Are Amendments Eminent for SSOA and Permit by Rule Permit Holders?

The answer is very likely YES! On May 31, 2011, IDEM sent out letters to companies with
SSOA and Permit by Rule type permits. The purpose of this letter was to alert permit holders of IDEM’s intent to modify their permits to meet current US EPA standards. Permit holders have until the end of June to make comments for IDEM’s consideration. The contact at IDEM for such comments is Amy Smith and you can reach her at (317) 233-8628 or asmith@idem.in.gov.

These rule changes are not surprising since IDEM must demonstrate to US EPA that they are
meeting all federal guidelines in their air permitting programs. The SSOA and Permit by Rule
programs have not been modified to keep up with such requirements as current emission factors, reporting and documentation requirements, etc.

At this time, IDEM has not specified exactly what this means to the permit holders. ECS suspects that once IDEM has approval by US EPA to update their programs, permit holders may have to reapply for their SSOA or Permit by Rule status in order to update information and assure that they still fall below category thresholds. ECS will keep our clients updated on IDEM’s plans as they release information.

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