ROSS Frequently Asked Questions (FAQs)

The ROSS program is administered by the Illinois EPA’s Bureau of Air.

All registration application material (including initial or annual fee submittals) will be directed to the Illinois EPA, not to the Illinois Department of Commerce and Economic Opportunity’s (DCEO) Small Business Environmental Assistance Program (SBEAP).

Illinois DCEO’s Small Business Environmental Assistance Program (SBEAP) has no regulatory authority in administering the ROSS program, that responsibility falls to the Illinois EPA.

SBEAP supports the ROSS program by providing free and confidential assistance related to state and federal environmental regulations, primarily to Illinois’ small businesses.  Assistance could include ROSS eligibility, assistance with exemptions, emission calculations, rule interpretations, when a Lifetime Operating Permit or Construction Permit would be needed, application content, etc.

The Illinois DCEO’s Small Business Environmental Assistance Program (SBEAP) does not administer the ROSS program and does not have certain administrative information, examples below, as such there are certain questions which only the Illinois EPA can address.

• Was my ROSS registration application received?
• Was my Name and Ownership Change received?
• Was my ROSS withdrawal request received?
• Was my payment received?
• When will I receive my annual billing?

For these kinds of questions, you may contact the Illinois EPA Bureau of Air at epa.boa.ross@illinois.gov or (217)785-1705.

Many forms utilized by IEPA must be opened using Adobe Acrobat Reader.  The issue is likely caused by your computer trying to use your web browser rather than Adobe Acrobat Reader to open the file.  At the top of the IEPA page and the IL SBEAP ROSS webpage there is a blue instruction box which provides the following instructions to resolve:

1. Right-click on the link and select  “Save link as…”  to download the form to your local drive.
2. Use Acrobat Reader to open the downloaded file from your local drive.

If this solution does not work for you, you should contact either the SBEAP program at dceo.sbeap@illinois.gov or (800)252-3998 or the Illinois EPA at (217)785-1705 and the form can be emailed or mailed if necessary.

The IEPA Bureau Of Air will send you a “ROSS Confirmation Letter” after they have approved your source’s ROSS application for registration.

Upon initial ROSS application submittal, after IEPA review you will receive a ROSS Confirmation Letter from the Bureau of Air which will confirm that your source has been registered in the ROSS program.

• For a brand-new ROSS, it takes the Illinois EPA a short bit of time to process the registration request.  If you have not received contact from the Illinois EPA, perhaps seeking information regarding your application, or you have not received a ROSS Confirmation Letter around 30 days after your submittal, at that point you can take the following steps:
  • Step 1: The Illinois EPA has a tool (i.e., Document Explorer) that can be used to retrieve application material or permitting determinations like issued permits or ROSS Confirmation Letters.  See ‘Informational’ Section FAQ #7 Step 1 for information on using the tool.
  • Step 2: If you were unsuccessful in using the Document Explorer tool to find your ROSS Confirmation Letter for your facility, you should next contact the Illinois EPA at epa.boa.ross@illinois.gov or (217)785-1705 to determine if your application was received or not, whether it was received and acted on but not yet loaded onto Document Explorer, or if your application was received but not yet acted upon for some reason.
    
    In the event that the ROSS application was approved the letter will be mailed out.  In the event the letter was mailed but you did not receive it, you can request a copy of the ROSS Confirmation Letter via to be sent to you via a FOIA request as explained in ‘Informational’ Section FAQ #7 Step 2.
• For existing ROSS sources (i.e., not an initial submittal), you will receive annual billing invoices from the IEPA for the ROSS site fee.  Those invoices are confirmation that your source continues to be registered in the ROSS program.  You will not receive a new ROSS Confirmation Letter at renewal.  If you wish to check on when your annual billing is due, see ‘Fee-Related’ Section FAQ #3.

If you have lost your ROSS confirmation letter and wish to replace it, you should take the following steps:

Step 1: The Illinois EPA has a publicly accessible search tool known as Document Explorer (IEPA Document Explorer - Search Facilities - IEPA Document Explorer (illinois.gov)) which can be used to retrieve issued registration documents.  Of note, newly confirmed registrations will not show up in that system for around 90 days as the documents have to be imaged.

The easiest way to use the system is to enter the Source ID# under the second tab and run the search.

