Texas Natural Resource Conservation Commission Interoffice Memorandum To: New Source Review Engineers Through: Jeff Saitas, P.E., New Source Review (NSR) Program Director From: Denise D. Simmons, P.E. Date: July 22, 1994 Subject: Standard Permits - General Information of Interest Purpose As of May 4, 1994, there is another option to comply with Regulation VI called a standard permit. On May 4, 1994 Regulation VI revisions became effective that provided for Standard Permits under Subchapter F, 116.610-617. In addition, similar provisions were previously adopted through Regulation V, Subchapter J, 115.950 and Regulation VII, Subchapter D, 117.550. However, the non regulation VI standard permits have limited use. A source can only use a non regulation VI standard permit if it must comply with a provision of that particular regulation. A Regulation VI standard permit is not an exemption but rather a permit defined by rule. All the conditions for standard permits are defined in the rule. Any allowable emission limits or any special provisions must be defined in the rule itself; no separate tables or conditions or permit face will be issued. The public notice requirements are satisfied as part of the rulemaking process when the regulation VI standard permit rules or revisions go through public hearings prior to final adoption. Impacts will be considered as necessary during rule development. To use any standard permit, the facility must comply with all federal and state statutory requirements including major source and/or major modification, nonattainment and PSD requirements. If a source qualifies a standard permit can be used in lieu of a permit or amendment. Background Standard permits were developed as a means of streamlining the authorization process for very specific cases. For example in cases where there is a reduction of emission due to voluntary controls or where controls are added or processes changed as a result of other regulatory requirements. In the May 4, 1994 version of Regulation VI you will find the first two standard permits which apply to sources that have provided for voluntary reductions or the sources that must meet conditions as a result of regulation changes. In the future, additional regulation VI standard permits will be adopted for specific industry types where the level of control and special provisions can be defined as part of the regulation and where we are comfortable that air quality is protected. Policy questions and issues that arise as we implement this new option will be addressed in policy updates as often as necessary.