A MassDEP Air Plan Approval Application is the form a business files with the Massachusetts Department of Environmental Protection (MassDEP) Bureau of Air & Waste to get written permission before it builds, rebuilds, or changes equipment that puts pollution into the air. You must hold an approval in hand before you start construction, or the project is illegal from day one.
The form lives inside the EEA ePLACE Portal and comes in three sizes: the Limited Plan Application (LPA, $645), the Non-Major Comprehensive Plan Application (CPA, $2,370), and the Major CPA ($24,305). Each year MassDEP’s four regional offices process hundreds of these, and a single missed field or a weak best available control technology write-up can push your review past 300 days, since the deadline clock does not even start until your fee is paid and the file is complete under 310 CMR 4.00.
Here is what you will learn in this guide:
- 🏭 How to tell which plan approval type your project needs and what each one costs
- 📋 The exact documents, emission numbers, and ID codes to gather before you log in
- 🖊️ A line-by-line walk through all seven ePLACE steps, field by field
- 👷 Three full filled-out examples that follow real businesses from start to finish
- ⚠️ The mistakes that get applications rejected and how to dodge every one
What the Air Plan Approval Application Is and Who Must File It
A MassDEP Air Plan Approval is a written permit that limits how much air contaminant your equipment can release, issued under 310 CMR 7.02. The state legislature created this power in M.G.L. Chapter 111, Sections 142A–142M. The plain-English point is simple: if your project can add pollution to the air, you ask first and build second.
The agency that receives the form is MassDEP’s Bureau of Air & Waste, working out of the Central, Northeast, Southeast, and Western regional offices. You file with the region that covers your facility’s town. The consequence of guessing wrong on region is small, since the portal routes it, but contacting the right regional permit chief early can save weeks.
You must file if you are building, substantially reconstructing, or altering a manufacturing process, a fuel combustion unit, or a crematory that can cause air pollution. Common triggers include a non-combustion process that can emit 10 tons or more of any air contaminant in any rolling 12-month period, a natural gas boiler rated at 40 MMBtu/hr or more, or a distillate oil boiler at 30 MMBtu/hr or more. A common misconception is that small shops are always exempt; in truth a single spray booth or a mid-size boiler can cross the line, so always check the Plan Approval Overview & Applicability Tables.
Some projects skip the written approval through other paths. Many boilers, engines, and turbines qualify for a one-time compliance certification under the Environmental Results Program, and some equipment falls under a permit-by-rule at 310 CMR 7.03. If your equipment fits one of these, you file that instead, and filing a full plan approval by mistake wastes both your fee and months of review.
Before You Start: Documents and Information You Need
Open the application only after you have gathered every number and document below. The ePLACE form times out, and half-finished records invite deficiency letters that reset your review clock. Build this folder first.
- Facility name, address, and MassDEP facility/AQ identifier. The portal cross-checks this against existing records, and a mismatch creates a duplicate facility that delays routing.
- Owner and Responsible Official details. The Responsible Official (the “Permittee”) must certify the form, so you need their legal name, title, email, and ePLACE account ready, or you cannot submit.
- SIC or NAICS code. MassDEP uses your NAICS code to classify the industry; a wrong code can misroute technical review.
- Equipment specifications and manufacturer cut sheets. These prove rated capacity and emission factors, and without them the reviewer cannot verify your numbers.
- Potential-to-emit (PTE) calculations for every pollutant. PTE drives which approval type you need; an undercount that hides a major source is the single most common cause of rejection.
- Proposed BACT description. Every LPA and CPA must propose best available control technology, and missing this stalls the file.
- Stack parameters (height, diameter, exit temperature, flow). Needed for the stack tables and any modeling; gaps here trigger a deficiency notice.
- A Massachusetts Registered Professional Engineer (PE). A licensed PE must certify the application, including license number and expiration, and the form cannot be submitted without one.
- Draft Environmental Justice Project Fact Sheet (CPAs only). Major and Non-Major CPAs require a two- to four-page EJ Fact Sheet; leaving it out makes a CPA administratively incomplete.
- MEPA status. Confirm whether your project crosses Massachusetts Environmental Policy Act thresholds, because MassDEP cannot finish technical review until MEPA is done.
If any item is missing, MassDEP issues a deficiency letter, and your file sits frozen until you cure it. Gathering everything up front is the difference between a clean 90-day review and a year of back-and-forth.
Where to Get the Form and How to Access It
There is no paper form to download for normal filing; the application is an online form inside the EEA ePLACE Portal. You reach the correct version through the MassDEP Air Plan Applications guide, which links to five “Apply” buttons: LPA-Fuel, LPA-Process, CPA-Fuel, CPA-Process, and CPA-Crematory. Pick the button that matches both your equipment type and your emission level.
