A Florida DEP Air Construction Permit is the written authorization issued by the Florida Department of Environmental Protection Division of Air Resource Management that lets a person or company build, modify, or relocate a stationary source of air pollution before any concrete is poured or any equipment is bolted down. The permit is filed on Form 62-210.900(1), the Application for Air Permit – Long Form (most recent revision 02/06/2024), or on the Short Form Form 62-210.900(1)(a) for smaller projects. The legal anchor is Chapter 62-210, F.A.C. and Section 403.087, Florida Statutes.
Florida DEP processes about 1,800 air construction permit actions per year across its six districts and seven delegated local programs, and roughly 35% of applications receive a Request for Additional Information (RAI) within the first 30 days because of incomplete emissions calculations or missing PE seals, according to the agency’s Air Permitting Guide. In this article you will learn:
- 🏭 What the air construction permit covers and who must file it
- 📋 The exact documents and data to gather before opening the form
- 🖊️ Line-by-line instructions for every section of Form 62-210.900(1)
- 👥 Three named-filer scenarios showing real entries
- 💻 How to file through ARMS or by paper at every district and delegated office
- ⚠️ The mistakes that trigger RAIs, denials, or $10,000-per-day civil penalties
What the Form Is and Who Must File It
The Florida DEP Air Construction Permit, often called an AC permit, is the pre-construction authorization required by Rule 62-210.300(1), F.A.C. for any new stationary source, any modification that increases emissions, or any relocation of a permitted unit. The form itself, Form 62-210.900(1), is incorporated by reference into the rule, which means the version on the DEP website is the only legally accepted version. Filers must use the revision date printed in the lower-left footer of the form.
Who must file? Any owner or operator of a stationary source whose potential emissions exceed the thresholds in Rule 62-210.300, F.A.C., including manufacturing plants, power generators, asphalt plants, concrete batch plants, dry cleaners using perchloroethylene, food processors with boilers, landfills, and any Title V major source under 40 CFR Part 70. Smaller categories qualify for general permits under Rule 62-210.310, F.A.C., and Prevention of Significant Deterioration (PSD) projects must use the Long Form with extra attachments under Rule 62-212.400, F.A.C..
The agency on the receiving end is either DEP’s central Office of Permitting and Compliance in Tallahassee, one of the six DEP districts (Northwest, Northeast, Central, Southwest, South, Southeast), or a delegated local air program in Broward, Duval, Hillsborough, Miami-Dade, Palm Beach, Pinellas, or Sarasota counties. Each program has its own contact and cannot be skipped because of the geographic split adopted by Rule 62-113.200, F.A.C.. Building without a permit triggers liability under Section 403.161, F.S., with civil penalties up to $10,000 per day per violation plus orders to remove the unauthorized equipment.
A common misconception is that buying like-kind replacement equipment avoids the permit. In reality, Rule 62-210.200, F.A.C. defines modification broadly enough that even a same-size boiler swap can require a permit if emission factors change. When in doubt, applicants should request an applicability determination from the district office before assuming an exemption.
Before You Start: Documents and Information You Need
The single biggest cause of RAIs is missing back-up data, so the pre-filing checklist matters more than the form itself. Gather every item on the list below in a single project folder before opening ARMS or printing the PDF. The DEP reviewer must be able to recreate every emissions number from the attachments without calling you.
- Facility ID number assigned by DEP (format XXXXXXX); without it, the application cannot be linked to your existing facility record and will sit in the unmatched queue.
- Latitude and longitude of the emissions unit to six decimal places, taken from a verified GPS source; rounded numbers fail the AERIS geocoding check.
- Process flow diagram showing every input, every emission point, and every control device; missing arrows lead to RAIs about fugitive sources.
- AP-42 emission calculations using the most recent edition of EPA’s Compilation of Air Pollutant Emission Factors; outdated factors trigger automatic recalculation requests.
- Manufacturer specifications for every fuel-burning unit and every control device, including guaranteed emission rates and capture efficiencies.
- Safety Data Sheets (SDS) for every coating, solvent, fuel, or raw material; without SDSs, HAP totals cannot be verified.
