Air Permits_Content Page_Registration Permit Options

Registration Permit Options

Registration operation permits (ROP) allow low emitting facilities to quickly register for an air permit. The permits contain facility-wide emission caps as well as monitoring, recordkeeping and reporting requirements. All four registration permit types have a 15-day or less required review time by DNR.

Benefits

Both DNR and facilities that qualify benefit from registration permits. The expedited review process saves DNR time. Facility benefits include:

  • streamlined application process
  • 15-day DNR decision on applications for coverage, if there is no existing permit to revoke. If there are existing permits that must be revoked, a 14-to-30-day revocation waiting period is required prior to making a decision on coverage
  • facility modifications without the need for a construction permit
  • the permit does not expire
  • simplified and less frequent recordkeeping

IMPORTANT:

For a faster application submittal, use the e-sign option. Follow the quick guide instructions to set up access for the Responsible Official in Switchboard and complete the e-sign process.

Rather than annual emission fees charged per ton of emissions, all facilities with registration permits are charged a $400 annual fee. The fee is due by the end of June every year, beginning the year after the facility is covered under the permit.

More information on qualifying for registration permits, including benefits and disadvantages of the permits, is found in the sections below.

Notice: To ensure proper functionality, always download Air Management Program PDF forms to the computer before opening and entering information. To download, right click on the document link, choose "Save link as", and save the file to a location on the computer. Open the downloaded file using Adobe Reader. For more information, visit the PDF help page.

ROP-A

ROP-A

The Type A Registration Permit (AM-364), or ROP-A, is the simplest of the registration permit options but has the lowest eligibility thresholds. Facilities must have emissions below 25% of the major source threshold for both criteria and hazardous air pollutants, along with meeting the other eligibility criteria described in the AM-364 fact sheet.

Read through this permit to understand the permit requirements that apply once coverage is approved: Final Type A Registration Permit ROP-A03/RCP-A03. Modeling requirements under the ROP-A differ by location as shown on the following map: ROP Threshold for Future Modeling - County Map.

Once a facility is ready to apply, review the appropriate application guide and application form. Contact the registration permit coordinator with questions. When submitting the application form, include appropriate emissions calculations.

Additional resources

ROP-B

ROP-B

The Type B Registration Permit (AM-531), or ROP-B, has higher eligibility thresholds than ROP-A or ROP-C. Facilities must have emissions below 50% of the major source threshold for both criteria and hazardous air pollutants and must meet the other eligibility criteria described in the AM-531 fact sheet.

Read through this permit to understand the permit requirements that apply once coverage is approved: Final Type B Registration Permit ROP-B01/RCP-B01.

Once a facility is ready to apply, review the appropriate application guide and application form. Contact the registration permit coordinator with questions. When submitting the application form, include appropriate emissions calculations.

ROP-C

ROP-C

The Type C Registration Permit, or ROP-C, is designed specifically for printers. Eligible facilities must have emissions below 25 percent of the major source threshold for criteria pollutants, be below 50 percent of the major source threshold for hazardous air pollutants and must meet the other eligibility criteria described in the The Type C Registration Permit (AM-379) [pdf]

Before applying for the ROP-C, review the permit to understand the requirements that apply once coverage is approved: Final Type C Registration Permit ROP-C02/RCP-C02 [pdf].

Apply by reviewing the application guide and completing the application form. Contact the registration permit coordinator with questions. When submitting the application form, include appropriate emissions calculations.

Use the Small Business Environmental Assistance Program's Printer Portal for additional resources. A comprehensive compliance assistance workbook describing how to comply with all DNR regulations that affect small printing facilities in Wisconsin is available on the Environmental tab. Calculation examples and sample spreadsheets are found on the Air tab of the Portal.

ROP-G

ROP-G

The Type G Registration Permits (AM-568), RCP/ROP-G01 and ROP-G02, are available to facilities who join the Green Tier Program.

There are two options under the Type G registration permits available to Green Tier participants: the RCP/ROP-G01 for facilities that are committed to achieving Tier 2 status within 18 months of receiving coverage under the ROP; and the ROP-G02 for facilities that have signed a Tier 2 contract. It is important to understand what Tier 2 requires for Green Tier facilities before investigating this option further.

In addition to achieving Tier 2 status under Green Tier, the facility must have emissions below 80% of the major source thresholds and must meet other air permit eligibility requirements. The Type G registration permits also have the added feature of allowing a facility to retain some types of source specific conditions. Review the Application Guide AM-569 below for details on the source specific conditions that can be included in the ROPG.

Read through the permits below to understand the requirements that apply once coverage is approved.

Once a facility is ready to apply, review the appropriate application guide and application form. Contact the registration permit coordinator with questions. When submitting the application form, include appropriate emissions calculations.

Compliance Resources

Registration Permit Compliance

The following information is for facilities covered by a ROP and includes key compliance issues. Click the down arrow to reveal additional details for each topic.

Annual Compliance Certification and Monitoring Summary

Registration permits require the annual summary of monitoring and the permit compliance certification to be submitted by March 1 every year. New facilities covered by a ROP-A or ROP-C are required to submit the first report March 1 following the first full calendar year of coverage.

