Complex Project Pre-Application Meetings
Table of Contents
The Air Permits Branch recommends pre-application meetings for Greenfield sources and any project that may become complex in nature (PSD, Netting, etc.). Preferably, the pre-application meeting would occur at the IDEM Air Quality office. To schedule a pre-application meeting please contact: Matt Stuckey, Kathy Moore, or Nysa James at (317) 233-0178.
Information needed prior to pre-application meeting
Submit the following information to the Air Permits Branch at least one week prior to the meeting (unless otherwise noted).
- Agenda of items applicant wishes to discuss at the meeting
- List of people attending (see below)
- Summary of proposed project
- Anticipated controls and emission rates
- Location of the new or modified facility
- List of nearby facilities that could be considered support facilities or are under common control
- PSD / Emission Offset applicability
- NESHAP / NSPS applicability
- Modeling Protocol (not applicable if modeling is not required)
- Company's plans to address pre-construction monitoring
- One year of pre-construction monitoring may be required if existing air quality data does not exist or is not representative. Information about air quality monitoring sites in Indiana can be found on the IDEM website.)
- Anticipated dates to begin construction and operation
Items to discuss at the pre-application meeting
- IDEM Forms page, Air Permit Application Checklist: Forms required in the application
- Clarify the permitting process for the company and the public.
- Discuss site-specific issues
- Discuss control technologies that are anticipated/acceptable
- Local air quality concerns (NAAQS, increment, others)
- Explore pre-construction monitoring and dispersion modeling
- Modeling Protocol
- Additional Impact Analysis
- Identify similar permitting examples
- BACT
- Monitoring, testing, recordkeeping
- Economic feasibility
- Establish communication expectations, procedures and responsibilities.
- Confidentiality
- Allowable pre-permit activities
- Establish the timeline for the review process.
- IDEM's statutory time periods for receiving determinations on permit applications can be found in 326 IAC 2-1.1-8.
Timing
Pre-application meeting should generally occur no earlier than three (3) months prior to permit application submittal. The application itself should be nearly complete before attending the pre-application meeting. Having a majority of the application complete before the meeting will provide information needed for the Department to answer questions that are more detailed.
Meeting Participants
A representative of the Applicant must be present to describe the process to the Air Permits Branch. This representative may be the Applicant's environmental manager, project engineer, and/or consultant. It is the applicant's responsibility to make sure the appropriate people attend the meeting to represent the company.
The appropriate people from the Air Permits Branch will attend based on the information provided prior to the pre-application meeting. This would likely include the following attendees:
- Permit Writer: A permit writer will attend to assure understanding of the project scope and facilitate the permit application review.
- Permits Management: A section chief or mentor may attend to help assure understanding of the project scope and facilitate the permit application review.
The Air Permits Branch will also coordinate with the following parties for their attendance if necessary:
- Local Agency: If the project will be located in a local agency's jurisdiction, a representative from the appropriate group may be included in the meeting.
- OAQ Modeler: At least one modeler should be present if the project will need to be modeled (required for PSD projects).
- OAQ Compliance: A member of the compliance staff should be included if the facility is not in compliance.
- Legal: A member of the Air Permits Branch legal team may be included if there are questions about confidentiality.
Stay Connected
