Understanding Air Permitting

Whether you’re a manufacturer expanding operations or a developer planning a new project, having the right permits in place is essential for compliance and avoiding costly delays. At Lord & Winter, we help businesses across the nation navigate air permitting requirements—whether they fall under Title 5 or Non-Title 5 regulations. 

Title 5 vs. Non-Title 5 Permitting

Title 5 of the Clean Air Act requires major sources of air emissions to obtain an operating permit. Major sources are those that emit or have the potential to emit specific quantities of regulated air pollutants. These permits are comprehensive and require facilities to document how they will comply with emission limits and monitoring requirements. For example, large manufacturing facilities or power plants often fall under Title 5 permitting due to their substantial emissions. In Tennessee, the Division of Air Pollution Control is responsible for overseeing Title 5 permitting. 
Non-Title 5 permitting, often referred to as minor source permitting, applies to facilities whose emissions are below the major source thresholds. Though less stringent than Title 5, these permits still require accurate emissions calculations and compliance with applicable standards. For instance, smaller-scale operations like dry cleaners or food processing plants may fall under non-Title 5 permitting. In states like Florida, the Division of Air Resource Management regulates both major and minor source permits. 

Emissions Calculations

Accurate emissions calculations are foundational to the permitting process. Calculations typically involve estimating potential emissions from various sources within a facility, such as boilers, generators, and manufacturing processes. These estimates are then compared against regulatory thresholds to determine whether Title 5 or Non-Title 5 permitting applies. Michigan’s Air Quality Division provides guidance on emissions calculations and permitting requirements. 

Best Available Control Technology

When applying for air permits, particularly Title 5, facilities may be required to implement Best Available Control Technologies (BACT) to reduce emissions. BACT determinations are made on a case-by-case basis and often involve balancing environmental benefits with economic feasibility. In Louisiana, the Air Permits Division ensures BACT standards are met where applicable. 

How Lord & Winter Can Help

With our expertise in air permitting, Lord & Winter guides clients through every step of the process, from emissions calculations to BACT assessments, ensuring compliance with federal and state regulations. 

By partnering with Lord & Winter, you not only achieve compliance but also gain valuable insights to streamline permitting, avoid costly delays, and reduce downtime. Contact us today to discuss your air permitting needs and discover how we can support your company’s growth while minimizing environmental impact. 

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