We discuss the price & ongoing costs of air quality permitting.
When it comes to dealing with environmental regulations, one of the first things our customers ask us about is the cost. How much is this? What is that going to run me? What are the long-term costs? We get it. Everyone has a budget, everyone is worried about the cost of running their business, and we're all concerned in some way, shape, or form, about money. So when it comes specifically to air permitting, we hear all the time, what will this air permit cost me? If that sounds familiar, let's dive in and address this commonly asked question.
A Quick Air Permit Lesson
If you aren't familiar with air permits, read on, otherwise, feel free to skip ahead.
Air permits are typically issued by state, regional, or local agencies, and are generally required for businesses producing over a specified quantity of pollutants. In short, it means that many, many types of facilities across the US, from dry cleaners to office buildings, to colleges, to police stations, to industrial facilities, could be required to obtain an air permit, for anything from emergency generators to boilers to rock crushing equipment. Unfortunately, if you meet the criteria for needing an air permit, you'll have to get one, regardless of the cost. Not having a permit could lead to hefty fines, penalties, closure of business, and, in extreme cases - even criminal charges and jail time!
The cost of an air permit isn't exactly a straightforward answer. As a ballpark estimate, you can expect an air permit to cost you anywhere between a few hundred dollars and a few hundred thousand dollars.
I know what you're thinking, that's too wide of a spread to be useful. Unfortunately, there's really no one answer that will apply to everyone as far as the cost of an air permit since each permitting agency, and each facility seeking coverage under an air permit, is unique. However, there are some ways that you can narrow it down to get a better idea of what you'll need to pay.
To make an analogy, it's like trying to price out a car. Are you looking to buy a junker that barely runs or a new Ferrari? Once you can identify your needs and wants, you can narrow down the price and find a realistic number. Until then, the most realistic answer is it depends.
Why do air permit costs vary so much?
Every facility's situation is different and there's no "one-size-fits-all" answer when it comes to the price you'll pay for an air permit. Although each agency will have different costs based on their unique laws, regulations, politics, economies, etc., there are some commonalities that might help you get an idea of what you can expect to pay for your air permit. Some of the most important factors contributing to the cost of an air permit follow:
Where is your facility located? The city, county, region, and state can all impact permit considerations in vastly different ways. Certain areas of the country, or even the state your operation is in, can have more cumbersome regulatory considerations, which generally means a higher permitting cost, but not always!
What are your processes and/or equipment on-site? Do you have an emergency generator in case the power goes out? A boiler for water & heating? Do you have stacks that release emissions from a process? Do you crush rocks in a quarry? Point is, the specific details about your facility can, and do, impact your permit requirements.
Are you a major or minor source of air pollution? There's a big difference for a small, emergency backup generator at a local hospital versus stack emissions from several sources at a petrochemical facility. Depending on what your "sources" of pollution will generally place you into either a minor or major source of air pollution, which dictates which air permits you may seek coverage under.
Are you building or already in operation? There are permits for facilities under construction, and for facilities already operating. As you can imagine, these do make a difference when it comes to the price of an air permit.
As you can see, the wide differences in air permits mean a wide variety in permitting costs. Let's go over some of the bigger differences which can impact the cost of an air permit.
Minor Source vs. Major Source Air Permit Costs
Those qualifying as needing an air permit are typically classified into one of two categories: Minor Sources and Major Sources. If you need an in-depth review of the differences between Minor and Major sources, we cover them in the above-linked articles.
For now, just know this:
Minor sources have lower emissions and tend to cost less for an air permit.
Major sources tend to be larger facilities that emit more pollution, so their air permits are more expensive.
In general, the more polluting your facility is, the more expensive your air permit will be.
How much will an air permit for a Minor Source cost?
This is a very generalized range, but you can figure anywhere from $500-$50,000 per operation. Some facilities may accrue large permit application fees due to a large amount of equipment on their air permits. The price of the application could increase by $500+ for each piece of equipment. Even small facilities could be subject to refined risk assessments to determine the health risk posed by your operation, and this could run you a few thousand dollars. Some minor sources like asphalt plants and emergency generators have even required air dispersion modeling in a few states, which again, will add even more to that total.
How much will an air permit for a Major Source cost?
Again, this is very generalized, but major source air permits (such as Title V air permits) can cost anywhere from $10,000 - $100,000+. The same principles listed for minor source permits apply for major source permits, however, there are additional considerations that must be factored in. Your major source operation very likely will require air dispersion modeling, which at a minimum can be $5000 - $40,000. You also will likely have to conduct stack testing before or shortly after your permit is issued, which for multiple stacks could run in the tens of thousands of dollars as well. Major source permits are going to be expensive, largely due to the testing requirements and increased emissions.
How does location impact air permitting costs?
It shouldn't come as a surprise that air permitting costs vary from region to region. Like anything else, prices vary from state to state, across the country. Just like the cost of car insurance or a gallon of gasoline, the cost of an air permit will depend on where you're located.
In addition to the basic criteria that determine which sources are subject to air permits, some states have additional permitting requirements that could add hundreds or even thousands of dollars in costs to your air permit fee. These fees vary by state but typically cover things like being required to conduct air monitoring at the facility. Even the county, region, or city/municipality within a state can make a difference with regard to air permitting costs!
