Amendments to CARB EICG and CTR

On September 30, 2020, the California Air Resources Board (CARB) hosted a webinar to discuss proposed amendments to the Regulation for the Reporting of Criteria Air Pollutants and Toxic Air Contaminants (CTR) and the Assembly Bill (AB) 2588 Air Toxics “Hot Spots” Emission Inventory Criteria and Guidelines (EICG). Although separate proposals, the two programs have significant overlapping elements pertaining to the quantification and reporting of emissions from stationary sources. The EICG pertains to the reporting of toxic emissions and CTR is the statewide reporting of criteria pollutant and toxic emissions, which relies on annual emissions reports from facilities.

The amendments will result in major changes to the program including modification of the applicability criteria and addition of substances that must be reported. The amendments will increase the number of facilities required to report each year. The amended CTR states that facilities that emit or have the potential to emit four or more tons per year of any criteria pollutant except carbon monoxide (CO). The threshold is proposed as 100 tons per year for CO. The amendments are expected to expand applicability to approximately 60,000 facilities across the state.

Each year affected facilities must submit an emission report that includes quantified emissions as well as process and release information for each emitting device at the facility. The amendments will add approximately 1,200 substances to the list of substances that must be reported. Many of these proposed substances do not have published emission factors or established health risk values.

Any facility that has prepared an emissions inventory in the past, plus those that have not prepared an emissions inventory but meet the amended applicability criteria should be aware of these amendments. Contact Chris Waller at for questions about the proposed amendments or whether the CTR and EICG are applicable to your facility.