- Site plan and plot plan drawn to scale, with property lines, stack heights, and nearest residence; required by Rule 62-210.900(1), F.A.C..
- Florida Professional Engineer (PE) seal and signature on the application certification page; an out-of-state PE seal is rejected outright.
- Application fee calculated from the Rule 62-4.050, F.A.C. fee schedule; underpayment by even a dollar makes the application incomplete.
- BACT, LAER, or RACT analysis if the project triggers PSD, nonattainment NSR, or RACT under Chapter 62-212, F.A.C..
- Statement of Basis explaining the project narrative, regulatory applicability, and proposed permit conditions; reviewers use this as the spine of the draft permit.
A field walk and a phone call with the assigned district permit reviewer before submittal usually saves two to four weeks of review time. Most district offices welcome a pre-application meeting and the Air Permitting Guide actively encourages it.
Where to Get the Form and How to Access It
The official, current version of every Florida air permit form lives on the DEP Air Permitting Forms page. Do not download the form from a third-party site, because the agency rejects superseded revisions even when the substantive content is identical. The version cited in this article carries revision date 02/06/2024 in the footer.
Three access channels exist. First, the Air Resource Management System (ARMS) portal is the preferred channel and uses a free DEP business account; ARMS auto-fills facility data, validates required fields, and accepts electronic PE seals registered with DBPR. Second, a paper PDF can be printed, completed in ink, sealed by a Florida PE, and mailed to the district or delegated local program. Third, in-person delivery is accepted at any district office during business hours and triggers a date-stamped receipt that becomes the official filing date for Section 120.60, F.S. processing-clock purposes.
The Long Form covers any project that does not qualify for a general permit or short-form treatment. The Short Form 62-210.900(1)(a) is limited to projects with potential emissions below specified thresholds and to certain minor source categories. Title V applicants must combine the Long Form with Form 62-213.900(1), the Title V Air Operation Permit Application.
Step-by-Step: How to Fill Out Form 62-210.900(1) Line by Line
The Long Form is organized into a cover Application Information page, Section I (Facility Information), Section II (Facility Pollutant Information), Section III (Emissions Unit Information), and a series of subsections labeled A through K inside Section III. Every entry must be typed or printed in black ink, dates use MM/DD/YYYY, and every monetary figure uses dollars with no cents. Sample entries below are italicized so they stand out from instructions.
Application Information – Cover Page
The cover page asks for the Type of Application, the Application Contact, and the Owner/Authorized Representative. In plain English, you are telling DEP what kind of action you want and who can answer the phone when the reviewer calls. Check exactly one of the boxes: Air Construction, Air Construction and Title V Revision, Concurrent Processing, or Air General Permit Notification.
For example, Maria Lopez, Plant Manager at Sunshine Concrete LLC writes her name, (813) 555-0144, and maria.lopez@sunshineconcrete.com on the contact line. The owner block requires the legal entity exactly as registered with Sunbiz, not the trade name. A nuance: if the applicant is a multi-member LLC, the authorized representative must match a person identified in the entity’s operating agreement, otherwise the PE certification can be challenged.
A common mistake on this page is checking Air Construction when the project is really a Title V Revision; the consequence is that the application enters the wrong queue and DEP issues an RAI directing you to refile, which restarts the 90-day clock under Section 120.60, F.S.. The misconception worth correcting is that this page is just contact info; in reality, it sets the legal scope of what DEP will review.
Section I, Subsection A – Facility Identification
This subsection asks for the Facility ID, Facility Name, Site Address, County, and UTM coordinates. Enter the seven-digit Facility ID that DEP assigned when the site first registered; new facilities leave this blank and write NEW across the box. The UTM zone for Florida is 17 and coordinates are in meters to the nearest whole meter.
For example, Carlos Vega’s new asphalt plant in Polk County enters Facility ID 1050213, county POLK, UTM Easting 412550, UTM Northing 3105180. A nuance is that handheld GPS devices often default to WGS84 lat/long; the form requires NAD83 UTM, so a coordinate transformation is needed before entry.
