Throughout our years in the “air permitting trenches,” we’ve seen permit applications with a variety of problems:
- No fees
- Missing signatures
- Missing forms
- Incorrect data
- Too little information
- No rule evaluation
…and the list goes on.
Air permitting can be a complex process that involves both internal and external stakeholders, but it’s a necessary process if you want to move your project forward.
We’ve come up with six ways to ensure that your next South Coast Air Quality Management District (SCAQMD) air permitting project will be successful.
1. Retain staff who understand the air permitting process.
Most people underestimate the complexity of the air permitting process and the amount of detail required for each permit application.
When it comes to permitting, the “devil is in the details”, and knowing how to navigate through them can be the difference between your project succeeding and failing.
It is easiest if you retain or hire, someone who is knowledgeable with the permitting process.
Many people have the misconception that only a Certified Permitting Professional (CPP) can prepare an air permit application, but that isn’t true.
Anyone can prepare a permit application, but only people who have the experience with the permitting process can prepare a complete air permit application.
(and that is one that the SCAQMD can actually process)
If you decide to retain someone who is not a CPP, you can gauge that person’s knowledge of the air permitting process by asking if that person knows all of the elements of a complete engineering evaluation.
2. Discuss your potential project with the SCAQMD prior to submitting your permit application.
One of the main goals of the permitting process is to determine if the equipment being permitted can operate in compliance with every rule and regulation of the air district.
With all of the rules and regulations that could apply to your project, is it possible to know all of the hurdles and requirements that need to be met ahead of time?
The answer is yes, and depending on the project, the best way to get this information is to get input from the SCAQMD before starting the permitting process.
During this process, some of the questions that can be addressed are:
- What is the best control technology for this piece of equipment?
- What information is needed to permit this piece of equipment?
- Is the project exempt from permitting under SCAQMD Rule 219?
- Is the project exempt from the California Environmental Quality Act (CEQA)?
- How can the air permitting for the project be expedited?
Having good communication with the SCAQMD can pay dividends during the air permitting process.
3. Be sure that everyone on your team knows how the permitting process can affect the project.
Depending on the complexity of your project, the preparation and processing of an air permit can affect several departments within an organization: legal, finance, operations, maintenance, etc.
When going through the permitting process, be sure that everyone has the same knowledge about how the permitting process can affect the project.
For example, maintenance/operations should know not to purchase any equipment until the permit is in hand.
In another example, the legal folks should be aware of any public workshops or comment periods that the project could trigger.
Good communication is the key to success, and having everyone on the same page can help prevent a lot of headache throughout the permitting process.
4. Start early and build contingencies into your project plan.
Depending on your project, the permitting process can be time-consuming and tedious.
Even if you do everything right when you prepare the application, the SCAQMD will still need to process your permit application.
How long does it take the SCAQMD to process a permit application?
It depends on a number of things, some of which you don’t have control over, so you need to incorporate “the unknown” into your project plan.
Many people tend to wait until the last minute before they file a permit application, but that’s one of the worst things to do for a project since construction of the equipment can’t occur without having the air permit in hand.
And if the piece of equipment is needed to get approval for another part of the project, then the SCAQMD permit can delay the downstream parts of the project.
Whatever the case, start the process well in advance of the deadline.
Also, in some cases, the Environmental Protection Agency (EPA) will also need to review the permit.
As an example, for Title V facilities, once the SCAQMD finishes processing your permit, it will need to go to the EPA for a 45-day review. This review should be included in your project timeline.
Lastly, you should also build contingencies into your project plan in the event that the project causes public notices or a public workshop.
In this case, your permit cannot be processed unless all of the notices have been mailed, or all of the comments have been addressed from the workshop.
5. Do not purchase any equipment before you receive your permit from the SCAQMD.
SCAQMD Rule 201 requires the owner or operator of a piece of equipment to obtain a permit from the air district before building, erecting, installing, altering or replacing any piece of equipment.
We have seen cases where an SCAQMD inspector will issue a violation for having “constructed” a piece of equipment by simply having it on the site without a permit. Although it may be an extreme scenario, you’ll want to consider it when purchasing and having equipment on site that needs a permit without first having an air permit in hand.
6. Be sure that your fees are correct.
Permitting fees are one of the three core elements of a permit application, so when you submit you permit application, be sure that you’ve correctly calculated your fees.
Even if your permit application is perfect, the district engineer cannot finish processing your permit application until all of the permitting fees have been collected.
Check and double check that your fee calculation is correct; you can use the SCAQMD’s fee calculator.
Permitting can be complicated, but you can make it easier on yourself by knowing the strategies that will help you achieve success in your permitting project.
Let’s take this over to you
Do you know of someone who is starting a project that needs an air permit from the SCAQMD?
If so, please share this article with them to make their life easier when they start down the sometimes windy road of permitting.
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