Title V Program Evaluations

1. Title V Program Evaluations 1st Round Overview Gregg Worley Section Chief Air Permits Section EPA Region IV

2. Program Evaluations • Areas of Strength • Staff Knowledge • Permit Development • Public Outreach • Areas of Concern • Knowledge Retention • Title V Fee Issues • Filing Systems

3. Program Evaluations – strengths • Staff Knowledge • Good overall understanding of title V program and it’s requirements • High quality title V permits that are clear and practically enforceable

4. Program Evaluations – strengths cont • Permit Development • 100% issuance of initial title V permits for most programs • Met or exceeded regulatory guidelines for modifications (administrative, minor, significant) • 100% review and follow-up of compliance reports (when applicable)

5. Program Evaluations – strengths cont • Public Outreach • Dedicated resources to citizen training on public participation • Website utilization in addition to mailing list and newspaper notification to inform public of comment period • Planning of public hearings prior to requests for hearings

6. Program Evaluations – Concerns • Knowledge Retention • Written training plans should be created to ensure consistency in staff development. • Succession planning should be implemented to prepare for the replacement of key title V staff.

7. Program Evaluations – concerns cont • Title V Fees • Inability to rollover title V funds from one fiscal year to the next • Failure to provide adequate accounting to allocate title V expenses from non-title V expenses • Use of title V funds for non-title V activities

8. Program Evaluations – concerns cont. • Filing Systems • Inconsistency of file content and/or file organization • Missing monitoring reports, compliance certifications and/or comments received from files

9. Program Evaluations – Conclusion Second Round of Program Evaluations Focused on Areas of Concerns and CAM Program Evaluation Contact : Randy Terry 404-562-9032 Terry.Randy@epa.gov