Environmental Permitting

Checklist for Reviewing Your Title V Permit

Reviewing Your Final Title V Permit (Y/N)

Does the final permit include the following components, along with emissions limitations and other standards that apply to the facility?

  • Inspection and entry authority for the regulating agency? ___
  • Compliance schedules and progress reports? ___
  • Compliance certifications? ___
  • Mention of permit shield? ___
  • A statement that an emissions release caused by an “act of God” will not be considered a violation, as long as certain conditions are met (e.g., you notified the agency within two days of any releases caused by storm)? ___

Has management of the parent company made sure that all people named in the permit have a copy and are familiar with its provisions? ___

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Has management of the parent company double-checked that all people named in the permit still work at the company? ___ The facility? ___

Has management of the parent company been informed of specific permit requirements and limitations? ___

Have the facility’s decision makers been informed of the types of business changes that may be delayed by a permit revision? ___

Have the facility’s decision makers been made aware of the other types of changes and expansions that may cause another part of the facility to have to obtain an operating permit? ___

Has management of the parent company cultivated a contact at the regulating agency, so that they may communicate with the agency about future inspections and other issues? ___

Has management of the parent company included in their management system a requirement for a determination of how future actions will affect permit conditions, before those actions are taken? ___

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EPA & State Review of Title V Permits

All agencies with Title V permitting authority are required to forward copies of all permit applications, proposed permits, and final permits. In some instances, the applicant may be required to make the submissions directly to EPA.

EPA objection. EPA has veto authority over all state-issued operating permits, and no permit may be issued if EPA objects to its issuance in writing within 45 days of receipt of the proposed permit and all necessary supporting information. EPA’s objection must state the reasons for objection and include a description of the terms and conditions that the permit must include to respond to the objections. If, within 90 days after the date of an objection, the permitting authority fails to revise and submit a proposed permit in response to the objection, EPA will issue or deny the permit in accordance with the requirements of the federal program under 40 CFR 71.

Public petition. If EPA does not object to a Title V permit in writing, any person may petition EPA within 60 days after the expiration of the agency’s 45-day review period to make such objection. Any petition must be based only on objections to the permit that were raised with reasonable specificity during the public comment period, unless the petitioner demonstrates that it was impracticable to raise such objections within the comment period, or unless the grounds for the objection arose after the comment period.

If EPA objects to the permit as a result of a petition, the permitting authority must not issue the permit until EPA’s objection has been resolved. If the permitting authority has issued a permit before receipt of an EPA objection due to a public petition, EPA will modify, terminate, or revoke the permit. However, the source will not be in violation of the requirement to have submitted a timely and complete application.

Affected states. The applicable permitting authority must provide notice of each draft permit to any affected state before or at the same time as the public notice. The affected state may submit comments and recommendations to the permitting authority for review. If the permitting authority does not accept all recommendations for the proposed permit that the affected state submitted, notice must be provided to EPA and the affected state detailing the reasons for not accepting such recommendations.

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