If your company operates in multiple states, you can expect each one to be handled differently - and cost differently - than the last. Again, the same might go for numerous operations just spread across one state! While it isn't possible to provide a comprehensive breakdown of each state's permitting costs, you should expect to pay more for an air permit in places like California and New York than you would if your facility were located somewhere with laxer requirements - such as West Virginia or Indiana. But, it all depends, and every situation is unique.
What are the hidden or ongoing costs of air permit compliance?
When complying with an air permit, there will be other fees and costs that aren't directly tied to the cost of the permit itself. While these fees don't necessarily count as part of what you can expect to pay to get a permit in hand, you should still consider them and be prepared for the extra costs you'll need to pay. These fees won't go away once your air permit has been approved: you'll be responsible for paying them even after you've obtained your permit, sometimes on an ongoing, repeating basis.
Here are the most common "hidden costs" that come along with air permit compliance.
Sampling /Testing Costs: Upon the request of your regulatory agency or as a requirement of your permit, your operation may have to conduct emission testing such as stack testing, Method 9 visible emission testing, or periodic emission monitoring for your emission units. This will represent one of the most expensive compliance endeavors for your facility. For smaller facilities, figure anywhere from $1000-$25,000 per year, and for larger facilities, much more.
Laboratory/Analysis Costs: In many cases, this will be one and the same with the sampling/testing costs category, as your stack testing firm or other testing agency will likely include the laboratory testing fees as part of their proposal to you.
Professional Costs: Hiring a consultant for any type of assistance will add additional fees. Typically, their services can range from getting you covered under the permit, helping your facility draft an air quality impact analysis, to ongoing services such as permit modifications, renewals, sampling, testing, analysis, etc. For smaller, minor source permit applications, figure anywhere from $1500 to $20,000. Major source applications will usually be even more expensive.
Modifications: Any modifications made to your permit, or any amendments will probably not be free, and result in the issuance of a new permit. This might not mean all the same costs as if you were getting a brand new permit from scratch, but you can expect to spend a few hundred to several thousand here.
Renewal Costs: Renewal costs are typically on an annual or five-year basis, and can also be expensive. Minor source permits could conservatively expect around $5000 every permit renewal cycle. Major source, again, will be more expensive.
Annual Emission Inventories: Many facilities with air permits will need to submit an emission inventory detailing their emissions for the previous year. Some states will require the facility to pay a fee for this service. Minor source permits or small emitters could realistically expect again anything from $0 to $5000.
Training: If you're the person on staff who's going to be responsible for dealing with your air permits, you may want, or be required to, take training on your air permit and responsibilities, such as if you need to conduct visual emission observations on a quarterly basis. Your training could be free, could be taken online, in the field, or in a classroom, all of which will likely cost you a few hundred dollars at a shot.
Time: You'll need to keep up with all other applicable recordkeeping, monitoring, and testing requirements. Essentially all air permits will have some form of recordkeeping or monitoring requirements. This does not necessarily cost money, but it does take time, and as we all know - time is money!
What is the cost of not getting an air permit?
If you're aware that you need an air permit, but are considering not getting one, what's the worst that could happen? Maybe you're asking yourself: "won't it be more expensive to pay for a permit and all of its associated "hidden fees" than it would be to just pay the penalty for not having one?
The short answer is a big no. If your facility needs an air permit, the cost of not obtaining a permit could far outweigh what you'd pay to just get one in the first place. Failure to maintain compliance with equipment operating requirements could be $30,000 or more. Emissions in excess of permitting thresholds can be anywhere from $10,000 to $50,000 depending on the severity of the situation. And, these fines can be imposed per-offense, per-day! We'll do the math for you - just 2 offenses over the course of one week could amount to $700,000 in fines! Surely, that money would have been better used just paying for a permit in the first place.
And, it's not just fines you need to worry about. Not having a permit could lead to temporary, or even permanent closure of your business, and in extreme cases - even criminal penalties. That's right, if you need an air permit and choose not to get one, it can mean jail time. Not good!
For any facility that is on the fence as to whether or not an air permit is money well spent, it's pretty easy to see that the costs of obtaining and complying with an air permit are much less than the costs of not getting one - let alone your freedom!
Need additional air permitting help?
If you’re trying to figure out whether or not you need an air permit, this might be a lot to take in. RMA has been actively involved in helping companies with environmental permitting since our founding in 1992. We can help you get into compliance with applicable environmental laws and regulations, ensuring your business stays out of trouble and in compliance.
Our staff members have been on-site at thousands of commercial and industrial operations across the country, so when we say we've seen it all and done it all, we mean it. We've provided help with air permits to everyone, from globe-spanning, multi-national organizations to small "mom & pop" operations. No matter your size, industry, or location, we'd love to learn how we can help with your air permitting needs.
If you're having any type of issue at your operation with your air permitting program, need to apply for an air permit, or anything else, and need the help of an environmental consulting firm with a proven track record, reach out. Even if we can't help, we’ll do our best to steer you in the right direction. Feel free to contact us at email@example.com, click here to contact us, or give us a call anytime at 888-RMA-0230 to learn how we can help your operation deal with environmental regulations and air permits.
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