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Region 4 Title V and NSR Program Evaluations

Region 4 Title V and NSR Program Evaluations. Evaluations Conducted South Carolina Florida Georgia Mississippi Alabama Jefferson County (Alabama) Kentucky Louisville (Kentucky) Mecklenburg County (N. Carolina) Forsyth County (N. Carolina).

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Region 4 Title V and NSR Program Evaluations

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  1. Region 4 Title V and NSR Program Evaluations Evaluations Conducted South Carolina Florida Georgia Mississippi Alabama Jefferson County (Alabama) Kentucky Louisville (Kentucky) Mecklenburg County (N. Carolina) Forsyth County (N. Carolina)

  2. Region 4 Title V and New Source Review Program Evaluations Upcoming Evaluations (FY06) North Carolina Tennessee Memphis (TN) Nashville-Davidson County (TN) Knoxville (TN) Chattanooga (TN)

  3. Region 4 Title V and New Source Review Program Evaluations Program Areas Excluded (>10 T5 Sources) Western Carolina (N. Carolina) Huntsville (Alabama)

  4. Program Evaluation Typical Process Prior to arrival • Six weeks out - establish dates for evaluation • 4 weeks out EPA sends title V and NSR questionnaires to State/Local Agency • 1 week out receive and review Agency’s responses to questionnaires. • 1 week out send list to Agency of permit files to be reviewed. On Site • 2 days spent covering questionnaires and conducting file review. • 3rd day conduct exit interview : • EPA provides a general overview of findings. • EPA lays out the timeframe for the issuance of the report.

  5. Program EvaluationsTypical Process Post on-site • 60 days EPA sends official draft report to the Agency for review. • 80 days EPA receives comments from Agency for incorporation into final report. • 90 days EPA issues the final report.

  6. Region 4 Title V and New Source Review Program Evaluations Next Steps • FY 06 Conduct Evaluations for remaining programs. • FY 07 Initiate a new round of evaluations (mini-evaluations) • Less time between evaluations (approx 2 years) • Fewer questions (approx 5-10) • Will include follow-up on main issues noted in initial reports. • Review of fees will still be included. • File review will still be included.

  7. Region 4 Title V and New Source Review Program Evaluations Universal Findings • Most programs are charging significantly less than the presumptive minimum fee. • Local programs have an inability to have rollover title V funds. • Majority of programs have not incorporated Environmental Justice in the permit process. • Initial issuance of title V permits took longer than expected. • Renewal permits are on pace to have similar backlog. • Programs that have salaries competitive to other Agencies have significantly lower staff turnover that those programs with lower salaries.

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