Merging Permits

Since the provisions of a federal operating permit program require every major source of air pollution to obtain an operating permit that incorporates all applicable requirements under the Act, it creates the potential for overlap between all three permit programs. Currently, the permit processes for federal operating permit revisions, case-by-case MACT, and NSR are separate and require the facility to meet unique notification and public comment obligations. The timing of the respective permit processes may not be compatible, resulting in lengthy delays in permit issuance and perhaps requiring the facility to undergo several public, state, and EPA review and comment periods for the same permit action.

The provisions for the federal operating permit program provide an option for states to merge the respective NSR and/or case-by-case pre-construction permit processes with the federal operating permit revision requirements and streamline the three separate processes. This option would allow states to "enhance" the NSR or case-by-case MACT processes to include the requirements of the federal operating permit so that facilities would be able to satisfy all permit revision obligations in one comprehensive process. Currently, most states do not have

"merged" programs in place and it is not clear how many will pursue this option.

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