A common mistake is using the mailing address (often a corporate PO box) in place of the physical site address; the consequence is that the inspector cannot locate the source, the air quality modeling fails, and the application is returned. The misconception is that latitude and longitude inside the same block are interchangeable with UTM; they are not, and the wrong format causes the AERIS emissions database to reject the import.
Section I, Subsection B – Facility Contact
Subsection B asks for the Facility Contact name, title, mailing address, telephone, and email. This is the person DEP calls for compliance questions after the permit issues, which can be different from the application contact on the cover page. Enter the name in Last, First Middle format with the title spelled out.
For example, Aisha Bennett, Environmental Health and Safety Manager, lists her direct line (305) 555-0188 and email aisha.bennett@evergladesfoods.com. A nuance is that DEP allows a third-party consultant in this block only if the consultant has a written authorization on file; without it, the consultant cannot receive enforcement correspondence.
A common mistake is leaving the email blank because the contact prefers phone calls; the consequence is delayed receipt of the electronic draft permit, which is now distributed first by email under DEP’s paperless initiative. The misconception is that this contact must be a corporate officer; any qualified employee with delegated authority is acceptable.
Section I, Subsection C – Application Responsible Official
This block is reserved for the Responsible Official defined in Rule 62-213.200, F.A.C.. For corporations, that is a president, vice-president, secretary, treasurer, or a delegated facility manager whose authority is documented. The signature here is a sworn statement under Section 403.161, F.S..
For example, Marcus Hill, Vice President of Operations, Sunshine Concrete LLC, prints his name, signs in blue ink, and dates the line 03/14/2026. A nuance: if the applicant is a partnership, a general partner signs; for sole proprietorships, the proprietor signs personally and accepts personal liability for false statements.
A common mistake on this block is having a plant manager sign without delegated authority on file; the consequence is that the certification is void and the application is treated as unsigned, which is grounds for outright denial. The misconception is that a notary is required; the form’s certification language is itself the sworn statement and no notarization is needed.
Section I, Subsection D – Professional Engineer Certification
Subsection D requires a Florida-licensed PE to seal, sign, and date the engineering certification. The PE attests that the engineering features and emissions calculations conform to sound engineering principles and applicable rules. Enter the PE’s name, license number (format PE 12345), firm, address, telephone, and email above the seal.
For example, Janet Park, P.E., License No. PE 67421, Park Air Consulting, Inc., applies her embossed seal across the bottom-right corner and signs in permanent ink. A nuance is that ARMS accepts a digital seal registered through the Florida Board of Professional Engineers digital signature program; a scanned image of a wet seal is not accepted in ARMS.
A common mistake is letting an out-of-state PE sign because the equipment vendor’s PE is licensed in another state; the consequence is automatic rejection because Section 471.025, F.S. requires a Florida license. The misconception is that the PE must design the equipment; the PE only certifies that the application package is technically sound.
Section II – Facility Pollutant Information
Section II captures Facility-Wide Potential Emissions in tons per year for each regulated pollutant: PM, PM10, PM2.5, SO2, NOx, CO, VOC, lead, total HAP, and any single HAP above one ton per year. Numbers are entered to one decimal place. Use facility-wide totals after the project, not just the new unit’s contribution.
For example, Evergreen Power LLC enters NOx 89.4, CO 152.1, VOC 18.7, and Total HAP 6.3. A nuance is that fugitive emissions count toward facility totals only for the Section 302(j) listed source categories; other sources exclude fugitives from major-source determinations.
A common mistake is entering project-only deltas in Section II rather than the post-project facility totals; the consequence is that DEP’s PSD applicability check produces a false negative and the permit is later voided. The misconception is that potential to emit means actual emissions; potential is calculated at maximum capacity, 8,760 hours per year, before any voluntary limits.
Section III, Subsection A – Emissions Unit Identification
Subsection A asks for the Emissions Unit ID, Description, NAICS code, Date of Construction, and Operating Capacity. Each emissions unit gets its own Section III package; for a project with three new boilers, you submit three sets of Subsections A through K. Use the next sequential ID after your existing units (e.g., Unit 005).
