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Guidance to Permit Applicants

Overview

Permit review gives the National Park Service (NPS) Air Resources Division (ARD) and Fish & Wildlife Service (FWS) Air Quality Branch (AQB) an opportunity to influence new air pollution emission sources and major changes in old emission sources located near mandatory class I parks and refuges. For areas of the National Park system, the National Park Service Organic Act of 1916 requires conserving resources "unimpaired for the enjoyment of future generations". For NPS and FWS areas, the Clean Air Act of 1970, as amended in 1977, charges the federal land manager with affirmative responsibility to protect the air quality related values of class I areas from adverse impacts.

Whenever a company wants to build a new facility or make a major change to an existing facility that will substantially change the amount of emissions in the air, they have to get a permit from the state permitting authority. The company submits a Prevention of Significant Deterioration (PSD) of Air Quality permit application to the state authority. When the state receives a permit application it sends the application to the NPS ARD and FWS AQB for review.

The application is reviewed to determine if resources will be impacted by the proposed emission increases from the new or modified facility. This is done by looking at what resources (plants, animals, water, soils, etc...) exist in the park or refuge and which ones are susceptible to certain levels of pollutants. Potential impacts on visibility is also reviewed. Modeling software is used to predict how much of the emissions from the new facility will actually reach the parks or refuges. Cumulative emissions from other sites as well as from the proposed facility are determined in order to assess the final "loading" on the park or refuge. If this "loading" reaches a level at which resources in the park are "impacted" or visibility impaired then an "adverse impact determination" may be made and the NPS ARD or FWS AQB will recommend to the state permitting authority that the permit application be denied.

Compromises are always explored and the NPS ARD and FWS AQB try to recommend ways to reduce or control emissions so resources will not be significantly impacted. The NPS/FWS have reviewed over 400 permit applications since 1980, and only two applications have been determined to cause an adverse impact on NPS/FWS resources. There are many problems which make evaluating these permits extremely difficult. First of all it is difficult to determine where pollution is coming from. Emissions can be "transported" a long way, as much as 200 miles. Also determining at what point resources are affected by pollution is difficult. Not to mention that frequently parks and refuges may not have a complete resource inventory. It is expensive and time consuming to adequately "inventory" a park or refuge to even know what is locate within the boundaries.

The Federal Land Managers, including the U. S. Fish and Wildlife Service and National Park Service have developed guidance documents for industry and states dealing with the permitting process. The following list provides in-depth information on modeling, air quality related values, and the process of submitting an air quality permit application to the federal land managers.

FLM Guidance

EPA Guidance

updated on 07/20/2010  I   http://www2.nature.nps.gov/air/permits/flag/guidance.cfm   I  Email: Webmaster