TITLE V PERMITTING: HOW WE MANAGE COMPLEX AIR COMPLIANCE ACROSS STATE LINES

For major industrial facilities, the Title V Operating Permit is more than a document—it is the license to exist. But managing Title V compliance is not a static task. It requires navigating a shifting landscape of federal EPA rules, state-specific implementation plans (SIPs), and local air district nuances.

The Challenge: One Rule, Fifty Interpretations

A manufacturing client with facilities in California, Texas, and New Jersey faces three entirely different regulatory environments for the exact same equipment. What qualifies as an "insignificant activity" in Texas might trigger a major modification review in California. This inconsistency is where compliance gaps usually form.

Mercy's Approach: The "Audit-Ready" Standard

We don't just file permits; we build compliance systems. Our team recently managed a Title V renewal for a multi-state chemical manufacturer. By centralizing their emission calculations and standardizing their record-keeping protocols, we reduced their annual reporting burden by 40%.

• Emission Inventory Correction: We identified over-reported emissions in previous years, saving the client over $45,000 in annual emission fees.
• Operational Flexibility: We successfully negotiated "Alternative Operating Scenarios" into the permit, allowing the facility to switch production lines without triggering a permit modification.
• Agency Negotiation: We acted as the technical liaison with state regulators, answering technical queries directly to expedite issuance.

"Title V compliance is not about hiding problems; it's about engineering solutions that make compliance the path of least resistance." — Samuel Akinyemi, P.E.