Greenhouse gas and registration permits

As a facility with an air emissions permit, federal and state rule changes regulating greenhouse gases (GHGs) directly affect your facility. The main changes that may affect you are as follows.

  • for all facilities, GHGs are regulated pollutants for determining whether or not you need an air permit;
  • for all facilities, several of the insignificant activities are revised such that some things may no longer qualify as insignificant and may need to be counted toward your facility’s emissions (see below for changes).
  • the use of certain chemicals are prohibited under the Option C ; and
  • GHG has emission limits in the Option D permit.

For more information about these changes, continue reading below.

Insignificant activities

Several insignificant activities in Minn. R. 7007.1300 are revised slightly under this rule. Changes to the insignificant activities list include revisions to: 7007.1300, subp. 2(A)(3) and 2(G)(1); subp. 3(A), (B)(2), and 3(I) (mostly combustion activities).

Options A and B

There are no new requirements for Option A and B permits. However, you need to determine if you still qualify for your current permit option. In addition, some insignificant activities will no longer qualify as such under the revised rules (see Minn. R. 7007.1300, subps. 2 and 3). If so, their emissions would need to be included to determine if you need a different kind of permit.

You should determine if you will still qualify for an Option A or B. Re-evaluate your insignificant activities, and for Option A, you need to calculate your GHG potential emissions. If you no longer qualify, you will need to apply for a different kind of permit. Deadlines are listed below.

Option C

The Option C permit has a new prohibition listed in Minn. R. 7007.1125, subp. 1(H). You may not have an Option C permit if your facility:

  • uses or generates nitrous oxide, other than from combustion units or at insignificant activities, or
  • uses or generates hydrofluorocarbons, perfluorocarbons, or sulfur hexafluoride (other than from insignificant activities).

If you no longer qualify for an Option C permit, you must apply for a new permit by the deadlines specified below. In addition, some insignificant activities no longer qualify as such under the revised rules (see Minn. R. 7007.1300, subps. 2 and 3). If so, their emissions would need to be tracked in your usual monthly calculations.

Option D

The rule has a new emissions limit for greenhouse gases — 50,000 tons per year (tpy) of carbon dioxide equivalent (CO2e). You are now required to calculate your GHG emissions as CO2e each month. This is the same requirement as for the other pollutants covered by this rule. You must calculate and track emissions of GHGs beginning on January 2, 2011 (compliance requirements are in Minn. R. 7007.1130, subp. 3(B), 3(M), 3(N), and 4(D)).

If your actual emissions of GHGs are such that you cannot comply with this new limit, you must apply for a new permit by the deadlines specified below.

Deadlines

As listed in Minn. R. 7007.1110, subp. 11a.

  • If you no longer qualify for your current registration permit option: submit a notice to the MPCA by February 23, 2011.
  • If you qualify for a different registration permit option: submit your application to the MPCA by February 23, 2011.
  • If you will need a different kind of permit (i.e., Capped Permit or individual State or Part 70 permit), submit your application to the MPCA by July 23, 2011.

For more information

All permit application forms are available on the Air Permit Forms page. If you have questions about the status of the MPCA’s rulemaking process, please see the MPCA’s rulemaking page for the appropriate rule contact.

Emission calculation spreadsheets for engines and boilers are available on the web. In addition, more information is available on the MPCA's instructions for calculating GHG emissions webpage.

Small businesses that are independently owned and have less than 100 employees can call the Small Business Environmental Assistance Program at 651-282-6143 or 800-657-3938.