RE: Permits and Rules

[David Clarke <David_Clarke@americanchemistry.com>]

Marci Kinter raises an important point - the need to differentiate between significant and minor or routine permitting issues. As I understand it, EPA has intermittently held stakeholder discussions on Title V permitting for several years and participants devoted an enormous amount of time to developing procedures designed to assure adequate opportunity for EPA and public review of proposed permit revisions while at the same time recognizing the need for industry - small businesses and large - to make expeditious changes to their operations to meet marketplace demands. During these EPA stakeholder discussions a key recognition was that only a small percentage of permit revisions will involve changes that could affect emissions in more than a de minimis manner. 

More broadly, EPA's Science Advisory Board, in a near-final report evaluating stakeholder process and how best to ensure that scientific information is fully integrated into such processes, noted that stakeholder processes can be time-consuming and expensive and therefore the types of process uses must be calibrated to the importance of the issues at stake. That principle ought to apply overall to stakeholder processes so that the right tools are applied to the right job. Otherwise, as SAB cautioned, EPA runs the risk of stakeholder burnout.