EPA's Operating Permit Regulations:
      Title V Permit Appeals and Strategic Considerations
                                
                                
                          Introduction


                         Of the many new provisions and programs enacted under the 1990
                    Clean Air Act Amendments, the Title V operating permit program will
                    likely have significant impacts on the greatest number of facilities. 
                    Because a source's Title V permit will govern the conditions under which
                    the source will operate on a daily basis, it is critical that the permit contain
                    reasonable terms that can be met and that provide the source necessary
                    operational flexibility.  The importance of appropriate permit terms has
                    been further heightened by new enforcement provisions and policies which
                    may have the effect of increasing the stringency of particular standards and
                    creating enforcement liability for performance which was previously
                    deemed to be acceptable by regulatory agencies.

                         An understanding of Title V permit appeal procedures and relevant
                    strategic considerations in pursuing permit appeals will be vital for sources
                    subject to the Title V program.  Because of the importance of reasonable
                    permit terms, the filing of Title V permit appeals is expected to become
                    relatively common as permitting programs reach maturity.  Although it is
                    hoped that permitting authorities will generally issue Title V permits
                    containing reasonable terms and that EPA will ordinarily exercise its
                    authority in an appropriate manner, the permit appeal process will
                    nevertheless play a significant role.  Given the vast number and novelty of
                    issues which can arise during the Title V permitting process and the
                    number and variety of emission points present in a major source, it is
                    inevitable that sources frequently will need to seek corrections of permit
                    terms by filing permit appeals.  Moreover, unlike the situation with
                    construction permits, it is typically not critical for a source that its initial
                    Title V permit be issued and finalized by any particular time.  Thus, a
                    source can ordinarily decide whether a permit appeal is warranted without
                    being concerned about any resulting delay in the receipt of a final Title V
                    permit. 

                         It has also become clear that the time to begin considering the Title
                    V permit appeal process is during the early stages of the permitting process
                      not simply after a final permit has been issued.  A source which is
                    preparing its permit application is also taking the initial step in the permit
                    appeal process.  At that point, a source should be formulating a clear idea
                    of what terms and conditions it wants its final permit to contain and should
                    begin developing a record for the permit appeal process in case that step
                    becomes necessary.  The development of an administrative record should
                    continue as the permit application is submitted, the permit negotiation
                    process ensues, and a draft permit is made available for comments. 

                         This issue analysis examines the procedures that exist for
                    challenging Title V permit decisions under federal and state law and
                    discusses important strategic considerations in planning for a possible
                    permit appeal and/or filing an appeal when necessary.  The analysis
                    primarily focuses on these topics from the perspective of industrial sources
                    needing to obtain Title V permits.  The first section summarizes the Title
                    V permit issuance process and highlights the different ways in which Title
                    V permits may be issued.  The second section provides an explanation of
                    the special public petition process created by Title V and its possible
                    impacts on the permit review process.  The third section analyzes the
                    various state and federal procedures which govern Title V permit appeals
                    and discusses certain issues which will likely arise in permit review
                    proceedings.  Finally, the last section focuses on certain strategic
                    considerations regarding permit appeals which sources should keep in mind
                    throughout the permitting process. 

                    Initial Permit Issuance


                         This section provides a brief overview of the various ways in which
                    Title V permits initially may be granted or denied pursuant to EPA's Part
                    70 permitting regulations.  Because the process of preparing and
                    submitting a Title V permit application has been extensively addressed in
                    other contexts, this discussion focuses on what transpires after the
                    application has been submitted rather than addressing the preparation of a
                    permit application.  However, it should be noted that the application
                    process is an important part of creating a record which can later be used
                    effectively in any permit appeal.

                          Before issuing a Title V permit, the state permitting authority
                    must provide an opportunity for public comment and a hearing on the draft
                    permit.  40 C.F.R.  70.7(h).  It must also notify "affected states" of the
                    draft permit.  40 C.F.R.  70.8(b)(1).  Affected states may make
                    recommendations to the permitting authority based on applicable
                    requirements or the requirements of Part 70 but do not have the ability to
                    veto the issuance of a permit.  40 C.F.R.  70.8(b)(2).  After considering
                    any comments made on the draft permit and recommendations of affected
                    states, the permitting authority must submit the proposed permit to EPA. 
                    40 C.F.R.  70.8(a)(1). 

