Air Permitting 101
Air Permits Division Interaction (Module 4)
If you are starting Module 2, 3, 4, or 5, you may begin with Page 3. Pages 1 and 2 of these modules contain the same information as Pages 1 and 2 of Module 1, with the exception of scoring. Each module requires a different minimum score to pass, so please review Page 2 of the module if you are interested in specific scoring values. Please review Pages 1 and 2 of this module if you need to refresh your memory regarding course objectives and any instructions that may be helpful for navigation, bookmarking, printing (lesson pages and certificate), accessibility, and contacts.
A person completing the Air Permitting 101 on-line training will be able to do the following:
Recognize the organizational structure of the Air Permits Division;
Identify the purpose of the two air permitting programs and the types of authorizations available under each program;
Apply the process of issuing air permits;
Identify which areas of the TCEQ are involved in the air permitting process and how air permits data is used;and
Recognize the different mechanisms to locate permit documents.
The module opens with the Table of Contents (TOC). From the TOC, you may go directly to any page within the module by clicking on the page number or specific heading within the page. You may navigate between pages by clicking on the page numbers at the top of each page or by using the "previous page" or "next page" options at the bottom of each page. You may return to the TOC at any time by clicking on any one of the "Contents" buttons in the upper left, sidebar, or bottom of each page.
If you click on a link within the module, you may return to the module from the linked page by using the following procedures:
There are quizzes throughout this module. The quizzes have points assigned to them, and you earn points with every correct response you give. If you answer everything correctly, you can earn a total of 55 points. If you earn a minimum of 38.5 points (70%) when you complete the last quiz, you've passed and earned your certificate. You can see your score in the lower right hand corner of the screen as you work through the quizzes or you can click on the "score" button in the upper right corner of the lesson page at any time to view your current score.
This module will not allow you to bookmark, so please keep that in mind as you begin. If you cannot finish the module and must close it, your scores will not be retained and you must start the module over to get complete credit on the scored quizzes and activities.
To print your certificate and score summary, type your name in the box at the end of the module. Your certificate will only print if you earn the minimum number of points.
Use the "print all" button in the upper right corner of the lesson page to print the lesson. Please be aware that any hidden text (i.e., text poppers), sidebars, quizzes, and activities will not print. If you'd like to print additional information from the module, press ALT-PRINT SCREEN then CTRL V. You can then paste that most current screen image into Word and print from Word.
When the accessibility icon (which looks like a keyhole) appears, users have the option of clicking the icon to view the data in a separate accessible content tab.
If you see brown, bolded text in the module, this is most likely a text popper. If you roll your mouse over the bolded word(s), additional information regarding that specific term will "pop up." The module also has hyperlinks scattered throughout. In the main pages of the module, these are in brown, underlined text. Additional links (identified by white, bolded, and underlined text) may also be found in the sidebars.
If you are an employee of the Air Permits Division and have any questions as you go through this module, please see the Subject Matter Experts list. See the contacts listed under the Subject Matter Heading, "On-line Training Modules - Air Permits."
If you are not an employee of the Air Permits Division and have any questions as you go through this module, please contact the Air Permits Division receptionist at (512) 239-1250. Ask the receptionist to transfer you to a subject matter expert for on-line training modules.
This training is broken up into the following five modules:
You are currently in Module 4, entitled "Air Permits Division Interaction and How Permitting Data is Used Throughout the Agency." To access the other modules, simply click on the bulleted links. For the most effective learning experience, it is recommended that the modules be completed in the order listed above.
After completing the previous module, entitled "Air Permits Division Process," you should have an understanding of the review processes associated with the different permit authorizations. The review processes require that the division interact with other parts of the agency in addition to outside entities such as local programs, the Environmental Protection Agency (EPA), and the public. In this module, we'll focus on the interaction between the Air Permits Division and other TCEQ programs.
Throughout the permitting process, Air Permits Division staff will interact with multiple staff from program areas around the TCEQ. In this module, we will focus on those program areas typically involved during the permitting process. The Air Permits Division also has more limited and specialized contact and interaction with other areas of the agency. These programs will not be covered in this module but include the Waste Permits Division, Water Quality Division, and the Office of Administrative Services.
The Office of Compliance and Enforcement (OCE) conducts the following duties:
OCE is made up of the following:
Additional information regarding each division can be found in the tabbed information below.
Toxicology is the study of the adverse effects of chemicals on living organisms, and a toxicologist is trained to examine the nature of those effects and assess the probability of their occurrence. Toxicology is used to help the TCEQ make scientifically sound decisions when developing environmental regulations and policy and when reviewing air quality permit applications.
Effects Screening Levels (ESLs) are health effects guidelines used during the air permitting process to help ensure that authorized emissions of air contaminants do not cause or contribute to a condition of air pollution.
The Air Permits Division relies on TCEQ toxicologists to:
The OCC issues notices of applications, public hearings, and public meetings. OCC also prepares the commission agendas, transmits final decision documents to applicants and other parties, and maintains the official records of pending commission proceedings.
