Air Permitting Hurdles: A Practical Perspective Based on the Oregon Permitting Experience

Nearly ten years after Congress passed the 1990 Clean Air Act Amendments, most states are struggling to finish issuing federal operating permits (also referred to as “Title V permits”). Two of the states in EPA Region X, Oregon and Washington, were in the forefront of developing their Title V programs and issuing the permits. Oregon, in particular, led the nation in issuing Title V permits; the last of its Title V permit applications was received in 1995 and many of its sources have already completed their first Title V permit renewal. As a result, EPA Region X developed many seminal positions for implementing Title V. It also resulted in the Oregon major sources having learned many lessons related to the Title V permitting process. This paper outlines several of the key issues that have arisen as a result of permitting sources in EPA Region X, particularly in Oregon, and suggests ways to avoid, or minimize, their impact.