  • This report is filed separately from the emissions report and is used to demonstrate the facility has met the permit conditions throughout the year.
  • The annual summary of monitoring and the compliance certification documents should be combined into a single PDF file and uploaded through the DNR Switchboard, under the Air Compliance Actions option and the Compliance Certifications tab.
  • Compliance Certification must be signed by the Responsible Official. To meet this requirement, DNR must receive either an original ink signature (not a scan or photocopy) or an e-signature.
  • Forms are available to complete this reporting requirement. However, any format may be used to submit the same information to DNR as long as the submittal meets the requirements in s. NR 439.03, Wis. Adm. Code.
  • Annual Compliance Certification Monitoring Report (4530-178)
  • Monitoring Summary/Checklist (4530-179)
  • After submitting the certification form, facilities can log into Switchboard to view tracking fields, including the signature received date. Paper submittals (including signature forms) require additional department processing time. For faster confirmation, facilities can use the e-Signature process, which provides instant updates.
Annual Air Emissions Inventory

Complete the report or the Under Threshold Notification (UTN) by March 1 every year for emissions generated during the previous calendar year.

If emissions from the previous calendar year are above any reporting level in NR 438, Wis. Adm. Code, submit an annual air Emissions Inventory (EI) by March 1. Certify the submitted EI by June 30.

  • EI Certification is different from the Annual Compliance Certification. Review AM-529 for additional information.

If emissions from the previous calendar year are below all reporting levels in NR 438, Wis. Adm. Code, submit an Under Threshold Notification (UTN) by March 1.

Complete NR 438, Wis. Adm. Code reporting requirements through the department’s Air Reporting System (ARS).

For additional EI information, visit the department’s EI website.

Deviation Notification

If the facility had any malfunction or other unscheduled event, not reported in advance to DNR, which caused or may cause any emission limitation to be exceeded, a deviation report must be submitted by the next business day.

Facility Changes

Any changes to the facility ownership, parent corporation, facility name, responsible official, facility air contacts, as well as facility relocation, expansion or closure must be reported to DNR.

  • Changes to the facility air contact, billing contact or permit contact can be made in the Air Reporting System (ARS) accessed through the DNR Switchboard
  • Changes to facility ownership, parent corporation, facility name, responsible official require additional notification and information provided to DNR.
  • Review the Construction or Modifications Under a Registration Permit fact sheet  (AM-639) to learn what steps to take when making changes to the facility.
  • Relocating or expanding the facility to additional buildings may require application for new registration permit coverage. Contact the registration permit coordinator to discuss whether the change qualifies as a single source (covered under same permit) or separate facilities (needs new permit coverage).
  • Changes in an ozone nonattainment area classification - Registration permits limit emissions of criteria pollutants as a percentage of the major source thresholds. Facilities located in certain nonattainment areas are subject to lower major source thresholds and, reduced ROP emission limits when the classification changes (current classification of nonattainment areas).
    • Location in an ozone nonattainment area may also present an opportunity for facilities that are closing or relocating. Facilities in certain nonattainment areas that emit VOCs or NOx may be eligible to generate emission reduction credits (ERCs) which can be held and traded to sources undergoing major construction permitting. Visit DNR’s Emission Reduction Credit Registry for more information.
  • Facility closure – Procedures for notifying DNR about a facility closure. After closing, the facility is still responsible for paying air emission fees for the time covered by the air permit.
  • Compliance Questions: Direct questions about compliance reports or any other compliance requirements to the facility-assigned DNR engineer. Use the Air Permit Search to find DNR staff assigned to the facility.

Compliance Assistance Reminders

Because the registration permit does not list all requirements that may apply to an individual facility, the Small Business Environmental Assistance Program works together with the Air Management Program's registration permit coordinator to send out quarterly reminders on topics of importance. Review the following documents for the content of recent emails sent to ROP facilities.

  • February 2024: Air Emissions Inventory – due March 1; Annual permit compliance certification and annual summary of monitoring – due March 1; Electronic reporting options
  • December 2023: Air Emissions Inventory Reporting System Changes Webinar; Facility Closure or Transfer Ownership; Calculating Actual Emissions; Records When Exempt; Malfunction Prevention and Abatement Plan; Federal Standards. NOTE: In the Calculating Actual Emissions section there was a slight change in wording from previous end of year messages. No change in policy was intended by that change in wording. The program values UTNs as a streamlining tool for the air emissions inventory report, and will continue to accept UTNs as a method for complying with the permit condition that requires all registration permit sources submit an annual air emissions inventory.
  • October 2023
    • PM Facilities: Emission Limits for Processes; Modeling Requirements; Fugitive Dust; Visible Emissions
    • VOC Facilities: VOC Control Requirements; RACT Applicability; LACT Requirements; Recordkeeping; Calibration of Monitoring Equipment
    • Printing Facilities: VOC Control Requirements; RACT Applicability; LACT Requirements; Recordkeeping; Calibration of Monitoring Equipment
  • May 2023: Malodorous emissions; Facility expansions; Maintain records; Stack testing
  • January 2023: Air Emissions Inventory – due March 1; Annual permit compliance certification and annual summary of monitoring – due March 1; Electronic reporting options
  • December 2022: Air Emissions Inventory Reporting System Changes Webinar; Facility Closure or Transfer Ownership; Reporting Deviations; Calculating Actual Emissions; Records When Exempt; Malfunction Prevention and Abatement Plan; Federal Standards.
  • September 2022
    • PM Facilities: PM emission limits for processes; Restricted Use RICE; PM modeling requirements; Fugitive dust; Visible emissions
    • VOC Facilities: VOC control requirements; RACT applicability; LACT requirements; Recordkeeping requirements; Calibration of monitoring equipment; Restricted Use RICE
    • Printing Facilities: Revised ROP-C; VOC control requirements; RACT applicability; LACT requirements; Recordkeeping requirements; Calibration of monitoring equipment; Restricted Use RICE
  • May 2022: Air Emissions Inventory Certification – due June 30; Facility Expansions; Maintain Records; Stack Testing; Malodorous Emissions; Keep Facility Contacts Up-To-Date