The Two Air Permitting Programs and Their Purposes

New Source Review (NSR) Program

Congress established the New Source Review (NSR) permitting program as part of the 1977 Federal Clean Air Act Amendments. The NSR permitting program ensures that air quality is not significantly degraded from the addition of new and modified facilities, assures the public that emissions from new and modified industrial sources will be reduced or eliminated through technically practicable and economically reasonable air pollution control method(s), and verifies that advances in pollution control occur concurrently with industrial expansion.

An NSR permit is required before construction on a facility begins. The purpose of the NSR program is to issue permits for new construction or modification, establishing emission controls and limits based on applicable state and federal rules and a best available control technology (BACT) and impacts review.

Federal (Title V) Operating Permits Program

Congress passed the Federal Clean Air Act Amendments of 1990, which included new provisions in Title V, creating an operating permit program to ensure better compliance and to allow for more thorough air pollution control.

A Title V permit is required for operation of major sources and certain non-major sources. Title V permits codify all applicable air requirements into one authorization. Some examples of Title V applicable requirements are:

In general, Title V permits prescribe monitoring and recordkeeping for determining compliance with applicable requirements, compliance plans for emission units that are not in compliance with applicable requirements, and requirements for permit holders to certify compliance with the permit annually and report any deviations with the permit semi-annually.

In many cases, such as initial issuance of a Title V permit, the site may operate while the Title V permit is being processed as long as a timely application was submitted.

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