For example, Sunshine Concrete LLC enters Unit ID 003, description Cement Silo with Bin Vent Filter, NAICS 327320, construction start 06/01/2026. A nuance is that Date of Construction means the date physical on-site work begins, not the date of equipment order; misstating this date can affect PSD grandfathering analysis.
A common mistake is reusing an old Unit ID for a replacement; the consequence is that DEP’s database overwrites the historical record and compliance history is lost. The misconception is that NAICS is optional; it is required and feeds into EPA’s National Emissions Inventory.
Section III, Subsection B – Control Equipment
Subsection B captures every air pollution control device tied to the unit, including type, manufacturer, model, design capture and control efficiencies, and the pollutants controlled. Enter one row per device. List in series order from process to stack.
For example, Carlos Vega’s asphalt plant lists Pulse-Jet Baghouse, MAC Equipment Model 144MCF684, 99.5% PM control, 100% capture. A nuance is that DEP wants the guaranteed efficiency from the manufacturer, not the typical efficiency from a brochure; the guarantee letter must be attached.
A common mistake is omitting secondary devices like a knockout drum upstream of a scrubber; the consequence is that emission calculations under-credit removal and inflate reported emissions, which can wrongly trigger PSD. The misconception is that passive devices like cyclones do not count; any device that affects emissions must be listed.
Section III, Subsection C – Emission Point Information
Subsection C describes each stack or vent: ID, height above grade, exit diameter, exit velocity, exit temperature, flow rate, and orientation (vertical, horizontal, or rain-capped). Heights are in feet, diameters in feet to two decimals, temperatures in degrees Fahrenheit. Round consistently and match the modeling input file.
For example, Stack S-003 is entered as height 45.0 ft, diameter 1.50 ft, exit velocity 52.3 ft/s, temperature 285°F, flow rate 5,540 acfm, vertical unobstructed. A nuance is that rain caps must be flagged because EPA’s AERMOD treats them as zero plume rise, which can fail ambient air quality standards.
A common mistake is reporting standard flow when the form asks for actual; the consequence is that dispersion modeling is wrong by 20% or more and the modeling demonstration is rejected. The misconception is that horizontal stacks are forbidden; they are allowed but require explicit modeling and are flagged for closer review.
Section III, Subsection D – Segment/Process Information
Subsection D lists each process segment feeding the emissions unit, with SCC code, description, throughput, throughput units, operating hours, and seasonal throughput percentages. One row per segment, even when several segments share a stack.
For example, Evergreen Foods enters SCC 10200602, Natural Gas Industrial Boiler 10-100 MMBtu/hr, throughput 85 MMscf/year, operating 8,760 hours/year, with seasonal split 25/25/25/25. A nuance is that seasonal percentages must sum to 100, and the form rejects rows where they do not.
A common mistake is using a generic SCC like generic combustion when a specific code exists; the consequence is that DEP cannot match the segment to standard emission factors and issues an RAI for clarification. The misconception is that SCC codes are interchangeable with NAICS; they are not, and both are required.
Section III, Subsection E – Pollutant Detail Information
Subsection E is the applicable requirements table for each pollutant on each segment, citing the rule, standard, BACT determination, RACT determination, NSPS Subpart, NESHAP Subpart, or other federal requirement. List each citation by full rule number with paragraph.
For example, Sunshine Concrete lists 40 CFR 60 Subpart OOO for the silo, Rule 62-296.414, F.A.C. for fugitive dust, and BACT determination dated 02/12/2026 for PM10. A nuance is that each pollutant gets its own row; lumping PM and PM10 into a single line is a frequent reviewer pet peeve.
A common mistake is citing the parent CFR Part without the Subpart; the consequence is an RAI demanding the specific subpart. The misconception is that state-only citations are sufficient when an NSPS applies; both must be cited because DEP enforces the NSPS via Rule 62-204.800, F.A.C..
Section III, Subsection F – Emissions Information
Subsection F is the calculation core: emission factor, factor units, factor source, control efficiency, hourly emissions (lb/hr), annual emissions (tpy), and basis. Show the uncontrolled, controlled, and allowable numbers in three rows per pollutant. Attach the calculation worksheets as Appendix F.
