Title V Operating Permits (Clean Air Act)
Current understanding
To be populated as evidence accumulates.
Evidence log
- 2026-09-25 — Clarifying the Scope of “Applicable Requirements” Under State Operating Permit Programs and the Federal Operating Permit Program: EPA final rule codifies longstanding interpretations that (1) Title V operating permits may reopen New Source Review preconstruction decisions only in limited circumstances, and (2) the Clean Air Act §112®(1) general duty to prevent accidental chemical releases is not an ‘applicable requirement’ enforceable through Title V permits. (novelty: 2)
Open questions
Related
Contributing findings
Clarifying the Scope of “Applicable Requirements” Under State Operating Permit Programs and the Federal Operating Permit Program
25-sep-2026
novelty 2
per-area 2
introduces