NACAA Releases Permit Streamlining Principles and Recommendations

December 19, 2017 – NACAA sent a letter to EPA Assistant Administrator Bill Wehrum setting forth a series of principles and recommendations for EPA to consider as it undertakes initiatives to improve and streamline Clean Air Act permitting programs. The letter was developed based on the  recommendations of the NACAA Permitting and New Source Review Committee and reflects members’ collective knowledge and experience as primary CAA permitting authorities.  NACAA encourages EPA to think broadly about ways in which the permitting processes can be made more efficient, while continuing to build on the clean air gains of recent decades.  The association presents three overarching principles that EPA should follow in any permit streamlining initiative: chief among them, that any reform or initiative must maintain or improve upon current levels of public health and environmental protection.  NACAA also offers a series of more specific recommendations for the agency to consider as it develops its air permitting policy priorities.  The recommendations cover a wide range of topics such as training, electronic permitting, regional consistency, availability of New Source Review offsets, the RACT-BACT-LAER Clearinghouse and flexible permitting.