If you don’t have the Source ID#, you will have to use the “Attribute Search.”   The system is literal in its search, meaning it will not recognize “ABC Co.” and “ABC Co. LLC” as the same company.  If you were to search for “ABC Co. LLC” but the name on file is “ABC Co.” the system will not find it.  Attempt to use as little information in one or more of the fields as possible and add/refine your search as needed.  Using the above example, search only for “ABC” as that is common to both.  Another search that has good success is the City and Address fields.  After submitting, depending on what your search parameters were, you may need to sift the results to find your facility.  If the initial search produces many results, in many cases you can greatly refine the initial search by adding in the city or zip code.  This will generally leave a very small list to review.

After selecting your source, on the next screen under the Category heading you will want the row for “Air Permit – Final.”  That row will possibly contain a historical record of air permitting actions, the most recent of which should be your ROSS Confirmation Letter.

Step 2: If the IEPA Document Explorer search under Step 1 was unsuccessful in finding your facility, you will need request the document from IEPA Records via a Freedom of Information Act (FOIA) request:  Freedom of Information Act (illinois.gov).  The IEPA FOIA page has a separate FAQ list on the homepage, and there is a tab and link at the top left of the page related to applicable FOIA Fees.

The Illinois EPA must be notified in writing within 45 days if there is a change in the name, address, email address or telephone number of the contact person given for the source in its ROSS registration.  To perform the notice, you may send an email to such as the sample below, edited as necessary for your particular update, to epa.boa.ross@illinois.gov with the subject line “Source Contact Information Update.”

Subject line:  Source Contact Information Update

To whom it may concern with the Bureau of Air ROSS program, [Company Name] is providing notice to update our current contact information for ID# [#########] as follows:

• Updated Contact Name: [**********]
• Updated Contact Email: [**********]
• Updated Contact Phone: [**********]
• Updated Contact Mailing Address: [**********]

If you have any questions, please contact [Name], thank you.

Alternatively, you may mail a letter to BOA containing the same kind of information to:

Illinois Environmental Protection Agency
Division Of Air Pollution Control -- Permit Section
P.O. Box 19506
Springfield, Illinois 62794-9506

If the owner/operator of the source registered in the ROSS program has changed, or if the existing owner is operating under a new name, then you should complete and submit a Name and/or Ownership Change Form (APC-620 form) within 45 days of the date of the change.  A link to the form can be found on our program’s ROSS webpage and is also linked here: Name and/or Ownership Change Information - APC 620 (illinois.gov).  The completed form can be mailed to the address given on the form or it can be attached to an e-mail directed to epa.boa.ross@illinois.gov.  Any unpaid site fees for the source must be paid to date and have a zero balance prior to the transfer of the registration.

If the source has been sold, the ROSS registration should be transferred to the new owner.  To accomplish this, you should complete a request for a Name and/or Ownership Change using the IEPA form Name and/or Ownership Change Information - APC 620 and either email the form to epa.boa.ross@illinois.gov or mail the form to:

Illinois Environmental Protection Agency
Division Of Air Pollution Control -- Permit Section
P.O. Box 19506
Springfield, Illinois 62794-9506

NOTE:  Any unpaid site fees for the source must be paid to date and have a zero balance prior to the transfer of the registration.

Yes.  Emission units and their ROSS are tied to a specific location.  If the owner/operator moves an emission unit with a ROSS to a new location, a new ROSS registration must be obtained.

According to the rule, an applicant for a new ROSS shall register at least 10 days before commencing construction or operation and may commence construction or operation 10 days after submittal to the Illinois EPA.

A site fee of $235 will be required with the new application.

Note:    Site fees are billed annually for all locations.  If all equipment has been moved out of the old location, to avoid being billed for unnecessary site fees, the owner/operator must request withdrawal of the old ROSS registration tied to the old location.  To withdraw a ROSS registration, follow the procedure at ‘Administrative’ Section FAQ #6.

The Illinois EPA will accept ROSS registration applications either electronically or via mail.

1. To submit your ROSS registration application package electronically, on the ROSS application there is a button near the signature line which will automatically open your email application (e.g., Outlook) and attach the file.  You will need to attach to that email any other supporting documentation.
   
