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Basics of Clean Air Act Title V Permitting

Level: Intermediate
Runtime: 90 minutes
Recorded Date: December 11, 2019
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Closed Caption


  • Title V Purposes
  • Applicable Requirements
  • Deviation and Compliance Certification Requirements
  • Compliance Schedule Requirements
  • Permit Shield
  • Petition Process
  • Administrative Amendments
  • Minor Modifications
  • Significant Modifications
  • Permit Revision Alternative
  • Procedures for Reopening
  • Takeaways
Runtime: 1 hour, 30 minutes
Recorded: December 11, 2019


In 1990, Congress established a new "operating permit" program for industrial sources classified as "major" under the Clean Air Act. Title V operating permits consolidate in a single document the "applicable requirements" established under the Act's substantive provisions and must periodically report deviations to their state agency and certify compliance to EPA. While simple in concept, in practice, Title V program requirements can be complex, even for simple facilities.

This program aims to educate new ABA members and seasoned practitioners about the Clean Air Act, implementing regulations, and EPA and state agency permitting processes.

This program was recorded on December 11th, 2019.

Provided By

American Bar Association
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Lisa Mitchell

Assistant Attorney General
Texas Office of the Attorney General

Lisa Mitchell is the Assistant Attorney General at the Texas Office of the Attorney's General.

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Kelly Haragan

Clinical Professor & Director of Environmental Clinic
The University of Texas at Austin School of Law

Kelly Haragan is a clinical professor and Director of the Environmental Clinic. Kelly joined the faculty in 2008. Prior to joining the Clinic, Kelly worked as legal counsel for national nonprofits including: the Environmental Integrity Project in Washington DC, Environmental Defense Fund in Austin, and Public Citizen’s Austin office. She also worked at the Austin firm Henry, Lowerre, Johnson, Hess & Frederick, representing citizen and environmental groups in permitting and enforcement matters. Kelly specializes in Clean Air Act permitting and enforcement.

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Louis Baer

Director and Assistant Council, Environment & Energy
Portland Cement Association

Louis Baer joined PCA in August 2017 as the Director and Assistant Counsel, Government Affairs and handles environment and energy regulatory issues for PCA. He has significant regulatory experience consulting for industrial facilities and government agencies on environmental regulatory compliance and policy experience working for lobbying and trade organizations.

Prior to PCA, He worked at consulting firms, where he advised government agencies and private industry on environmental and regulatory compliance, including performing environmental auditing, training, and risk assessments. Also, he worked for the U.S. Chamber of Commerce conducting advocacy efforts on environment & energy issues.

Louis is a native of Portland, Oregon and holds a B.A. in political science and history from Washington University in St. Louis and a J.D. from Washington University School of Law. Louis is also a Certified Professional Environmental Auditor and is a member of the American Bar Association, participating in the Section on Environment, Energy & Resources.

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Shannon S. Broome

Hunton Andrews Kurth

Shannon is the managing partner of the firm’s San Francisco office and leads the firm’s California environmental practice. Her prior experience as a chemical engineer in the oil and gas industry affords her unparalleled insights into the development of regulations and counsel on environmental, health and safety issues. Shannon also maintains an office in Washington, DC. Splitting her time between these offices allows her to help her clients wherever they may be. Shannon’s work focuses on permitting, enforcement, environmental incident response, and regulatory advocacy and litigation.

A nationally recognized authority on Clean Air Act matters, with more than 25 years of experience addressing all aspects of the act, Shannon represents clients in a variety of manufacturing and energy sectors, including oil and gas, chemical, paper, automotive, power generation and utilities. Shannon also advises companies in preparation for and responding to environmental incidents and under federal and state process safety management and risk management plan regulations.

Highly regarded for her litigation practice challenging and defending EPA and California regulations and permits before federal and state appellate courts, in 2018, she was named to The National Law Journal’s list of “Energy & Environmental Trailblazers.” She is also lauded for her deep knowledge of environmental enforcement matters, and is respected by her Fortune 100 clients for her solid advice on compliance advocacy. She was previously an engineer for Chevron, USA, in Los Angeles, California.

Shannon is admitted in the Supreme Court of California; US District Court, Eastern District of California; and US Courts of Appeals for the District of Columbia, Ninth and Tenth Circuits.

Shannon is a contributor to the firm’s environmental blog, The Nickel Report.

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