of the electronic monitoring plan information is required…”

    An updated electronic monitoring plan will be required for non-ARP CO2 Budget units to begin reporting CO2 emissions to US EPA.  US EPA will not be able to accept any CO2 electronic monitoring plans for non-ARP CO2 Budget units before January 1, 2009, so please plan to submit your monitoring plan at the time of the first quarterly submittal (due April 30, 2009).

    CO2 authorized account representatives for ARP CO2 Budget units must submit and maintain the complete electronic, up to date, monitoring plan file with the US EPA pursuant to 40 CFR 75.62.
  5. Does my CO2 monitoring system need to be certified (or recertified)?

    If you are proposing to use certain heat input methodologies (e.g., certified fuel flow meters, the long term fuel flow heat input method or Maximum Rated Hourly Heat Input Rate (MHHI) values previously approved under 310 CMR 7.28 and/or 310 CMR 7.32) for a non-ARP CO2 Budget unit to calculate CO2 emissions, then you must perform a Data Acquisition and Handling System (DAHS) verification and any other appropriate diagnostic test to ensure that the monitoring system accurately calculates CO2 emissions from each fuel that is burned in the unit.  DAHS verifications are diagnostic tests that do not require a Relative Accuracy Test Audit (RATA) and thus are not re-certification events[2] and do not need to be submitted.  Certified fuel flow meters do not need to be recertified to begin reporting under 310 CMR 7.70.

    No recertification is required under 310 CMR 7.70 for ARP units with monitoring systems that have been certified under 40 CFR 75.

    CO2 Budget units for which a new CO2 or O2 analyzer and/or stack flow monitor, or fuel flow meter, are being proposed to calculate CO2 emissions, must certify their CO2 monitoring system.  Non-ARP CO2 Budget unit certification test data must be submitted to MassDEP within 45 days after completing all CO2 monitoring system tests.
  6. How do I report a Low Mass Emissions (LME) unit under the CO2 Budget Program?

    For CO2 Budget units subject to ARP and/or CAIR, LME unit status will continue to be determined by NOx and/or SO2 emissions pursuant to 40 CFR 75.19.  Qualifying units must use the CO2 emissions calculations for LME units under 40 CFR 75.19 for purposes of compliance with 310 CMR 7.70.  No new qualifying information needs to be provided with this application for the CO2 Budget Program.  CO2 Budget units that are subject to CAIR and that qualify for LME unit status will need to report CO2 and NOx emissions year round.

    For CO2 Budget units that are not subject to either ARP or CAIR, qualification for LME unit status will be determined pursuant to 310 CMR 7.70(8)(a)3.c.iii.
  7. Where and when do I submit my quarterly electronic data reports?

    All quarterly electronic data reports must be submitted to US EPA.  An electronic data report must be submitted for each CO2 Budget unit within 30 calendar days of the end of each of the four calendar quarters.  CO2 authorized account representatives for CO2 Budget units that were only submitting an electronic data report during the ozone season for the NOx Budget and CAIR Programs must begin submitting electronic data reports and reporting CO2 and NOx emissions year round for these units starting with the first calendar quarter of 2009.
  8. How do I certify each quarterly emissions submittal as required by 310 CMR 7.70(2)(a)6?

    When any submission is made to US EPA’s Emissions Collection and Monitoring Plan System (ECMPS), the required certification language in 310 CMR 7.70(2)(a)5. will appear and must be accepted and agreed to by the submitter.
  9. How do I certify that my energy output monitoring system(s) meets the accuracy requirements of 310 CMR 7.70(8)(h)4?

    The CO2 authorized account representative must complete and sign Section G of the application form to certify that the energy output monitoring system(s) meet the accuracy requirements of 310 CMR 7.70(8)(h)4.  This section of the application form must be completed for each initial CO2 Budget ECP application even if there are no proposed changes to an energy output system that has been previously approved under either 310 CMR 7.28 and/or 310 CMR 7.32.  This section must also be completed for any proposed changes to an energy output monitoring system previously approved under 310 CMR 7.70.
  10. I wish to co-fire biomass as a compliance mechanism – how should I complete the ECP application?

    You must contact Sue Ann Richardson at MassDEP to arrange a pre-application meeting to address site-specific issues before submitting the CO2 Budget ECP application.  Sue Ann Richardson can be reached at 617-348-4098 or via email to: sue.ann.richardson@state.ma.us.
  11. Where and when do I submit my compliance certification reports?

    Compliance certification reports shall be submitted, pursuant to 310 CMR 7.70(4), by March 1 following each relevant control period to the RGGI CO2 Allowance Tracking System (COATS). Annual energy output reports shall be submitted, pursuant to 310 CMR 7.70(8)(h)6.c, by March 1 following each calendar year to Sue Ann Richardson at the MassDEP Boston office. Energy output reports must be submitted in both electronic and hardcopy format.
  12. What is the Primary Permit Location?  What is the Reserve Copy Location?

    Primary Permit Location:

    Department of Environmental Protection
    Air Quality Section
    ________*Regional Office

    Reserve Copy Location
    :
    Department of Environmental Protection
    Bureau of Waste Prevention, Attn: Sue Ann Richardson
    1 Winter Street
    Boston, MA 02108

    * Find Your Region
  13. What is the annual compliance fee?

    See:
    Permit Application Timelines and Fees Schedule pdf format of Permit Application Timelines and Fees Schedule
  14. What are the regulations that apply to these permits?  Where can I get copies?

    These regulations include, but are not limited to:

    Massachusetts Air Quality Regulations, 310 CMR 7.00.

    These may be purchased online, in person, or by Mail at the Massachusetts State Bookstore
    An unofficial copy of these regulations may also be obtained at http://www.mass.gov/dep/air/laws/regulati.htm

    Federal Regulations:

    Continuous Emission Monitoring Regulations, 40 CFR Part 75.

    These may be purchased at:
    U.S. Government Bookstore
    Thomas P. O’Neill Building
    Room 169
    10 Causeway Street
    Boston, MA 02222
    617-720-4180
    These regulations may be obtained through the federal government web site: http://www.gpoaccess.gov/cfr/index.html
[1] Long-term cold storage means the complete shutdown of a unit intended to last for an extended period of time (at least two calendar years) where notice for long-term cold storage is provided under 40 CFR 75.61(a)(7). (40 CFR 72.2 Definitions)
[2] 40 CFR 75.20(b) “Any change to a flow monitor or gas monitoring system for which a RATA is not necessary shall not be considered a recertification event.”