   
    
   Alternatively, you can complete and save the file to your computer, and then attach the form and other supporting material in an email sent to:  epa.boa.ross@illinois.gov.  In the subject line of the email include “ROSS PDF Form Submission."
2. You may mail your ROSS registration application package to the address at the top of the registration form, copied below:
   
   Illinois Environmental Protection Agency
   Division Of Air Pollution Control -- Permit Section
   P.O. Box 19506
   Springfield, Illinois 62794-9506

• All emission units or emission generating activities have been removed from this source; however, the business has not ceased operation.
  • Example:  The source had a parts coating operation and a parts assembly operation.  Parts now arrive already coated, and you continue to assemble as you always have.  You sell and remove the coating operation.
• All emission units or emission generating activities have ceased operation at the source but will remain on site.
  • Example:  The source had a parts coating operation and a parts assembly operation.  Parts now arrive already coated, and you continue to assemble as you always have.  You cease coating operations onsite, but chose not to sell and remove the coating operation in case future business requires coating.  You decide to keep the coating operation and render it inoperable (e.g., disconnecting main power).
• The only emission units remaining onsite are considered exempt from ROSS by 35 IAC 201.146.  For additional information on state permit exemptions, see ‘Technical’ Section FAQ #3.
• The entire source has ceased operation and been permanently shut down.

For the above situations you will need to request a withdrawal of the source’s ROSS registration.  This should be done as soon as possible after the last emission unit requiring registration is removed or permanently shut down.  A withdrawal can be accomplished by completing and submitting the Withdrawal Of Permit Or Permit Application form.

When completing the Withdrawal of Permit form, as the entire source is now exempt from registration, under Section Three, in Item 1 you will need to select “Yes,” as shown below:

The form may be submitted to the Illinois EPA either through attaching the form to an e-mail directed to epa.boa.ross@illinois.gov (note in the subject line Withdrawal of Source ID# XXXXXXXXX), or the form may be mailed to the address at the top of the form:

Illinois Environmental Protection Agency
Division Of Air Pollution Control -- Permit Section
P.O. Box 19506
Springfield, Illinois 62794-9506

Of note, unpaid site fees for the source must be current and have a zero balance before the request for withdrawal will be approved.  See ‘Fee-Related’ Section FAQ#4 to determine how to check your balance.

A request for withdrawal should be submitted as soon after the shutdown as possible to prevent future annual site fee assessments for the inoperative source.  The Illinois EPA considers an active registration as an active source and will continue to bill until the withdrawal has been processed.  See ‘Administrative’ Section FAQ #6 for additional information on how to withdraw a permit.

Yes.  From the main ROSS webpage (Registration of Smaller Sources (ROSS) Program - Environmental Assistance Program (illinois.gov) there is a link to the IL State Treasurer’s e-pay tool:  Illinois ePay.

If you pay by check, no, the Illinois EPA will not provide a receipt.  However; if you pay online using the IL State Treasurer’s e-pay tool (Illinois ePay) you will be provided a confirmation number of the transaction, which can be printed for your records.

The IEPA will mail you an invoice each year for the source’s $235 annual site fee.  You should expect to be invoiced at around the same time each year for the annual site fee.  If you wish to know the approximate date when you can expect to be invoiced, or are concerned that the invoice is late or may have been lost, you should contact the IEPA’s Fiscal Office at 217-782-3250 or via e-mail at epa.acctsreceivable@illinois.gov.  Reference and/or be prepared to reference the source’s Bureau of Air ID# in all communications with the Agency.

To find out if you are current on your source’s annual site fee payments, you should contact the IEPA’s Fiscal Office at 217-782-3250 or via e-mail at epa.acctsreceivable@illinois.gov.  Reference and/or be prepared to reference the source’s Bureau of Air ID# in all communications with the Agency.  See ‘Technical’ Section FAQ #1 for how to determine your source’s ID#.

If you have not submitted for withdrawal of your ROSS prior to the billing due date on your invoice, then yes, the fee must be paid.  The Illinois EPA considers an active registration as an active source.  To resolve the issue, you will need to pay the total for which you are being invoiced and then submit a request for withdrawal for the source.  It is advised to submit the withdrawal as soon as possible after the permanent shutdown.

See ‘Administrative’ Section FAQ #6 for additional information on how to withdraw a permit.

The IEPA Bureau Of Air (BOA) will assign a unique identification number to your source when they approve your ROSS application and add it to the ROSS program.  It is geographically based and consists of six digits followed by three letters in upper case as in 123456ABC.  This number can be found in the upper left corner of the letter (known as the ROSS Confirmation Letter) you should receive from the BOA confirming your source has been granted a ROSS registration.  You should reference this BOA ID# in any communications with the IEPA.