                         The Act sets forth procedures for EPA review of proposed permits
                    and authorizes EPA to object to such permits under certain circumstances. 
                    The grounds on which EPA may object to a proposed permit are prescribed
                    by the statute and EPA's implementing regulations.  Section 505(b)(1) of
                    the Act provides for EPA to object to (or "veto") a proposed permit if it is
                    not in compliance with the Act's "applicable requirements . . .  (including
                    the requirements of an applicable implementation plan)."  EPA's
                    regulations provide that EPA will object to the issuance of any proposed
                    permit which is determined "not to be in compliance with applicable
                    requirements or requirements under [Part 70]."  40 C.F.R.  70.8(c)(1).  In
                    addition, EPA may object if the permitting authority failed to provide
                    proper notice and supporting documentation to EPA, or if the permitting
                    authority failed to provide adequate opportunity for public participation or
                    "affected state" review.  40 C.F.R.  70.8(c)(3).

                         If  EPA decides to object to a proposed permit, it must make the
                    objections in writing within 45 days to prevent the permit from being
                    issued.  Section 505(b)(3); 40 C.F.R.  70.4(h)(3)(ix), 70.8(c)(1).  At this
                    stage, the permitting authority may either revise the permit to meet EPA's
                    objections and resubmit the permit for approval, or it may deny the permit. 
                    If the permitting authority fails to revise and submit a proposed permit in
                    response to the objection within 90 days, EPA is given the authority to
                    issue or deny the permit itself  in accordance with the requirements of Title
                    V and the Part 71 federal program regulations.  Section 505(c); 40 C.F.R.
                     70.8(c)(4), 71.4(e).   If EPA does not object to the proposed permit
                    within 45 days, the permitting authority may grant the permit.

                         Thus, there are three ways in which a source may receive an initial
                    Title V permit under Part 70: (1) from the permitting authority absent an
                    EPA objection, (2) from the permitting authority after modification in
                    response to an EPA objection, or (3) from EPA following the permitting
                    authority's failure to respond to its objections.

                  The Public Petition Process 
  
                         Section 505(b)(2) of the Act creates a special petition process
                    which allows "any person" under certain circumstances to petition EPA to
                    object to a permit where EPA has not exercised its authority to object to
                    that permit as proposed.  Under this process, EPA may object to a permit
                    even where the state permitting authority has already issued the permit in
                    final form.  As discussed in the next section, this "public petition" process
                    may also provide an optional path for the Title V source to obtain judicial
                    review of a state-issued Title V permit.

                         If a state permitting authority submits a proposed permit to EPA
                    and receives no objection within 45 days, it may issue the permit. 
                    However, section 505(b)(2) provides that, once the 45-day veto period has
                    run, any person (including a source) may petition EPA to object to the
                    permit.  See also 40 C.F.R.  70.8(d).  Such a petition must be filed within
                    60 days of the expiration of the 45-day veto period.  A petitioner is limited
                    to arguments raised with reasonable specificity during the public comment
                    period, unless he or she demonstrates that it was impracticable to have
                    raised such objections or unless the ground for objection arose after the
                    public comment period.  EPA has 60 days within which to grant or deny the
                    petition.  Id.  

                         The statutory scheme may give rise to a situation where EPA will
                    object to a permit which has already been issued and has become effective. 
                    Because a public petition cannot be filed until the 45-day veto period has
                    expired and because EPA has 60 days in which to respond, it is possible for
                    a permitting authority to issue a final permit before EPA has taken action
                    on the petition.  Moreover, the filing of a public petition does not stay the
                    effectiveness of any permit issued after the expiration of the initial 45-day
                    period set aside for EPA objections.  Id. 

                         If, in response to a petition, EPA decides to object to a permit after
                    it has been issued, EPA is to modify, terminate, or revoke the permit as
                    necessary in accordance with prescribed procedures.   In particular, EPA
                    must give the permitting authority 90 days in which to revise the permit to
                    satisfy its objection and must provide written notice to the permittee
                    regarding the reasons for the objection.  40 C.F.R.  70.7(g)(4) and (5),
                    70.8(d). 

