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EGLE's Air Quality Division initiates new Renewable Operating Permit Central Unit

EGLE’s Air Quality Division (AQD) is responsible for permitting sources of air pollution in Michigan. AQD operates two air permitting programs – a Permit to Install (PTI) Program and the Title V Renewable Operating Permit Program (ROP). Both programs involve a technical review of a permit application, drafting of permit conditions, and issuance of an air permit. Where the PTI allows for new or modified construction, the ROP, applying to only the largest emitters, is an on-going renewable permit. The purpose of these air permitting programs is to ensure air quality and public health are protected.

Renewable Operating Permit (ROP) Program Central Unit infographic showing stats on active permits, inspectors, ROP Central Unit staff, and number of active ROPs and applications in house.

When a company requests an air permit, it must include a variety of information, including the expected air emissions. The larger the quantity of emissions, the more complex an air permit can be. These larger emitters also have more regulatory oversight, more testing, monitoring and recordkeeping, as well as having to pay annual fees and report the quantity of pollutants emitted each year.

In the air permitting world, these more complex permits are called Title V or Renewable Operating Permits (ROPs).  ROPs take all existing PTIs at a facility and incorporates them into a total facility wide permit. These permits include all air quality requirements in one place. A ROP can be hundreds of pages long and must be renewed every five years, unlike PTIs which are typically shorter and are valid for the life of the equipment – as long as it has not been reconstructed or modified.

In the past, AQD permit engineers reviewed, drafted, and issued all the PTI’s across the state, and air inspectors in the District Offices reviewed, drafted, and issued ROPs. Recently AQD created a new group of existing staff to focus on completing ROPs. This group of experienced staff is called the ROP Central Unit.

“The combination of experienced staff, peer reviews, and updated processes are really helping us work as a team on these ROP permits.” said Assistant Division Director Chris Ethridge.

The ROP Central Unit contains seven permit writers and one support staff person. The permit writers still conduct inspections and other inspector duties, but the majority of their time is now being spent working on ROPs and getting through an existing backlog of permits waiting to be reviewed and renewed.

There is a peer review aspect to the ROP Central Unit as well that helps create consistency across the state by ensuring language between districts and across similar industry types is the same. This also helps ensure the latest feedback from the United States Environmental Protection Agency is integrated into ROPs.

Julie Brunner, ROP specialist, said “The peer review process has been really successful. In the beginning, it helped to identify where we had holes in our process. Now it is used to build bridges of consistency of applicable rules and requirements.”

The creation of this group helped create a faster and more thorough process and just as important, consistent ROPs. The group’s focus will be to continue forward with creating efficient processes and to focus on this important part of AQD’s work.