This can be an involved question to answer.  To help with this, the Illinois DCEO’s Small Business Environmental Assistance Program (SBEAP) is developing a webinar series to help address this fundamental question.

If you need help in making this determination, please contact either the SBEAP program at dceo.sbeap@illinois.gov or (800)252-3998 or the Illinois EPA at (217)785-1705.

Yes.  The state of Illinois has a State Permit Exemption listing at 35 IAC 201.146.  The ROSS rule specifically excludes exempt emission units from inclusion in calculating the annual emissions total for ROSS at 35 IAC 201.175(b).

The exemption listing has many specific categories for processes which should be excluded.  A source should cross-reference their emission units and processes versus the exemption listing to determine what should and should not be included.  If you are in doubt as to the exemption status of an emission unit, please contact either the SBEAP program at dceo.sbeap@illinois.gov or (800)252-3998, or the Illinois EPA at (217)785-1705.

Note:  When determining whether a process has an exemption, there is a general category which cannot be used for a ROSS source, specifically 35 IAC 201.146(jjj), copied below emphasis added.

35 IAC 201.146(jjj)
“Replacement, addition, or modification of emission units at permitted sources that are not major sources subject to Section 39.5 of the Act and that do not have a federally enforceable State operating permit limiting their potential to emit…”

This exemption can only be applied to a source already holding a permit.  It therefore cannot be used if your operation only has one emission unit, nor can it be used at a ROSS source as ROSS is a registration program and not a permit program.

No.  If all of your emission units fit within one or more of the exemptions listed in 35 IAC 201.146, you are not required to register under the ROSS program.

Of note, you need to be aware that even if you are not required to register under ROSS, there may still be applicable state or federal regulatory requirements.  Some examples of exempt processes with applicable rules are:

1. State Requirement
   A material cutting operation exhausted inside a building could be exempt under 35 IAC 201.146(aa); however, it is still subject to an allowable particulate matter limit specified by the process weight rate rule (35 IAC 212.321) which may also require a control device to comply with.
2. Federal NSPS Requirement
   A 1,400 hp compression ignition engine could be exempt under 35 IAC 201.146(i); however, it is likely subject to the federal Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR Subpart IIII).
3. Federal NESHAP Requirement
   A metal part coating operation using 3,000 gallons of coating could be exempt under 35 IAC 201.146(g); however, it could still be subject to the federal National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products (40 CFR 63 Subpart MMMM).

USEPA maintains a list of so-called “Area Source” standards which apply to many small sources of emissions.  It is recommended that you review the Area Source rule listing with your emission unit listing to determine if a rule(s) may be applicable to your operation’s exempt emission units.

The broader state and federal rule sets can be found below.

• National Emission Standards for Hazardous Air Pollutants (NESHAP) | US EPA
• New Source Performance Standards | US EPA
• Title 35 Procedural and Environmental Rules (illinois.gov)

If you have any doubt regarding the applicability of a rule, you should contact either the SBEAP program at dceo.sbeap@illinois.gov or (800)252-3998 or the Illinois EPA at (217)785-1705 and seek clarification.

NOTE:  It is advised that in all cases regarding exempt emission units that you maintain documentation showing how you meet the exemption.  Some exemptions can be documented simply by a listing in a record on file.  In Example II above, maintaining documentation that the engine rating is 1,400 hp which is under the exemption level of 1,500 hp would be sufficient.  Other exemptions though, like Example III above, may require ongoing records showing the current usage is below the allowable rate of 5,000 gallons.  Were you to receive a site inspection from IEPA, these records may need to be provided.

No.  The portable emission unit rule specifically requires that an emission unit be permitted containing special conditions.  ROSS is a registration program, not a permitting program and does not contain any special condition, and so the portable allowances under that particular rule are not applicable to a ROSS source.

If you have an emission unit that is portable, you will need to apply for a ROSS at each location that it is moved to.

Additionally, when the portable emission unit that held the ROSS for the old location moves, in addition to applying for a new ROSS for the new location, you will additionally need to withdraw the ROSS for the old location.

See  ‘Administrative’ Section FAQ #6 for additional information on how to withdraw a permit.

No, there is no de minimis (i.e., minimum) threshold of emissions applicable to the ROSS program.  In other words, there is no level of emissions too trivial or minor beneath ROSS thresholds where a source would not be required to register in the program.

