When it comes to air permitting, some of the most common questions we receive are related to construction permitting. Do I need a construction permit? Am I exempt? When do I need to apply? How often do I have to update or renew?
To answer these questions, the Iowa Air Emissions Assistance Program (IAEAP) created a webpage and presentation to walk facilities through the process. “We wanted to focus on the main things facilities ask about and the information they need to know to get started,” says Jen Wittenburg, IAEAP Program Manager.
According to the Iowa Air Quality Regulations, “All new or modified equipment and control equipment that emits air pollutants must have a construction permit unless the equipment is otherwise exempt.” Air quality regulations are regulated by the Clean Air Act; managed nationally by the U.S. Environmental Protection Agency and in Iowa by the Iowa Department of Natural Resources (DNR) Air Quality Bureau to control air pollution and protect public health and public welfare. The DNR writes permits for equipment in all counties except Linn and Polk which have their own local permitting programs.
What air pollutants are commonly regulated?
- Carbon monoxide (CO)
- Particulate matter (PM, PM2.5 and PM10)
- Lead (Pb)
- Nitrogen oxides (NOx)
- Sulfur dioxide (SO2)
- Volatile organic compounds (VOCs)
- Hazardous air pollutants (HAPs)
What types of equipment are common emission sources?
Numerous types or equipment emit one or more of the regulated pollutants listed above and must meet permitting requirements but some of the most common include paint booths, combustion sources, abrasive blasting, material handling, and many others.
When do I need to get a construction permit?
An air quality construction permit must be applied for AND issued BEFORE construction begins. It may be possible to start construction prior to permit issuance if you meet the requirements of Iowa Administrative Code 567 IAC Chapter 22.1(1)”c”. Additionally, certain construction activities are allowed prior to permit issuance as discussed in the DNR guidance memo “Construction Allowed Prior to Permit Issuance”.
How do I know if my process is exempt?
There are permit exemptions for many emission sources. A complete list of exemptions and additional details on exemptions listed below can be found in the Iowa Administrative Code 567 IAC Chapter 22.1 (2). Some of the most common exempt sources we see include the following.
- Direct fired equipment burning natural gas <10 million btu/hr
- Direct fired equipment burning fuel oil <1 million btu/hr
- Non-production equipment or equipment vented indoors used for cutting, machining, sawing, grinding, shot/sand blasting, etc.
- Manually operated equipment used for a variety of purposes
- Indoor vented powder coating equipment with filters
- Welding with various usage limitations
- Small unit exemption (SUE) - this exemption can be used for processes with emissions below the SUE thresholds.
My process or equipment is listed as an exempt emission source. Now what?
Ensure you are maintaining any records outlined in the Iowa Administrative Code to document your exemption. You don’t need a construction permit at this time, but be sure if something in your operation changes, you check to see if you’re still exempt.
My process or equipment is not exempt. Now what?
First, we need to see if you qualify for an industry/process specific or a general application form.
- Do you operate a surface coating operations that sprays three gallons or less per day?
- If yes, you may be able to use the Notification Letter for Permit by Rule for Spray Booths form.
- If yes, complete fill out and submit the Registration Form for Group 1 Grain Elevators.
- If yes, permit templates are available for these industries. Simply navigate to your industry under the Specific Application Forms & Guidance section.
- Then you need to apply for an air quality construction permit(s) by completing and submitting the Basic Application Forms to DNR.
- Once you submit the application forms to the DNR, a DNR engineer will review, your site-specific operating and monitoring conditions will be determined, and you will then be issued your permit(s).
Once I obtain a permit, am I done?
Once you receive your permit be sure to review the contents of the entire permit closely and specifically note requirements in the following sections.
- Section 1. Emission Limits
- Section 2. Compliance Demonstrations
- Section 3. Emission Point Characteristics
- Section 4. Federal Standards
- Section 5. Operating Requirements and Associated Recordkeeping
- Section 12. Notification, Reporting and Recordkeeping
Iowa air quality construction permits do not need to renewed; however if at any time you anticipate a change to the emission point characteristics or the processes, or you are not able to comply with the operating limits, you must request to modify your permit (prior to making that change).
I still have questions.
We can help! The IAEAP was specifically created to provide air quality assistance to Iowa businesses with less than 100 employees. We have a variety of recordkeeping tools and resources as well as an experienced staff available to answer your questions. We can talk to you about your operations and one of our specialists can provide recommendations for maintaining compliance with regulatory requirements. Our number is 1-800-422-3109, or you can send us your questions through our online contact form.
For businesses with more than 100 employees or for direct Iowa DNR questions, you can visit iowacleanair.gov or call the DNR’s toll-free helpline at 1-877-AIR-IOWA (1-877-247-4692) for construction permit application technical assistance.
The Iowa Air Emissions Assistance Program is funded by the Iowa Department of Natural Resources. This information is intended solely as guidance, cannot be used to bind the Iowa Department of Natural Resources and is not a substitute for reading applicable statutes and regulations.