I’ve mentioned many times that a complete permit application contains three core elements:
Each of these is critical to the entire application, and missing even one element can lead to a major delay in the processing of your permit application — and your entire project. So it’s important to get your application correct the first time.
The SCAQMD has many permitting forms on their website, and it’s very easy to get confused as to which one pertains to your situation. So let’s discuss some of the basic forms that are required when submitting your permit application.
When it comes to permitting forms, there are three specific forms and two basic groups (series) of forms you need to know about:
- Form 400-A
- Form 400-CEQA
- Form 400-E series
- Form 400-XPP
- Form 500 series
Be sure you use the most recent version of the forms when preparing your permit application. Your company may have forms stored away on a shared drive, or even blank hard-copy forms. Don’t use those.
Instead, head over to SCAQMD’s website and download the most recent version of the specific form. I recommend that you either print or download the form while going through this section of the book to get familiarized with the structure and the information requested. Note that you can click on any of the images in this post to enlarge.
The first form on the list is Form 400-A, the basic permit application form, which contains such information as the equipment being permitted, the company who owns the equipment, and the facility at which the permitted equipment will be located.
Form 400-A is broken down into six sections, labeled A through F, each of which asks for specific information related to the permit application being submitted.
Let’s focus on Section D, where you’ll provide information related to your facility and the type of permit for which you are applying. Section D6 is where you need to indicate if your facility is in the RECLAIM and/or Title V programs, while Section D7 is where you need to indicate the reason you are submitting your permit application.
So if you are submitting your permit because of new construction, then you will check one of the boxes in Section D7a.
On the other hand, if you are seeking a permit for an existing piece of equipment, then you will check one of the boxes in Section D7c.
There are two important points to note about Form 400-A:
- A separate form 400-A is required for each piece of equipment being permitted. So if you are permitting 50 emergency generator engines, then you must submit 50 Form 400-As with your application.
- If your facility has a facility permit, like a Title V and/or RECLAIM permit, you also need to submit one Form 400-A to modify your facility permit along with your permit application. For example, if your facility is both Title V and RECLAIM, you will need to submit two Form 400-As (one for Title V and one for RECLAIM). This Form 400-A is in addition to the 400-A forms submitted for the individual pieces of equipment.
If you want to expedite the processing of your permit, Form 400-XPP authorizes the SCAQMD permit engineer to work overtime to expedite your application. Expediting also requires that you pay an additional fee according to Rule 301 (v).
Expedited permit processing is subject to the availability of staff. In the event that the SCAQMD determines that it does not have staff available to work on your permit application, you will be notified within 30 days and will receive a refund of the expedited permit-processing fees.
Form 400-CEQA is a screening tool the SCAQMD uses to determine if the permit application being submitted is exempt from the California Environmental Quality Act (CEQA), a state law designed to inform the public and the government of any potential adverse environmental effects associated with a given project. If the permit application is not exempt, additional analysis of the environmental impacts may be needed in order to satisfy your requirements under CEQA.
Looking at Form 400-CEQA, you will see that the SCAQMD has simplified the screening process to a series of yes-or-no questions divided into two sections:
Unlike with Form 400-A, only one Form 400-CEQA is required per project. So let’s revisit the example of the 50 emergency generator engines we used for Form 400-A. Since the permit application for those engines is considered to be one project, you only need to submit one Form 400-CEQA.
Form 400-E Series
The fourth form is actually a group of forms called the 400-E series. The E-series is actually a group of equipment-specific forms that require detailed information on the equipment being permitted.
Because there are so many forms in the series, and they’re all virtually the same, except for some equipment-specific questions, we’ll use Form 400-E-13a for internal combustion engines as an example.
If you look at all of the E-series forms, you will see that a specific form exists for a variety of types of equipment. I’ve listed a few examples below. You can find more equipment-specific forms on the forms section of the SCAQMD’s website.
- 400-E-1a: Particulate Matter Control Fabric Filter (Baghouse)/Cartridge Collector
- 400-E-1b: Particulate Matter Control Cyclone Separator
- 400-E-1c: Particulate Matter Control Electrostatic Precipitator (ESP)
- 400-E-2a: Gaseous Emission Control Form Afterburner/Oxidizer
- 400-E-2b: Gaseous Emission Control Form Adsorber (Carbon, Others)
- 400-E-2c: Gaseous Emission Control Form Flare
- 400-E-3: Scrubber
If you run into a case where an E-series form does not exist for your specific type of equipment, you need to use the general form, Form 400-E-GI, which is a summary of general information related to the piece of equipment you’re permitting.
For each permit application, at least one E-series form is needed to provide the details about the equipment being permitted.
Form 500 Series
The final type of form we’ll review is another group of forms, the 500-series, Title V forms.
As you might expect from the name, the Title V forms are only required if your facility is in the Title V program. The specific set of Title V/500 Series forms required for your permit application will depend on the type of application being submitted.
To help in the determination process, the SCAQMD has created a Matrix of all the Title V forms (and for some reason used the reviled Comic Sans font to do so) that pertain to a specific situation. When you use the matrix, it is important to note that the Title V forms are in addition to the basic permitting forms already mentioned in this post. For example, if you are submitting a permit for an engine at a manufacturing facility operating with an existing Title V permit, you need to submit the following forms:
- Form 400-A
- Form 400-CEQA
- Form 400-E13b
- Form 500-A2
- Form 500-C1
- Form 500-C2 (if applicable)
Form 500-F1 will not be applicable to most facilities unless you are in the SCAQMD’s Acid Rain Permit Program, and Form 500-B is only required if submitting an application for an initial or renewal Title V permit.