Emission units either fall under an exemption at 35 Illinois Administrative Code 201.146, or the emission unit must register with ROSS.

For additional information on state permit exemptions, see ‘Technical’ Section FAQ #3.

Not necessarily.  The ROSS rule was designed for actual aggregate emissions of less than 5 tons, but the rule was written to allow some flexibility to allow a situation for a temporary increase to not force a ROSS source into a Lifetime Operating Permit, and then transition back to ROSS shortly thereafter.

For the purposes of determining continuing eligibility with ROSS there is a two-step test you need to perform.

Test #1:
If your emissions for the prior* calendar year are less than 5 tons you pass the first test, you continue to be eligible for ROSS, and you don’t need to do the second test.  However; if you are not less than 5 tons for the prior year, you still might be eligible under the second test.

Test #2:

• Were your emissions for the prior calendar year less than or equal to 7 tons, and
• Were your emissions from the prior two calendar years less than or equal to 10 tons?
  
  * The rule’s usage of “prior” calendar year can be confusing.  The “prior” year is the current year under evaluation.  By the time you have the full calendar year of data you will be in the new year, so at the time you can make the evaluation you are evaluating the “prior” year which just ended.

Again, the ROSS program was designed for sources emitting less than 5 tons; however, it built in some flexibility to keep businesses from popping in and out of the program for temporary increases in emissions.  The flexibility allows emissions a peak rate of never greater than 7 tons and an average rate of never more than 5 tons over a 2-year period.  This might be somewhat confusing and can be better explained with an example.  Below is the analysis for a hypothetical source to see how the rule flexibility works.

• In 2019 and 2020, the emission rate is less than 5 tons.  The source remains eligible for the ROSS program by the first test and does not need to perform the second test.
• In 2021 emissions increased to 6.8 tons and therefore the source fails the first test by exceeding 5 tons.  This is where the rule flexibility might help the source stay in ROSS.  In applying the second test, you first check the prior year (i.e., the year which just passed) to see if it was less than or equal to 7 tons, and then check to see if the prior two years added together are less than or equal to 10 tons.
  
  In this example, 2021 is the prior calendar year and 2021 and 2020 are the prior two calendar years.  In 2021, the source was less than 7 tons and the sum of 2021 and 2020 is just less than 10 tons.  The second test is passed and the source remains ROSS eligible.
• In 2022 emissions are again above 5 tons.  The first test again fails and so you have to look at the second test.  In 2022, the prior calendar year is less than 7 tons (i.e., 5.1 tons).  Adding the prior two calendar years together (i.e., 2022 added to 2021) results in a total greater than 10 tons (i.e., 11.9 tons).  A two-year total of 11.9 tons averages out to 5.95 tons per year, and so the rule considers this a long-term increase rather than a temporary one.  At this point the source has failed the second test and must exit the ROSS program and obtain a traditional Lifetime Operating Permit.

See ‘Technical’ Section FAQ #8 for information of how to address exiting the ROSS program.

If a source fails to meet the ROSS eligibility requirements (35 IAC 201.175(a)), the source must leave the registration program and enter the permitting program, applying for the appropriate construction and operating permits going forward, according to the specifications of 35 IAC 201.175(g), summarized below:

1. If there was a new or modified rule which now makes your source ineligible for ROSS:  you must apply for a permit by the date required by the new or modified rule.
2. Did the source hold a Lifetime Operating Permit (LOP) prior to registration in ROSS?

NO:

YES:

Yes.  The ROSS program was specifically designed to alleviate the administrative matter of applying for permits or submitting notice for those sources who are eligible.  The rule specifically states at 35 IAC 201.175(a) that “an eligible source shall annually register with the Agency instead of complying with the requirement to obtain an air pollution construction or operating permit under the Act or complying with a permit issued under Section 201.169.”

Of note, while the ROSS program eliminates the administrative need to apply for a permit, the program does not change the of application or content of an applicable rule.

Additionally, while you do not need to provide notification with the addition of a new emission unit, you will need to include the new unit in the records required to show you remain eligible for ROSS.  See ‘Technical’ Section FAQ #11 for additional information.

The owner or operator of a new source shall register at least 10 days before commencing construction or operation, and may commence construction or operation 10 days after submittal to the IEPA, pursuant to 35 IAC 201.175(d)(1)(C).  Site fee payment is due at the time of registration.

