March 17, 1994


MEMORANDUM 

SUBJECT:  Policy on Title V Permit Program Data Elements

FROM:     John Seitz /s/

TO:       Regional Air Division Directors

     The purpose of this memorandum is to set forth the data
elements that will be required on a national basis for all
permits in order to oversee and respond to inquiries concerning
the implementation of Title V of the Clean Air Act of 1990.  In
order to respond to the questions raised by the Regional Offices
and States on why we need this permit information and how EPA
will manage it, we have formatted this memorandum in terms of
questions and answers.  I believe that this format best sets
forth the policy, Regional and State responsibilities and
rationale.


Question: What data elements are needed and when?

Response: The following is a list of the required permit program
          data elements (PPDE's) and the party responsible for
          providing the information.  Both the States and the
          Regions are charged with providing the required data
          elements.  Because permit program implementation is a
          State function, the States have the principal
          responsibility for supplying the data.  On the other
          hand, the Regions are the only party in a position to
          supply some of the data elements.  It will ultimately
          require a team effort to ensure that this information
          is produced and this is the reason why we encourage
          this topic to be addressed in the EPA-State permit
          program implementation agreements.

           1.  Permitting authority name (State)
           2.  New permit or permit modification (State)
           3.  AFS plant identification number (State)
           4.  Permit number (State)
           5.  Date that proposed permit or permit modification   
               was received by the Regional Office (Region)
           6.  Date that the EPA 45-day review period ends.  [The 
               computer system will generate this date.  This     
               date may need to be entered into the system for    
               certain permit modifications where the EPA review  
               period is less than 45 days.] (Region)
           7.  Date permit issued (State or EPA responsibility    
               depending upon who issued the permit)

          The following PPDE's would be entered only if the 
          particular event occurs:
               
           8.  Date EPA objects to a proposed permit (Region)
           9.  Date that revised permit pursuant to an EPA        
               objection is received (Region)
          10.  Date that EPA denies a revised permit submitted    
               pursuant to an EPA objection (Region)
          11.  Date that the public petitions EPA on a proposed   
               permit (Region)
          12.  Date that EPA takes action on a proposed permit    
               based on a public petition. (Region)

          With the exception of data element number 7, all
          information that is the responsibility of the State
          needs to be provided no later than when the State
          submits the proposed permit to EPA.  All other
          information, whether supplied by the State or by EPA,
          needs to be provided within a reasonable amount of time
          after the action or event occurs (quarterly, at a
          minimum).

Question: Why does OAQPS need the PPDE's? 

Response: OAQPS needs the PPDE's for the following reasons:

                  Oversee the Title V and Part 70 requirements,
                  Ensure program consistency, and
                  Respond to reasonable requests for information
                   regarding implementation of the operating
                   permits program.  Examples of these questions
                   are:

                   1. How many permits were submitted to EPA for
                      review?  How many were permit
                      modifications?
                   2. How many permits did EPA object to during
                      the 45-day review period?
                   3. How many revised permits did EPA deny
                      pursuant to an EPA objection?
                   4. How many public petitions did EPA receive?
                   5. How many permits were issued by the States? 
                      By EPA?

          As discussed later, the Aerometric Information
          Retrieval System (AIRS) will be designed to answer
          these questions.  In all likelihood, however, there
          will be requests for information beyond these questions
          both on a permit-specific level and on a national
          level.  Requests about permit fees is one such example. 
          The Regions and States need to be prepared to answer
          other information requests given a reasonable amount of
          lead time.  This can be accomplished by State or
          Regional internal permit management systems that go
          beyond monitoring the data elements required in this
          policy.


Question: What system will be used to store the PPDE's?

Response: The AIRS Facility Subsystem (AFS) will be used to store
          and retrieve the PPDE's.  The AFS was chosen because of
          the evolving efforts over the last few years to enhance
          the system to accommodate operating permit information
          and to make the system more user-friendly.  The latter
          has been accomplished by developing screen and field-
          level HELP features, establishing a simple process to
          access AFS through personal computers (PC's) that are
          served by EPA local area networks capable of accessing
          AIRS, expanding report retrieval capabilities, adding
          new data elements, and improving/expanding table look-
          up capabilities.  

          As mentioned, we are enhancing AIRS in order to
          accommodate operating permit information.  While
          additional permit-related AIRS enhancements are still
          underway, the system is now able to receive and store
          the PPDE's shown above for those States that have
          successfully merged their plant-level compliance and
          emissions data in AFS.  Those States that have not
          completed this merging process will not be able to
          successfully input the PPDE information into AIRS.  The
          data merging effort is essential to effectively using
          the permitting enhancements to AFS and it is critical
          that States that have not yet completed this process do
          so as soon as possible.  However, it is recognized that
          some States may never merge their emission and
          compliance data in AFS, thus complicating State and
          Regional Office access to and entry of permitting data. 
          The AFS Permit Data Management Work Group will be
          exploring system-related alternatives that will allow
          entry of permitting information under conditions where
          State data are unmerged.  We also plan to provide AFS
          with the capability to generate reports that produce
          summary statistics from the questions listed earlier as
          well as others.  This capability will only be available
          for those States with merged data.

          Given the successful evolution of AFS into a more user-
          friendly system, more readily accessible from EPA LAN-
          connected PC's, and the need to merge compliance,
          emissions, and permits data, training becomes an annual
          "must" for all users.  We presently are focusing our
          attention on outreach in the form of training and
          better system documentation.  Over the next several
          months, detailed guidance and training schedules on AFS
          will be issued on the permitting enhancements, user
          support, and the merge process.  Easy to follow
          instructions on inputting the PPDE's will be part of
          this guidance.

Question: Who is responsible for entering the PPDE's into AIRS?

Response: As shown above, the States and EPA share the
          responsibility for providing the PPDE information to
          AIRS.  The Regions should assure that States do this by
          incorporating this requirement into the State-EPA
          permit program implementation agreements and/or by
          using grant commitments.  If States do not provide the
          PPDE's to AIRS on all permits, then the Regions will be
          expected to do so.  As noted above, entering the PPDE's
          into AFS is designed to be relatively simple and should
          require minimum effort.  Where Regional resources
          become an issue, options can be pursued with OAQPS. 
          Lack of having this information for all permits will
          result in the inability of the Regions and Headquarters
          to manage the program and to respond to questions about
          how we are overseeing implementation of the permits
          program.

      This policy is effective immediately.  Please ensure that
the appropriate staff in your office receive this policy.  We
appreciate your continuing efforts to assure the success of the
operating permits program implementation process.

cc:  W. Becker
     Air Branch Chiefs, Regions I - X