Air permitting falls into three main categories:
- Construction Permits
- New Source Review (NSR)
- Title V Operating Permits
Each of these categories represents a complex process of permitting. We will look at each one in a little more detail.
Before installing new emission units at an existing or new facility you must obtain the appropriate construction permits. Because some states exempt certain kind of emission sources, so you should understand the local permitting requirements early in your project’s the planning phase. If a source is considered “major” under the Prevention of Significant Deterioration (PSD) program, your project will be subject to additional requirements. Our permitting services will help you navigate these complex and time-consuming issues so that your project obtains the needed permits without unnecessary delays, surprises, or costs.
New Source Review (NSR)
The entire preconstruction permitting program, including both the PSD and NNSR permitting programs, is referred to as the NSR program. The NSR program can be divided into two categories:
- Prevention of Significant Deterioration (PSD) permits. These are permits for sources in attainment areas and for pollutants regulated under the major source program.
- Nonattainment New Source Review (NNSR) permits. These are permits for major sources emitting nonattainment pollutants and located in nonattainment.
Prevention of Significant Deterioration (PSD) Permits
As the most common permit under the NSR program, a PSD applies to major sources of air pollution in areas designated “in attainment” or “unclassifiable.” A source is considered major if it has the potential to emit more than 100 tons per year for the 28 source categories and 250 tons per year for all other sources. The purpose of this permit is to ensure environmental protection while allowing economic growth.
CPP provides services and support for all aspects of the PSD program, including:
- PSD Permit Applications
- Minor PSD Permits
- Best Available Control Technology (BACT) Determinations
- Permit Amendments
- PSD Air Quality Analysis
- Class I Area Evaluations
Nonattainment New Source Review (NNSR) Permits
The purpose of Nonattainment New Source Review Permits is to allow economic expansion without degrading the air quality in areas designated in nonattainment for a specific criteria pollutant. These permits are similar to PSD permits in many respects but with the following key differences:
- They have lower major source thresholds
- Pollutant evaluated include criteria pollutants and precursors.
- Control Technology is Lowest Achievable Emission Rate (LAER). This is more stringent than PSD’s BACT
- Need of offsetting emissions. Offsets are actual emission reductions of the pollutant or precursor pollutant that is increasing, and must be obtained from within the nonattainment area. These can be internal (reductions from the facility in question) or external (from a different facility).
Whether your New Source Review requires a PSD or NNSR permit, we can help you through the process in a cost-effective and responsive manner.
Title V Operating Permits
Operating Permits are legally enforceable documents that are issued to all “major” sources and a limited number of “minor” sources. These permits include all air pollution requirements that apply to a source including emission limits and monitoring, record keeping, and reporting requirements. Additionally, these permits have to be renewed every 5 years.
CPP provides support for all aspects of the Title V program, including:
- Securing your initial Title V permit
- Renewing your Title V permit (done every 5 years)
- Revising your Title V permit
The process and how we help
From initial assessments through permit issuance, we can help. Our permitting services include:
Emission Impact AnalysisThe initial permitting assessment includes the calculation of emissions from a proposed project. These emission estimates are calculated based on operational information from the facility and available emission factors obtained from performance testing data or published sources.
Regulatory Applicability/ Permit AssessmentOnce emission calculations have been established these values have to be compared to the applicable permitting thresholds. This will determine the type of permit that is necessary for a given project.
Permitting StrategyThis is a critical step in the permitting process where the timing, cost and potential delays from the available options are discussed and a course of action is determined. For example, in some cases it is possible to establish operational or emission limitations to avoid a lengthy permitting process. CPP assists clients in assessing the permitting options available and choosing the most suitable strategy that includes contingency options.
Application processOnce a strategy is determined, CPP assist clients in preparing the air permit application to the regulatory agency. This application package may include dispersion modeling evaluations.
Agency negotiationOnce a permit application is submitted to the regulatory agency, CPP assists clients negotiate permit terms that provide operational flexibility and minimize recordkeeping and reporting. Additionally, CPP provides response to regulatory and technical questions that arise during the permitting process.
Public commentSome types of permits require public involvement before issuance. In those cases CPP assist in responding to comments raised by the public or stakeholder groups about the specific project.
Permit issuanceOnce a permit is issued it is necessary to understand the requirements that may include notifications, emission and operational limitations, recordkeeping, and reporting. CPP assist clients understand and be in compliance with their permit by providing training and management tools.
Through each of these steps, CPP provides the expertise and support to help you acquire the necessary air permits in an efficient and cost-effective way.