Federally Enforceable State Operating Permit (FESOP)

Federal regulations require each major source of air pollutant emissions to obtain an "operating permit" that consolidates all of the air pollution control requirements into a single, comprehensive document covering all aspects of the source's air pollution activities. Air pollution permits are also required for businesses that build new pollution sources or make significant changes to existing pollution sources. These are sometimes referred to as "preconstruction" or "new source review" permits. Operating permits document how air pollution sources will demonstrate compliance with emission limits and with other "applicable requirements" such as work practices (e.g., periodically watering a dirt road to prevent dust emissions). Operating permits also document how air pollution sources will monitor, either periodically or continuously, their compliance with emission limits and all other applicable requirements on an on-going basis. Thus, monitoring requirements are a very important aspect of the operating permit because:

  • Monitoring provides facility owners/operators with the information they can use to: (a) self-assess their performance relative to meeting air pollution requirements, and (b) assist them in determining the proper corrective actions, when necessary, and
  • Monitoring provides the basis for most on-going compliance demonstrations and provides documentation to support the compliance certification required of the source owners/operators.

In short, the role of monitoring is to assure compliance with the operating permit conditions and air pollution regulations.


Preparation for USEPA/IEPA Air Inspection
February 25, 2020