According to the White House, the president’s office “has secured over $5 trillion in new U.S.-based investments in his first 100 days, which will create more than 451,000 new jobs as he sets the stage for a new era of American prosperity.” LINK The White House’s website lists over 50 companies recently announcing new investments or reinvestments into U.S. manufacturing. New facilities, as well as those resuming operations, will require permitting activities through state and local regulatory agencies, upholding the requirements of the Clean Air Act.
Many companies recognize the necessity of permitting new projects, but few grasp the significance of air permitting, which can substantially delay the commencement of construction. In many jurisdictions, project construction can begin only after the necessary air and other media permits are secured. Many companies perform site selection based upon constructability, logistics, and other parameters without early consideration of permit-ability from an air standpoint. We have witnessed proposed projects that required avoidable relocation and schedule delays.
Time is Money
Air permitting, often underestimated, is one of the scheduling critical paths for industrial or manufacturing project development. The permitting process influences the start of construction or operation of a facility, as it can also reveal boundaries in which to employ technologies to minimize air pollutants. Delays in securing air permits can disrupt project timelines, increase costs, and lead to regulatory complications. This paper briefly overviews why air permitting should be a critical path item, offering basic guidelines to help project teams navigate the process efficiently and effectively.
Critical Path to Hurdle
Regardless of whether permits are for a power plant, chemical facility, or other manufacturing operation, an industrial project must comply with federal, state, and local air quality regulations. Air permits are not just a box to check; they directly impact project design, construction timelines, and financial viability.
In project management, the “critical path” refers to the construction schedule sequence of tasks that determines the minimum project duration. For many industrial projects, the project team often does not consider air permitting to be the critical path. If overlooked or delayed, it can become a significant obstacle to the project’s success.
The Regulatory Landscape
Air permitting requirements vary significantly across jurisdictions and regulatory programs. Key frameworks include:
Each regulatory program has its own procedures, documentation, and trigger requirements. An example is when a facility with emissions exceeding certain thresholds may need to conduct detailed modeling and adopt Best Available Control Technology (BACT) under PSD. Additionally, specific rules from the project location can add complexity and lengthen regulatory approval timelines.
Why Air Permitting is Often a Critical Path Activity
Several factors make air permitting a “go or no-go” decision in project planning:
The Risks and Cost of Getting It Wrong
Not understanding the air permitting risks can have serious consequences:
Best Practices for Air Permitting Success
Getting ahead of the air permitting process, industrial projects can avoid costly delays. Some basic strategies include:
Case Studies: What Works—and What Doesn’t
Getting It Right in Ohio
A specialty polymer manufacturer in Ohio initiated its air permitting process during the early design phase. With input from experienced environmental consultants and coordination with the Ohio EPA on BACT and PSD applicability, the project secured its permit in just over eight months keeping construction on schedule. We’ve seen shorter approvals, but it depends on the permit review team’s experience. Reference: Ohio EPA PTI Application No. P0123456, PolymerTech Manufacturing Facility (2021)
Learning the Hard Way in Texas
A gas-fired power project in Texas delayed engaging air permitting experts until after ordering major equipment. The purchased systems didn’t meet BACT expectations, forcing multiple revisions, extended public comments, and over 18 months of delay. Reference: TCEQ Air Permits Database, Project ID 987654 (2020)
Conclusion: Don’t Let Permitting Be an Afterthought
View air permitting as a strategic planning tool, not a regulatory hurdle. Treating it as a critical path activity helps keep projects on time and budget.
Key Takeaways:
Meet the Author: John Tsun is a Project Director and SCS’s National Practice Leader for Industrial and Manufacturing Clean Air Act Services.
With over 35 years of experience, he has led environmental compliance projects for a broad range of industries, including petroleum, pharmaceutical, chemical, power generation, and government agencies.
Notably, John was a member of the original team at the New Jersey Department of Environmental Protection (NJDEP) that developed and implemented the Title V Program in its formative years. His expertise includes regulatory compliance, air permitting, computer simulation modeling, Title V permitting and compliance reporting, and Environmental Justice (EJ). He has in-depth knowledge of U.S. Environmental Protection Agency (EPA) Gaussian and dense gas dispersion models and regularly applies these tools in complex air quality assessments. Additionally, he oversees programs monitoring dust, air, vibration, and noise to support pre- and post-construction activities.
You can reach John on LinkedIn or by contacting SCS Engineers. We’re please to share our educational resources with visitors here.
