Created by Congress as an amendment to the Clean Air Act, the Major Source Review Program (Title V) requires large industrial facilities to issue a single comprehensive operating permit that shows all federal, state, and local air quality requirements. The program includes requirements to monitor emissions and make regular reports.

Key features of the Major Source Review process include:

• Review of all federal, state, and local air quality requirements that apply to the facility.
• A public notice and U.S. EPA review period. All comments must be addressed before the initial Title V permit is issued or renewed.
• Federally enforceable requirements may also be enforced via citizen lawsuits.
• The EPA can modify, terminate, or revoke and reissue a permit if necessary.
• Permits must be renewed every five years with the full public notice and EPA review process.

The District’s Major Source Permit program is approved by the U.S. EPA.  The District has streamlined its permitting process to issue a combined local and federal operating permit. This avoids duplicated documents and reduces costs for applicants.

There are three principal benefits:

• Public engagement. The public is invited to comment on these permits, and all public comments are considered before permits are issued.
• Enhanced monitoring, recordkeeping, and reporting requirements. These requirements promote ongoing internal vigilance by industry operators, and ensure that facilities are subject to consistent oversight by the U.S. Environmental Protection Agency.
• Emission reductions. Some potential Title V sources have reduced emissions to get below the threshold pollution levels so they will not be required to obtain these federal permits.

A facility becomes subject to this federal program based on its potential to emit air pollution, which is determined by the physical and operational design of the facility. The District is classified attainment for all federal ambient air quality standards, as well as California state standards, except for the state PM10 standard.  Major sources are categorized by having potential emissions that meet or exceed the major source threshold for that location. In the North Coast Unified AQMD, a source is classified as major if emissions exceed one or more of the following:

• 100 tons per year of any one criteria pollutant,
•  10 tons of any one hazardous air pollutant, or
• 25 tons of any combination of hazardous air pollutants

Permits describe how a facility must comply with air pollution rules. For example, a permit might require that a facility install certain kinds of pollution control devices or might impose limits on a facility’s operating times or total emissions. Monitoring and recordkeeping requirements are important components of Title V permits. Permits usually require facilities to keep track of their emissions and make regular reports.

Yes. Public participation is one of the most important features of the Title V process.

During the official public comment period, any member of the public may review a proposed Title V permit and comment on it. Members of the public may also request that the District hold a public hearing for discussion of any permitting issues.

Comments are most effective when they make specific suggestions for changes to the permit, explain why these changes are needed, and refer to applicable rules and regulations.

The major source Title V Permit administrative process consists of the following steps:

1. Application Completeness Determination: Staff review the application submitted by the owner or operator of the facility and evaluate whether all the required elements are addressed.

2. Evaluate Proposal: Staff evaluate the proposal, verify emission calculations, and identify regulatory requirements. Staff recommends a course of action and prepares a statement of basis. If revisions to the permit are required, a draft permit is written.

3. Notice of Proposed Decision: Official notice of a proposed decision is provided to the public and regulatory agencies. The notice identifies the public comment period (usually 30 days), and the date of the public hearing if scheduled. The notice is published in a newspaper of general circulation in the area where the source is located and is also posted on the District’s website. Notification is mailed to USEPA, CARB, and other air agencies within and adjacent to the District boundary. Individuals may request to be added to the notice distribution list.

The notice includes:

• The name of the facility, the name and address of the permittee and the permitting agency;
• Activities covered by the draft permit;
• Any emissions change involved in the permit action;
• Who to contact for more information, including a copy of the draft permit and supporting materials;
• How to submit comments; time/place of any hearing already scheduled;
• How to request a hearing if one has not already been scheduled.

4. Consider Comments: Staff consider all comments received and prepare a written response. The entire project file is then transmitted to EPA for a 45-day review period.

5. Final Decision: The District Executive Office issues a final decision on the application resulting in either issuance of a new permit, or in the of a modification, renewal, or revocation of an existing permit.

Facilities must comply with all applicable rules and regulations. Only the equipment listed on the permit may be used. The permit contains emission limits and operation restrictions specific to the facility. Periodic monitoring, performance testing, and inspection requirements are common.  Some of the typical reporting obligations are listed below.

• Periodic Monitoring Requirements
• Deviation and Breakdown Notification
• Semi-Annual Monitoring Reports
• Annual Compliance Certifications
• Non-Compliant Operations
• Current SIP Approved Rule

Once a final Title V permit is issued, it does not need to be renewed until five years from the effective date.  To renew the permit, a responsible official shall submit a complete standard application no earlier than 18 months and no later than 6 months before the expiration date of the current permit to operate. Once the responsible official submits a timely and complete application for renewal of a Title V Permit, the source shall operate in accordance with the existing permit to operate and all applicable regulations until the District takes final action on the application.

• Contact District Staff at (707) 443-3093 or via support@ncuaqmd.org
• Contact US EPA Region