Developing a Framework for Effective Air Quality Management
3.7 Implementation of Air Quality Plans
3.7.5 Use of Permits to Support Compliance
A permit program makes it easier for an air quality management program to address pollution problems from stationary sources. In the absence of some form of licensing program, if a government run compliance program wishes to stop the operations of a polluting business, in much of the world, the law in this case requires that the government agency must demonstrate that the business should be stopped from polluting. This takes longer and raises the level of evidence that must be obtained by the compliance agency. On the other hand, if the business must get some form of license to operate and produce emissions, then the government agency which issues that license to operate has a simpler procedure and a lower burden of proof to stop polluting operations. The license to operate, or permit, specifies pollution limits and related factors that a company must meet to continue operations. If a company is suspected to be in violation of its permit conditions, then the permit can be cancelled, which places the company in the position of proving that it is in compliance. Thus, most compliance programs have developed some form of permitting system to support their compliance operations.
Permits are often issued in three forms as shown below:
1. Permit to Construct
2. Temporary Permit to Operate
3. Permit to Operate
A Permit to Construct is the permit that a polluting business must get in order to build a new facility or to expand an existing facility. A permit to construct is not required if changes to a business do not impact their air emissions. A facility is not allowed to begin construction until the Permit to Construct is issued by the compliance agency.
A Temporary Permit to Operate is the permit that a polluting business must get in order to demonstrate their new or expanded facility. This permit is typically good for only one year; although renewals are allowed in special circumstances. The Temporary Permit to Operate is used while the new or expanded facility completes required emissions testing and the compliance agency has the opportunity to become convinced that the business is operating in compliance with the Permit to Construct.
A Permit to Operate is issued to existing businesses or new businesses once the compliance agency is convinced that the businesses is operating in compliance with relevant requirements. A Permit to Operate is issued, typically, for a one or, at most, a two-year period.
In addition, to the compliance benefits of a permit program, a permit system can serve as the basis to collect revenue to support the compliance program. This issue is discussed further in the next section.
Permits are often issued in three forms as shown below:
1. Permit to Construct
2. Temporary Permit to Operate
3. Permit to Operate
A Permit to Construct is the permit that a polluting business must get in order to build a new facility or to expand an existing facility. A permit to construct is not required if changes to a business do not impact their air emissions. A facility is not allowed to begin construction until the Permit to Construct is issued by the compliance agency.
A Temporary Permit to Operate is the permit that a polluting business must get in order to demonstrate their new or expanded facility. This permit is typically good for only one year; although renewals are allowed in special circumstances. The Temporary Permit to Operate is used while the new or expanded facility completes required emissions testing and the compliance agency has the opportunity to become convinced that the business is operating in compliance with the Permit to Construct.
A Permit to Operate is issued to existing businesses or new businesses once the compliance agency is convinced that the businesses is operating in compliance with relevant requirements. A Permit to Operate is issued, typically, for a one or, at most, a two-year period.
In addition, to the compliance benefits of a permit program, a permit system can serve as the basis to collect revenue to support the compliance program. This issue is discussed further in the next section.
