The EPA's Title V permits help regulate harmful air pollutants. The Clean Air Act sets strict thresholds for volatile organic compounds (VOC), nitrogen oxides (NOx), sulfur oxides (SOx), carbon monoxide (CO), particulate matter (PM), and hazardous air pollutants (HAPs), in addition to setting requirements for specific sources of air pollution based on industry. Facilities that exceed these limits are classified as “major sources” and must undergo a rigorous Title V permitting process, which can be costly and time-consuming. If the source is not otherwise categorized as requiring a Title V permit, staying below these thresholds allows a site to be considered a “minor source,” streamlining the permitting cycle and enabling a faster time to power.
The EPA routinely measures the air quality around the country and classifies geographic regions as either in attainment or non-attainment with air quality standards set by the EPA and state agencies. For example, in “marginal” non-attainment areas, a site must remain under the default 100 tons per year (tpy) of VOC or NOx. In “extreme” non-attainment areas, sites must remain under 10 tons per year of NOx emissions.
Source: United States Environmental Protection Agency website.
Traditional onsite power generation—like turbines or reciprocating engines—relies on combustion, which produces significant emissions. Even the cleanest combustion-based technologies struggle to keep NOx and other pollutants low enough to avoid major source classification. This limits how much power a site can generate before hitting regulatory barriers.
By contrast, fuel cells use an electrochemical process to convert fuel directly into electricity. There’s no combustion, so emissions of VOC, NOx, SOx, CO, and PM are sharply lower than traditional technologies. For example, FuelCell Energy’s carbonate fuel cells can achieve NOx emissions as low as 0.01 lbs/MWh—well below regulatory thresholds.
Fuel cells can allow sites to stay below the “major source” classification, avoiding additional costs and project delays. Even in areas designated as Extreme non-attainment by the EPA for NOx, FuelCell Energy’s technology can generate 200 MWs of power while staying below the “major source” threshold.
Exhaust emissions reference: Catalog of CHP Technologies https://www.epa.gov/chp/chp-technologies
FuelCell Energy’s carbonate fuel cells are certified to operate on natural gas and digester gas under the California Air Resources Board’s (CARB) standards, expediting the permitting process in certain air quality districts. Outside the state of California, the CARB 2007 certification independently validates the clean air profile of our plants.
Sites using fuel cells can add more generating capacity without triggering the lengthy Title V process. For example, a data center or industrial facility can scale up its power supply—sometimes doubling or tripling its onsite generation—while staying within minor source limits.
Under EPA regulations, sites in certain geographic regions can avoid "major source" classification by keeping emissions below a 250 Tons/Year threshold. In the example below, a site can install 450 MW of reciprocating engines and remain under that limit. By contrast, fuel cells enable the same site to double its total power generation while still staying below the 250 tons/year threshold, enabling a faster permitting process.
As demand for clean energy grows, fuel cells offer a proven pathway to scale up operations without sacrificing compliance or sustainability. By leveraging their low emissions and permitting advantages, businesses can unlock new levels of capacity and efficiency—powering growth while protecting the environment.
Contact us today to learn more about our carbonate fuel cell systems.