For example, Carlos Vega’s drum mix asphalt plant writes PM10 factor 0.024 lb/ton, AP-42 Table 11.1-3, control 99.5%, hourly 0.18 lb/hr, annual 0.78 tpy. A nuance is that startup, shutdown, and malfunction emissions belong in this subsection if they are part of normal operations; otherwise list them in Subsection K.
A common mistake is using uncontrolled annual emissions to determine PSD applicability; the consequence is wrongly triggering or wrongly avoiding PSD review. The misconception is that AP-42 factors are mandatory; site-specific factors from prior stack tests are usually preferred when available.
Section III, Subsection G – Visible Emissions Information
Subsection G asks for the opacity standard, averaging time, test method (Method 9 or Method 22), and frequency. Most Florida air construction permits adopt a 20% opacity limit on a 6-minute average under Rule 62-296.320, F.A.C., unless a stricter NSPS applies.
For example, Evergreen Power writes 20% opacity, 6-minute average, Method 9, annually. A nuance is that NSPS Subparts often impose a 10% or 7% standard that supersedes the state default; check the subpart before defaulting to 20%.
A common mistake is omitting the test method; the consequence is that DEP writes the permit using its default method, which may be stricter than the applicable NSPS. The misconception is that opacity only applies to combustion sources; many fugitive sources, including conveyors and stockpiles, carry opacity limits.
Section III, Subsection H – Continuous Monitor Information
Subsection H captures any CEMS, COMS, or PEMS installed on the unit: pollutant monitored, monitor make and model, span, certification protocol, and data acquisition system. Leave blank if no continuous monitor is required.
For example, Evergreen Power’s Unit 1 boiler lists NOx CEMS, Thermo 42i-HL, span 0-200 ppm, certified per 40 CFR 75 Appendix A. A nuance is that COMS (opacity) must follow Performance Specification 1, and the cert plan must be in Appendix H.
A common mistake is listing a CEMS without proposing a certification deadline; the consequence is that the permit is silent on the schedule and DEP imposes a 60-day default that may be impossible to meet. The misconception is that CEMS are required for every Title V source; many Title V boilers operate on parametric monitoring instead.
Section III, Subsection I – Stack Test Information
Subsection I sets the initial compliance test and renewal frequency: pollutants tested, test method (e.g., EPA Method 5, 7E, 25A), and proposed test date relative to startup. Most permits require initial testing within 60 to 180 days of achieving normal operation.
For example, Sunshine Concrete proposes Method 5 PM10 within 90 days of startup, retests every 5 years. A nuance is that EPA’s Methods 1-30 cover most pollutants but Florida sometimes accepts ASTM equivalents under Rule 62-297, F.A.C..
A common mistake is proposing a test date before normal operation can be demonstrated; the consequence is a failed test and a re-test fee. The misconception is that stack testing is one-and-done; most NSPS subparts require annual or biennial retests.
Section III, Subsection J – Fuel Information
Subsection J lists every fuel: type, sulfur content, ash content, heating value, and annual usage. Show each fuel even when a unit can switch.
For example, Evergreen Foods Boiler 1 lists Natural Gas, 0.4 grain S/100 scf, 1,020 Btu/scf, 85 MMscf/year and a backup No. 2 Fuel Oil, 0.0015% S, 19,500 Btu/lb, max 200,000 gallons/year. A nuance is that biogas and renewable fuels require attaching a third-party fuel analysis.
A common mistake is omitting the backup fuel; the consequence is that the permit prohibits fuel switching during natural gas curtailments. The misconception is that ultra-low sulfur diesel automatically qualifies as a clean fuel; the form still requires the sulfur certification.
Section III, Subsection K – Additional Information
Subsection K is the catch-all narrative: startup/shutdown/malfunction plans, alternative operating scenarios, and any voluntary federally-enforceable limits the applicant proposes to synthetic minor the project. This is where you ask DEP for limits below PTE.
For example, Carlos Vega writes Voluntary throughput cap of 200,000 tons/year to remain a synthetic minor for PM10, supported by Appendix K calculations. A nuance is that voluntary limits become legally enforceable once written into the permit; back-tracking later requires a permit revision.
