New York Air Permitting Issues

New York does have a Title V permit program in place. Sources with the potential to emit more than 100 tons of VOC per year, or 10 tons of one hazardous air pollutant (HAP) or 25 tons of a combination of Hazardous air pollutants are required to apply for a Title V permi State facility permits are given to:

• Their actual emissions exceed 50 percent of the level that would make them major, but their potential to emit as defined in 6NYCRR Part 200 does not place them in the major category
• They require the use of permit conditions to limit emissions below thresholds that would make them subject to certain state or federal requirements
• They have been granted variances under the department's air regulations, or
• They are new facilities that are subject to New Source Performance Standards (NSPS) or that emit hazardous air pollutants.

Permitting thresholds for facilities located outside the New York Metropolitan Area:

• Actual VOC emissions facility wide less than 3 tons per 12-month period – no permit or registration required, only recordkeeping
• Actual VOC emissions facility wide under 25 tons per year but more than 3 tons per year – Registration required
• Actual VOC emissions facility wide greater than 25 tons per year – State minor source permit required
• Potential to emit VOC facility wide greater than 50 tons per year – Title V permit required

In the New York City Metro Area, permitting thresholds are:

• Registration is required for facilities that emit less than 12.5 tons of VOC per year.
• State minor source permits are required if a facility’s VOC emissions exceed 12.5 tons per year.
• Title V permits are required for facilities with the potential to emit 25 tons of VOC per year or more.

Facilities also need an air permit from the New York City Department of Environmental Protection.