Title V Air Permit
Last reviewed · By Chad Griffith
Title V of the Clean Air Act establishes federal operating permits for major stationary sources of air pollution. Major sources are facilities with potential to emit at or above 100 tons per year of any criteria pollutant (lower in non-attainment areas), 10 tons of any single hazardous air pollutant (HAP), or 25 tons of any combination of HAPs. Title V permits consolidate all federal Clean Air Act requirements applicable to a source, with maximum 5-year terms. Implementation at 40 CFR Part 70 (state-administered) or Part 71 (EPA direct). Required reports include semi-annual deviation reports and annual compliance certifications signed by a responsible official.
Frequently Asked Questions
What is a major source under Title V?
Per 40 CFR 70.2: a facility with potential to emit at or above 100 tons per year of any criteria pollutant (50 tpy in some non-attainment areas), 10 tons per year of any single HAP, 25 tons per year of any combination of HAPs, or any source subject to NSPS or NESHAP that triggers Title V coverage. Non-attainment areas have lower thresholds depending on pollutant and severity classification.
What is a synthetic minor source?
A source whose actual potential to emit would exceed the major source threshold but accepts federally enforceable limits (FELs) capping emissions below the threshold. Synthetic minor sources operate under state construction or operating permits with binding emission limits enforced through stack testing, fuel caps, or hours-of-operation restrictions.
What reports does a Title V permit require?
Semi-annual deviation reports per 40 CFR 70.6(a)(3) listing every permit deviation; annual compliance certifications per 40 CFR 70.6(c)(5) signed by a responsible official; stack testing reports as scheduled; CEMS data where required; and ad-hoc reports for upset conditions, malfunctions, or noncompliance events as defined in the permit.
How long is a Title V permit valid?
Maximum 5 years per 40 CFR 70.6(a)(2). Renewal applications must be filed at least 6 months before permit expiration to maintain operating authority during renewal review. Renewals can take 12-24 months in some states due to public comment and EPA review steps.
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