     Appeals of Final Permits and Other Reviewable Actions


 Introduction  

                         The route which a source can pursue to appeal a final Title V
                    permit decision generally depends upon which agency   state or federal  
                    issues that decision.  If the state permitting authority makes the final permit
                    decision, appeals ordinarily proceed in the state administrative or judicial
                    system in accordance with the state's Title V program and relevant state
                    law principles.  If EPA makes the final decision, appeals ordinarily proceed
                    first to EPA's Environmental Appeals Board and then to the federal courts
                    of appeals.  In addition, EPA's denial of a public petition requesting that
                    it object to a permit can give rise to direct judicial review in the federal
                    courts of appeals.  Below we summarize the procedures for obtaining
                    review of state or federal Title V permit decisions and discuss some of the
                    issues that may arise in such proceedings.

Review of State Actions

                         The Clean Air Act and EPA's regulations contemplate that the great
                    majority of Title V permit decisions will be made by state permitting
                    authorities.  Furthermore, the Act expressly provides that, when state
                    permitting authorities grant or deny Title V permits, judicial review is to
                    be sought in the state judicial system.  Section 502(b)(6) requires, among
                    other things, that each state Title V program provide "an opportunity for
                    judicial review in State court of the final permit action by the applicant, any
                    person who participated in the public comment process, and any other
                    person who could obtain review of that action under applicable law."  In
                    addition, section 502(b)(7) states that the failure of the state permitting
                    authority to take timely action on a permit application shall be treated as a
                    final action for purposes of obtaining judicial review in state court to
                    require the permitting authority to grant or deny the permit.

                         EPA's Part 70 regulations prescribe certain additional requirements
                    for judicial review which all state Title V programs must satisfy.  The
                    regulations provide that the opportunity for judicial review required
                    pursuant to section 502(b)(6) of the Act must be the exclusive means for
                    judicial review of Title V permit terms and conditions and that any petition
                    for judicial review of a final permit decision must be filed within 90 days
                    of the decision or such shorter time as the state designates.  40 C.F.R. 
                    70.4(b)(3)(xii).  A petition can be filed later than the designated deadline
                    for judicial review only if it is based on grounds arising after the deadline. 
                    A challenge to the state permitting authority's failure to take final action
                    on a permit may be filed anytime before such action is taken.  Id.  

                         The precise route for obtaining judicial review of permit actions by
                    state permitting authorities will vary from state to state.  In some states, the
                    initial level of review takes place before an environmental appeals board
                    or similar administrative body.  Appeals from the appeals boards'
                    decisions in those states are subsequently to be filed in a state court.  In
                    other states, appeals from final decisions of the permitting authority are to
                    be filed directly in a state court.

Issues That Will Likely Arise in State Review Proceedings

                         We briefly discuss below some of the key issues which will likely
                    arise in state administrative or judicial proceedings involving the review of
                    Title V permit decisions.  Because Title V permit review processes have
                    yet to be utilized in most states, numerous procedural and substantive
                    points remain unsettled.  We also note that, because Title V review
                    proceedings will frequently take place in the context of existing state
                    administrative structures and  procedures, many procedural requirements
                    may vary from state to state.

                         One important issue is whether the appeals board or state court will
                    confine its review of the final permit decision to the administrative record
                    before the permitting authority or whether it will allow the parties to submit
                    new documentary evidence and/or provide testimony regarding the legality
                    of the permit decision.  Although some state systems may offer applicants
                    the opportunity to present new evidence, it is nevertheless imperative that
                    a source establish support in the administrative record for the permit terms
                    it seeks far in advance of appellate proceedings.  Indeed, the failure to
                    articulate objections to particular terms and conditions and to provide
                    supporting materials prior to permit issuance may preclude a source from
                    raising certain challenges after the final permit is issued.

