What Do Permit Reviewers Do?

Air Permits Initial Review Team

Every application must go through initial review to determine if there are any major administrative application deficiencies. This step of the permit issuance process is completed by the Air Permits Initial Review Team (APIRT). APIRT also logs projects into a database, assigns project numbers, ensures that the minimum application fee was collected, sends the site review Request for Comments to the appropriate regional office, and prepares the initial public notice package.

Technical/Production Sections

The application and all supporting documents are then forwarded for the appropriate technical/production section to complete the technical review. During the technical review process, the permit reviewer ensures that the authorization will be issued in compliance with the applicable rules and regulations. Source identification, air emission quantification, analysis of the off-property health impacts of emissions, determination of best available control technology (BACT), and applicability of any source category or emission-based state and federal regulations are all considered during the technical review and are the responsibility of the permit reviewer.

Compliance History Review

A site's compliance history must be considered for certain authorizations and is also evaluated by the permit reviewer. Compliance history is a uniform standard used to determine how well an applicant has been complying with environmental regulations over the past five years. Applicants are classified as being unsatisfactory, satisfactory, or high performers. Compliance history may be used in determining eligibility for authorizations or may result in additional permit requirements.

For example:
If an applicant has an unsatisfactory compliance history classification, it is possible that one of the general, streamlined authorizations like a permit by rule may not be claimed. In addition, an applicant with an unsatisfactory classification may be given a shorter permit expiration date or more monitoring or reporting requirements in a case-by-case permit (Title V or NSR).

Public Notice

Some air permit applications are subject to public notice, which requires the applicant to publish a newspaper notice and post signs regarding the pending permitting action. Most individual public notice periods last 30 days. Notice is published in a newspaper of general circulation. The sign postings allow members of the community that drive by the facility to be informed that there is a pending action at the site. Some applications are also subject to public notice requirements in alternative languages -- Spanish and Vietnamese being some of the more common alternative languages found in Texas.

Minor source applications received on or after June 24, 2010 and all major source applications are subject to a second public notice (including sign postings). Newspaper publication of the second notice usually occurs after the permit special conditions and maximum allowable emission rates table have been drafted. Preparation of the second public notice package is the responsibility of the permit reviewer.

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