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Regulatory Updates from the Latest Industrial Stakeholder Group (ISG) Meeting


At Baron Environmental, we make it a priority to stay on top of the latest regulatory updates and discussions to ensure we can provide the most up-to-date guidance to our clients. Our team recently participated in the in-person Industrial Stakeholder Group (ISG) meeting held by the New Jersey Department of Environmental Protection (NJDEP) on 6/7/24. Here are some key takeaways:

General Permits (GPs):

The NJDEP has recently implemented two new general permits - the GP-020A for R&D operations and GP-021A for fumigation operations. The GP-021B for outdoor fumigation was published for comments, the comment period ended on May 14th. Revisions are also in the works for several existing GPs, including GP-017B for boilers less than 5 MMBtu, GP-018B for 5-10 MMBtu boilers, GP-007 for storage tanks, and GP-008A for site remediation. These revisions will consider adding Hazardous Air Pollutant (HAP) emissions, PM2.5 limits, incorporating NSPS elements, and allowing subsurface contamination remediation.

Billing and Fees:

Overdue NJDEP invoices that are 2 years or older will now be sent to collections by the Treasury. Once sent to collections, they can no longer be paid online.

Also note that annual emission fees will be increased by about 3% over the previous year based on CPI inflation changes. Permit fees for Preconstruction Permits (PCPs) and General Permits will see a more significant 22-25% increase starting 1/1/25.

Policy Changes:

Under a previous policy document, the NJDEP did not require risk assessments for HAPs for emergency generators. However, a new memo indicates that risk assessments will be required for consistency with the Environmental Justice (EJ) rule. According to the new memo, this change applies to EJ area facilities: major facilities and minor facilities that trigger Title V requirements. The final determination of applicability will be on a case-by-case basis. The takeaway from this discussion was that the new policy memo remains under revision and attendees were encouraged to submit feedback/concerns to the Department for further consideration.

Other Updates:

  • New and updated state-of-the-art (SOTA) manuals are available or in progress for landfills, combustion engines, boilers/heaters, combustion turbines, graphic arts and surface coating.

  • The NJDEP is working with the Cannabis Commission on registrations for growers and processors, many of which will likely require air permits. Extraction and mechanical clipping operations have already been issued permits.

The NJDEP will alternate between virtual and in-person ISG meetings going forward, with the next one being virtual. Rest assured that the Baron team will continue to monitor these meetings and all NJDEP communications to stay fully apprised of the dynamic air regulatory landscape in New Jersey. Our expertise allows us to guide clients in navigating these complex requirements to achieve and maintain compliance. Contact us to learn more about how we can help with your air permitting and compliance needs.


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