A common mistake is proposing a synthetic-minor limit without explaining how it will be tracked; the consequence is that DEP rewrites the limit with daily monitoring rather than monthly. The misconception is that this section is optional; it is required when any narrative beyond the structured fields is needed.
Three Filled-Out Examples Using Real Scenarios
Below are three named-filer scenarios that walk the entire form. Each table has 2 columns and shows the most important entries.
Scenario 1: Maria Lopez, Sunshine Concrete LLC – New Concrete Batch Plant in Hillsborough County
| Form Section | What Maria Enters |
|---|---|
| Type of Application | Air Construction |
| Facility ID | NEW |
| Site Address | 4400 Industrial Blvd, Tampa, FL 33619 |
| County / Local Program | Hillsborough – delegated to EPC of Hillsborough County |
| Section I Subsection D – PE | Janet Park, PE 67421, Park Air Consulting |
| Section II – Facility PTE PM10 | 11.4 tpy |
| Section III Unit 003 | Cement Silo with Bin Vent, NSPS Subpart OOO |
| Subsection F – Emission Factor | 0.0046 lb/ton, AP-42 11.12 |
| Subsection K – Voluntary Limit | Throughput cap 300,000 yd³/year |
| Application Fee | $2,500 per Rule 62-4.050(4)(a)17 |
Scenario 2: Aisha Bennett, Everglades Foods Inc. – Adding a 60 MMBtu/hr Natural Gas Boiler at an Existing Plant
| Form Section | What Aisha Enters |
|---|---|
| Type of Application | Air Construction and Title V Revision |
| Facility ID | 0570138 |
| Site Address | 2100 Packing House Rd, Belle Glade, FL 33430 |
| Section II – Post-Project NOx | 54.2 tpy |
| Section III Unit 005 | Cleaver-Brooks 60 MMBtu/hr Watertube Boiler |
| Subsection B – Control | Low-NOx Burner with FGR, 0.036 lb/MMBtu |
| Subsection E – NSPS | 40 CFR 60 Subpart Dc |
| Subsection F – NOx | 0.036 lb/MMBtu, vendor guarantee |
| Subsection J – Fuel | Natural gas primary; ULSD backup 100,000 gal/yr |
| Application Fee | $5,000 per Rule 62-4.050(4)(a)24 |
Scenario 3: Carlos Vega, Polk Asphalt LLC – PSD Major Source for a New Drum-Mix Asphalt Plant
| Form Section | What Carlos Enters |
|---|---|
| Type of Application | Air Construction (PSD) |
| Facility ID | NEW |
| Site Address | 9876 Phosphate Rd, Lakeland, FL 33805 |
| Section II – Facility PTE NOx | 112.5 tpy (PSD major) |
| Section III Unit 001 | Astec Double Barrel 400 tph Drum Mix Plant |
| Subsection B – Control | Pulse-Jet Baghouse 99.5% PM |
| Subsection F – PM10 | 0.024 lb/ton, AP-42 11.1 |
| BACT Determination | Attached as Appendix F-2 |
| Modeling Demonstration | AERMOD attached as Appendix M |
| Application Fee | $7,500 PSD fee per Rule 62-4.050(4)(a)27 |
How to File the Completed Form
Three filing channels exist and each starts the Section 120.60, F.S. 90-day completeness clock when the agency receives the package. Pick the channel that fits the project complexity and recordkeeping preference.
Online via ARMS. Log in at fldeparms.dep.state.fl.us using a registered DEP business account. Upload the application PDF, the PE-sealed certification, all appendices, and the fee payment confirmation. Pay by ACH or credit card; ARMS issues a confirmation number that serves as proof of filing. Expected processing time is 30 days for general permits and 90 days for individual air construction permits, extendable through RAIs.