Every person who touches the application needs a free ePLACE account, including the preparer, the PE, and the Permittee. The 2019 update removed the old shared-PIN system, so access now flows through named accounts you list inside the form. Create accounts before you start, because you cannot add a certifier who has no account.
Before you click “Apply,” call your MassDEP regional office and schedule a pre-application conference. This meeting is not just a courtesy; if you skip it, MassDEP may require one anyway before declaring your file administratively complete. The current screen-by-screen instructions, dated September 2019, are posted as the CPA Instructions & FAQ and the online filing screen-by-screen guide, so confirm you have the current revision before you begin.
Step-by-Step: How to Fill Out the Air Plan Approval Application Line by Line
The online form moves through seven numbered steps. Below, each step gets its own breakdown with what it asks, how to answer, an example entry, an edge case, a common mistake, and a myth to drop. Use the exact field names shown on the screens.
Step 1: Contact Information (Preparer, Permittee, PE, Submitter)
This first screen asks who is working on the application: the Preparer(s), the Permittee (applicant/Responsible Official), the Massachusetts Registered Professional Engineer, and the Submitter. To answer, the person who starts the record enters each party’s name and ePLACE account so the system grants them access. For example, Dana Reyes, an environmental consultant, lists herself as Preparer, names plant owner GreenCoat Finishing LLC as Permittee, lists PE Samuel Ortiz, and designates herself as Submitter.
The Submitter is the only person who can edit the file after submission, so pick that role with care; many consultants keep it themselves to fix deficiencies fast. A common edge case is a large firm where one engineer prepares and a different officer certifies, which the form handles by simply listing both. The most common mistake here is naming a Permittee or PE who has no ePLACE account yet, which freezes the application because you cannot route it for certification. The myth to drop is that you still need a shared PIN; the 2019 update killed the PIN, and access now runs entirely through named accounts.
Step 2: Facility and Owner Information
This screen asks for the facility name and address and the facility owner. To answer, first search the pre-loaded facility list and select your site if it appears; only enter new details if the facility is genuinely new or not listed. For example, Dana searches “GreenCoat Finishing,” finds the existing record at 14 Mill Road, Worcester, and selects it so the prior history links automatically.
If you have filed for this facility or owner before, you can look up and reuse the ownership block, which saves time and avoids typos. The edge case is a brand-new facility with no record, where you type all fields fresh and do not pick from the list. The common mistake is creating a duplicate facility by typing a new entry when the site already exists, which splits your compliance history and confuses reviewers. The misconception is that “facility owner” means the operator; it means the legal owner, which may be a separate holding company.
Step 3: Application Information (SIC/NAICS, MEPA, Project Tables)
This is the heart of the form. It first asks for your SIC Code or NAICS Code, then whether the project is subject to MEPA review, then walks through several data tables. To answer, enter the industry code that matches your operation and answer the MEPA question honestly based on the MEPA thresholds. For example, GreenCoat enters NAICS 332812 for coating services and answers “No” to MEPA after confirming the project stays under review thresholds.
The following pages hold the tables that define your project. Page 2 asks for the List of Existing Approvals; Page 3 asks for a Brief Description of the project and Regulatory Information, including whether you are altering previously approved equipment or triggering federal New Source Review under 310 CMR 7.00 Appendix A. Page 4 appears only if Appendix A applies and asks you to describe emission reduction credits. Page 5 asks about federal Prevention of Significant Deterioration (PSD) and how you made that call, and Page 6 holds a table where you list each applicable federal Part and Subpart, such as NSPS at 40 CFR 60 or NESHAP/MACT. A late page holds the Energy Efficiency Survey.
The edge case is a process unit that touches both NSPS and MACT; you list both subparts rather than picking one. The most damaging mistake on this step is answering “No” to PSD or Appendix A when your potential-to-emit actually crosses the threshold, because that omission can void your approval later and expose you to enforcement. The myth here is that fields without a red asterisk are optional; MassDEP warns that unmarked fields still must be filled in for the file to count as complete.
Step 4: Documents (Attachments)
This step asks you to attach supporting documents. To answer, click “Browse,” select each file, then pick the attachment type from the drop-down and write a short description. For example, Dana uploads the booth manufacturer’s cut sheet as “Equipment Spec,” her PTE spreadsheet as “Emission Calculations,” and her EJ Fact Sheet labeled “Other – Fact Sheet.”
