Air Permitting

Davenport Engineering is well versed in the many rules that govern air quality permitting such as Prevention of Significant Deterioration (PSD), New Source Review (NSR), Title V, and California Environmental Quality Act (CEQA). These programs address different aspects of permitting and can often be intricate and nuanced. Guided by our SCAQMD Certified Permitting Professionals (CPP) and specialists, we can help you navigate the permitting maze and secure a permit that is both workable and accurate.

Project Permitting

A facility planning to add or modify equipment that changes its emissions must obtain an authorization permit from the air agency prior to construction. The purpose of these permitting programs, known as Prevention of Significant Deterioration (PSD) and New Source Review (NSR), is to protect air quality at the same time facilities are constructed and expanded.

Davenport Engineering has extensive experience obtaining pre-construction air permits, particularly for projects at complex industrial facilities. Our role on these projects include defining the Best Available Control Technology (BACT) requirements, preparing the permit application package (with associated air impact analysis and rule compliance analysis), securing emission offset credits, responding to agency information requests, and negotiating the most favorable permit conditions.

We have a very successful track record in obtaining permits-to-construct within budget, within schedule, and with the terms and conditions that work for your business.

Title V Initial and
Renewal Permitting

Title V is a federal operating permit program established under the 1990 Clean Air Act amendments and usually administered by the local air agency such as SCAQMD and BAAQMD. Facilities are drawn into the Title V program by multiple criteria, one of which is by classification as major source based on the facility’s actual and potential emissions. Different air districts can have different emission threshold definitions for a major source.

The centerpiece of the program is the Title V permit which pulls together the facility’s applicable federal, state, and local air rules and regulations; emission limits and other requirements driven by these rules; and periodic monitoring requirements imposed to demonstrate compliance with these rules.

Facilities that trigger Title V applicability, whether due to new or modified equipment, or increased emission levels, or another reason, must submit a permit application for an initial Title V permit. The initial Title V permit should not impose new emission limits, but should provide more regulatory detail such as listings of existing rule emission limits and citations and may add new periodic monitoring requirements.

Facilities with a Title V permit are required to submit a permit application every five (5) years to renew their Title V permit. The renewal process gives the local air agency, EPA, and public the opportunity to re-evaluate the facility’s permit and incorporate rule changes that have occurred since the last Title V permit issuance.

Davenport Engineering is prepared to assist with all your Title V permitting needs, whether it’s determining your facility’s Title V applicability, or setting enforceable limits to avoid Title V applicability, or preparing your initial Title V permit application, or renewing your existing Title V permit.

Permitting Other Changes

Facilities may wish or need to submit a permit application for reasons other than Title V or authorization to make project changes to equipment or operations. Such permit revisions include:

  • Permit condition changes: These include changes to throughput or activity limits, monitoring requirements, and work practice requirements, sometimes in order to maximize operational flexibility.
  • Permit cleanup: These include changes of the responsible official or clarification of a poorly worded equipment description or correction of a typographical error. Often, these revisions can qualify as an administrative permit amendment.

Davenport Engineering’s air permitting services run the gamut, including reviewing existing permits for obsolete, missing, or inaccurate equipment descriptions and conditions. We value the importance of striving for a complete and accurate permit.