NACAA Streamlined Permitting Recommendations

March 15, 2018 - NACAA’s Committee on Permitting & NSR has produced series of principles and recommendations for EPA & other decision-makers to consider in any initiatives to improve and streamline Clean Air Act permitting programs. These reflect our members’ collective knowledge and experience as primary CAA permitting authorities.  NACAA encourages EPA & others 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 for 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.