Federal Air Permitting
In addition to securing pre-construction approvals at the local level, ALG has extensive experience with permitting Federal Title V facilities. ALG staff helped our clients and trade associations comment on the design of the EPA and state/local operating permit programs, and have secured scores of Title V permits for major sources throughout the United States. Technical services including preparation of initial and renewal Title V applications include:
Calculation of emission inventories for criteria, air toxic, and GHG emissions;
Definition of applicable federal, state and local requirements;
Definition and negotiation of monitoring, recordkeeping and reporting protocols;
Air dispersion modeling and health risk analyses (where applicable);
Strategic design to optimize operating flexibility, leverage application and permit shields and alternate operating scenarios, where necessary, and negotiation of streamlined permit terms and conditions;
Title V implementation programs and data management software;
As part of ALG’s diverse air quality practice, we routinely assist major source facilities, including refineries, oil and gas operations, electrical power generating facilities, manufacturing facilities, and their legal counsel on Title V operating permitting and compliance requirements. ALG is recognized as a leader in Title V permitting matters, and has been distinguished by both our clients and federal agencies for our work in resolving complex air permitting matters. We have a solid command of Title V permitting and the complex web of federal, state, and local air quality compliance requirements.
In the early mid-1990’s our staff assisted industry, trade associations, and agencies in developing state and local Title V operating permit regulations; including the Bay Area, the South Coast, San Joaquin, San Diego, Alaska, Louisiana, Hawaii, and several eastern states.
Applications and Plans
Over the past 20 years, we have prepared scores of Title V permit applications for complex source operations around the United States, and designed and secured approvals of Part 64 Compliance Assurance Monitoring (CAM) Plans required of major sources that rely on pollution control systems to maintain compliance with applicable requirements.
ALG has authored papers with EPA senior staff (EPA Region 9 and EPA Headquarters staff) on Title V implementation issues, including Title V permit negotiation/renewals, excess emission reporting, and the due diligence that is to support Title V annual certifications. We regularly support our clients in administrative proceedings by providing expert testimony on Title V enforcement matters. Finally, we provided expert testimony in the defense of one the largest litigation matter brought by the California Department of Justice over Title V permit compliance issues.