Streamline. This one word effectively summarizes the TCEQ Air Permits Division's message from the 2019 TCEQ Trade Fair. In addition to requiring use of the New Source Review (NSR) electronic workbook and the electronic modeling evaluation workbook (EMEW) as of June 1, 2019, TCEQ is implementing several other permitting streamlining efforts. (Click here to read our article detailing the changes for NSR and EMEW.) Throughout the Trade Fair, TCEQ emphasized several ways to ensure efficient processing of your permit application. For the applicant, TCEQ emphasized the following:
- Contact TCEQ for a pre-application meeting via phone or in-person (highly recommended);
- Ensure a complete application is submitted; and,
- Use the new workbook tools that include the NSR Workbook and EMEW (mandatory as of June 1, 2019).
TCEQ is taking the following steps to reduce internal turnaround times during permit reviews:
- Streamlining deficiency items to applicant by providing formal letters and shorter timelines (maximum of 30 days with 10-15 days being more common);
- Initiating modeling at the start of the permitting process (reducing the final modeling request timelines);
- No longer requiring TCEQ Regional Offices to review draft permit conditions (removes 21 day waiting requirement); and
- If TCEQ completes the permit review within 15 days, only one public notice period is required.
Another option TCEQ is working on to streamline permit issuances is through their readily available permits (RAPs) program. RAPs are draft NSR permits that have been developed and tailored for a specific type of facility. Unlike case-by-case NSR permits however, in order to meet the qualifications of a RAP, the applicant must meet very specific requirements. If the applicant can meet these requirements, the streamlined nature of RAPs enables issuance of the final permit within 90 days of submittal.
RAPs are currently only available for simple cycle turbines and compressor stations, but TCEQ is actively working to develop more. Specifically, TCEQ is working to develop a RAP for tanks and loading increases. This RAP would enable authorization of tanks and loading increases from existing NSR permits that meet the qualification criteria within 90 days of submittal. Trinity will provide a more detailed update on the specifics of this RAP when the TCEQ issues the final version.
Streamlining the application process is going to continue to be a point of emphasis for TCEQ. If you have any questions on how to take advantage of TCEQ's streamlining efforts, reach out to your local Texas office by calling (800) 229-6655 for more information; we are here to help.