Of note, ROSS registration applications are not automatically approved as the Illinois EPA will perform a review.  The Illinois EPA may determine that a ROSS application was deemed ineligible for the program.  It is therefore recommended that prior to commencing construction or operation, you should wait until you receive your ROSS Confirmation Letter from IEPA.  For additional information, see ‘Informational’ Section FAQ #6.

No.  One of the benefits of the ROSS program is that submission of an Annual Emissions Report (AER) is not required.

While a formal AER is not required, certain documentation must be kept and made available for inspection by the Agency upon request which demonstrate the source’s eligibility for the ROSS program.  You need to maintain:

• A current listing of the source’s emission units and, if any, the emission unit’s associated control devices (including control efficiency or emission rates).
• Documentation of the source’s actual emissions demonstrating that the source is eligible for ROSS.  This would include emission calculations and necessary supporting rational.  You should be maintaining a record of the variables which are the elements in the emission calculations you are using, these will typically be things like usage rates, material contents, machine specifications, emission factors, or test data.

Illustrative examples could include:

• Actual monthly coating usage rates.
• Type and actual quantity of fuel combusted for the month (e.g., gas bills).
• Widgets produced per month.
• Material data sheets showing VOC/HAP content.
• You mix at a ratio of 3 Parts A to 1 Part B.
• Machine data such as manufacture stated maximum processing rate.
• Manufacture control device efficiency rate guarantees.
• USEPA AP42 Emission Factors.
• Site-specific emission factor based on internal testing.
• Assumed or tested coating spray transfer efficiency rates.

The ROSS rule requires you to keep a copy of the annual fee payment for at least the most recent five (5) calendar years.  The ROSS rule is silent as to how long to maintain other necessary records, but it is recommended that you keep all documentation supporting the source’s actual emissions and calculations demonstrating the source’s eligibility for ROSS for the same most recent five (5) calendar years.

NOTE:  In lieu of annual emission report submittals, your payment of the annual site fee serves as the owner or operator's verification that the source continues to meet the eligibility criteria for the ROSS program.  See ‘Fee-Related’ Section FAQs #1-4 for additional fee-related information.

The ROSS rule lays out two scenarios when a notification is required:

1. The owner or operator of the source must notify the Illinois EPA in writing within 45 days after the change to the source:
   1. Name, address, or telephone number.
   2. Contact person responsible for submitting and retaining copies of the registration information and the records.
2. If you fail to meet the eligibility for ROSS, and you held a Lifetime Operating Permit (LOP) prior to your registration in ROSS, and you remain in compliance with the terms and conditions of your old permit.  Under this scenario you need to submit a notification to reinstate your Lifetime Operating Permit.  See ‘Technical’ Section FAQ #8 for additional information.

There are a number of issues which may contribute to a longer review time, some issues are in your control, some that are not.

Examples of issues that are outside of your control could include:

• Your source is located in an Environmental Justice (EJ) area.  To determine if your facility is in such an area, see ‘Other’ Section FAQ# 2.  If your operation is inside of an EJ area, that will automatically trigger an enhanced internal review.
• Assuming you recently purchased the source, historical issues for that source such as citizen complaints, odor issues or dust issues create a public interest and may warrant an enhanced internal review.
• While ROSS eligible HAP levels are small, operations that emit hazardous air pollutants (HAP) will be under greater scrutiny in relation to the type and quantity your application denotes you will be emitting.

Some issues that are inside of your control could include:

• Incomplete registration applications are the main issue which will slow things down.  Be sure to completely address all requested fields on the ROSS 200 form.
  
