Emissions Inventory Reporting Requirements

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An emission inventory (EI) is a listing, by source, of the amounts of pollutants actually emitted to the atmosphere over a period of time.

The emission inventory is required by Code of Federal Regulations 40 CFR Part 51 Subpart A - (Air Emissions Reporting Requirements) and requires that emissions data be collected from certain facilities by all state agencies responsible for regulating air pollution and submitted to the Environmental Protection Agency (EPA). The EPA uses these submittals to build the National Emissions Inventory (NEI). The NEI is a national database of comprehensive estimate of annual air emissions of criteria pollutants, criteria precursors, and hazardous air pollutants from point, nonpoint, and mobile air emissions sources. An updated version of the NEI is released every three years.

** On February 12, 2018, the State of Tennessee Rule for Emissions Inventory Requirements that applies to facilities meeting the criteria specified in 40 CFR Part 51 Subpart A was adopted. The detailed information for this rule is available on the Tennessee Secretary of State publication website.

Facilities whose potential emissions equal or exceed thresholds shown in the tables below for any of the indicated pollutants are required to submit actual emissions data to the Division of Air Pollution Control by June 1 following the year of inventory.

Any facility that fails to respond to an EI submittal request by June 1 of each year, may be subject to enforcement action for violation of the Tenn. Comp. R & Regs Rule 1200-03-10-.05

Calendar Year Thresholds

Thresholds for point source determination are shown in tons per year of potential to emit as defined in 40 CFR part 70. Reported emissions must be in actual tons emitted for the required time period.

Pollutant Every-year (Type A sources)1 
(1) SO2 ≥2500
(2) VOC ≥250
(3) NOX ≥2500
(4) CO ≥2500
(5) Lead Not applicable
(6) Primary PM10 ≥250
(7) Primary PM2.5 ≥250
(8) NH3 ≥250

1 Type A sources are a subset of the Type B sources and are the larger emitting sources by pollutant.

Pollutant Triennial Type B sources​
(1) SO2 ≥100
(2) VOC ≥100
(3) NOX ≥100
(4) CO ≥1000
(5) Lead ≥0.5 (actual)
(6) Primary PM10 ≥100
(7) Primary PM2.5 ≥100
(8) NH3 ≥100

1 Type A sources are a subset of the Type B sources and are the larger emitting sources by pollutant.

Common Air Emissions Reporting System (CAERS)

The Common Air Emissions Reporting System (CAERS) is an online, internet-based system.  Each year's emissions inventory report is required to be prepared and submitted through CAERS by the due date of June 1.

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Please Notice that:

  • Review and Comply with the APC Requirements for CAERS Submissions. See the link above under Access to CAERS.
  • CAERS will be used for reporting all total actual calendar year emissions for all active processes at a facility. This is to include any process that the Title V permit has specified as insignificant or exempt. ALL ACTUAL emissions are required to be reported by calculation or at least by estimation based on operations records for each process.
  • Emission inventory submittals must be complete and accurate.
  • Download the TDEC CAERS Registration Form (CN-3189) and Instructions for CN-3189.
  • PM10-FIL, PM10-PRI, PM-25-FIL, PM25-PRI and PM-CON are the only acceptable pollutant codes for submittal of particulate matter. APC suggests that the PM specified in the Title V permit most closely correlates to PM10-FIL
  • Although reporting of hazardous air pollutants (HAPs) is voluntary, we strongly encourage you to report individual HAP emissions. The individual HAP-VOC emissions for each process must be reported in total VOC emissions for each process. The total VOC emissions must be greater than or equal to the HAP-VOC emissions.
  • All pollutants specified in the tables above must be reported, not just the pollutants that qualify the source as a point source.
  • Minor sources, conditional major sources with federally enforceable permit limits, and sources that are major for HAP only are not required to report emissions. Any sources with actual lead emissions of 0.5 tons per year or more must submit their emissions on a triennial basis.

Uses for emission inventory data:

  • Attainment/nonattainment designations for criteria air pollutants
  • State Implementation Plans (SIPs) for attainment and maintenance of the NAAQS Rule development
  • PSD permit reviews
  • Air Quality & Human Health Effects Research

Actual Emission Analysis Required (AEAR) 

The use of MyTDEC Forms is required for the Actual Emission Analysis Required (AEAR) submission process (Fee calculation and document attachments). APC does not accept hardcopy documents for the AEAR. All AEAR documents (extension requests, supporting records or documents, final report, Responsible Official Certification Statement, etc.) shall be submitted through MyTDEC Forms as a form attachment.

What to Know About AEAR

  • Fiscal Year Fee Basis - AEAR due August 1, may extend until September 30 upon request
  • Calendar Year Fee Basis – AEAR due April 1, may extend until June 30 upon request
  • Due by April 1st
    1. Annual Title V Fee calculation
    2. Facilities with a FY basis use estimated annual emissions
    3. Facilities with a CY basis use
    4. Final Annual emissions if NOT requesting an extension
    5. Estimated Annual Emissions if requesting an extension

AEAR extension requests must be attached in MyTDEC Forms. Minimum Payment of 65% of estimated Annual Fee is due April 1 when an extension is requested.

  • The AEAR report Certification Statement is to be signed by the Responsible Official with the Title V Truth and Accuracy Statement using the following language:
    “I have reviewed this document in its entirety, and to the best of my knowledge, based on information and belief formed after reasonable inquiry, the statements and information contained in this document are true, accurate, and complete.”
  • MyTDEC Forms will be available beginning March 1 of each year
  • Online Payments can be made through MyTDEC Forms

Credit Card & Debit Card payments accepted
eCheck payments accepted

  • Payment by Check is available as follows:
    1. Download Payment Voucher in MyTDEC Forms
    2. Make check payable to either:

Division of Air Pollution Control
Tennessee Department of Environment and Conservation

  • Mail Payment Voucher and Check to:
Division of Fiscal Services-Consolidated Fees Section
500 James Robertson Pkwy, 6th Floor
Nashville, TN 37243
  • Write on your check:

‘APC Title V Fee, APC Facility ID (##-####)’

  • For questions email APC.Inventory@tn.gov
Contact Information
Emission Inventory Group
For questions email APC.Inventory@tn.gov 

This Page Last Updated: March 30, 2026 at 3:01 PM