Title V Program Evaluations 1 st Round Overview Gregg Worley Section Chief Air Permits Section EPA Region IV

Program Evaluations Areas of Strength Staff Knowledge Permit Development Public Outreach Areas of Concern Knowledge Retention Title V Fee Issues Filing Systems

Program Evaluations – strengths Staff Knowledge Good overall understanding of title V program and it’s requirements High quality title V permits that are clear and practically enforceable

Program Evaluations – strengths cont Permit Development 100% issuance of initial title V permits for most programs Met or exceeded regulatory guidelines for modifications (administrative, minor, significant) 100% review and follow-up of compliance reports (when applicable)

Program Evaluations – strengths cont Public Outreach Dedicated resources to citizen training on public participation Website utilization in addition to mailing list and newspaper notification to inform public of comment period Planning of public hearings prior to requests for hearings

Program Evaluations – Concerns Knowledge Retention Written training plans should be created to ensure consistency in staff development. Succession planning should be implemented to prepare for the replacement of key title V staff.

Program Evaluations – concerns cont Title V Fees Inability to rollover title V funds from one fiscal year to the next Failure to provide adequate accounting to allocate title V expenses from non-title V expenses Use of title V funds for non-title V activities

Program Evaluations – concerns cont. Filing Systems Inconsistency of file content and/or file organization Missing monitoring reports, compliance certifications and/or comments received from files

Program Evaluations – Conclusion Second Round of Program Evaluations Focused on Areas of Concerns and CAM Program Evaluation Contact : Randy Terry