Air Monitoring Directive FAQs

Frequently Asked Questions about Alberta’s Air Monitoring Directive

Air Monitoring Directive Revision

Why was the Air Monitoring Directive (AMD) revised?

The AMD was written in 1989 and an amendment was released in 2006. Both documents were out of date. The AMD was revised to bring the directive in line with current practices, technology, legislation and approval requirements.

In some cases, requirements were added to ensure that the Regulator and associated agencies receive the necessary air quality information to be able to craft effective policy, make management decisions, report on the state of air quality, and ultimately manage cumulative effects to the environment.

The amendment also serves to incorporate airsheds into the definition of person responsible and require electronic reporting of summary information that is reported in monthly and annual air reports.

How was the AMD revised?

All sections of the 1989 and 2006 AMD have been reviewed and revised, and new sections have been developed. The revision was completed in chapters with input from Alberta Environment and Parks (AEP) and the Alberta Energy Regulator (AER).

As each chapter was completed, drafts were provided via the AMD website for stakeholder review and feedback. Feedback was incorporated into a final version and the chapter and the response to feedback were posted to the AMD website.

Stakeholders have been notified of revision progress through an email distribution list as well as through regular webcasts.

Where do I find the new requirements and what if I have questions?

The AMD website has a table of contents with links to each of the nine chapters of the revised AMD. Also, Chapter 1 has a correlation table which compares the revised to the former requirements and includes dates for when new requirements take effect.

Questions on the revised AMD can be directed to:

Some of the requirements in the revised AMD seem to be open to interpretation. How can we discern what is the intent of the new requirements?

It is important to consult Chapter 1 of the AMD (the Introduction), where all definitions for the AMD are housed. Chapter 1 also has general requirements that pertain to the AMD as a whole. Industrial operations also need to consult their approval conditions when interpreting how AMD requirements apply to them.

If you have questions on how to interpret a clause you can direct your question to your Alberta Environment and Parks/Alberta Energy Regulator approvals coordinator (or airshed representative in the case of airsheds) or for general inquiries email:

What changes have been made to Continuous Emission Monitoring System (CEMS) monitoring?

No changes were made to CEMS monitoring as part of the AMD revision. As was required by the 2006 AMD, and continues to be required by the revised AMD Chapter 9, industrial operations must electronically submit all CEMS data collected by any CEMS that is required by approval requirements. CEMS monitoring is still dictated by the approval and the CEMS Code. The CEMS Code is in the process of being updated. A draft will be posted for public review on the AMD website once available.

Section 6 of the CEMS Code states that quarterly reporting required in section 6.2 ceases to apply once CEMS reporting is incorporated into the AMD. Therefore, the revised AMD now supersedes section 6.2 of the CEMS Code.

Chapter 9 of the AMD now requires monthly reporting on CEMS (in place of quarterly reporting) via the AMD CEMS Summary Form. Manual Stack Survey, Cylinder Gas Audit (CGA) and Relative Accuracy Test Audit (RATA) reporting requirements are also now within AMD Chapter 9.

Can I provide feedback on the AMD once the new requirements are in effect?

Yes. Environment and Parks would like to receive feedback from stakeholders as they implement the new AMD requirements. Feedback can be submitted at any time to:

How will the new AMD chapters be reviewed and revised?

The new AMD chapters will have a regular review cycle after requirements come into effect. Chapters will be updated or amended as needed. Feedback received from stakeholders will be taken into account during this review.

Drafts will be posted for stakeholder review and comment for any substantial changes to requirements. Any new chapters developed will follow a similar review process.

How can I stay up to date on AMD changes and implementation?

Notifications are sent to stakeholders via an email distribution list. Sign up for notifications under the AMD Mailing List section at:

AMD Requirements and Compliance

Who does the revised AMD apply to?

The requirements of the revised AMD, unless otherwise specified, apply to:

  • The owner of a facility that is the subject of an approval or other authorization under the Environmental Protection and Enhancement Act (EPEA)
  • The holder of an approval or other authorization under the EPEA
  • The Alberta airshed
  • Any other person specified in any other part of the AMD

My approval says to follow the "Air Monitoring Directive, 1989, as amended". Does this mean I now follow the new AMD requirements, or does my approval need to be revised?

The new AMD requirements (2016 AMD version) amend the 1989 AMD and its 2006 amendment. Approvals require adherence to the AMD 1989, as amended. Therefore this 2016 amendment to the 1989 AMD is included under current approval clauses.

