US | COVID-19 | EPA Temporarily Amends Continuous Emissions Monitoring and QA Requirements

In the April 22, 2020 edition of the Federal Register, the Environmental Protection Agency (EPA) temporarily amended the emissions reporting regulations for the Acid Rain Program, the Cross-State Air Pollution Rule (CSAPR), and the NOX SIP Call. The purpose is to provide regulatory relief for sources unable to comply with their regulatory obligations due to the COVID-19 national emergency.

This rule is effective April 22, 2020 and will expire 180 days after publication in the Federal Register. Comments will be accepted through May 22, 2020.

Actual vs. Substitute Data

By enacting this temporary rule, an affected unit can temporarily report actual monitoring instead of substitute data if:

  • It fails to complete a required test by the applicable deadline due to impacts from the COVID-19 emergency, and
  • The unit’s actual monitoring data would be considered valid if not for the delay in testing.

Substitute date is intentionally skewed to cause emissions reported for the source to be higher than if the test had been completed on time. Under normal circumstances, this approach provides operators with incentive to meet their monitoring deadlines. However, the current pandemic has created restrictions to travel, plant access, and access to necessary testing supplies. Additionally, the EPA finds these substitute requirements necessary to reduce risk of essential personnel to COVID-19.

Required Monitoring

Required monitoring covered by this action includes:

  • Required quality assurance
  • Certification or recertification
  • Fuel analysis
  • Emission rate tests

To qualify for relief under this action, sources must maintain detailed documentation, notify EPA when a test is delayed and later completed, and certify to the EPA that they meet the criteria for using amended reporting procedures. Required tests must be completed within 60 days of the close of the emergency.


Sources:EPA Interim Final Rule, Continuous Emission Monitoring; Quality-Assurance Requirements During the COVID-19 National Emergency (April 22, 2020)


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