Title V Permitting Tutorial

Timeline

1. We start with an operating plant.
2. The company completes and submits an application to the District.
3. The application is checked for administrative completeness.
4. The engineer begins the technical review of the application.
5. Based on the application, the engineer drafts a permit and a summary.
6. The permit goes through internal review at the District level.
7. The permit is issued in draft form.
8. Citizens can submit comments on the draft permit.
9. Proposed permit is sent to EPA for final review.
10. The EPA can object to a permit.
11. All comments which are received are compiled to create a final permit.
12. Citizens can petition the EPA after their review.
13. The permit is issued as a final permit.

Once the permit is final, there are still legal avenues to pursue.

Modifying the permit during the permit term.

There are three different types of modifications.

• Administrative Amendments
• Minor Modifications
• Significant Modifications

For significant modifications, a draft permit is created and offered for public review and comment.

When and how can I get involved in this process?

1. Do some homework before the draft permit is issued.
2. When the draft permit is issued, gather the necessary information.
3. Formulate comments and submit them on time.
4. Keep track of important dates:
   • Public comment period.
   • EPA review period.
5. Submit the right documents at the right time.

What procedures does the District follow when it issues, renews, reopens or makes a significant change to a Title V permit?

The District generally follows the following steps:

1. Determine if the permit application is complete enough to begin processing it.
2. Prepare a draft permit.
3. Publish a notice to inform the public of (1) the public comment period (30 days) for the draft permit, and (2) deadline for requesting a public hearing on the draft permit.
   • Notice can be published in a newspaper of general circulation in the area where the source is located or in a State publication, like a State register.
   • The permitting authority must mail notices of draft permits to persons who have requested to be on a mailing list.
   • The notice must include:
     • the name of the facility, the name and address of the permittee and the permitting agency;
     • activities covered by the draft permit;
     • any emissions change involved in the permit action;
     • who to contact for more information;
     • how to get a copy of the draft permit and supporting materials;
     • how to submit comments;
     • time/place of any hearing already scheduled;
     • how to request a hearing if one has not already been scheduled.
   • You can start getting prepared for permit review before the public comment period.
4. Decide whether to revise the draft permit (based on comments from the permittee, the public, or EPA).
5. Send the proposed permit to EPA for its 45-day review.
   • The permitting authority will often change the permit in response to EPA comments.
   • If EPA has agreed to “concurrent review,” then its 45 days starts at the beginning of the public comment period.
6. Revise permit with 90 days, if EPA has objected.
7. Issue permit.

» Next: Opportunities for Public Participation