Services
Air
The Clean Air Act Amendments established the Title V permit program, with individual states then responsible for administering the program in their state via State Implementation Plans (SIPs) and building associated minor source permitting programs. You would think that each state would have similar air programs and processes, but you’d be wrong. Nearly every state is different, and some (such as California) are vastly different depending on the part of the state.
Associated Services:
- Title V renewals, modifications, compliance reporting, initial permitting
- Minor source air permitting
- Permitting Due Diligence for Large Projects
- Continuous Emissions Monitoring and Ambient Emissions Monitoring protocols
- Environmental impacts assessment
- Professional Engineer services available (New York and New Jersey)
Social Impacts and Environmental Justice
We have only had environmental protection regulations in this country for fifty years. Policy choices over time have led to overburdened communities in every state across the country. We do not live in vacuums. Our choices and activities impact others. Even if a facility is meeting their operating permit compliance conditions, they may still be contributing to adverse cumulative impacts in their community. Cumulative impacts analysis focuses on this and can take a number of forms. The cumulative impacts of nearby industrial operations and associated processes have led to elevated environmental and public health burdens. However, this does not follow a uniform pattern. If you imagine an elevated burden level as a 100, in some communities it may be two large sources and a few small causing that burden or you can have many medium and smaller sources still adding up to that same burden level. Some examples include:
Community One:
35 + 30 + 25 + 10 = 100
Example 1:
Community Two:
25 + 15 + 10 + 5 + 5 + 20 2’s = 100
Environmental impacts can often linger over time. Historical contamination (soil and water) usually takes years to remediate. Having these locations nearby your home can limit economic opportunities, post certain environmental and public health risks, and make you more susceptible to health impacts from ambient environmental impacts such as air emissions or through drinking water.
Example 2:
The New Jersey EJ Model. One site can cause detrimental impacts to a wide range of public health stressors. New Jersey focuses on 26 such stressors, but other states like New York focus on close to 60.
Example 3:
Untangling that mess is tricky since facilities in those areas can be following their existing permits yet still contributing to cumulative impact burdens locally. State programs (led by New Jersey, and now 10 other states) have been at the forefront of this issue as it relates to operating permit compliance. The industrial history of the area will always also come into play. The longer the history, the more likely you will be to have legacy issues from prior operations.
Before any large project is built, the developer and operator should have a feel for existing social and environmental baselines in the area and how their project will contribute to each. All projects positive and negative impacts, from an economic, environmental, and social perspective. Maximize the positive, minimize the negative, and be transparent in your communications with the community.
Associated Services:
- Environmental justice impact statements
- State and local law compliance
- Social baseline summary
- Community engagement strategy and management
- NEPA assistance
- EJ policy development
- Website content enhancements
- Community benefit agreements
- Reputational risk assessment
Water
The Clean Water Act and Waters of the United States (WOTUS) rules govern most water issues. The scope of involvement here for any industrial site will depend on how much water is utilized in their processes, if they are located in flood zones, or near any wetlands.
Associated Services:
- Stormwater permitting and reporting
- Discharge permitting and reporting
- Flood risk assessment
Climate Change
Our climate is changing. Understanding those changes and being able to project how they will impact your operations has become an imperative for anyone looking to minimize their risks. Many states have climate laws in place to target certain climate impacts, such as to minimize development in flood prone areas. Commonly climate laws and EJ laws will be connected, as will a goal to reduce reliance on fossil fuels.
Associated Services:
- Climate impacts risk analysis
- Climate policies and messaging
- Resiliency planning
- Supplemental Environmental Projects
- Grant applications