EPA Guidance on Title V Operating Permit Renewals

April 23, 2026

The U.S. Environmental Protection Agency (USEPA) has issued guidance to simplify the Title V operating permit renewal process, emphasizing administrative efficiency while maintaining full compliance obligations. The guidance encourages focusing on changes rather than resubmitting unchanged information, but facilities must remain vigilant as renewals can reveal unresolved compliance issues.

• Streamlined renewal process: The guidance permits the use of previously submitted materials, incorporation by reference, and directs agencies to concentrate on changes, without altering regulatory or compliance requirements.
• Renewal as compliance check: Even if operations are unchanged, renewals prompt reassessment of assumptions, monitoring, and applicability, potentially affecting more than just the renewal itself.
• Risks and consequences: Identified gaps during renewal can lead to notices of violation, permit modifications, increased monitoring, enforcement actions, and future scrutiny, often uncovering longstanding issues rather than new violations.
• Common issues and affected industries: Problems frequently arise from outdated potential to emit assumptions, monitoring methods, operational changes, or unvalidated permit bases, impacting sectors such as manufacturing, printing, power generation, food production, petroleum, and data centers.

Read the full SCS Title V Technical Bulletin