Solving a Complex Air Permitting Issue using a Flexible Permit

Solving a Complex Air Permitting Issue using a Flexible Permit


Service Area:
Air Quality Permitting

Client's Challenge

In a particular area of manufacturing, the client often needs to make minor process modifications to respond to the market and meet customer needs.  These “tweaks” can meet the definition of a modification but often result in no emissions changes, or very small emissions increases.  The number of such projects being submitted by a particular facility concerned the state agency and brought into question whether the projects needed to be aggregated for purposes of evaluating New Source Review (NSR) requirements (i.e., for determination of whether the major modification thresholds would be triggered).

ALL4's Solution

ALL4 led several meetings with the client and the air quality permitting staff at the state to explain why the projects were not economically or technically related and therefore should not be aggregated.  As part of those conversations, the state recommended exploration of a Flexible Permit that would allow these small changes to be made under a blanket approval.  ALL4 drafted proposed permit language and continued to work closely with the state to finalize a Flexible Permit that will streamline the process for the client, allowing them to respond to customer needs more efficiently.

The Results

After a lengthy back and forth with the state, a Flexible Permit was issued in 2021.  The permit meets the client’s needs and also addresses the state’s concerns.


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