Emission Reduction Credit (ERC) Banking Program - Generation and Deposit
How can I generate ERCs?
Emission reductions creditable as ERCs may be generated by a number of emission reduction techniques. Keeping in mind that the reduction meets the minimum requirements of being surplus, quantifiable, permanent and federally enforceable, ERCs can be generated with one of the following techniques:
- Permanent shutdown of an existing air pollution source or facility
- Permanent curtailment in production or operating hours of an existing air pollution source or facility
- The installation and operation of air pollution control equipment
- New technologies, materials, processes or process equipment modifications
- Incidental emission reductions resulting from reductions of a collateral pollutant
- Mobile source reduction determined on a case-by-case basis
If you want Ohio EPA to verify your emission reductions as creditable emission reductions (verified ERCs) in accordance to OAC Chapter 3745-111, then request to generate verified ERCs on your Generation Notification and Deposit Form (ERC Form -1). Verified ERCs may be transferred under the ERC Banking Program and used for offsetting emissions. However; if you do not want Ohio EPA to verify your emission reductions, but you want an estimated amount of ERCs deposited in the ERC Bank, then you may request to generate un-verified ERCs on your Generation Notification and Deposit Form (ERC Form -1). Un-verified ERCs may not be transferred or used for the purpose of offsetting emissions under the ERC Banking Program until the completion of Ohio EPA verification.
How should I calculate ERCs so they are “quantifiable”?
A source generating ERCs must use a calculation method that is creditable, accurate, workable, enforceable and replicable. Ohio EPA prefers a facility utilize direct measurement techniques, when available, before applying indirect methods. Facilities may use the following methods in calculating ERCs.
- Continuous emission monitoring, stack testing, sampling of fuels and materials or other direct measurements
- Calculations using equations that are a function of process and control equipment
- Mass-balance calculations
- Emission factors, emission calculation methods or emission quantification protocols approved by Ohio EPA
- Ohio EPA may accept other methods of quantification on a case-by-case basis
Note: If more than one emission quantify method is available, Ohio EPA expects participants to use the most accurate method available to do this calculation.
When can I use my annual fee emission report to generate ERCs?
Verified ERC Generation
If verified ERCs are generated from an acceptable emission reduction technique at a Title V or synthetic minor Title V facility, then you may use your annual emission fee report to submit ERC calculation data in certain cases. There may be instances that Ohio EPA will need more information than what is provided on an annual fee emission report in order to complete the verification process. It will be necessary to ensure the fee emission report provides all the information necessary for quantification and covers a 24-month period that is most representative of normal operations, as approved by Ohio EPA. If all necessary information is not contained in the fee emission report, it will be necessary to provide supplemental information. Currently Ohio EPA is developing a guidance document on this topic to assist facilities in understanding what information Ohio EPA will need.
For a facility that is not a Title V or synthetic minor Title V facility, annual fee emission reports will not represent sufficient data for verified ERC generation that constitute “quantifiable” baseline calculations (e.g., a range of emissions is not considered “quantifiable”). You must use actual operating hours, productions rates and types of materials processed, stored or combusted during the selected time period to calculate the actual emissions emitted during your selected baseline period.
Un-verified ERC Generation
When generating and depositing un-verified ERCs to the ERC banking system, you may use your annual fee emission reports to submit estimated emission data to the ERC Banking Program. Complete your emissions estimation information by emission unit and pollutant in Section XII of the ERC Generation Notification and Deposit Form (ERC Form-1).
How does Ohio EPA verify permanence of an emission reduction, and how are ERCs made federally enforceable?
- Emission reductions achieved from methods other than permanently shutting down an air contaminant source (e.g, synthetic minor restrictions):
These types of emission reductions must be made permanent and federally enforceable as part of the verification process by Ohio EPA. Typically, permanence and federal enforceability will be achieved by incorporating the appropriate requirements into a permit issued by Ohio EPA in draft and then final form.
- Emission reductions from permanently shutting down an air contaminant source:
This type of emission reduction will be made federally enforceable at the time of use by Ohio EPA. However, Ohio EPA will require certification from a responsible official/authorized individual of the permanence of the shutdown in order to participate in the program. Typically, federal enforceability will be achieved by incorporating the appropriate requirements into a permit issued by Ohio EPA in draft and then final form.
What pollutants can be deposited into the Bank?
The ERC Banking System will track the generation, transfer and use of ERCs for nitrogen oxides (NOx), volatile organic compound (VOC), sulfur dioxide (SO2), fine particulate matter (PM2.5), carbon monoxide (CO) and lead (Pb). Keep in mind that only SO2, NOx, PM 2.5 and VOC ERCs are currently needed for the purpose of emission offsets in Ohio’s nonattainment areas.
How are ERCs deposited?
Facilities must complete and submit a Generation Notification and Deposit Form (ERC Form- 1) to the Ohio EPA ERC Banking Program coordinator. Submit individual forms for each facility generating ERCs. After Ohio EPA reviews your form, ERCs will be deposited in the facility’s account within the ERC Banking System and posted on the Ohio EPA website. When completing ERC Form - 1, consult the instructions for details on how to complete the form. In addition to completing the ERC Form - 1, we encourage you to include any attachments to show how ERCs were quantified in accordance to OAC Chapter 3745-111.
ERC determination process
After Ohio EPA’s review is complete, we will send the facility generating ERCs a letter with our determination, unless more information is needed. If additional information is needed for our determination then we will contact the technical contact listed on ERC Form -1 to request clarifying information before a determination letter is sent. Ohio EPA will process ERC generation notification requests in a timely manner.
If a facility requests to deposit verified ERCs, the facility generating ERCs will receive an ERC Certificate which will include an Unique ID and ERC generation summary. Un-verified ERCs will receive an ERC Certificate upon verification. Only the original generator that actually generated the emission reductions may submit un-verified ERCs via ERC Form -1 to participate in the program.
Are mobile sources eligible to generate ERCs?
Mobile sources are eligible for ERC generation on a case-by-case basis. If you wish to generate ERCs from a mobile emission source please contact Ohio EPA’s ERC Banking Program Coordinator for more information on how to proceed with the ERC generation process.
Is there an affected date for generating ERCs?
For ERCs to be approved, the emission reduction must be permanent, quantifiable, federally enforceable and surplus and for all ERCs generating NOx, VOC or PM 2.5 must have occurred after Dec. 31, 2005.
However, Ohio EPA has set aside NOx, VOC and PM 2.5 emissions in the ERC Bank for sources that permanently shutdown prior to Dec. 31, 2005, and want to generate ERCs. Please contact the Ohio EPA’s ERC Banking Program Coordinator for a case-by-case determination in generating ERCs from permanent shutdowns in your area that occurred prior to Dec. 31, 2005.
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