Summary operating records 2026: what must the operator check before submission?

Why not to underestimate summary operating records

Summary operating records are reported annually for the previous calendar year through ISPOP. They concern operators of listed stationary sources under Annex 2 to the Air Protection Act, unless a special exception applies.

Operators sometimes treat summary operating records as routine copying of a few figures into a form. That is risky. Data in the report should link to actual source operation, operating records, operating permit, emission measurements, emission calculations, and possibly also the fee return.

In practice, summary operating records are an annual technical-administrative picture of source operation. If capacity, operating hours, consumptions, exhausts, measured substances, or emissions do not match, this can trigger authority queries or problems during inspection.

Who the obligation concerns

The obligation generally concerns operators of stationary sources listed in Annex 2 to the Air Protection Act. This may typically involve boiler plants, combustion sources, paint shops, technological lines, dryers, crushing and sorting equipment, recycling plants, waste management facilities, some deposits and handling areas, or other listed sources.

Before submitting the report, it is advisable to verify whether anything changed during the year that may affect content of summary operating records:

• source classification under Annex 2,
• permitted capacity, output, or input,
• number and designation of exhausts,
• type of fuel, raw materials, or solvents,
• operating hours,
• quantity of processed material,
• filtration or separation,
• emission measurement results,
• method of annual emission calculation,
• link to fee return.

For sources newly classified, newly permitted, or that had an operating permit change in 2025, we recommend checking before filling in the form itself.

What to check before submission

First, it is advisable to compare three things: operating permit, actual state of the source, and data you intend to submit in ISPOP. If these three planes do not match, it is better to find the error before submission than after an authority query.

Plant and source identification

Check whether identification data of the plant, sources, and exhausts are correct. At older plants, a common problem is that source designations in the operating permit, older measurement protocols, and internal records are not the same.

This can especially complicate link to emission measurement. If a different exhaust designation is used in the form than in the protocol or permit, it may later be difficult to demonstrate which source the data relate to.

Operating permit and actual state

Summary operating records should match both the actually permitted and actually operated state. If technology, exhaust, filter, fuel, operating hours, or capacity changed during the year, it is necessary to verify whether the change was reflected in the operating permit and operating records.

Pay special attention especially when:

• a new exhaust was added,
• technology was replaced,
• filtration or separation changed,
• fuel or solvent consumption increased,
• type of fuel or raw materials changed,
• operation was expanded,
• the source did not run part of the year or ran only limited,
• a trial phase or exceptional operating regime took place.

If data in summary operating records show higher operation or different emissions than the permit allows, it is advisable to assess the situation professionally. It may not automatically be a problem, but it is necessary to know how to explain and document the change.

Operating hours and operating regime

Operating hours are important for emission calculation, fees, operation evaluation, and compliance check with the permit. For some sources, the difference between calendar availability of technology and actual operating time of the source may matter.

We recommend distinguishing especially:

• normal operation,
• start-up and shutdown,
• trial operation,
• service tests,
• emergency or exceptional regime,
• backup operation,
• time when equipment was installed but not actually operated.

For backup sources, combustion equipment, and technological lines, number of operating hours may also be important for assessing measurement and fee obligations.

Consumption of fuels, raw materials, and solvents

Consumptions are one of the basic inputs for emission calculation. For boiler plants this will mainly be fuel; for paint shops and surface treatment organic solvents and coating materials; for technological plants quantity of processed raw materials or material.

Before submitting summary operating records, we recommend comparing data with:

• accounting or warehouse documentation,
• operating records,
• fuel invoices,
• records of coating material and solvent consumption,
• production records,
• waste records if related to source operation,
• VOC balance if relevant for operation.

A common mistake is taking over last year's data without verifying actual consumptions. For plants with variable output, this can lead to a significant error in emissions.

Emission measurement and calculations

Summary operating records must link to how the operator determines pollution levels. For some sources, authorised emission measurement is used; for others calculation from consumptions, emission factors, balances, or conditions set in the operating permit.