Approvals do not need to be revised. Approval holders that are currently required to follow the AMD 1989 are now required to follow the 2016 AMD. Some 1989 AMD and 2006 AMD requirements will remain in effect until Chapter 9 (Reporting) requirements come into effect in 2019.

When do the new AMD requirements come into effect?

Effective dates vary by chapter; therefore each chapter must be referred to. The AMD website homepage lists the overall compliance date for each chapter; however, some chapters also have specific compliance dates for individual requirements.

What monitoring and reporting requirements must be followed in the interim, before compliance dates for new requirements are reached?

Requirements in the 1989 AMD and 2006 amendment are in place until compliance dates for the new AMD requirements are reached. Chapter 1 has a correlation table which compares the old and new requirements and provides the compliance date for each chapter.

With revised AMD chapters coming into effect at different times, is the person responsible required to revisit past projects and ensure they are compliant with each chapter as it comes into effect or will existing sites be grandfathered?

In general, no – there will not be grandfathering. Each approval holder, airshed or other person responsible who monitors air quality and reports to the Regulator will need to comply with the revised AMD. However, some individual requirements are specific to approval conditions.

What happens if there is a conflict between AMD requirements and my approval?

Regulations and approvals supersede the AMD if there is a direct conflict. For example, if an approval provides a date for submission of monthly reports, then that is the date the monthly report would need to be submitted.

Under the new AMD requirements, is a contractor able to conduct monitoring and reporting on behalf of a facility or airshed?

Yes. Third party contractors can carry out monitoring, prepare reports and submit reports/data/forms on behalf of the person responsible. Facilities and airsheds remain responsible for what is submitted, as well as for meeting AMD requirements.

How is the AMD enforced?

The AMD is enforceable under the Environmental Protection and Enhancement Act (EPEA) approvals, contracts and grants with airsheds, and will also be enforceable through proposed revisions to the Substance Release Regulation. Contraventions of the AMD would be handled as any other contravention, with compliance actions used at the discretion of the Regulator.

Do the changes have a direct effect on approval holders if they participate in an airshed?

The AMD requirements apply to the "person responsible" which is the party that is responsible for the monitoring and reporting to the Regulator. The approval holder is required to follow the AMD for all air monitoring and reporting that is conducted by the facility.

If an approval holder participates in an airshed, there may be ambient air monitoring and reporting that the airshed conducts on the facility’s behalf. The only chapter that does not directly apply to approval holders is Chapter 2 (requirement for airsheds to develop a monitoring plan).

How is non-compliance with the AMD handled?

There is no change from current practice. In accordance with the Environmental Protection and Enhancement Act (EPEA), all contraventions of the AMD must be immediately reported. Persons responsible must exercise due diligence and report any non-compliance with the AMD by calling it in according to the instructions provided in A Guide To Release Reporting and the Reporting Spill and Releases Fact Sheet which are available under the Reporting section at:

If in doubt, it is recommended to err on the side of caution and call it in.

If my facility’s monitoring requirements are fulfilled through airshed monitoring, am I still the "person responsible"?

For the most part, yes, the facility’s role and responsibilities do not change. The facility is responsible for the requirements in the facility’s approval as well as meeting AMD requirements for any air monitoring and reporting that the facility conducts.

The facility’s relationship with an airshed is analogous to that of a contractor. The airshed conducts ambient monitoring on behalf of the facility, and under the AMD the airshed must adhere to AMD requirements. However, the facility is still accountable for ensuring that approval requirements and AMD requirements are being met by the airshed.

How can I make sure that the airshed complies with the AMD requirements, if I am not doing the monitoring?

As with a contractor, the person responsible is accountable, in the regulatory context, to the Regulator for the data submitted. As part of due diligence, some facilities conduct second or third party audits of airsheds who monitor/report on their behalf. Facilities should be aware of the airshed’s Quality Assurance Plan (QAP) and stay abreast of the airshed’s monitoring activities. As well, some facilities participate on airshed boards or technical committees.

Can you compromise AMD requirements of continuous air monitoring when several facilities are operating within a part of a region?

No. No matter how many facilities are operating in a given area, the requirements of the AMD apply to all monitoring in the province, required by an approval or conducted by an airshed or other party, for which data is reported to the Regulator.

Each monitoring station must comply with the requirements of the AMD for monitoring and reporting.

Chapter 2: Ambient Air Monitoring Program Planning

Who from the Department will provide authorization (e.g. of an airshed monitoring plan)?

The Director, as designated under the Environmental Protection and Enhancement Act (EPEA), will provide authorization or signoff for AMD requirements.