By mail. Send a wet-signed, PE-sealed package to the appropriate district or delegated local program. The Northwest District is at 160 W Government St, Pensacola, FL 32502; Northeast at 8800 Baymeadows Way W, Suite 100, Jacksonville, FL 32256; Central at 3319 Maguire Blvd, Suite 232, Orlando, FL 32803; Southwest at 13051 N Telecom Pkwy, Temple Terrace, FL 33637; South at 2295 Victoria Ave, Suite 364, Fort Myers, FL 33902; Southeast at 3301 Gun Club Rd, MSC 7210-1, West Palm Beach, FL 33406. Include a check or money order payable to the Florida Department of Environmental Protection for the Rule 62-4.050, F.A.C. fee. USPS Certified Mail with return receipt is the recommended proof of filing.
In person. Walk the package into the district office during business hours, ask for a date-stamped copy of the cover sheet, and keep that stamp as your proof. Delegated local programs accept in-person delivery at their own offices: EPC of Hillsborough, Broward EPGMD, Miami-Dade RER-DERM, Palm Beach ERM, Pinellas Air Quality, Duval Environmental Quality, and Sarasota Environmental Protection. Each has its own counter hours.
What Happens After You File
Within 30 days of filing, the assigned reviewer issues either a Completeness Determination or a Request for Additional Information (RAI) under Section 120.60(1), F.S.. An RAI tolls the 90-day processing clock from the date the request is mailed until the day the response is received, so prompt responses are critical to keeping the project schedule on track.
After completeness, DEP drafts the permit, publishes a Public Notice of Draft Permit in a newspaper of general circulation in the affected county, and accepts public comments for 14 days (or 30 days for PSD projects). For PSD and Title V revisions, the EPA Region 4 office receives a copy and may file objections within 45 days. Any substantially affected person may petition for an administrative hearing under Section 120.569, F.S..
If no comments arrive, DEP issues the Final Permit and the applicant has 18 months under Rule 62-4.080, F.A.C. to begin construction. Construction must be completed within the schedule on the face of the permit; missing the milestone requires a permit extension request. Once the unit is built and tested, the applicant files an Application for Air Operation Permit and shifts into Title V or minor source operating status.
Mistakes to Avoid When Filling Out the Form
The mistakes below are drawn directly from the patterns flagged in the Air Permitting Guide and from the agency’s published RAI logs.
- Using an out-of-state PE seal; the application is rejected as unsigned.
- Entering a PO Box in the site address; the inspector cannot find the source.
- Submitting facility-wide potential emissions that exclude the new unit; PSD applicability is wrong.
- Citing NSPS Subparts without the paragraph; reviewer issues an RAI for specificity.
- Forgetting the fee; the application is incomplete and the clock does not start.
- Listing typical control efficiency instead of guaranteed; the permit’s emission limit becomes unenforceable.
- Mixing up NAICS and SCC codes; emission factor lookups fail.
- Entering standard flow rate where actual is required; modeling fails.
- Skipping Subsection K narrative when proposing synthetic-minor limits; reviewer cannot tell limits are voluntary.
- Forgetting to attach manufacturer guarantee letters; vendor data is rejected.
- Using AP-42 factors that are no longer current; emissions are recalculated.
- Listing the wrong UTM zone; AERMOD geocoding fails.
- Failing to update the Statement of Basis when project scope changes mid-review; DEP issues a fresh draft and restarts public notice.
Do’s and Don’ts
- Do call the assigned district reviewer for a pre-application meeting before submitting the package because it identifies fatal flaws early.
- Do include a Statement of Basis that mirrors the structure of the draft permit because it speeds reviewer drafting.
- Do number every appendix and reference each appendix in the text because reviewers grade clarity.
- Do keep a delta table showing pre-project and post-project emissions because it makes PSD applicability obvious.
- Do save the ARMS confirmation number in two places because losing it complicates future inquiries.
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Do track the RAI clock day by day because every day of tolling pushes back construction.
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Don’t assume an exemption applies without confirming with DEP in writing because Rule 62-210.300, F.A.C. is narrow.
- Don’t sign as Responsible Official without delegated authority because the certification is then void.
- Don’t submit handwritten calculations because reviewers cannot audit them.
- Don’t mix project-only and facility-wide numbers because PSD and Title V tests look at different totals.
- Don’t rely on vendor brochures alone because guaranteed numbers must be in writing.
