The following text is an abridged and edited transcript of the above video.
The South Coast Air Quality Management District’s (AQMD) Certified Permitting Professional Program (CPP) is a permitting credential that certifies private consultants who are familiar with the AQMD’s permitting process. The program acts as part of the AQMD’s permit-streamlining process that aims to make it faster and easier to obtain a permit from the agency.
Getting an AQMD permit can be a long and arduous process — but a necessary one, because permits are needed to build any piece of equipment that can or will emit air contaminants. The CPP program is just one way that the AQMD has created to help make the permitting process more efficient. Others include the Certified Equipment Program (CEP) and Expedited Permit Processing (which used Form 400-XPP, and so is sometimes referred to by those letters), the latter which comes with higher fees so as to authorize engineers to work overtime or on days off so as to speed up the process.
Benefit of Using a CPP [02:50]
The main benefit of having a CPP prepare your permit application is that you can expect a shorter permit-processing time due to the district knowing that the application was prepared by someone familiar with the permitting process. The AQMD maintains a lengthy list of select CPPs, although it is far from complete, because a CPP can elect not to include their name.
Tips for Preparing Permit Applications [04:53]
The AQMD provides CPPs with various tools and guidance documents that you need to prepare permit applications. It’s worth noting that this information is in the public domain and so is accessible by anyone, not just CPPs. However, the information on the website isn’t centralized and so it can be hard to track down individual pieces of information.
There is one tool that only CPPs can access. you need to be a CPP to get access to, and I’ll talk about that later.
The AQMD does provide information for submitting complete permit applications as well as the tools needed to calculate air emissions, much of which can also be found in the CPP manual.
The CPP Manual [06:16]
Reading and understanding the handbook is the single best step you can take to learn how to prepare complete permit applications. The manual is structured around the different AQMD rules, each of which is centered on a specific topic. For example, Regulation II includes all of the rules related to permits, such as Rules 201, 202, 219, 218, 222, and 212, among others. Note that rules are numbered according to the regulation under which they fall; thus, all of the rules under Regulation II begin with a 2.
A CPP needs to know how to apply the rules and regulations to a piece of equipment that needs a permit as well as how to understand how permit conditions are developed. Permit conditions exist to ensure that equipment is constructed and operated in compliance with all the rules, and a CPP knows how to draft and develop permit conditions to meet that goal.
The overall goal of the permit processing process is so that the engineer can determine whether a piece of equipment can operate or be constructed in compliance with all the rules and regulations of the air district.
The One Tool Accessible Only by CPPs [10:00]
As mentioned above, the majority of the information on the AQMD’s permitting process is accessible by anyone. But there is one tool that only CPPs can access: the CPP database, which contains some of the AQMD’s internal databases.
A CPP preparing a permit application on behalf of a client must request access to this database. If your request is granted, you then have access to some internal files related to the client’s facility — very handy information indeed.
How to Become a CPP [10:40]
To become a CPP, you just need to pass an exam with a score of at least 70 percent. No formal experience or special training is required to take the exam, so you can simply study the material yourself. Once certified, you must renew your certification annually. If you don’t renew your certification, you lose your credential, and the only way to get it back is to pass the exam again.
There’s a common misconception that only CPPs can prepare permit applications. But anyone can do so, although having the certification makes it more likely that the application will be prepared and submitted accurately the first time around, which is why the AQMD started the CPP program to begin with.
Study Materials for the CPP Exam [13:30]
There are a few study courses available for the CPP exam, but in my experience, the best way to pass is to follow these six points:
- Read the CPP manual [14:17]. I recommend doing this even if you’re not looking to become certified, as it will give you an overview of the permitting process and some of the roadblocks you might encounter.
- Study sample air permit applications [15:00]. Become familiar with what information is needed to complete the application as well as the three main components: forms, fees, and detailed engineering evaluation.
- Learn how to complete a tier-one and tier-two Health Risk Assessment (HRA) [17:13], required by Regulation XIV (14), Rule 1401.
- Learn how to determine when a permit is needed by understanding Rules 201, 219, and 222 [17:50], and how they relate to each other.
- Learn how to prepare a fee calculation [18:55]. Although this is covered in the CPP manual, you want to make sure you are familiar with information such as when a permit is eligible for a discount, when a penalty needs to be applied, and fee structures.
- Become familiar with the structure of AQMD rules and regulations. [20:50] If you understand how the rules and regulations are organized, you can more quickly determine which rules apply and which ones don’t. Especially important to know are the regulations for the AQMD RECLAIM and Title V programs. I also highly recommend reading an overview of air quality regulations by a lawyer named Curt Coleman, the air district’s former general counsel.
Best of luck on the exam! Let us know how it goes in the comments below.