Where do I submit my airshed monitoring plan or status update for AMD Chapter 2?

Just as with monthly or annual report submissions, airshed monitoring plans and implementation status updates under Chapter 2 are emailed to:

It is recommended that Environment and Parks regional airshed representatives be copied on the email.

Chapter 4: Monitoring

Does the revised AMD require additional air monitoring to be conducted?

No. The revised AMD only sets out minimum requirements for how to conduct air monitoring. Monitoring requirements are set out in the approval, or decided on through a multi-stakeholder process for airshed monitoring. However, the AMD may require additional estimations or calculations, not specifically set out in approval requirements, in order to meet the specific reporting requirements set out by the AMD. In absence of monitoring data, a reasonable effort must be made to otherwise determine the required information.

What if ambient analyzers operate at specifications above and beyond that required in Chapter 4? Do we need Director authorization?

Chapter 4 of the AMD outlines the minimum specifications that analyzers in use must be capable of meeting. If an analyzer is operated at specifications above the minimum requirement (more stringent, greater precision/accuracy), Director authorization is not required. Director authorization is only required if an analyzer is not capable of meeting the minimum specifications.

Chapter 5: Quality System

Do I have to prepare a Quality Assurance Plan (QAP) even if I don’t monitor but report air data – that is, for example, based on emissions estimates and calculations?

Yes, the requirements for the QAP still apply; however, the complexity of the QAP and the efforts associated with documentation and record keeping may be lower, where appropriate, as compared to a facility that conducts various monitoring activities.

Who is responsible for drafting the QAP if I use a contractor or airshed for my monitoring and reporting activities?

The person responsible is required to have a QAP for the monitoring, reporting and maintenance related activities that they undertake, including but not limited to the processes used to hire contractors and evaluate their performance in conducting monitoring activities.

The contractor or airshed is also required to have a QAP that meets the requirements of the AMD for the monitoring, reporting and maintenance related activities they undertake on behalf of the person responsible. While hiring a contractor to conduct monitoring and reporting activities does not remove the responsible person’s requirement to have and follow a QAP, the responsible person’s QAP may refer to a contractor’s QAP for activities that have been contracted out.

Do I have to share my Quality System and/or air monitoring data with an airshed?

This would depend on the arrangement between the airshed and the approval holder. It is suggested that approval holders and airsheds share information and learnings, when it comes to monitoring and reporting, and as appropriate.

Does the QAP need to be located at the continuous monitoring station?

Yes. Any information and data required for the technical station audit must be available onsite at the station including the QAP. Available includes electronic access. All documents and records must be produced during an audit upon request.

Do the QAP requirements of the Quality System Chapter apply to CEMS?

No. The CEMS Code has requirements for a QAP, which are very similar to the AMD requirements. There should be no conflict between the two sets of requirements.

Is a guide or template available for the Quality System/QAP?

No, a guide or template has not been developed. Facilities and airsheds have a highly variable nature; therefore, a "one size fits all" approach would not satisfy the needs of the individual facility or airshed.

Is it is still necessary to retain original hard copies of field sheets or are scanned/electronic versions suitable?

Records retention is covered in Section 3.0 of AMD Chapter 5. The format of retention is not specified. Records may include electronic, written, photographed, or otherwise recorded evidence, including data.

Chapter 7: Ambient Calibration and Chapter 8: Ambient Audit

Chapter 7 requires that a zero/span be completed daily on continuous ambient analyzers 23 to 25 hours apart. What if a zero/span is missed in a 23 to 25 hour period due to equipment malfunction? Would this be considered an AMD contravention?

If a zero/span is missed within a 23 to 25 hour period due to equipment malfunction or another issue, and if the issue can be rectified, a zero span can be completed later on in the day. In such a case, the hour during which the zero/span is completed would need to be flagged as the calibration hour. This would be noted in the monthly report.

After one zero/span is completed in a day, any additional zero/spans would contribute to accrued downtime for maintenance. A contravention would occur if the additional zero/span accrued downtime resulted in the site not meeting the 90 per cent uptime requirement.

If in doubt on whether or not to report a potential non-compliance, it is recommended to err on the side of caution and report.

Chapter 8 requires that each calibration system be calibrated to the Environmental Monitoring and Science Division (EMSD) reference calibrators annually. Does this require that in-situ calibration systems be removed and transported to EMSD’s lab?

Each in-situ calibration system must be verified directly to EMSD’s reference calibrators and gases on an annual basis. If the calibration system must be removed and transported, notification should be given to any applicable approval holders that the calibration system will be out for a number of days.

