A Note on the New Online UST FCQ Registration
Months ago, NJGCA brought you news that the NJ Department of Environmental Protection (DEP) was working to revise the yearly Underground Storage Tank Facility Certification Questionnaire (“UST FCQ”) submission process.
This process, which is commonly known as yearly “tank registration”, has often been frustrating for members. Completing the application and submitting payment aside, the questionnaire must also include a copy of the owner's entire insurance policy. A PDF copy of that policy must also be emailed to a specific email address, and then the entire package (UST FCQ, check, and insurance policy together) are sent to Trenton for processing.
The frustration doesn't end there, because the package is actually split between two departments. In a normal annual renewal, your submission is actually sent first to the Division of Revenue in the Treasury Department (where your check is processed), and then is forwarded along to DEP's UST Registration & Billing Unit (for further review and approval).
This created a cloud of confusion over the process. That's because once a station owner saw that their check was cashed, they believed the registration was renewed – and there was nothing further to worry about. Yet, the process wasn't actually completed. That's because the FCQ itself needed to be reviewed, and any errors needed to be corrected and cured before final approval (with many of our members stating that they were never contacted/informed of those lapses or errors).
Thankfully, as part of a larger effort to speed up this process and eliminate the “old way” of completing your yearly tank registration, DEP has been testing and refining an online application and payment portal.
The new process requires each owner to have an NJDEPOnline (www.njdeponline.com) account. You may already have an account registered on the site, as the existing Community Right to Know (CRTK) program and your air permit are both processed through this page.
Once logged in, there is an admittedly complex process to add the UST FCQ application to your dashboard; then complete the application, upload a PDF of your insurance policy, and make an online payment. But any such challenges are only an issue the first time you complete the process. What's more, you can save your progress along the way to ask questions or get clarification; then pick right back up from your last session upon your return.
This week we had the opportunity to help a member with the new process. We hit a small obstacle and had some questions for DEP that needed to be answered before the application could be submitted. Candidly, it took an extra few days to get the information we needed (the staffer was out on PTO). But, by the time we circled back to our member, he reverted to filling the old paper FCQ by hand, cut a physical check, copied his entire insurance policy, and sent the package via overnight delivery.
Keep in mind, the application is due by June 30th, and there was plenty of time to spare. But the frustration and anxiety with the new online system got the better of them.
Don't let this example happen to you – have patience and take advantage of the online submission process. Think back to some of the horror stories we've shared (and you have personally experienced) over the years during the annual submission process. Applications that have gone missing, checks that were not received, station insurance policy information, missing pages, etc. Any scenario you can think of, we've heard about. And each type of delay only pushes back your tank registration approval, and may actually trigger a delivery ban if not cured by the deadline.
It is true that the online FCQ asks a few extra pieces of information than is sought in the paper FCQ registration, so you have to set aside extra time the first time you're filling it out in order to answer everything correctly. However, unless you've made changes to your existing UST system from the last submission to the next, every annual submission thereafter is easy and quick to submit. That's because you're essentially duplicating the previous year's application and re-submitting it.
The bottom line: Have patience, put in the time, fill out the questionnaire properly online; and every submission thereafter will be less involved.
The new online submission process is an enormous advantage over the old process. If you have any questions or need some guidance, please feel free to reach out to Nick at nick@njgca.org at your convenience.