  If you have any question on how to complete the form, you should contact either the SBEAP program at dceo.sbeap@illinois.gov or (800)252-3998 or the Illinois EPA at (217)785-1705 and seek clarification prior to submitting.
• Did you forget to attach a completed APC 391 Operating Program For Fugitive Particulate Control (Fugitive Particulate Matter Operating Program (FPOP)) form if it was needed?
• Questionable control efficiency rates will trigger greater scrutiny.  If you are claiming a 99.99% particulate matter control rate for a cyclone, especially if that rate will determine whether or not you are eligible for the program, the Illinois EPA will likely follow-up asking for manufacture or site-specific testing data proving up that claim.
• The use of nonstandard emission factors will likely warrant extra scrutiny from the Illinois EPA.  There are many standard and accepted emission rates, if you are claiming something vastly lower than what is standard for a standard process, the Illinois EPA will likely follow-up asking for data proving up that claim.
• Emission calculation issues are very common and might include:
  • A lack of detail in your emission calculation.  You need to provide enough detail and supporting information such that the Illinois EPA can spot check and recreate your numbers.  This is especially true for Hazardous Air Pollutants (HAPs) emission calculations.
  • Failing to document or explain the assumptions fundamental to the emission calculation.  For example: failing to document the origin of the emission factor you used, failing to explain why you used the lowest side of the range of VOC content on a material data sheet, failing to explain your use of a high emission control rate, if no standard emission factor exists for your specific process why the emission factor you are using is adequate (e.g., while not exact, this factor is similar, and because it was C-rated, we added a 10% safety factor to account for uncertainty and are well below the threshold).
  • The Illinois EPA cannot recreate the results of your provided calculations.  Perhaps you made a math error, which is very common on spreadsheets when cells are dragged and copied.  Double check your emission calculations prior to submitting.
  • You provided sample calculations for only some of your processes, but not all.  The Illinois EPA will want to see at least a sample calculation for each kind of process to prove that you will be following proper practices in determining eligibility for the program.

In brief summary, Environmental Justice (EJ) is a policy to ensure that communities are not disproportionately impacted by degradation of the environment or receive a less than equitable share of environmental protection and benefits.  For a much more detailed explanation of the policy, please see the Illinois EPA page dedicated to the topic:  Environmental Justice (EJ) Policy (illinois.gov)

If a ROSS source is in an EJ area, the source will undergo an enhanced internal review consistent with the policy.

The Illinois EPA has a GIS mapping tool known as EJStart which will allow you to easily determine whether you are in an Environmental Justice (EJ) area.  Below is an edited screenshot of the tool before entering a location.

• The red arrow is the search bar where you enter the source location address.
• The blue arrow is a convenient locating tool if the computer you are using is at the source.  By clicking it, it should zero in on your location saving a little time entering the address.  Be sure to sanity check the location it jumps to for accuracy.
• The green arrows denote EJ areas throughout the state.  As you can see, EJ areas are common, and you can see by the legend at the far right that EJ areas are either for a minority population (blue) or low income (yellow), or the combination of the two (red).

To use the tool, you simply enter an address into the field in the top right, and then execute a search using the magnifying glass icon to resolve the map like the below.  Alternatively, you can use the “My Location” tool by clicking in the search box.  The below is based on the SBEAP office location as a proxy for an emission source.  Your particular location will either be in or out of an EJ area as the identified areas already contain a boundary buffer.  In the example below, the SBEAP office is in an area designated as both low income and minority population for Environmental Justice and would therefore be under enhanced review by the Illinois EPA following its Environmental Justice Policy (see 'Other' Section 1 for additional information).

What are they: The North American Industry Classification System (NAICS) is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.  NAICS was developed and adopted in 1997 to replace the Standard Industrial Classification (SIC) system.

NAICS is based on a production-oriented concept, meaning that it groups establishments into industries according to similarity in the processes used to produce goods or services.  SIC codes are based on primary business activities and are a much more general classification system.

1. Do I really need to fill them in?
   
   Yes.  The IEPA uses this information to better determine and verify program eligibility as well as other administrative needs.
2. What happens if I do not fill them in?
   
   If you do not provide the NAICS/SIC data, the IEPA will be required to contact you to obtain that information.  This slows down the overall process for IEPA, other permit and registration seekers in the queue, and will act as an interruption to you as you will have to field the call.
3. How do I find my NAICS and SIC numbers:
   
   There are a number of free and easy to use online tools that you can use to look up your operations NAICS or primary SIC numbers using keyword searches.  Some of the tools have help files to guide on how to use their tool. Screenshots of each link are included for your confirmation.
   
   https://www.naics.com/search/
   
   https://www.naics.com/everything-sic/
   
   
   If you know one of either of your NAICS or SIC codes, you can use the “crosswalk” page to seek out your missing code:  https://www.naics.com/naics-to-sic-sic-to-naics-crosswalks/
   
    
   
   The Census.gov site has both a keyword search tool as well as a downloadable manual of the entire listing:  https://www.census.gov/naics/
   
   
   
   The OSHA.gov site has an easy to search online SIC Manual where you find your major SIC group and then drill down to your industry group:  https://www.osha.gov/data/sic-manu us.