Construction & Operation Air Permits (non-Title V)
LEAF's basic philosophy for air permitting support is to work with our clients to achieve the simplest permit feasible that will meet the business needs of our clients. In some cases, a facility must remain a Title V facility in order to have necessary flexibility to respond to changing business conditions. In other cases, the facility's basic operation mandates Title V applicability, however, many plants require an air permit as a small or synthetic minor facility. LEAF has developed numerous air permit applications for new small and synthetic minor facilities, for facilities seeking to expand, and for Title V facilities that we were able to have successfully reclassified as small or synthetic minor for purposes of an air permit.
Selected project summaries for non-Title V applications can be accessed here (pdf).
Air Permit Reclassifications
As part of our work with clients, we routinely evaluate plant air permits to ensure that a client has what is needed in an air permit to meet both their business needs and the regulatory requirements. In many instances, we have found that facilities were classified into a higher level (more complex) permit than required or needed. We have worked with clients in numerous industries to have their air permits modified, when appropriate from a business, operations and regulatory perspective. We have had facilities reclassified from Title V to small, from Title V to synthetic minor, and from synthetic minor to small sources. The bases, options, and pros and cons of such reclassification are reviewed in detail with clients, prior to making final recommendations, and the cost savings are often substantial. For example, the savings in permit fees alone when reclassifying from Title V to small is thousands of dollars. Often of greater importance, however, is the savings due to reduced reporting, recordkeeping, and other associated regulatory costs.
Selected project summaries for air permit reclassifications can be accessed here (pdf).