The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requires livestock farms emitting more than 100 pounds of ammonia or hydrogen sulfide in a 24-hour period to report to federal authorities under CERCLA of a continuous air emissions release.
US EPA filed a motion to the DC Circuit late last night to delay issuing a mandate requiring emissions reporting. US EPA is seeking an additional 90 days (until April 23, 2018) to work on reporting forms.
Under the DC Circuits usual practice, no mandate is issued while a motion is pending. Motions are due in 10 days and then US EPA will file its response 7 days later, likely gaining us at least an additional 17 days till air emission reporting is due.
Additionally, the 30-day written report clock does not start until the mandate goes into effect. EPA is currently working on a document to streamline the 30-day written reporting process and that will be posted on their website in the next week.
IPPA will keep you updated if something changes regarding the CERCLA mandate.
If you have any additional questions or concerns please contact the IPPA office at 217-529-3100.