It is recommended that as an alternative, a spare calibration system be verified by EMSD and used as a direct reference to the EMSD system. On-site records would need to be maintained to show the direct reference and confirm that the results of the comparison of each system meets AMD requirements.

Will EMSD conduct a site audit at each continuous ambient monitoring station each year?

EMSD currently audits airshed ambient stations annually and industrial ambient stations once every two to three years unless otherwise requested by Environment and Parks or the Alberta Energy Regulator.

Chapter 9: Reporting

Does the Reporting Chapter apply to facilities whose air monitoring requirements consist solely of CEMS monitoring?

Yes. The Reporting Chapter of the AMD applies to all Environmental Protection and Enhancement Act (EPEA) approved facilities. However, not all of the reporting requirements will apply to all facilities. If a facility only carries out CEMS monitoring, then only the sections of Chapter 9 related to CEMS would apply (e.g., electronic CEMS data submission, certain monthly/annual reporting requirements, Relative Accuracy Test Audit (RATA) Reports and Cylinder Gas Audit (CGA) Reports).

Is Section 6 of the CEMS Code (on CEMS reporting) now obsolete?

Section 6 of the CEMS Code states that quarterly reporting required in section 6.2 ceases to apply once CEMS reporting is incorporated into the AMD. Therefore, the revised AMD now supersedes section 6.2 of the CEMS Code.

Chapter 9 of the AMD now requires monthly reporting on CEMS (in place of quarterly reporting) via the AMD CEMS Summary Form. Manual Stack Survey, Cylinder Gas Audit (CGA) and Relative Accuracy Test Audit (RATA) reporting requirements are also now within AMD Chapter 9.

How will ambient data reporting requirements change for industrial facility stations?

Any facility required by an approval to conduct ambient monitoring will be required to electronically report ambient air data to AEP, as per the requirements in the Reporting Chapter (Chapter 9). This will include any ambient data from continuous, passive or intermittent monitoring that the industrial facility conducts. If an airshed conducts ambient monitoring on behalf of the facility, it would be the airshed that reports the ambient data.

Ambient air data will be submitted online through ETS (the Electronic Transfer System). Ambient data must be submitted using XML (eXtensible Markup Language). The XML schema is posted at:

More information on submission of XML files to ETS will be provided to the AMD email distribution list. Sign up for notifications under the AMD Mailing List section at:

How many additional continuous ambient monitoring stations are expected to be reported online as a result of the changes to reporting requirements?

The Reporting Chapter requires that industrial facilities report all ambient air data electronically to the ambient air quality data warehouse, as airsheds currently do. With industry data added, there will be an addition of approximately 100 or more ambient stations submitting data which will be publically available online.

Will there be a new protocol for reporting ambient data to the online Data Warehouse?

Yes. AEP is developing a new air data management system for intake, storage and dissemination of air data. Airshed and industrial facilities will submit ambient data online through ETS (the Electronic Transfer System). Ambient data must be submitted using XML (eXtensible Markup Language). The XML schema is posted at:

More information on submission of XML files to ETS will be provided to the AMD email distribution list. Sign up for notifications under the AMD Mailing List section at:

When does electronic reporting of ambient data begin?

Industrial facilities will begin to report ambient data to ETS (the Electronic Transfer System) beginning in January 2019.

Airsheds will continue to submit to the airdata warehouse, as they have been, until the new air data management system has full reporting capabilities enabled to allow for extraction of data and reports. Reporting capabilities of the new air data management system will be added and enhanced over time from 2019 to 2021. Once the reporting functions are built into the new air data management system for ambient data, airsheds will use the new ambient XML schema to report their ambient data to ETS. The timeline for this transition has not yet been determined.

Are industrial facilities required to electronically submit 2018 ambient data?

No. The first ambient data submission for industrial facilities will be at the end of February 2019 for January 2019 data. Industrial facilities are not required to electronically submit 2018 ambient data.

What is required to be submitted with ambient data?

When ambient data is uploaded to ETS (the Electronic Transfer System), a PDF calibration report is required to be submitted for continuous ambient data and a PDF certified laboratory analysis report is required to be submitted with intermittent or passive ambient data. A naming convention will be provided for these two reports.

Starting in 2019, industrial facilities will upload calibration and certified laboratory analysis reports to ETS at the same time that ambient data is uploaded. Airsheds will continue to provide their ambient air data to the airdata warehouse in 2019 and will submit PDF calibration and certified laboratory analysis reports by email along with their monthly report. When airsheds begin submitting their data through ETS, these two reports will be uploaded at the same time as ambient data upload. The timeline for this transition for airsheds is still to be determined.

