This 13-hour course covers the basics of the title V permit program from submitting a permit application through issuance and resolution of challenges to the permit while also providing a background on the underlying policy and legal foundation for requirements. Upon completing the training, students will understand the difference between application and permit shields; regulated pollutants for purposes of fees vs. for applicable requirements; inherent vs. non-inherent process equipment; federally enforceable operating permit programs vs. title v operating permit programs, and the difference between periodic, enhanced and compliance assurance monitoring. Students will gain an understanding of the importance of timely reporting; handling confidential business information; determining compliance using the Laxton Method vs. other approaches to significant digits and considering credible evidence in compliance certifications; crafting appropriate “averaging” language; recognizing SIP gaps; addressing affirmative defenses related to startup, shutdown, and malfunction emissions; and writing permits to improve readability and compliance. Relevant judicial and administrative decisions will be reviewed in each topic area.

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