The Clean Air Act (CAA) and the Clean Water Act (CWA), while both aimed at protecting environmental quality, employ distinct regulatory approaches concerning permitting requirements that reflect the unique characteristics of air and water pollution sources. A central difference lies in the scope and nature of the permitting process itself.
Under the CAA, the primary permitting program for stationary sources of air pollution is Title V, also known as the Operating Permit Program. This program requires major sources of air pollutants (defined based on the quantity of pollutants emitted) to obtain comprehensive operating permits. These permits consolidate all applicable air pollution control requirements into a single, enforceable document. The CAA permitting approach is highly source-specific and emphasizes detailed emission limits and monitoring requirements tailored to the specific processes and technologies used at each facility. For example, a power plant burning coal might have specific limits on emissions of sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and other pollutants, along with requirements to install and operate continuous emission monitoring systems (CEMS) to ensure compliance. The CAA also includes New Source Review (NSR) provisions that r....
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