Earlier this year, the NJDEP announced the annual Emission Statement due date would no longer be June 15th for those who submit electronically. This year the May 15th deadline would be the final deadline for all those required to submit an annual Emission Statement.
On March 24, 2020, in response to the ongoing COVID-19 emergency, the NJDEP released the following statement:
"In response to the COVID-19 national emergency, the New Jersey Department of Environmental is extending the due date for the 2019 Annual Air Emission Statements to June 15, 2020. This extension does not require a formal request as described in N.J.A.C. 7:27-21.9."
However, despite this extension, the NJDEP remains active at this time. In fact one of our clients has recently received contact from the NJDEP regarding setting up a site inspection to review changes to their Discharge Prevention Control & Countermeasures (DPCC) program.
This is a clear reminder that, despite the current emergency, compliance does not take a break. Therefore, Baron recommends that to the extent possible, based on individual working conditions, you continue to gather the data needed for completion of your Emission Statements and still move forward with them now. This will alleviate the added burden of having to do this work at a time where your operations may be ramping back up and trying to make up for lost production.
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