Title V and Synthetic Minor Permits
Title V is one of several programs authorized by the U. S. Congress in the 1990 Amendments to the federal Clean Air Act (CAA). The intent of the program is to:
- Enhance nationwide compliance with the Clean Air Act
- Provide the basis for better emission inventories
- Provide a standard means to implement the following other programs in the federal Clean Air Act:
- Hazardous Air Pollutants (CAA 112);
- Periodic Monitoring (CAA 114 and 504); and
- Acid Rain (CAA Title IV)
The Title V program requires local and state air quality agencies to issue comprehensive operating permits to facilities that emit significant amounts of air pollutants. For all implementing agencies in the country, there are standard requirements for permit programs and permit content.
Title V operating permits differ from other District issued operating permits in that they explicitly include the requirements of all regulations that apply to operations at Title V facilities.
Any facility subject to Title V because its potential emissions exceed the trigger levels in the District's program, but which has actual annual emissions that are always below those levels, may opt out of Title V through one of the following two approaches:
- A facility may apply for and receive a Synthetic Minor Operating Permit (SMOP). The requirements for a SMOP are laid out in Regulation 2, Rule 6, Major Facility Review (75 k PDF, 22 pgs); or
- A facility may show that its Potential to Emit (PTE) is below each Major Facility pollutant threshold by using the procedure set forth in the Manual of Procedures Volume II, Part 3, Major Facility Review (130 k PDF, 38 pgs)).
The following policies and procedures provide clarification for the processing Title V and Synthetic Minor permits.
Manual of Procedures, Volume II, Engineering Permitting Procedures, Part 3 (Major Facility Review Permit Requirements) (130 k PDF, 38 pgs) - 5/2/2001