                         A closely related issue concerns the specific standard of review
                    which the appeals board or court will apply in reviewing the permit
                    decision.  The standard of review will determine, as a legal matter, the
                    degree of scrutiny the reviewing body will give to the decision and what
                    burden the challenging party must meet to prevail.  For example, the
                    standard may be articulated in terms of whether the decision being
                    reviewed is "arbitrary and capricious," "clearly erroneous," "contrary to the
                    weight of the evidence," or some other comparable formulation.  In some
                    instances, state law may even provide for de novo review, i.e., the
                    reviewing body may decide the issues for itself without regard to how they
                    were presented and decided in the prior proceeding.  Although for some
                    state programs the applicable standard of review may be spelled out, for
                    other state programs there may be no explicit mention of the standard of
                    review applicable to Title V permit decisions.  In establishing the
                    applicable standard of review in such instances, however, state courts and
                    appeals boards likely will rely heavily on the procedures used in other
                    permit programs.

                         Another issue concerns the deference which state appeals boards
                    and courts will give to EPA's interpretation of regulatory terms which are
                    identical to, or correspond to, the terms in state Title V permit programs. 
                    Such EPA interpretations may be set forth in such sources as Federal
                    Register preambles, guidance documents, or administrative decisions. 
                    Although a state appeals board or court is not required to follow such an
                    EPA interpretation, it is likely that a state reviewing body would give the
                    federal interpretation significant weight in reaching decisions on EPA-adopted 
                    regulations.   The precise amount of deference due to EPA's
                    interpretations will typically be decided in each state as it becomes
                    necessary to address various Title V issues.   
     
Review of EPA Actions

                         Although most initial Title V permit decisions will be made by
                    state permitting authorities, EPA itself has the authority to issue or deny
                    Title V permits in certain situations.  EPA's exercise of this authority can
                    arise in two different ways.  

                         First, if a state does not obtain Title V program approval or if EPA
                    withdraws approval from a state, EPA becomes the permitting authority
                    and is to issue permits pursuant to the Part 71 federal program regulations. 
                    See sections 502(d)(3) and (i)(4) of the Act.  Although EPA may
                    subsequently delegate its Part 71 permit-issuance authority to the state
                    under specified conditions, the state must comply with Part 71
                    requirements in exercising that authority, and appeals of such permit
                    decisions are brought in accordance with Part 71 procedures.  40 C.F.R. 
                    71.10(a) and (i). 
  
                         Second, if EPA objects to a proposed permit and the state
                    permitting authority fails within 90 days to revise and submit a proposed
                    permit in response to the objection, EPA is to issue or deny that permit in
                    accordance with Part 71, rather than Part 70, procedures.  40 C.F.R. 
                    70.8(c)(4). 

                         Part 71 sets forth a detailed set of procedures for obtaining review
                    of EPA Title V permit decisions (or decisions of a state with delegated Part
                    71 authority).  Any person who filed comments on the draft permit or
                    participated in the public hearing may petition EPA's Environmental
                    Appeals Board ("EAB") to review any condition of the permit decision. 
                    An appeal of EPA's issuance or denial of a Title V permit must be filed
                    with the EAB as a prerequisite to seeking judicial review.  40 C.F.R. 
                    71.11(l)(4).  Additionally, the EAB may, on its own initiative, review any
                    condition of any permit issued by EPA under Part 71.  40 C.F.R. 
                    71.11(l)(2).  

                         Petitions for EAB review must be filed within 30 days of EPA's
                    permit decision.  The petition is to demonstrate, as appropriate, that
                    findings of fact or conclusions of law are "clearly erroneous" or that an
                    exercise of discretion or an important policy consideration warrants EAB
                    review.  40 C.F.R.  71.11(l)(1). 

                         Within a reasonable time following the filing of a petition for
                    review, the EAB is to issue an order either granting or denying the petition. 
                    40 C.F.R.  71.11(l)(3).  To the extent that review is denied, the conditions
                    of the final permit decision become final agency action for purposes of
                    judicial review.  If the petition is granted, the EAB will ordinarily issue a
                    briefing schedule and proceed to issue a decision on the merits.  Id.   