MassDEP encourages you to attach more than the minimum the system lists, because extra backup speeds technical review. The edge case is a non-top-case BACT proposal, which requires a full written BACT analysis attached here rather than a single line in a table. The common mistake is mislabeling or skipping the EJ Fact Sheet on a CPA, which makes the file administratively incomplete and bounces it back. The misconception is that the reviewer will request documents later if needed; in practice a thin attachment set just earns a deficiency letter that costs you weeks.
Step 5: Special Fees
This screen handles special fee circumstances under 310 CMR 4.00. To answer, most filers do nothing here, but if you qualify for a fee exemption you select the exemption type and attach supporting proof. For example, a municipal applicant claiming a government exemption picks that category and uploads its authorizing documentation.
The base permit fee itself is paid later, after certification, not on this screen. The edge case is a public entity or a project that qualifies for reduced fees, where the exemption must be documented now or it will not be honored. The common mistake is claiming an exemption with no backup, which the agency rejects, forcing full payment anyway. The myth is that this page is where you pay; it only flags special situations, while normal fees come at the very end.
Step 6: Application Review
This step shows the entire application for final review. To answer, read every page, and either click “Edit Application” to fix something or move forward if all is correct. For example, Dana spots that the stack exit temperature was left blank, clicks “Edit Application,” fills it, and returns to review.
This is your last clean chance to catch errors before the certification chain begins. The edge case is discovering a wrong emission figure that changes your approval type; fix it now, because changing it after submission means restarting certifications. The common mistake is rushing past this screen and submitting with a blank required field, which guarantees an administrative deficiency. The misconception is that you can freely edit after submitting; only the named Submitter can, and only if MassDEP reopens the file.
Step 7: Authorization Forms (Supplemental Forms and Certifications)
This final step lists Supplemental Forms and Pollution Control Device forms, plus the certification forms for the Submitter, PE, and Permittee. To answer, complete each supplemental form linked on the page, then the Submitter certifies and submits, which creates the permit application number and emails the PE and Permittee to accept. For example, Dana fills the AQ Coatings & Inks supplemental form, certifies as Submitter, and the system emails PE Samuel Ortiz and GreenCoat’s owner to add their certifications.
The PE certifies next, entering license number and expiration, and the Permittee certifies last; the application is not officially filed until both accept. After acceptance, the Permittee opens the fee link and pays online by card or e-check, or mails a check. The edge case is a PE or Permittee who denies certification, which returns the file to the Submitter for fixes rather than killing it. The common mistake is skipping a required supplemental or pollution control device form, which the system flags; if a needed form is not listed, go back to Application Information and add it. The myth is that hitting “Submit” finishes the job; the review clock does not start until the fee is paid and certifications are complete.
Three Filled-Out Examples Using Real Scenarios
Below are three businesses moving through the form. Each table shows the key sections and what the filer enters.
Scenario 1 — GreenCoat Finishing LLC (Limited Plan Application, surface coating line): A small Worcester shop adds one spray-coating booth with a potential to emit just under the major threshold.
| Form Section | What GreenCoat Enters |
|---|---|
| Application Type | LPA-Process (AQ 01), fee $645 |
| Step 1 Contacts | Preparer Dana Reyes; Permittee GreenCoat Finishing LLC; PE Samuel Ortiz; Submitter Dana Reyes |
| Step 2 Facility | GreenCoat Finishing, 14 Mill Road, Worcester (selected from list) |
| Step 3 NAICS | 332812 – Metal Coating |
| Step 3 MEPA | No – below MEPA thresholds |
| Equipment Details | One enclosed spray booth, 5,000 CFM |
| Proposed BACT | High-volume low-pressure guns plus dry filters |
| Step 4 Documents | Booth cut sheet, VOC emission calculations |
| Certification | PE Ortiz license #44210, then Permittee certifies |
Scenario 2 — Bay State Foods Inc. (Non-Major CPA-Fuel, new boiler): A food plant installs a 45 MMBtu/hr natural gas boiler, crossing the 40 MMBtu/hr trigger.
| Form Section | What Bay State Enters |
|---|---|
| Application Type | CPA-Fuel Non-Major (AQ 02), fee $2,370 |
| Step 1 Contacts | Preparer Marcus Lin; Permittee Bay State Foods Inc.; PE Olivia Tran; Submitter Marcus Lin |
| Step 2 Facility | Bay State Foods, 220 Industrial Way, Springfield |
| Step 3 NAICS | 311991 – Perishable Prepared Food |
| Equipment/Fuel Details | 45 MMBtu/hr boiler, natural gas |
| Regulatory Info | Not Appendix A; subject to NSPS 40 CFR 60 Subpart Dc |
| Proposed BACT | Low-NOx burners with flue gas recirculation |
| Stack Details | 40 ft height, 24-inch diameter |
| EJ Fact Sheet | Attached, labeled “Other – Fact Sheet” |
Scenario 3 — Pioneer Aggregates Corp. (Major CPA-Process, large rock crushing/asphalt plant): A facility with potential to emit above major thresholds triggers full review and modeling.
