OAR Policy and Guidance Metarecord
TitleIV-Title V Interface Guidance for States
|Signed by: Lydia Wegman and Paul Stolpman
Signature Date: May 21, 1993
Information Transfer and Program Integration Division (OAQPS)
Policy & Guidance Memos
EPA Document Number:
Environmental Protection Agency
Clean Air Act
This memo provides guidance on interface of Title V and the National Acid Rain Program. State Title V programs must be compatible with the National Acid Rain Program under Title IV. EPA is retaining certain Title IV requirements, including operation of the sulfur dioxide allowance system, automatic fines for exceedances, the mandatory hourly recordation of specified emissions transmission directly to EPA, the quality assurance systems for operation of CEMS, and the determination of whether utilities are using qualifying repowering technologies. Phase I permitting is underway, but Phase II permitting to over 800 affected sources is the responsibility of States with approved Title V programs.
The criteria for approval of State program submittals include: legal authority, regulatory authority, forms, regulatory revisions, and commitment to acid rain deadlines. Each criterion is discussed in detail.
Attachment A (2 pages) identifies the fundamental differences between Titles IV and V, including mandatory use of the permit shield, certain applications of expedited permit revision procedures, and permits 5 years in duration.