Before submission, check especially:

• whether required emission measurement was carried out,
• whether measurement corresponds to the relevant source and exhaust,
• whether correct pollutants were measured,
• whether the protocol matches the operating regime of the source,
• whether measurement results are correctly used for annual emission calculation,
• whether emission calculation is traceable and technically defensible.

If emissions are calculated, the calculation should be traceable retrospectively. It is not enough to have only the final figure in the form. The operator should be able to document input data, emission factor used, calculation procedure, and link to operating records.

Link to fee return

If the operator has a fee obligation, summary operating records must also make sense in relation to the fee return. Data on emissions, operation, and consumptions should not show something different in one form than in the other.

We recommend special attention especially to these substances:

• total suspended particulates,
• sulphur dioxide,
• nitrogen oxides,
• volatile organic compounds,
• other chargeable substances according to the specific source.

If there was a significant year-on-year increase or decrease in emissions, it is advisable to have an explanation ready. This may be due to change in operating hours, different fuel consumption, change in raw materials, filter servicing, technology change, or simply lower production. Without explanation, a significant change may look like an error in records.

Most common mistakes in practice

Similar problems often recur in summary operating records. It is not always a major substantive error, but even a small inconsistency can trigger a query or delay.

The most common mistakes are:

• data in the form do not match the operating permit,
• exhausts are designated differently than in measurement protocols,
• operating hours are taken as an estimate without link to records,
• fuel or solvent consumptions are not verified against internal documents,
• emission calculation is not traceable retrospectively,
• link to authorised emission measurement is missing,
• technology changes during the year are not reflected,
• operator does not address that the source was out of operation part of the year,
• summary operating records are not aligned with fee return,
• operating records are not stored so as to be usable during inspection.

The greatest risk is not filling in the form itself. The risk is a situation where the operator cannot demonstrate where the submitted data came from.

Practical procedure before submission

Before submitting summary operating records, we recommend a simple check procedure:

1. Open current operating permit and latest decision amendments.
2. Check list of sources, exhausts, and pollutants.
3. Compare permitted state with actual operation in the given year.
4. Prepare operating hours, fuel, raw material, and solvent consumptions.
5. Check emission measurement protocols and their usability.
6. Recalculate or verify annual emissions.
7. Compare data with summary operating records from last year.
8. Verify link to fee return, if submitted.
9. Check that documentation is stored and traceable.
10. Only then submit the form in ISPOP.

This procedure is especially important for plants where technology changed during the year, outage took place, reconstruction occurred, fuel changed, solvent consumption changed, or new authority requirements were addressed.

What you can send us for assessment

If you are unsure whether data for summary operating records are correctly prepared, send us the existing operating permit, operating rules, latest emission measurement protocols, data on operating hours, fuel, raw material, or solvent consumption, and possibly last year's summary operating records report.

We will verify whether data match the operating permit, emission measurements, operating records, and any fee obligations. In unclear cases, we can prepare emission calculation, check link to measurement, assess need for update of operating rules, or point out inconsistency that is advisable to address before submitting the report or before further inspection.

Summary

Summary operating records are an important annual document linking operating permit, actual source operation, emission measurements, emission calculations, operating records, and fee obligations. It is not enough to fill in the form in ISPOP alone. Data must be technically correct and retrospectively demonstrable.

Greatest attention deserves sources with technology change, fuel change, new exhausts, filtration change, significant change in operating hours, solvent consumption, or annual emissions. For these plants, we recommend checking documentation before submitting the report.

Factual basis of the article

The article is based mainly on Act No. 201/2012 Coll., on air protection, Decree No. 415/2012 Coll., and rules for reporting through ISPOP.

From a practical perspective, these sources show that summary operating records should not be an isolated annual report without link to operational documentation. They must match actual source operation, operating permit, emission measurements, calculations, operating hours, consumptions, and any fee data.

The operator should be able to demonstrate not only that the report was submitted, but also how the stated data were arrived at. It is therefore important to store operating records, measurement protocols, emission calculations, fuel and raw material consumptions, operating hours data, and other documentation so that they are usable during inspection or during subsequent operating permit change.