| Form Section | What Pioneer Enters |
|---|---|
| Application Type | CPA-Process Major (AQ 03), fee $24,305 |
| Step 1 Contacts | Preparer Janet Cole; Permittee Pioneer Aggregates Corp.; PE David Nguyen; Submitter Janet Cole |
| Step 2 Facility | Pioneer Aggregates, 7 Quarry Lane, Fall River |
| Step 3 NAICS | 324121 – Asphalt Paving Mixtures |
| PSD Question | Yes – PTE exceeds PSD threshold; determination attached |
| Federal Applicability | NSPS Subpart OOO; MACT as applicable |
| Proposed BACT | Baghouse plus water sprays for particulate |
| Air Quality Modeling | AERMOD results submitted to Boston HQ |
| EJ Fact Sheet | Attached; project sits near an EJ population |
How to File the Completed Form
The primary and expected channel is online through the EEA ePLACE Portal. After the Submitter, PE, and Permittee all certify, the Permittee opens the fee link on the “My Records” page and pays by credit card or electronic check, each carrying a small handling fee. Keep the electronic receipt and your permit application number as proof of filing, because the review clock starts only once payment posts.
If you prefer to pay the permit fee by check, the portal lets you select mail payment, and you send the check to your regional office. The fee depends on which application you filed: $645 for a Limited Plan Application (AQ 01), $2,370 for a Non-Major Comprehensive Plan Application (AQ 02), and $24,305 for a Major Comprehensive Plan Application (AQ 03), all set in 310 CMR 4.00.
A paper path exists only as a backup. If you truly cannot file online, contact your MassDEP regional office to obtain a paper form, complete it, and mail it to that office, marked “Attention: BAW Regional Data Manager.” Whichever path you use, save a full PDF copy of the certified application, since the system emails one to the PE and Permittee at submission.
If your project needs ambient air quality modeling, that file goes separately to MassDEP Air and Climate Programs at 1 Winter Street, 6th Floor, Boston, MA 02108, following the Massachusetts Air Quality Modeling Guidance. Major CPAs always require modeling, and the agency may require it for other projects after the pre-application conference.
What Happens After You File
Once your fee posts, MassDEP begins Administrative Review, allowed 24 days, to confirm the file is complete. If something is missing, the agency issues an administrative deficiency, and the clock pauses while you respond; the Submitter is the only person who can edit during this window. A clean, complete package is the fastest way through this gate.
Next comes Technical Review, where a permit engineer evaluates your emissions, BACT, and stack data. Technical review time scales with complexity: roughly 48 days for an LPA, 72 days for a Non-Major CPA, and 128 days for a Major CPA, with deficiency periods of up to 180 days that pause the clock if the reviewer needs more. Comprehensive plan approvals also include a 30-day Public Comment Process plus a public comment review period, which is why CPAs take longer than LPAs.
You can track every stage on your ePLACE “My Records” page. The agency then issues either a written Plan Approval with conditions or a denial. A Plan Approval stays in effect for the life of the approved equipment, even through a change of ownership, until the unit is substantially reconstructed or altered, or until MassDEP determines deeper emission cuts are needed.
After approval, ongoing duties begin. You owe an annual compliance assurance fee tied to facility-wide potential emissions under 310 CMR 4.03, and failing to pay it can suspend or revoke your approval. To change a name, owner, or contact later, you file a no-fee Administrative Amendment (AQ 34).
Mistakes to Avoid When Filling Out the Form
- Starting construction before approval issues. This violates 310 CMR 7.02 and exposes you to penalties under 310 CMR 5.00.
- Undercounting potential-to-emit. Hiding a major source can void the approval and trigger enforcement once discovered.
- Choosing the wrong application type. Filing an LPA for a CPA-level project means refiling, a new fee, and lost months.
- Skipping the pre-application conference. MassDEP may force one later, delaying your completeness finding.
- Leaving unmarked fields blank. Fields without a red asterisk are still required for a complete file.
- Omitting the EJ Fact Sheet on a CPA. This alone makes the application administratively incomplete.
- Naming a certifier with no ePLACE account. The file cannot route for certification and stalls.