                         Final decisions of the EAB may be appealed to the federal courts
                    of appeals pursuant to section 307(b) of the Act.  Section 307(b) provides
                    that any petition for review of an EPA action must be filed within 60 days
                    of the final decision, unless the petition is "based solely on grounds arising
                    after such sixtieth day."  Under section 307(b), exclusive jurisdiction over
                    a final action which is "locally or regionally applicable" (such as a
                    permitting decision) would lie with "the United States Court of Appeals for
                    the appropriate circuit."  For purposes of Title V permit appeals, the
                    "appropriate circuit" would presumably be the circuit in which the source
                    is located.  

                         The federal appellate court's review of the EAB's decision will be
                    conducted pursuant to the judicial review provisions of the Administrative
                    Procedure Act, 5 U.S.C.  701-706, and the Federal Rules of Appellate
                    Procedure.  Accordingly, the court will uphold the Agency's factual
                    findings unless they are "unsupported by substantial evidence" and will
                    otherwise uphold the decision unless the court concludes that the decision
                    is "arbitrary, capricious, an abuse of discretion, or otherwise not in
                    accordance with law."  5 U.S.C.  706(2).  The record on review will
                    ordinarily consist of the administrative record before the EAB.

                         In addition to the procedures above for review of EPA decisions
                    issuing or denying Title V permits, the Act provides a second avenue for
                    judicial review of EPA action in certain circumstances.  As explained
                    above, any person (including the permit applicant) may file a "public
                    petition" requesting that EPA object to a proposed permit.  Section
                    505(b)(2) of the Act specifically provides that review of EPA's subsequent
                    denial of such a petition may be sought directly in the federal courts of
                    appeals pursuant to section 307(b).  However, if EPA grants the public
                    petition and objects to the permit, EPA's objection is not subject to judicial
                    review until EPA takes final action on the permit itself.  Section 505(c)(2). 
                    

                    Strategic Considerations


                         Throughout each step of the Title V permit application and
                    issuance process, sources should be aware of the need to prepare for a
                    possible permit appeal as well as the options available for seeking such
                    permit review.  We discuss relevant strategic considerations in more detail
                    below.

The Need to Develop a Full Record in Preparation for a Possible Permit Appeal

                         It will be critical to make certain that the administrative record
                    includes the necessary support for those terms that the facility has
                    identified as being essential to be included in the Title V permit.  The
                    highest priority typically will be those that are necessary for assuring that
                    the source can demonstrate that it is in compliance with all requirements
                    and, in turn, to certify such ongoing compliance in its periodic
                    certifications.  

                         The development of the record begins with submission of the
                    permit application and continues at every stage of the permitting process. 
                    The preparation of supporting documents should begin long before the
                    permit is made available for public comment in order to enhance the
                    chances of having permitting authorities ultimately write acceptable permit
                    terms.  The guiding principle is that the official record before the
                    permitting authority should contain documentation to support every
                    essential permit term and should include responses to any relevant
                    comments submitted by other parties or to points raised in public hearings. 
                    In many instances, the most significant document to be included in the
                    record is the document setting forth the permit applicant's comments on the
                    draft permit.  Accordingly, such comments should be carefully drafted and
                    subjected to comprehensive legal and technical reviews before submission. 
                    Examples of other types of documentation which should be submitted for
                    inclusion in the official record include guidance documents, preamble
                    discussions, engineering reports, and technical articles.  In submitting
                    documents, the permit applicant should be aware that documents sent to
                    different offices within the state permitting authority, other state agencies,
                    or EPA will typically not be considered a part of the permit record unless
                    they are also sent to the specific address for that record and explicitly
                    designated for inclusion.  Throughout the permitting process, it is important
                    to keep in mind that the record developed before the permitting authority
                    may constitute the only record that will be considered by a reviewing court.

                         In preparing submissions for inclusion in the administrative record,
                    the source should take into account relevant state law provisions and
                    agency practices.  For example, where state law provides that emission
                    control requirements can be no more stringent than under federal law, this
                    stringency comparison may be a key element of the submission.  In some
                    instances, the source may need to address in compelling detail the custom
                    in the state regarding the meaning of compliance, e.g., the factors that are
                    determinative are installation of necessary controls and proper operation of
                    such controls.  As a result, the need to address important substantive issues
                    may require an early commitment of resources by the source .  

