The Different Kinds of Title V Authorizations

Now that we have covered the different types of NSR (pre-construction) permits in some detail, we will briefly discuss the two different types of Title V (operating) permits.

Site Operating Permit

Site operating permits (SOPs) are Title V permits that contain requirements specific to an individual site and thus, receive case-by-case reviews. The permits contain requirements that apply to the site as a whole, as well as requirements that are specific to individual emission units. All Title V SOPs are subject to public notice and the opportunity for a notice and comment hearing, affected state review (if the site is within 50 miles of an affected state), Environmental Protection Agency (EPA) review, and public petition (which is a 60-day period that occurs after the SOP is issued). SOPs must be renewed at least every five years.

General Operating Permit

General operating permits (GOPs) are issued to cover numerous similar sites, as is authorized under the Federal Clean Air Act. GOPs are analogous to PBRs and standard permits in the NSR program.

The executive director has issued GOPs for oil and gas sites, air curtain incinerators, and municipal solid waste landfills. When the executive director initially issues a GOP, it is subject to public notice, affected state review, EPA review, and public petition.

An owner or operator may obtain an authorization to operate (ATO) under a GOP. The ATO is not subject to individual public notice, affected state review, EPA review, or public petition, as these requirements are fulfilled by the executive director when the GOP is initially issued. GOP applications are enforceable and the ATO (in the form of a grant letter) is issued to the owner or operator. The executive director is required to renew GOPs every five years. In addition, individual ATOs are required to be renewed every five years.

GOPs can only include:

GOPs can't include*:

A site that's in compliance

A compliance plan or permit shield

PBRs/Standard exemptions

A case-by-case NSR permit

Standard permits

Provisions specific to an individual site

*If any of these items need to be included in a Title V permit, an SOP would have to be obtained.

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