Vanguard helps your facility stay compliant with complex air permitting requirements across all regulatory levels. If your operations release pollutants into the air, you’re likely required to obtain an air permit before construction, modification, or continued operation of your facility. Vanguard provides full-service air permitting solutions, helping businesses navigate requirements under EPA’s Clean Air Act Amendments of 1990 (CAAA), as well as state-specific permitting programs.
What is Air Permitting
Air permitting is a regulatory process that ensures industrial, commercial, and institutional facilities comply with air quality standards when emitting regulated pollutants. Permits are typically issued at the state level under delegation from the EPA, and they define allowable emission limits, operational controls, testing and monitoring obligations, and recordkeeping requirements.
Note: Even if your facility holds a “lifetime permit,” you must still comply with the operational and reporting conditions it outlines. Permits can be revoked or modified if regulations change or violations occur.
Types of Air Permits We Manage
Vanguard offers expert support for a wide range of air permit types and regulatory structures:
Major Source Permits (Title V)
Facilities classified as major sources emit quantities of pollutants above specific thresholds (generally measured in tons) set by the EPA. These facilities are required to obtain a Title V Operating Permit, which involves:
- A comprehensive application
- Annual compliance certifications
- Emission inventory submissions
- Public notice and comment periods
- Complex monitoring, reporting, and recordkeeping
Vanguard handles all aspects of the Title V permitting process, including review and updating, facility modifications, and state agency communications, although some communications occur at the county level.
Minor Source Permits
Also called non-Title V or state-level permits, these apply to facilities that emit pollutants below major source thresholds. These permits are typically less complex but still require:
- Emissions calculations
- Operational control plans
- Initial and renewal applications
- Ongoing compliance recordkeeping
Vanguard ensures your minor source permits are structured accurately and remain up to date with regulatory changes.
Synthetic Minor Permits
If your emissions exceed major source thresholds but you can voluntarily limit them below those levels, Vanguard can help you obtain a Synthetic Minor Permit. These enforceable limits must be properly documented and managed to avoid triggering Title V requirements.
Our team will:
- Analyze current and projected emissions
- Determine eligibility
- Draft enforceable permit conditions
- Communicate directly with regulatory authorities
- Set up systems for monitoring and demonstrating ongoing compliance
Permit-by-Rule (PBR) (primarily Texas)
Some states allow certain low-emitting operations to operate under Permit-by-Rule frameworks. These are standardized permits with predefined conditions based on process types (e.g., paint booths, fuel-burning equipment, etc.).
Vanguard will:
- Confirm eligibility for PBR
- Submit required registrations or notifications
- Ensure your operations meet PBR limits and best practices
- Set up recordkeeping procedures to demonstrate compliance during audits
Registration of Smaller Sources (ROSS – Illinois Specific)
Facilities with very low emissions may qualify for the ROSS program in Illinois. Vanguard handles all eligibility screening and submission requirements for ROSS registration and will monitor your status annually to ensure it remains valid.
Comprehensive Air Permitting Services
Vanguard’s support extends far beyond application filing. Our team of regulatory experts and engineers delivers:
Emissions Calculations & Modeling
– We quantify regulated pollutants (e.g., VOCs, NOx, PM, HAPs) from all emissions points using EPA-approved methods or stack test data.
Permit Application Development
– We handle all necessary forms, supporting documentation, and emissions analyses for initial permits, renewals, and modifications.
Agency Coordination
– We communicate directly with your state environmental agency or local air district to resolve questions, track review timelines, and negotiate permit conditions.
Air Dispersion Modeling Support
– For projects requiring modeling under NAAQS or PSD review, we coordinate or manage AERMOD-based analyses in line with agency protocols.
Public Notice & Comment Assistance
– For major sources or facilities triggering public review, we prepare public notices, manage outreach logistics, and respond to public comments in coordination with agency staff.
Permit Modifications
– Whether you’re adding a new emissions source, changing equipment, or adjusting operating limits, we handle permit amendments and revisions to keep you compliant.
Compliance Documentation & EMS Integration
– We help you build checklists, tracking logs, and monitoring/reporting notifications into your Environmental Management System (EMS) to maintain compliance throughout the year.