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Well, avoiding Title V permitting is the incentive, but in my experience no regulatory agency actively promotes lowering emissions. Of course everyone still has to meet regulations and cannot harm/ health hazards to the surrounding community.
Just to be clear, the agencies do not "actively promotes lowering emissions" but that doesn't mean there is no mitigation/ prevention of environmental damage. The permits - especially higher level permits like Title V - are exactly that. The higher your potential emissions, the more permit special conditions, compliance demonstrations, and restrictions you must adhere to. And there are plenty of limitations - too many to go into detail here - that are a flat out "no" and a permit will get rejected. It's not like companies can do whatever they want so long as they submit paperwork, if that was the impression that you were getting.Got it, thanks. Bottom line is that these certifications are used as more of an administrative tool for properly regulating facilities that have higher, Title V-level PTEs but that are, in reality, operating more like minor source facilities. Makes sense.
Interesting to hear, though, that working with companies/facilities to lower emissions isn't standard practice for air quality agencies. That's quite different from my experience administering Section 404 of the Clean Water Act. At the Corps, we work with applicants to reduce/offset impacts to aquatic resources by applying what's known as the mitigation sequence ("avoid, minimize, compensate"). Permit applicants must first demonstrate that they've avoided impacts to the maximum extent practicable. We next explore measures to minimize remaining unavoidable impacts through project modifications and permit conditions. After avoidance and minimization have been fully explored, applicants are required to compensate remaining impacts through compensatory mitigation requirements (e.g., restoring an aquatic resource on- or off-site).
If air quality agencies aren't working with applicants to lower emissions, I guess I'm wondering what types of conditions get added to air permits to mitigate environmental damage? I suppose, for example, the permit conditions might stipulate what times of day emissions could occur (e.g., to ensure emissions don't go above a certain level at any point in a given area), right? What sort of influence do air quality agencies exert through permitting to promote real-world environmental benefits?