With new projects and facilities opening, it is crucial to have up-to-date permits. Unfortunately, many times the need for air permits gets overlooked, resulting in fines from state agencies. AET’s Environmental Air Compliance Team has three things to consider when starting a new project and determining your permit needs to help avoid fines.
With the economy ticking along, many businesses have decided to open new facilities, while others have taken steps to expand or relocate existing facilities. Unfortunately some businesses are doing so without giving thought to environmental permits—particularly air quality permits—the facilities may require before beginning construction and/or operation.
Air quality permits are required if the emissions from your facility exceed specific thresholds based on the “Potential to Emit” (PTE). PTE is the theoretical maximum amount of air pollution your facility could emit if it operated at full capacity 24/7. The PTE scenario is unrealistic for nearly all manufacturing operations; however, it is the criterion the state and federal environmental agencies use to determine if a permit is required. An air quality permit may be required even if you operate a process that emits air pollution for only a few hours a year. Needless to say, the world of air quality permits can be confusing for business owners to navigate!
So if you’re thinking about moving ahead with a new project, be sure to consider these three things:
1. You may need an air quality permit, even if you think you don’t.
Just because your facility doesn’t have smokestacks doesn’t mean it’s exempt from an air quality permit, the only way to know for sure is to conduct an air permit assessment.
An air permit assessment will provide you with the following: a detailed summary of the current and maximum potential (PTE) air emissions from the operations at your facility; the federal and state environmental regulations that apply to your facility; and an explanation of why each regulation applies. This information is key to determining if your existing operations need an air permit as well as the appropriate permit type for your facility. If you’re planning to expand or relocate a facility, the assessment can also help determine if you’ll need to amend your current permit.
It is best practice to perform an air permit assessment as part of their internal environmental, health and safety audit. Just because you’ve been operating for years without one doesn’t mean you’re in the clear. Better to be safe (i.e., in compliance) than sorry.
2. Failing to not have a permit—or the right permit—can be costly.
Falling into the “sorry” category when it comes to air quality permits could cause your business to incur tens of thousands of dollars in fees. Fines are generally based on your degree of negligence (did you know you needed a permit and failed to act?) and on the amount and type of pollutants your facility may have emitted.
Not having the right permit could dent your bank account, too. Often times, multiple types of permits are available for your facility. However, permit types may differ in the amount of compliance information required to manage them (some can incur more expense than others) or in the amount of time the agency needs for its review (some require 30-60 days; some require 150). Some permits may even allow you to make certain changes in your facility, such as adding equipment, without having to modify the permit.
It’s important to choose the air quality permit that best fits your current and future business needs. Remember: Permit application fees can add up;getting your application (including permit type) right the first time is key.
3. Start the process early.
Your air quality permit should be in place before you put a shovel in the ground. Since the permitting review can take time, it’s critical to start as soon as possible.
Starting early gives you a chance to develop an environmental compliance strategy that complements your business strategy. It is prudent to also consider the impact future regulations could have on your business.
This is not an exhaustive list but lends itself as a starting point when thinking about air permits. More and more people are concerned about air emissions, and that’s a good thing for the air we breathe. But it also means that you should thoroughly evaluate the type of air quality permit your existing or planned facilities may need.
For more information on AET Environmental Compliance and Permitting please visit: /services-delivered/environmental/compliance-permits/
Gail Cederberg, Ph.D., Principal Engineer in AET’s St. Paul Environmental Department at AET. She can be reached at firstname.lastname@example.org.