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Criteria Toxics Reporting

Learn about the California Air Resources Board's regulation for criteria pollutant and toxics emissions reporting.

The California Air Resources Board, or CARB, adopted a new regulation for criteria pollutant and toxics emissions reporting titled, “Regulation for the Reporting of Criteria Air Pollutants and Toxic Air Contaminants (CTR)."

For more information, please visit CARB’s CTR web page.

The CTR Regulation aims to:

Require calendar year reporting of criteria and toxic pollutant emissions data from regulated air emissions sources; and
Establish consistent statewide annual emissions inventory data.

Compliance with CTR reporting will be implemented through:

The Data Update for the emissions inventory during the permit renewal process.
Other non-emissions inventory CTR data requirements may be requested during the Data Update or via a separate request.
Failure to provide required CTR information may be subject to enforcement action under the rule.

How is CTR reporting different from the Air District’s Data Update?

Data Update forms for CTR are sent to impacted facilities in early January regardless of the facility’s permit expiration date.
Reported data will represent the previous calendar year material usage/throughput, activity, and emissions. That means your reported data covers activity from January 1 to December 31.
Information for all permitted devices/sources with a Permit to Operate will be required.
- The only exception would be any new device/source started up during the permit renewal process.
Additional CTR data requirements may be collected during the Data Update or via a separate request.

Who is subject to CTR reporting?

*A Priority Score is an Air District calculated number based on the estimated air toxics emitted at a facility.

Is my facility subject to Applicability 1 or 2 requirements, and what are the next steps?

If you are required to report for CTR as an Applicability 1 or 2 facility, the Air District will send Data Update forms for CTR around late December or early January every year to the current facility contact.

For my Applicability 1 or 2 facility, what are the next steps to satisfy CTR reporting?

The Air District will notify you and send out the Data Update for CTR reporting.
The owner or operator will be required to return the Data Update forms by the due date.
For facilities with numerous sources, you may be contacted and receive via email your Data Forms in Excel or fillable PDF format instead of hard-copy paper. Your electronic submissions of the completed forms will help process your data more efficiently.
- The Air District is developing a system to better collect this information in the future.
For detailed instructions, reference the documents:
Instructions: How to Comply with Criteria Toxics and Reporting Requirements - Paper Forms(119 Kb PDF, 2 pgs, posted 1/13/2022)
Instructions: How to Comply with Criteria Toxics and Reporting Requirements - Electronic Forms(263 Kb PDF, 2 pgs, revised 4/27/2023)

Is my facility subject to Applicability 3 or 4?

If your facility requires specific reporting under CTR, the Air District will notify you.
There has been no change in the current process for Applicability 3 and 4 facilities.
If the Air District requests information via Data Update forms, returning your completed Data Update forms satisfies CTR reporting.

I am still unsure if I am subject to CTR and if I am complying with CTR reporting. What do I do?

The Air District is responsible for reporting emissions from permitted facilities to the California Air Resources Board. This is accomplished during the permit renewal process by customers completing and returning Data Update forms.

If the Air District requests information via Data Update forms, as long as you return your completed Data Update forms, you have satisfied CTR reporting.
If your permit is current (not expired), that is an indication that you have satisfied CTR reporting.

What happens if I do not return the Data Update forms on time?

The owner or operator may be subject to a violation.
Late reporting may prevent or delay your permit renewal invoice from being issued.

Are there any other best practices I should follow?

Keep your facility contacts up to date. Fill out and submit a Facility Contacts form as needed.
If you receive Data Update forms, complete and submit them by the due date to avoid delays in the permit renewal process.

Does the Air District have plans to improve CTR reporting?

The Air District is designing a system to fully implement CTR requirements, including providing Data Update responses online.

How do I return my completed Data Update forms?

Do not create any custom forms or files. Only return completed forms as provided by the Air District.
By email (preferred)
- Email completed forms to DataUpdate@baaqmd.gov
  - Do not add any additional Air District email addresses
- Use subject line “CTR reporting for Facility ID/Plant #:XXXXX”
- Attach only PDF or image files (e.g., jpeg, jpg, png, tiff, bmp)
  - Some facilities have specifically been asked to pilot reporting using an Air District-provided Excel file
- Email plus attachments are limited to 35 MB in size
By mail:

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San Francisco, CA 94105

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Last Updated: 10/30/2020

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