Flawed Permits

Calculations of ozone from pollution sources in the Denver metro area often rely on what's on paper, rather than what's actually released into the air. We've seen this with emissions of ozone forming compound from oil and gas developments, but it's happening at many other sources.

Part of the problem is that the State fails to require monitoring of ozone forming compounds when they issue pollution permits for stationary sources. While many permits prescribe a limit, for example 100 tons per year of ozone forming compounds, the permits don't require monitoring to ensure the limit isn't violated.

In financial terms, this would be like setting a budget, then failing to do the accounting needed to keep on budget. In a sense, monitoring is accounting of air pollution. Without accounting, well, there's no accountability and no way to keep on budget.

Case in point is a permit that's out for comment right now on the Air Pollution Control Division's website. The State wants to allow a new wood products finishing facility to be built in Douglas County in the Denver metro area. According to the draft permit and permit analysis, the facility has the potential to release over 20 tons per year of volatile organic compounds, or VOCs, which form ozone. Although the draft permit limits VOC emissions to 20 tons per year, the permit doesn't actually require monitoring of VOCs. Without monitoring, there's no way to make sure the 20 ton per year limit is not violated. Even more disconcerting is that since there's no monitoring, the source could exceed the VOC limit without anyone ever knowing.

Despite this, the State asserts that VOC emissions will not exceed 20 tons per year because, well, the permit says that emissions will not exceed 20 tons per year. The State, however, won't really know what's actually released into the air. The State's estimates rely on paper, not what's actually released into the air.

Although this wood products finishing facility is a small source of VOC emissions, it's indicative of a larger problem. Many permits fail to require monitoring of actual VOC emissions and as a result, there's no real accounting of ozone pollution from many stationary sources. These flawed permits continue to be issued, despite rising ozone levels and the threat of nonattainment designation.