Training Air Quality Regulators to Prepare Effective Permits

Air quality permits, issued by local, state, and federal agencies, authorize sources of air pollution to emit pollutants, but only within established regulatory limits to protect public health and the environment. To ensure compliance, these permits must clearly outline all applicable requirements and include enforceable conditions that enable ongoing monitoring, recordkeeping, and reporting. Permits serve as critical tools for regulatory agencies, the regulated community, and the public to verify that environmental standards are being met. Because air quality regulations at all government levels are dynamic, permitting staff must stay informed and flexible so that new permit writers can engage confidently with the permitting process and seasoned staff can recognize and address novel or complex issues (rather than default to routine practices) during application review.

Drawing on decades of experience, ERG’s air permitting experts developed a three-day interactive course on “Effective Permit Writing” that has been regularly featured in the training programs of multi-jurisdictional organizations (MJOs), including the Northeast States for Coordinated Air Use Management (NESCAUM), Lake Michigan Air Directors Consortium (LADCO), Metro 4/Southeastern Air Pollution Control Agencies (SESARM), and Western States Air Resources Council (WESTAR). The course begins with a review of the legal foundations for permit issuance, followed by an overview of various types of federal and state air quality permits. Participants are then guided through the complete permitting process—from application completeness review and regulatory analysis to emissions calculations and the development of enforceable permit conditions. Attendees then engage in an in-depth examination of permit requirements to gain or refine their understanding of what makes a condition enforceable, including essential elements such as emission limits; averaging times; and associated monitoring, recordkeeping, and reporting requirements. To inspire new approaches and highlight best practices, the course presents examples of permit structure and content from regulatory agencies across the country. These examples also illustrate common pitfalls, such as vague or unenforceable conditions. When offered through an MJO, the “Effective Permit Writing” training course has provided a valuable opportunity for cross-agency learning. Interactive discussions and small-group breakout sessions encourage attendees to collaborate on real-world permitting challenges, fostering innovative solutions and shared insights that participants can apply in their day-to-day roles.