TCEQ Emissions Inventory Reports Due March 31
Texas facilities that meet TCEQ’s Emissions Inventory (EI) applicability thresholds are required to report actual annual emissions of criteria pollutants, hazardous air pollutants (HAPs), and other regulated contaminants. These reports play a key role in the state’s air quality planning and ensure compliance with both state and federal requirements.
For many sites, preparing an accurate AEI requires coordination across multiple operational areas — production data, fuel usage, stack testing, control efficiencies, hours of operation, and historical records. Because the process can be complex, beginning early helps prevent errors and avoids the spring reporting bottleneck.
Who Must Submit an Emissions Inventory?
Facilities subject to 30 TAC 101.10(a) — typically those with:
- any account that emits or has the potential to emit 100 tpy or more of any contaminant, except for greenhouse gases
- any account that emits 0.5 tpy or more of lead (Pb)
- an account which meets the definition of a major facility/stationary source, as defined in §116.12 of this title (relating to Nonattainment and Prevention of Significant Deterioration Review Definitions)
- any account in an ozone nonattainment area emitting a minimum of ten tons per year (tpy) volatile organic compounds (VOC), 25 tpy nitrogen oxides (NOX), or 100 tpy or more of any other contaminant subject to National Ambient Air Quality Standards (NAAQS);
- any account which emits or has the potential to emit 10 tpy of any single or 25 tpy of aggregate hazardous air pollutants as defined in Federal Clean Air Act (FCAA), §112(a)(1); and
- any minor industrial source, area source, non-road mobile source, or mobile source of emissions subject to special inventories under subsection (b)(3) of this section. For purposes of this section, the term “area source” means a group of similar activities that, taken collectively, produce a significant amount of air pollution.
Core Elements of the EI Submittal
Each EI must include detailed, accurate reporting across several key categories:
1. Activity & Operational Data
Production rates, fuel usage, hours of operation, and process changes are central to calculating actual emissions.
2. Emissions Calculations
Facilities must quantify emissions using approved methods, including:
- AP-42 emission factors
- Manufacturer data
- Stack test results
- Mass balance calculations
- Control device efficiencies
3. Emissions by Pollutant & Release Point
Reporting must detail:
- Point, fugitive, and mobile sources
- Criteria pollutants
- HAPs and other state-regulated pollutants
- Emissions before and after controls
4. Verification Against Permit Limits
AEI data must align with NSR permit or Operating permit limits to avoid inconsistencies.
5. STEERS Submittal Requirements
All data is submitted through TCEQ’s STEERS system — where accuracy and completeness are essential for acceptance.
How ESE Partners Supports EI Compliance
ESE Partners works with industrial and manufacturing facilities across Texas to prepare accurate, defensible Air Emissions Inventory reports. Our air quality team provides:
- Data review and verification
- Emissions calculations and control device evaluations
- Analysis of criteria pollutants and HAPs
- Consistency checks with NSR permits, Operating Permits, and historical AEI data
- STEERS EI preparation and submittal
- Ongoing air permitting and compliance support
We ensure your EI is complete, compliant, and submitted with confidence.
Why Early Preparation Matters
The late February-March window is one of the busiest compliance periods of the year. Starting ahead of time helps facilities:
- Resolve data discrepancies
- Verify changes in operations or controls
- Update emission factors if needed
- Ensure permit and AEI records align
- Avoid delays caused by STEERS access or data errors
Early EI preparation means fewer surprises — and a smoother path to compliance.
Stay Ahead of the April 1 Deadline
With the deadline approaching, now is the ideal time to begin organizing operational data, reviewing emissions calculations, and preparing your submittal. Whether you need targeted support or full EI management, ESE Partners is ready to help your facility meet all TCEQ reporting requirements.
