Certain New Jersey Department of Environmental Protection (NJDEP) air permit applications pursuant to N.J.A.C. 7:27-22 require facilities to submit a netting analysis (N.J.A.C. 7:27-18.7). This must be conducted for all operating permit modifications that will require an emission increase and all general operating permit registrations. A netting analysis is conducted in order to calculate if the maximum allowable emissions stated in a permit application would result in a net emission increase or significant net emission increase, emissions equal to or greater than the increase levels below, at the facility for any of the following air contaminants:
Air Contaminant Significant Net Emission Increase Levels (tons/year)
In the past, this netting analysis calculation was done by facilities using the following formula:
NI = IP + INP + IF + IA - DO – DC
NI = The net emission increase at a facility
IP = Any increase(s) in the allowable emissions of the air contaminant which occurred during the contemporaneous period and which were authorized by permits issued by the Department;
INP = Any increase(s) in the allowable emissions of the air contaminant which occurred during the contemporaneous period and which came from any equipment or control apparatus for which no permit was in effect at the time of the increase;
IF = Any increase in fugitive emissions of the air contaminant from the facility during the contemporaneous period;
IA = Any proposed increase in allowable emissions of the air contaminant from the newly constructed, reconstructed, or modified equipment or control apparatus which is the subject of the permit application;
DO = Any increase(s) in the allowable emissions of the air contaminant which occurred during the contemporaneous period, if emission offsets were secured for these increases from the facility or from another facility; and
DC = The sum of all creditable emissions reductions at the facility during the contemporaneous period, not including any creditable emissions reductions previously used as emission offsets at the facility or any other facility.
The NJDEP has standardized this calculation into the electronic Netting Analysis (eNAT) tool that facilities are now required to use. The eNAT tool, which is available here: http://www.state.nj.us/dep/aqpp/enat.html, is a Microsoft excel based spreadsheet with two tabs, one containing instructions on how to use the spreadsheet and a second tab for the actual calculations.
If you have any questions or would like Baron Environmental to assist with completing a netting analysis, please contact us at firstname.lastname@example.org.