- Forgetting a supplemental or pollution control device form. The system flags it, and review cannot proceed.
- Submitting without paying the fee. The review clock never starts until payment posts.
- Proposing weak or undocumented BACT. A thin BACT proposal draws a deficiency letter and slows technical review.
- Ignoring MEPA thresholds. MassDEP cannot finish technical review until the MEPA process closes.
- Creating a duplicate facility record. Typing a new entry for an existing site splits your compliance history.
Do’s and Don’ts
Do’s
- Do call your regional permit chief first, because early guidance shapes a stronger, faster application.
- Do calculate PTE carefully for every pollutant, since this number sets your approval type.
- Do attach more documentation than the minimum, as extra backup speeds technical review.
- Do confirm all parties have ePLACE accounts, or certification cannot happen.
- Do propose top-case BACT where possible, which avoids a separate written BACT analysis.
- Do save the certified PDF and receipt, as your proof of filing and approval type.
Don’ts
- Don’t break ground before the written approval, because it is illegal and penalized.
- Don’t guess your NAICS code, since a wrong code misroutes review.
- Don’t skip the EJ Fact Sheet on a CPA, or the file bounces back incomplete.
- Don’t assume blank non-asterisk fields are fine, because they still must be filled.
- Don’t let the Submitter role default randomly, since only that person fixes deficiencies.
- Don’t ignore federal NSPS, MACT, or PSD questions, because answering wrong risks enforcement.
Pros and Cons of Filing on Your Own vs. With a Consultant or PE
| Filing Mostly Yourself | Filing with a Consultant/PE Team |
|---|---|
| Lower cost, since you avoid consulting fees | Higher cost, but fewer costly deficiencies |
| Full control over timing and content | Expert handling of BACT and PTE math |
| Good fit for a simple LPA with one unit | Strong fit for Major CPAs needing modeling |
| Risk of missing federal applicability traps | Lower risk of voided approvals later |
| Slower if you learn ePLACE as you go | Faster review from a clean first submission |
A PE certification is mandatory either way, so even a do-it-yourself filer must involve a licensed engineer. The trade-off is whether you also pay for full preparation help.
FAQs
Do I need a MassDEP Air Plan Approval before I start building?
Yes. You must hold the written approval before construction or installation begins. Starting early violates 310 CMR 7.02 and can bring penalties under 310 CMR 5.00.
Do I have to use the ePLACE Portal?
Yes. Online filing through ePLACE is the standard channel. A paper form exists only as a backup from your regional office if you truly cannot file online.
Do I need a Professional Engineer to file?
Yes. A Massachusetts Registered PE must certify the application, including license number and expiration date. Without a PE certification, the form cannot be submitted.
Do all parties need separate ePLACE accounts?
Yes. The preparer, PE, and Permittee each need their own account. The old shared-PIN system ended in 2019, so access now runs through named accounts.
Do I enter a SIC code or a NAICS code in Step 3?
Yes. Either one works; you provide a NAICS or SIC code that matches your operation. The wrong code can misroute your technical review.
Do I list the legal owner or the operator in Step 2’s “facility owner” field?
No. Enter the legal owner, not the operator. The owner may be a holding company that differs from the day-to-day operator.
Do I have to attach an Environmental Justice Fact Sheet?
Yes for Major and Non-Major CPAs. You attach a two- to four-page draft Fact Sheet labeled “Other – Fact Sheet.” LPAs do not require it.
Do I answer the PSD question even for a small project?
Yes. You must answer the PSD question and explain how you made the call. Answering “No” wrongly can void your approval later.
Do fields without a red asterisk really need answers?
Yes. MassDEP warns that many unmarked fields are still required for a complete file. Do not assume a field is optional just because it lacks an asterisk.
Do I pay the fee during Step 5 Special Fees?
No. Step 5 only flags fee exemptions. You pay the actual permit fee after all certifications, through the fee link on your “My Records” page.
Does the review clock start when I hit Submit?
No. The timeline starts only after the fee is paid and the file is complete. Certifications by the PE and Permittee must also finish first.
Does an LPA cost the same as a CPA?
No. An LPA (AQ 01) costs $645, a Non-Major CPA (AQ 02) costs $2,370, and a Major CPA (AQ 03) costs $24,305 under 310 CMR 4.00.
Do I owe anything after the approval issues?
Yes. You owe an annual compliance assurance fee based on facility-wide potential emissions. Failing to pay it can suspend or revoke your Plan Approval.
Do I refile the whole application to change my company name?
No. You file a no-fee Administrative Amendment (AQ 34) to update a name, owner, or contact, rather than a full new plan approval.
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