What does the term "release" mean in the AMD Reporting Chapter?

The term "release" in the Reporting Chapter means an air release or a release affecting the air.

What does "immediate" notification mean?

According to A Guide to Release Reporting, immediate reporting means reporting a release, exceedance or contravention at the first available opportunity, as soon as the person responsible knows, or should know about the release, exceedance or contravention.

More information on how to provide immediate notification can be found in A Guide to Release Reporting or the Reporting Spills and Releases Fact Sheet which are available under the Reporting section at:

Who is responsible for notifying of exceedances of Ambient Air Quality Objectives when an airshed is conducting monitoring on behalf of a facility?

Generally, it is the responsibility of whoever is conducting the monitoring to do the reporting. However, it is up to the facility and airshed to determine who will call in Ambient Air Quality Objective exceedances. This should be documented in both the facility’s and the airshed’s QAP.

Do exceedances of both ambient objectives and guidelines need to be reported?

Yes. Chapter 1 of the AMD provides a definition for Alberta Ambient Air Quality Objectives (AAAQOs) as including guidelines as well. Exceedance of both objectives and guidelines (e.g., fine particulate matter) must be reported according to Chapter 9.

Do exceedances of ambient objectives need to be reported for passive data?

Yes. Passive data would be compared to monthly or annual objectives, as applicable, and reported in the monthly or annual report.

AMD Chapter 9 requires that passive data be reported one year following data collection; however, my approval requires monthly reporting on passive data. Which timeline do I follow?

The approval takes precedence. Reporting passive monitoring results one year following collection is the minimum requirement; however, if an approval requires monthly reporting of passive data, the passive data needs to be submitted monthly via XML upload and the data would be summarized in monthly reports.

Can I submit my airshed monthly or annual report via email?

Yes. Beginning January 1, 2019, all reports are required to be submitted electronically. Until that time, airsheds are able to begin submitting their reports by email, using the naming conventions provided in the EPEA Approval Industrial Monitoring Documentation Submission Naming Guideline, to:

For file naming, airsheds should substitute their airshed acronym in place of approval number and they would not include IAM (Industrial Air Monitoring).

The EPEA Approval Industrial Monitoring Documentation Submission Naming Guideline is available under the Reporting section at:

If monitoring is carried out for our own purposes, are we required to report the data?

No. Monitoring conducted for the person responsible’s own purposes (i.e., not required by the Regulator) does not need to be reported under the AMD. However, if for any reason, monitoring data collected for the person responsible’s own purposes is being submitted or going to be submitted to the Regulator, it must meet all AMD requirements (for monitoring, reporting and equipment maintenance) in order for the Regulator to accept the data.

Do results of incomplete source tests need to be submitted under the AMD Reporting Chapter?

Yes, information on incomplete source tests (manual stack surveys, RATAs, CGAs) must be submitted. This includes: providing a brief overview of any incomplete source test as part of monthly/annual reports, submitting a source testing report for any incomplete source test, and providing a summary of the results of any incomplete source test using the appropriate AMD Form.

Why has Alberta Environment and Parks (AEP) moved to reporting using Excel-based forms instead of online reporting?

Excel forms have been used for emissions reporting in the past. They were chosen as a low cost interim solution for collecting summary data in an extractable, digital format. XML schema are also being provided for submission of the form data. Industrial facilities can choose to submit the Excel forms or XML files starting in January 2019; however, XML is the format of data submission going forward. The long-term goal is to move towards more comprehensive online reporting of environmental data.

Are there any limitations to submission of the Excel form?

If industrial facilities choose to submit the Excel forms rather than XML, the Excel forms must be submitted as .xls (Excel format) files. Forms submitted as PDF will not be accepted. The version of Excel used to populate and save the Excel form must be 2010 or later. Earlier versions of Excel will convert the AMD forms for compatibility, which would make them unacceptable for upload into the new air data management system. Excel forms that have been converted will not be accepted. If Excel 2010 or later is not available to you, XML would be the option for AMD form submission.

What if a field in a reporting form or an entire form does not apply to our operations? What if we cannot fit our summary data into the form?

Not all reporting forms will be relevant to all facilities and not all fields in a given form will apply. You would not submit a form if it does not apply to your operations (e.g., you would not be required to submit an AMD CEMS Summary Form if you do not conduct CEMS monitoring).

Blank forms do not need to be submitted. Similarly, a field in a form may be left blank if it does not apply to the facility’s operation. In that case the comment field in the form can be used to provide a reason for the blank field(s).

