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Title V Operating Permits: Compliance and Renewals

Major sources of air pollutants, along with some other certain sources, are required to secure an operating permit for compliance with Title V of the Clean Air Act. Sources with a Title V operating permit are required to certify compliance at least annually with the permit’s requirements. The annual compliance certification is required by the permit holder to certify that it is in compliance with the specific requirements of their permit. Most operating permits under Title V are issued by state regulatory agencies and are classified as Clean Air Act Part 70 permits. EPA does issue a smaller number of operating permits, which are classified under Clean Air Act Part 71.

Title V operating permits are required for all major sources and some smaller sources, also referred to as area sources or minor sources. A Title V major source is classified as one that has actual or potential air emissions that are above the major source threshold value for any air pollutant, which is 100 tons/year. For non-attainment areas, lower threshold values can apply for the pollutant that is in non-attainment. Hazardous air pollutants (HAP) have major source thresholds of 10 tons/year for a single HAP or 25 tons/year for any combinations of HAPs. The U.S. EPA currently has a list of 187 HAPs to regulate air emissions.

Title V operating permits are renewable every five years from the date of issuance for the current permit. Renewal applications must be sent to the applicable regulatory agency within a 12-month application submittal window that is between 6 and 18 months prior to the current permit’s expiration. As an example, if your permit is set to expire on September 1, 2019, you must apply for a renewal between March 1, 2018 and March 1, 2019.

Title V compliance and renewal requires an experienced environmental air emissions professional.

has a long track record of providing its clients with the expertise required for Title V compliance.

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