- Don’t start any physical site work before the permit issues because that is construction under Section 403.087, F.S..
Pros and Cons of Filing on Your Own vs. With Help
Many small-source filers ask whether to file directly or to hire an air consultant. Each side has clear benefits and drawbacks, and the decision often turns on project complexity and internal staffing.
Pros of filing on your own:
- Saves consultant fees that often run $10,000 to $50,000 for a Long Form package.
- Builds in-house knowledge of the facility’s emission profile that pays off at every renewal.
- Direct contact with the DEP reviewer creates a relationship for future questions.
- Faster decision-making because internal staff control the schedule.
- No risk of consultant turnover mid-application.
Cons of filing on your own:
- The Florida PE seal still has to be procured externally for most companies.
- AP-42 and AERMOD modeling carry a steep learning curve.
- One missed Subpart citation can add 60 days through an RAI.
- PSD-level analyses (BACT, Class I area impacts) require specialized tools.
- The applicant bears full liability for Section 403.161, F.S. certifications.
A Quick Comparison: Long Form vs. Short Form
| Dimension | What It Means |
|---|---|
| Form Number | Long Form 62-210.900(1) vs. Short Form 62-210.900(1)(a) |
| Eligibility | Long: any source; Short: minor sources below specified PTE |
| PE Seal | Both require Florida PE |
| Typical Fee | Long: $2,500–$7,500; Short: $250–$1,000 |
| Processing Time | Long: 90 days; Short: 30–60 days |
| Public Notice | Long: required; Short: usually waived |
| Best Fit | Long: PSD, Title V; Short: small boilers, dry cleaners |
FAQs
Do I need a permit to replace an old boiler with the same size?
Yes. A like-kind replacement still meets the definition of modification under Rule 62-210.200, F.A.C. when emission factors change, so most replacements need an air construction permit.
Can I start site preparation before the permit issues?
No. Any physical on-site work on the emissions unit before permit issuance violates Section 403.087, F.S. and exposes the applicant to civil penalties.
Do I write NEW or leave Facility ID blank in Section I, Subsection A?
Yes. Write NEW in the Facility ID block when the site has never been permitted, because a blank field stalls the database intake.
Must I list both NAICS and SCC in Section III, Subsection D?
Yes. Both codes are mandatory because NAICS feeds the National Emissions Inventory and SCC feeds emission factor lookups.
Is an out-of-state PE seal acceptable on Subsection D?
No. Only a Florida-licensed PE may seal the certification under Section 471.025, F.S., and an out-of-state seal causes immediate rejection.
Do I list uncontrolled or controlled emissions in Subsection F?
Yes. List both, plus the allowable limit, on three separate rows because reviewers compare the three when setting permit conditions.
Can ARMS accept a scanned image of a wet seal?
No. ARMS requires a registered digital seal through the Florida Board of Professional Engineers; scanned wet seals are rejected.
Are fugitive emissions counted toward facility totals in Section II?
Yes. Fugitives count for the 28 listed source categories under 40 CFR 52.21(b)(1)(iii); other categories exclude fugitives from major-source determinations.
Do I need a separate Section III package for each new emissions unit?
Yes. File one set of Subsections A through K per emissions unit because the database stores compliance history at the unit level.
Is a notary required on the Responsible Official signature?
No. The certification language under Rule 62-210.900, F.A.C. is itself the sworn statement, and notarization is not required.
Can I file the Long Form by email?
No. Email submission is not accepted; use ARMS, mail, or in-person delivery as listed in Rule 62-110.106, F.A.C..
Will the 90-day processing clock pause if I receive an RAI?
Yes. The clock tolls under Section 120.60(1), F.S. from the date DEP mails the RAI until the date your complete response is received.
Do delegated local programs use the same form?
Yes. Delegated programs in Broward, Duval, Hillsborough, Miami-Dade, Palm Beach, Pinellas, and Sarasota use Form 62-210.900(1) but submit to the local office instead of DEP.
Is the application fee refundable if I withdraw?
No. Filing fees under Rule 62-4.050, F.A.C. are non-refundable once the application is logged in, even when the applicant withdraws before permit issuance.
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