Emerging Challenges in Title V Implementation: Compliance

摘要

Nearly seven years after Part 70 was promulgated, state and local air quality agencies are in the midst of issuing title v operating permits. Although the issuance schedule mandated in Part 70 required that most title v permits already be issued, this is clearly not the case. Uncertainties with the requirements for initial applications followed by the difficulties in developing real world operating permits have systematically slowed implementation. Perhaps the largest obstacle encountered by agencies drafting operating permits has been the development of adequate compliance requirements, particularly periodic monitoring. Fortunately, state and local agencies have gained sufficient experience to efficiently address periodic monitoring issues for most situations and the permit issuance pace has risen accordingly. As the permitting authorities hit their stride in the race to issue operating permits to major sources, agencies may not be looking far enough ahead to prepare for the next, and quite possibly highest, hurdle in the implementation of a title v program. Based on a survey of permitting authorities in EPA Region 4, implementing the title v compliance/enforcement requirements will likely result in new difficulties for agencies with limited resources. This paper takes a close look at the goals intended for the title v program and how the goals can best be translated into the compliance requirements of title v permits.