OCC's interaction with the Air Permits Division consists of the following:
OCC also conducts some of the duties of the former Office of Public Assistance. These duties include acknowledging receipt of written comments and requests for public meetings and hearings, conducting public meetings around the state on permit applications and air quality rule development, and managing the Environmental Equity Program.
With regard to air permit applications that publish notice and receive comments and requests for public meetings and hearings, OCC initially responds to the commentor(s) - informing these individuals that their comments and requests have been received and forwarded to the TCEQ permit reviewer and staff attorney. When requested, OCC also works with the permit reviewer and staff attorney in completing the RTC by providing a final review.
The Environmental Equity Program is now part of OCC. This program works to help citizens and neighborhood groups participate in the regulatory process, ensure that agency programs that may affect human health or the environment operate without discrimination, and make sure that citizens' concerns are considered thoroughly and handled in a way that is fair to all.
The Environmental Law Division (ELD) represents the Air Permits Division and other offices in the agency in implementing state law requirements, the federally approved air permitting programs, and State Implementation Plan requirements. ELD also represents other offices in the agency that implement state law requirements (such as water rights and water utilities) and various waste and water quality matters, which include both state and federally delegated and approved permitting programs.
With regard to air quality permits, ELD provides legal guidance and counsel regarding the interpretation of the laws which directly affect the technical review, special conditions, and other requirements included in air permits.
ELD staff attorneys play key roles when public comments regarding permit applications are received. They finalize the Response to Comments (RTC), file all necessary information with the Office of the Chief Clerk, and otherwise ensure all RTC procedures are followed.
The staff attorney is the primary agency contact when a permit application is contested and a public hearing is pending. Staff attorneys represent Air Permits Division staff before the commission for any contested matters and are the agency's counsel at hearings. They also attend public meetings associated with a contested air permit application.
ELD is one of the primary participants in the rule and standard permit development process. ELD staff attorneys provide legal guidance and counsel when new air quality rules and standard permits are being developed or when existing rules and standard permits are being amended. They are also responsible for drafting specific sections of rule and standard permit preambles. Staff attorneys assess risks associated with certain rule and standard permit development issues and provide comments on how the proposed language may be interpreted and whether it complies with statutory requirements. They also provide support for Air Permits Division staff before the commission on rulemaking issues.
Let's take a break here and make sure you understand the interaction of the Air Permits Division with the programs mentioned thus far. Please work through the following set of quiz questions to test your knowledge.
When you're ready, please continue working through the module.
The Office of Air (OA) currently consists of two divisions: Air Permits and Air Quality. You should already have a good idea of the functions of the Air Permits Division. The Air Quality Division (AQD) develops and implements statewide and regional plans, rules, strategies, and technical guidance to attain quality standards for air.
The Air Permits Division works primarily with the AQD's:
See the tabbed information below for more detailed information regarding each of these areas (in addition to information about the AQD's interaction with the Air Permits Division concerning rule development).
|DFW||HGB||BPA||El Paso||East and Central Texas||West Texas|
*The BPA and El Paso Ozone Nonattainment Areas were redesignated to attainment, effective November 19, 2010. The offset requirement no longer applies in these areas as of November 19, 2010; however, the offset requirement still applies to those sources that committed to it when the areas were designated as nonattainment.
O = Optional
M = Mandatory
NA = Not Applicable
DFW = Dallas-Forth Worth
HGB = Houston-Galveston-Brazoria
BPA = Beaumont-Port Arthur
For additional information regarding banking and trading programs, including credit programs and cap and trade programs, review the flash cards.
It is important to note that the emissions banking and trading programs and emissions inventory are applicable requirements of Title V operating permits.
That was a lot of information, so let's take some time to go over the banking and trading information by working through the following quiz questions. You'll be quizzed over AQD's other program areas at the end of the module.
The Small Business and Environmental Assistance (SBEA) Division:
SBEA offers services to a variety of customers, including small businesses and local governments, industries and manufacturers, agricultural operations, students and academia, and anyone interested in environmental stewardship.
SBEA is the primary point of contact for small business permit applicants and thereby directs the TCEQ Public Education Program, manages the toll-free confidential hotline (800-447-2827) and assistance Web site for small businesses, provides compliance support, and often helps these applicants fill out forms. In conjunction with helping small business applicants, SBEA staff members review the forms and guidance documents created by the Air Permits Division for readability and understandability from the small business perspective.
SBEA also acts as a liaison between small business applicants and the Air Permits Division in the rule development process, which includes participating in rule and standard permit team meetings, and attending stakeholder meetings.
The Air Permits Division also partners with SBEA for the TCEQ Environmental Trade Fair, Advanced Air Permitting Seminar, and Oil and Gas Facilities Workshop each year to determine the venues, agendas, and presentation programs for each of these events.
You've just completed Module 4. Please work through the quiz questions that follow. These will cover this entire module.
Don't forget your certificate (see below). From this module, you should now be able to identify the areas of the agency that have the most interaction with the Air Permits Division. It's now time to become familiar with how the division handles the documentation generated during a permit review. When you are ready, please proceed to Module 5, the final module of this training, entitled "Permit Document Availability/Final Exam."