The forms have been created from the original reporting tables that were provided in the appendix of the 1989 AMD as well as current monthly, annual and source reports submitted by facilities. The forms have been designed to suit all facilities and sectors; however, it is recognized that they may not suit all equally well. Ultimately, if key pieces of data/information cannot be inserted into the forms (e.g., special reporting), the information must still be provided in monthly/annual/source reports, as is currently done. The forms do not replace monthly, annual and source pdf reports. They are considered a supplement to these reports.

How do reports and forms get submitted?

Submission of reports (monthly, annual, source sampling) will follow the same protocol as current, submission by email according to the Acceptable Formats for EPEA Approval and Code of Practice Records and Submission Coordinators for AEP regulated facilities and airsheds and the Acceptable Formats for EPEA Approval and Code of Practice Records and Submission Coordinates for Energy Projects for AER regulated facilities.

Report files follow the naming conventions set out in the EPEA Approval Industrial Monitoring Documentation Submission Naming Guideline.

Acceptable formats and naming guidelines for air reports are available under the Reporting section at:

The AMD reporting forms will have a different submission method – they will not be emailed. The Excel reporting forms or XML files will be uploaded to the ETS (Electronic Transfer System) online portal. An ETS account is required before an industrial facility can upload to ETS. Naming conventions for the AMD forms are provided in the instructions tab in each form. The naming convention for submission of XML files will be shared when the XML schema are posted.

How do I obtain an ETS account for submission of ambient air data and AMD reporting forms?

An ETS account is required for submission of ambient air data, PDF ambient calibration reports and certified laboratory analysis reports, and for submission of the AMD reporting forms. Some companies (the legal entity of an industrial operation) already have an ETS account. Airsheds and companies that do not have an ETS account will need to submit an application form to request an account before submission begins in January 2019.

Companies that already have an ETS account would use their existing ETS account and will be granted access to the air data submission component. Some companies with an existing ETS account will need to create sub-accounts for the facilities that will be reporting under AMD Chapter 9 – a sub-account for each submitter (including any contractors submitting on an industrial facility’s behalf).

After the testing phase of the new air data management system is complete, a link will be provided on the AMD website for ETS and the application form for requesting an ETS account. Note that it takes up to two weeks for a new ETS account to be processed.

Do submission of the AMD reporting forms replace submission of monthly, annual and source sampling reports?

No. The electronic reporting forms must be submitted in addition to monthly, annual and source sampling reports. The purpose of the forms is to pull data which were previously submitted as tables within monthly, annual and source sampling reports and provide this in a digitally extractable format. The forms are to be submitted at the same time as the relevant monthly, annual or source sampling report. See the instructions tab on the form for directions on how to submit the Excel form or see the XML schema for form data (once posted) for instructions on submitting the XML file for form data.

Do we need to wait until January 2019 to begin using and submitting the AMD reporting forms, or can they be submitted earlier?

Although the forms are not intended or required to be submitted prior to January 1, 2019, AEP will accept any reporting forms which are submitted prior to January 1, 2019. The forms were released one year in advance to allow reporters time to review the forms and prepare for implementation in 2019.

Whether or not the forms are used prior to 2019, the person responsible must continue to ensure that all current approval/AMD reporting requirements are fully met.

Form and XML submission to the new air data management system is being testing from September to October 2018 using a select group of airshed and industry testers.

Which AMD forms apply to airsheds?

There are no AMD reporting forms that apply to airsheds. AMD forms 1 through 12 only apply to industrial operations.

With online submission of ambient data to ETS, do I still need to complete and submit the Ambient Data Validation and Certification Form?

No. The new online submission system includes a validation and certification step. The Ambient Data Validation and Certification Form is no longer required. AMD Chapter 9 will be updated accordingly.

Do exceedances of ambient objectives need to be included on the AMD Contravention Form?

No. Ambient Air Quality Objective exceedances are not approval contraventions and do not need to be included on the AMD Contravention Form. Exceedances of Objectives and Guidelines do however need to be immediately reported for public safety reasons and these need to be identified in monthly and annual reports.

If an hourly limit has been exceeded and it is exceeded for an extended period, do we need to fill out the AMD Contravention Form for each individual hourly exceedance within the extended period, or do we report on the event as a whole?

You do not need to fill out a separate line for each hourly exceedance of a limit, if the hourly exceedances all result from the same incident, same cause, and were dealt with by the same corrective action. The form has fields for start date/time and end date/time for incidents over an extended time period.

