Advocacy Alert – IDEM OAQ Fee Increases

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IDEM OAQ Fee Increases:  IDEM recently sent letters to most Title V sources across the state notifying them about the pending fee increases.  Although we knew that IDEM was going to ask the Environmental Rules Board for an increase in the near future, the specifics of the request were a bit of a surprise.  I’ll try to break down the basics in this post, but here is a link to the full document so you can evaluate for yourself.  For annual fees, you’re looking at a $506 increase in the base fee, plus about a $1.13 increase in the per ton emission-based fee.  For the landfills that I am responsible for, it looks like we will see about a $1,000 increase in annual Title V fees for each site.  In addition to the annual fee increase though, IDEM has increased the fees for various permit actions.  The table was a little unclear, but we were able to get a little clarification from IDEM.  For the purposes of this discussion, we have to assume that there are no additional complications (i.e. BACT, LAER, MACT).  In the explanation that we got from IDEM, they made it clear that there are no fees for a ‘straight’ Title V renewal, but if there are any new federal requirements (NSPS/NESHAP) that need to be reviewed as part of the renewal, then there will be a $793 review fee for each new federal rule.  The review fee would also apply if any of the existing federal rules have changed substantially since the last renewal.  There are no fees for a ‘permit modification’, although there will be fees for a ‘source modification’ that are based on the level of the modification; a minor modification is $793, while a significant source modification has increased to $5,556.  In addition, if there are any federal rules (NSPS/NESHAP) applicable to the source modification, each of those reviews will incur a $793 fee.  Just like the renewals, if there have been significant changes to the federal rules, that may trigger a review and the fee that goes with it.  So far, we haven’t heard anything specific about the schedule for the OLQ or OWQ fee increases, but they are definitely coming.


 

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