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The Federal Title V Air Quality Permit Program: A Primer on the Substantive and Procedural Requirements Imposed on Industrial Facilities by the 1990 CAA Amendments, Applicable Regulations, and Key EPA Guidance Documents

October 2003

Citation: 33 ELR 10815

Issue: 10

Author: Rolf R. von Oppenfeld, Eric L. Hiser, Mark E. Freeze

All companies today, whether large or small, need to be aware of the types and amounts of their air emissions. Based on the types and amounts of emissions, these sources may be required to obtain operating permits under the Clean Air Act's (CAA's) Title V program. This Article provides a detailed discussion of the Title V operating permit program and a review of the contents required in a Title V permit.

Rolf R. von Oppenfeld is Managing Partner with the Team for Environmental Science and Technology Law (TESTLaw) Practice Group, operating under the law firm of von Oppenfeld, Hiser & Freeze, P.C., with western regional offices in Phoenix, Arizona, and eastern regional offices in Columbia, South Carolina. Mr. von Oppenfeld is a Martindale-Hubbell AV-rated attorney and has been listed in The Best Lawyers of America (1993-1996 editions). Mr. von Oppenfeld received his B.S. in chemistry and biology and worked as a chemist for the U.S. Environmental Protection Agency (EPA). He received his J.D. (summa cum laude) from George Washington University.

Eric L. Hiser is a partner and heads the regulatory practice for the TESTLaw Practice Group. He is a principal author of the Arizona Environmental Law Handbook (3d ed. 1999) and the South Carolina Environmental Law Handbook (3d ed. 2000), published by Government Institutes, ABS Consulting. He represents steel mills, copper plants, oil and gas pipelines, metal fabricators, electronics manufacturers, paper mills, food/beverage plants, and other businesses. Mr. Hiser received his J.D. with honors from Duke University.

Mark E. Freeze is a partner with the TESTLaw Practice Group in the areas of environmental toxic tort, and commercial litigation. Mr. Freeze has extensive experience in mold claims, C3100 cost recovery action, CERCLA allocations, Resource Conservation and Recovery Act and Clean Water Act (CWA) citizen suits, environmental insurance, and toxic tort litigation. Mr. Freeze received his J.D. in 1988 from the University of Texas.

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