Separate incidents do need to be reported on separate lines though. For example if there is an incident related to a sulphur surge for 4 hrs in the morning, then there is a power outage 2 hours later, each of those incidents would need to have a start and end time. As well if on top of hourly exceedance, another timeframe exceedance occurs (e.g., 24-hour), that would be reported separately.

If my facility has only annual reporting requirements, no monthly reporting requirements, does AMD Chapter 9 now require that I submit monthly forms?

The approval dictates the frequency of reporting, while the AMD sets out minimum requirements for what to include in those reports. There are several clauses in the annual report requirements section of Chapter 9 (section 6.0) that require that monthly forms be submitted with the annual report if they have not already been submitted monthly. This does not mean that the forms need to be submitted on a monthly basis, but rather it means that the monthly summary data needs to be submitted collectively with the annual report. The instructions tab in the forms explains submission of monthly forms with an annual report.

For example, if you conduct sulphur recovery and only have an annual reporting requirement, you would submit 12 monthly AMD Sulphur Recovery and Removal forms with your annual report to cover each month of the year.

Do I need to submit monthly forms in my first annual report to cover 2018?

No. Monthly forms for 2018 data are not required with the first annual report in February 2019. The only forms that may be required with the first annual report (depending on approval requirements) is the AMD Annual Emission Summary Form (AMD5) and the Annual Production Summary Form (AMD8).

Note that the first Annual Emissions Inventory Report form does require 2018 data and is required to be submitted by September 20, 2019, if the emission thresholds in Chapter 9 of the AMD are met.

We are required to report against a quarterly SO2 emissions limit. How would we report this using the AMD Emissions Summary Form?

SO2 emissions for each quarter would be reported using the monthly/quarterly tabs of the AMD Emissions Summary Form. There are fields for quarterly total and quarterly average in the "Monthly-3" tab.

There seems to be three forms which require reporting of flaring emissions. Do we need to complete the S-30 Form, Flare Stack Form and Sulphur Recovery Form if we do flaring?

The S-30 Form, Flare Stack Form and Sulphur Recovery Form each have a specific purpose. You should not be required to submit all three. The Flare Stack Form is intended for reporting emissions from non-routine flares. Emissions from routine flaring should be captured in either the S-30 (for sour gas plants with an approved sulphur inlet of <1 t) or the Sulphur Recovery and Removal Form for larger facilities (>1 t sulphur inlet) required to recover sulphur.

The approval takes precedence. If you currently report sulphur recovery with daily/hourly sulphur dioxide frequency distribution and include a flare report for non-routine flaring in your monthly report, you would continue to report both of these and would submit both the Flare Stack Form and the Sulphur Recovery Form with your monthly report.

On the AMD Flare Stack Form, why does it specify that "both S and SO2 must be reported"? Is this facility specific (i.e., applied to specific facilities)? The form shows how to convert from SO2 to S, but is that required for everyone?

The requirement for reporting both sulphur and sulphur dioxide comes from historically Alberta Environment requiring SO2 reporting while the ERCB required reporting of sulphur. Current monthly and annual reports therefore provide a mix of one or the other. For air management purposes, AEP needs to track SO2 emissions, but we also want consistency with the AER. The AMD Flare Stack Form therefore requires reporting of both sulphur and sulphur dioxide.

The AMD Flare Stack Form and its requirements are not facility specific, but note that sulphur and sulphur dioxide reporting will only apply to facilities flaring sulphur compounds, not all types of flaring. The reporting of both sulphur and sulphur dioxide would apply to sour gas plants, all of which are now regulated by the AER. If the SO2 emissions have been determined by the facility, then they are also able to calculate and report sulphur emissions.

Who is required to submit Annual Emissions Inventory Reports?

The AMD Reporting Chapter requires that, as of 2019, all EPEA approved industrial operations annually carry out an emissions inventory. If the reporting thresholds set out in the AMD Reporting Chapter are met, an EPEA approved industrial operation is also required to prepare and submit an Annual Emissions Inventory Report.

Which sources at an industrial operation need to be covered in an Annual Emissions Inventory Report?

All release points and non-point sources (and all units, processes, equipment and control technologies/equipment related to the release points and non-point sources) are required to be included in the Annual Emissions Inventory and reported via the Annual Emissions Inventory Report Form.

How do I know which substances to report in Annual Emissions Inventory Reports?

If any of the reporting thresholds are met by an EPEA approved industrial operation, then air emissions of the Schedule 1 substances are required to be reported, along with the air emissions of any applicable Schedule 2 substances.