Optional Judicial Review Route in Connection with EPA's Authority to
Object to Permits   

                         Although permit appeal procedures generally prescribe a single
                    path by which a permittee can obtain review of a particular permit decision,
                    the Title V program provides an optional review path for sources in certain
                    situations related to EPA's authority to object to proposed permits.  As
                    discussed above, if EPA takes no action within the 45-day review period
                    to object to a proposed permit, "any person," including a Title V source,
                    can file a petition with EPA requesting that it object to allegedly unlawful
                    terms.  Section 505(b)(2).  If EPA subsequently denies that petition, the
                    petitioner can obtain review of the denial in the appropriate federal court
                    of appeals pursuant to section 307(b).  

                         Sources may wish to consider utilizing this review option in certain
                    circumstances.  If a permit contains unacceptable terms, the source can
                    either seek review in accordance with state Title V procedures or it can
                    submit a public petition and seek federal court of appeals review if EPA
                    denies the petition.   As a result, this option may allow a source to
                    determine whether a particular issue will be litigated before a state tribunal
                    (a state appeals board or state court) or before a federal court of appeals,
                    based on the nature of the particular issue in question.  For example, where
                    the issue is whether certain requirements should be designated as state-only
                    requirements rather than federally enforceable "applicable requirements,"
                    it may be appropriate in some instances to seek direct federal judicial
                    review.  Thus, if certain requirements do not constitute "applicable
                    requirements" under the definition in 40 C.F.R.  70.2, but the state
                    permitting authority essentially ignores the definition and refuses for
                    "policy" reasons to designate them instead as state-only requirements,
                    federal court review is probably more appropriate.  However, where the
                    issue is whether particular permit limits are properly spelled out so that
                    they are achievable as a factual matter based on the administrative record,
                    state court review is probably more appropriate.  

                         An additional consideration in determining what review path to
                    follow is that review in a federal court of appeals may be preferable in
                    terms of attempting to ensure uniform decisions on issues affecting sources
                    in more than one state.  Rather than litigating a major issue of general
                    applicability on a state-by-state basis, a company may want to seek a
                    broader precedent from a federal court of appeals.     

                         At the same time, a source should recognize that the scope of such
                    direct federal judicial review is limited in certain respects.  While a state
                    appeals board or reviewing state court can address a wide array of issues
                    involving Title V permits, federal judicial review of EPA's denial of a
                    public petition is limited to those issues which would provide a basis for an
                    EPA permit objection.  In other words, to be a proper subject of a public
                    petition, the permit term in question must not comply with the applicable
                    requirements of the Act or the requirements of Part 70.  See  40 C.F.R. 
                    70.8(c).  In addition, the source can only seek direct judicial review
                    regarding those issues which were identified in its petition to EPA and
                    adequately raised during the public comment period.  40 C.F.R.  70.8(d). 
                    Accordingly, it is important to provide a foundation in the record for
                    possible direct judicial review of EPA's denial of a public petition.

                         Such federal court review may also entail a different standard of
                    review as compared to state review.  Federal judicial review will be based
                    on a standard of review concerning whether or not EPA's denial of the
                    petition was "arbitrary and capricious"   a standard which is generally very
                    demanding.  As discussed above, the applicable standard of review in state
                    proceedings can vary widely from state to state.  Moreover, state court
                    review will focus primarily on the legality of the permit terms themselves,
                    not whether EPA was "arbitrary and capricious" in failing to object to them
                    based on the regulatory criteria for EPA objections. 

                         Finally, the relief available to a successful challenger may differ
                    depending upon whether review is sought in a federal or state forum.  In
                    most instances, the relief to be obtained upon direct federal review would
                    be a remand of the case to EPA so that it can grant the public petition and
                    exercise its objection authority properly.  Assuming that an objection is
                    subsequently made, the state permitting authority would then have an
                    opportunity to propose a revised permit.  In short, the relief granted may be
                    somewhat indirect because of the nature of the objection process.  On the
                    other hand, in a state review proceeding, the relief granted could range
                    from an order expressly directing the permitting authority to delete or
                    include a particular term to an order simply remanding the case to the
                    permitting authority to reconsider a particular term in light of the appellate
                    decision.  Thus, the scope of relief available is another factor which a
                    source should consider in determining what strategy to pursue in seeking
                    review of permit terms.

