The federal Clean Air Act operating permit program as now constituted will have a major impact on a wide variety of industrial operations, particularly those facilities that need to make frequent process, product, or materials changes. This paper offers four suggestions for improving the operating permit process to benefit both the regulated facilities and permitting authorities. These recommendations are: 1) to allow the Title Ⅴ program to become established and functional, so that future regulatory changes can be appropriately targeted to address widely acknowledged problems; 2) to use Title V to truly compile in one place a source's applicable requirements, not as a place to revisit or duplicate underlying regulatory processes or control requirements: 3) to provide flexibility in operating permits, reducing the need for permit revisions; and 4) to accept the proposition that the permitting process will be iterative, and encourage the issuance of initial permits―allowing permits to be perfected over time.
展开▼
