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         Texas Natural Resource Conservation Commission
                     Interoffice Memorandum

To:  New Source Review Engineers 
Through:  Jeff Saitas, P.E., New Source Review (NSR) Program
From:  Denise D. Simmons, P.E.
Date:  July 22, 1994
Subject:  Standard Permits - General Information of Interest


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.  


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