Addressing Situations Where EPA May Object To A Proposed Permit But The
Permitting Authority and Source Are In Agreement On The Permit Terms To Be
Included

                         Title V sources and state permitting authorities are generally
                    working together to develop permit terms that are reasonable and carry out
                    the Act's requirements.  Inevitably, though, there will be situations where
                    EPA will submit comments on a draft permit which suggest that it may
                    veto a particular permit term that the source and permitting authority
                    believe should be included in the final permit or, alternatively, that it may
                    veto a permit for failing to contain a term that EPA maintains should be
                    included.  For example, such disagreements may well arise with regard to
                    the manner in which the permit specifies what constitutes compliance with
                    certain applicable requirements or what monitoring provisions should be
                    included in the permit.

                         As an initial matter, there are, of course, two main options
                    available for the state permitting authority in this situation.  The permitting
                    authority can either write the proposed permit in the manner agreed upon
                    by it and the source despite the indication that EPA may veto the permit or
                    it can make the changes in the proposed permit necessary to address EPA's
                    concerns.  Below we address certain considerations regarding what course
                    of action may be preferable for the source in this situation.

                         If the permitting authority writes the proposed permit as it did the
                    draft permit and EPA in fact vetoes the proposed permit, the state
                    permitting authority will have 90 days in which to revise the permit to meet
                    EPA's objection or to deny the permit.  If the permitting authority takes no
                    action within 90 days in response to EPA's objection, EPA is given the
                    authority to issue the final permit pursuant to Part 71 procedures.  40
                    C.F.R.  70.8(c)(4).  As a result, the source's subsequent appeal route
                    would be first to the EAB and then to the federal courts of appeals, if
                    necessary.

                         On balance, the source will in many instances be best served by the
                    permitting authority's writing the proposed permit submitted to EPA in the
                    same way that it wrote the draft permit.  If EPA decides not to veto the
                    permit, then the issue has almost certainly been resolved, and no permit
                    appeal would be necessary.   If  EPA does veto the permit, the permitting
                    authority would presumably revise the permit to satisfy EPA's objection. 
                    Once the final permit is issued, the source can then challenge the disputed
                    aspect of the permit in a state forum and argue that EPA improperly
                    objected to the permit and directed that it be revised.  The source could
                    further argue that the manner in which the permitting authority wrote the
                    proposed permit supports the source's position that EPA's objection was
                    improper.  The permitting authority also would be able to explain its
                    reasoning for writing the proposed permit as it did.  The permitting
                    authority's views in support of the proposed permit would likely receive
                    substantial deference from a reviewing state court.

                         If, on the other hand, the permitting authority were to write the
                    proposed permit in accordance with EPA's comments, i.e., to change the
                    disputed aspect of the draft permit, the source could subsequently pursue
                    an appeal in accordance with state permit appeal procedures challenging
                    the disputed aspect of the final permit.  In this situation, the permitting
                    authority could also indicate its support for writing the final permit as it
                    wrote the draft permit rather than the proposed permit.  However, the
                    permitting authority will not have gone on record in the proposed permit
                    as supporting the disputed aspect of the draft permit.  Also, the opportunity
                    will be lost to test EPA's resolve to take an action that conflicts with the
                    state permitting authority's best judgment.  Under Title V, as under state
                    implementation plans, states are, after all, to have the principal role in
                                        carrying out the Act's requirements. Conclusion 
                

                         The Title V permit appeal process will play a significant role in the
                    efforts of numerous sources to ensure that their Title V permits contain
                    reasonable, achievable terms and conditions.  Although the prospect of an
                    appeal may sometimes seem distant, it is important that a source prepare
                    for the possibility at every stage of the application and permitting process
                    by developing a record that thoroughly supports requested permit terms and
                    conditions.  It is also vital that a source become familiar with applicable
                    permit appeal procedures and with available options for seeking permit
                    review.

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