Description
This Effective Permit Writing course focuses on practical aspects of writing good permit conditions and preparing a permit that is not only effective but is also less vulnerable to legal and technical challenges and easier for sources and inspectors to understand and implement. It includes exercises to engage students by assigning a permit condition to each attendee to evaluate and analyze and present their analysis of that permit condition to the class.
This Effective Permit Writing course:
• Provides an overview of the role of permits in air pollution control programs and the two Federal permit rules: NSR and Title V.
• Addresses the audience (who uses the permits and what for), program goals, and efforts to improve the process.
• Discusses types of problems with permit conditions (e.g., unworkable, too broad, unauthorized) and how to recognize and correct them.
• Identifies the elements of an effective permit (e.g., standard conditions, emission limits) and discusses those elements.
• Categorizes emissions limits (effects-based, technology-based, and applicability-based) and discusses the characteristics of each type, including the appropriate averaging time.
• Addresses how to specify compliance demonstrations and how to use emissions and monitoring data in preparing permit conditions.
• Demonstrates how to set an emissions limit using examples and exercises, including use of statistics to detect outliers, determine Potential to Emit (PTE), and establish a reasonable not to exceed limit (including the appropriate averaging time).
• Discusses the use of other conditions, summary tables, and attachments; the permit writer’s report; and the art of referencing materials.
• Summarizes the characteristics of effective permits: language (including when to use “shall” and “may”), organization of the permit, the importance of consistency, and accuracy.
• Identifies important but at times overlooked aspects of writing permits, including the importance of a complete application, communications with stakeholders, and documentation.
• Presents EPA’s Title V permit writer’s tips and the findings of the EPA Title V Task Force and of the Congressional Research Service regarding permit quality, problems and recommendations
This Effective Permit Writing course:
• Provides an overview of the role of permits in air pollution control programs and the two Federal permit rules: NSR and Title V.
• Addresses the audience (who uses the permits and what for), program goals, and efforts to improve the process.
• Discusses types of problems with permit conditions (e.g., unworkable, too broad, unauthorized) and how to recognize and correct them.
• Identifies the elements of an effective permit (e.g., standard conditions, emission limits) and discusses those elements.
• Categorizes emissions limits (effects-based, technology-based, and applicability-based) and discusses the characteristics of each type, including the appropriate averaging time.
• Addresses how to specify compliance demonstrations and how to use emissions and monitoring data in preparing permit conditions.
• Demonstrates how to set an emissions limit using examples and exercises, including use of statistics to detect outliers, determine Potential to Emit (PTE), and establish a reasonable not to exceed limit (including the appropriate averaging time).
• Discusses the use of other conditions, summary tables, and attachments; the permit writer’s report; and the art of referencing materials.
• Summarizes the characteristics of effective permits: language (including when to use “shall” and “may”), organization of the permit, the importance of consistency, and accuracy.
• Identifies important but at times overlooked aspects of writing permits, including the importance of a complete application, communications with stakeholders, and documentation.
• Presents EPA’s Title V permit writer’s tips and the findings of the EPA Title V Task Force and of the Congressional Research Service regarding permit quality, problems and recommendations