If any of the reporting thresholds have been met, then air emissions of all Schedule 1 substances must be reported regardless of whether the individual substance’s reporting threshold has been met. However, if the industrial operation does not actually emit one of the individual Schedule 1 substances (e.g., sulphur dioxide or ammonia), the industrial operation can identify the Schedule 1 substance as negligible and exclude it from reporting.

More information on negligible Schedule 1 substances is provided in the Annual Emissions Inventory Report Standard and Guidance Document.

Reporting of Schedule 2 substances is not dependent on the Schedule 1 reporting thresholds. If a industrial facility is required to submit an Annual Emissions Inventory Report, air emissions of all non-negligible Schedule 1 substances would be reported. If any of the Schedule 2 substances are applicable to the industrial facility, then the specific applicable Schedule 2 substances would also be included in the Annual Emissions Inventory Report. An individual industrial facility could have zero or several applicable Schedule 2 substances that must be reported.

What is meant by "applicable Schedule 2 substances"?

As stated in the AMD Reporting Chapter, applicable Schedule 2 substances are those substances (listed in Schedule 2), which the industrial operation emits to the atmosphere in amounts that can be quantified with reasonable effort, and would include, at a minimum, the:

  • Substances that are part of the industrial operation’s current approval emission limits, monitoring, or reporting requirements
  • Substances whose air emissions have otherwise been quantified by the industrial operation for the same calendar year
  • Substances whose air emissions were reported by the industrial operation to another regulatory or non-regulatory reporting program, such as the National Pollutant Release Inventory, for the same calendar year

What is the difference between "annual actual", "normal" and "maximum" air emission rates?

"Annual actual air emissions" means the actual, measured or estimated quantity of a substance being emitted to the atmosphere from a source during a specific calendar year. The terminology of "annual actual" does not necessarily mean that the value has been measured. An estimated value can be, and is often, used to determine the annual actual air emissions. Annual actual air emissions are simply meant to capture a representative emission rate for the specific inventory year for the industrial operation (for the specific source and substance). Annual actual air emissions are to be reported in tonnes/year.

"Normal air emissions" means the rate at which a substance is emitted to the atmosphere from a source under normal operating conditions. Normal air emissions are intended to capture the usual, average or typical air emission rate for the specific source and substance, as determined during normal (usual, average or typical) operating conditions. Normal air emissions are only required for release points and are to be reported in tonnes/day.

"Maximum air emissions" means the maximum rate at which a substance is emitted to the atmosphere from a source, factoring in emission limits, equipment specifications, or other relevant information. The maximum emission rate is to be determined using the applicable emission and operating limits set out in the industrial operation’s EPEA approval terms and conditions. Maximum air emissions are intended to capture the maximum air emission rate allowed (but not upset or emergency limits) or (when no limit is specified) the maximum emission rate the source could potentially emit (based on normal maximum design or emission capability). Maximum air emissions are only required for release points and are to be reported in kilograms/hour.

Which documents are required for submission of Annual Emissions Inventory Reports?

Annual Emissions Inventory Reports include three components:

  • The completed Annual Emissions Inventory Report Form
  • The Quantification Methodology Document describing the inventory development and emission quantifications
  • The signed and dated Statement of Certification

When are Annual Emissions Inventory Reports due?

As specified in the AMD Reporting Chapter, completed Annual Emissions Inventory Reports are required to be submitted by September 30th of the reporting year (the year following the inventory year).

What is the difference between "inventory year" and "reporting year"?

The "inventory year" is the year to which the Annual Emissions Inventory is to cover. The first inventory year will cover the January 1 to December 31, 2018 calendar year and would need to be completed by September 30, 2019. The next annual inventory would cover the January 1 to December 31, 2019 calendar year and would need to be completed by September 30, 2020. Therefor, 2018 will be the first inventory year for the first Annual Emissions Inventory Report.

The "reporting year" is the year during which the Annual Emissions Inventory Report is being prepared and will be submitted (by September 30). The reporting year is the year following the inventory year. The person responsible will not typically prepare the Annual Emissions Inventory Report until after January 1 of the reporting year, as it will need to cover all of the inventory year. The first Annual Emissions Inventory Report will cover the 2018 inventory year and would therefore be prepared sometime after January 1, 2019. The first reporting year would therefore be 2019.

What do I do if I have questions on annual emissions inventory reporting?

Questions on annual emissions inventory reporting can be sent to:

Frequently asked questions on annual emissions inventory reporting are covered in the Annual Emissions Inventory Report Standard and Guidance Document, which will be posted at:

 

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Updated: Sep 24, 2018