The Ohio EPA Air Permit-to-Install (PTI), now issued for most smaller facilities as the Permit-to-Install and Operate (PTIO), is the state approval you must get from the Ohio EPA Division of Air Pollution Control before you build, install, or modify any equipment that puts pollution into the air. It applies to every air contaminant source installed or modified after January 1, 1974, and you must hold it before construction starts.
If you skip it or fill it out wrong, you risk a denied permit, a delayed project, or an enforcement action that can shut down equipment you already paid to install. Ohio EPA issues a PTIO for 10 years to non-Title V sources and 5 years to synthetic minor sources, and the application can take one to three months to process once it is complete, per the agency’s own steps to obtain permits page.
Here is what you will learn in this guide:
- 📋 How to complete Section I, Section II, and the Emissions Activity Category (EAC) forms line by line
- 🏭 Three full walkthrough examples for an auto body shop, a new boiler, and a synthetic minor plant
- 💻 How to file through the Ohio EPA eBusiness Center: Air Services portal, by email, and through a local air agency
- 💵 The current fees, deadlines, and the penalties that follow if you build without a permit
- ⚠️ The field-level mistakes filers make most, from potential-to-emit math to the signature page
What the Air Permit-to-Install Is and Who Must File It
The Air Permit-to-Install is Ohio’s preconstruction air permit. It is the legal permission slip that says you may build or change a piece of equipment that emits air pollution. The rule that requires it is Ohio Administrative Code 3745-31, and the broader authority comes from Ohio Revised Code Chapter 3704, the state’s Air Pollution Control law.
The agency that receives and reviews your application is the Ohio EPA Division of Air Pollution Control (DAPC), often working through a District Office or Local Air Agency (DO/LAA) that covers your county. Some counties, like Cuyahoga, use a local agency such as the Cleveland Division of Air Quality to do the front-line review.
Most small and mid-sized facilities now get a combined Permit-to-Install and Operate (PTIO), which rolls the old standalone “install” permit and the “operate” permit into one document. Larger Title V facilities still receive a true PTI for construction and then carry a separate Title V operating permit. Throughout this guide, “PTI” is used as the umbrella term, and the form is the same PTI/PTIO application either way.
You must file if you run a “stationary source” with an “air contaminant source” that emits a regulated pollutant. Per Engineering Guide 1, that means anything with a stack, vent, or dust collector, anything that burns fuel, anything using paints or solvents, or anything that makes visible dust, smoke, or odor. A few small sources are exempt under the de minimis rule in OAC 3745-15-05 and the exemptions in OAC 3745-31-03, but the safe move is to call your DO/LAA before you assume you are exempt.
A common misconception is that only big factories need a permit. Dry cleaners, gas stations, small coating shops, and a single new boiler all routinely need a PTIO. Building first and asking later is the costliest mistake a small business can make.
Before You Start: Documents and Information You Need
Gather everything below before you open the form. A complete application avoids the back-and-forth “request for more information” letters that add weeks or months to your review. Ohio EPA will not even start the clock until your application is deemed complete.
Here is your pre-filing checklist:
- Your facility’s Core Place ID, the agency-wide number Ohio EPA assigns to your physical site. Without it the reviewer may struggle to match your application to existing records, though you can leave it blank if you truly do not know it.
- The full legal name of the company and any “doing business as” (d.b.a.) name. A wrong legal name sends permits and invoices to the wrong entity.
- The physical street address of the facility, not a P.O. Box. P.O. Boxes are not accepted for the facility location, and a missing address can delay routing to the correct district office.
- Owner and operator names, mailing, and billing addresses. Invoices go to the billing address, so an error here means a fee notice you never see and a possible late payment.
- An equipment list for each emissions unit, with make, model, and capacity. Missing equipment details force the reviewer to write back for more, stalling the project.
- Your process or activity flow diagram showing inputs, outputs, control devices, and egress points. Without it the reviewer cannot understand how pollution moves through your operation.
- Emissions estimates and calculations, including the potential to emit (PTE) for each pollutant. Estimates without the math behind them are the single biggest cause of incomplete applications.
- Material data, such as gallons of paint per year, fuel type and heat input, or tons of product per year. These numbers drive every emission limit in your permit.
- SIC and NAICS codes for your industry, which help Ohio EPA classify and route your file.
- The name and title of the responsible official who will sign the certification page, since an unsigned or wrongly signed application is treated as not received.
Where to Get the Form and How to Access It
You can get the PTI/PTIO application three ways, and all of them start at the PTI and PTIO Information page. The fastest path for most filers today is the online portal, but the downloadable Microsoft Word forms still exist for those who prefer to fill them out offline.
The online route is the eBusiness Center: Air Services portal. You first create an OH|ID account at ebiz.epa.ohio.gov, then request a PIN that acts as your electronic signature. The portal walks you through Section I, Section II, and the EAC forms on screen, checks your math, and lets you pay and submit in one place.
The offline route uses the active Word forms. You download Section I (the file is named PTIappsec1.doc), one Section II for each emissions unit (PTIappsec2.doc), and one or more EAC forms. The official PTI Application Instructions explain how to collate them into a single document using “Next Page” section breaks so each form keeps its header.
The third route is to call your DO/LAA directly. The agency strongly recommends you discuss your project with a representative four months to two years before construction, depending on the size of the source. Doing this early often shapes the permit limits you will live with for the next decade, so it is time well spent.
Step-by-Step: How to Fill Out the PTI/PTIO Application Line by Line
The application has three building blocks: a General Cover Sheet, Section I (facility-wide permit information), Section II (one per emissions unit), and one or more Emissions Activity Category (EAC) forms (one per emissions unit). You repeat Section II and the EAC for every separate operation you want permitted. Below is each major field, in the order it appears.
Cover Sheet, Field 1: Facility Information
This field asks for the basic identity of the physical site where the equipment lives. You enter the Core Place ID (if known), the legal name, any alternate or d.b.a. name, a plain-language location description, the street address, and the county.
Write the legal name out in full with no abbreviations, describe the location like a set of driving directions, and use a real street address rather than a mailbox. For example, Rondinelli d.b.a. Dutchess Dry Cleaners enters its legal name as Rondinelli, its alternate name as Dutchess Dry Cleaners, and a location of “on Main Street, about 1.7 miles south of State Route 13 in the City of Hobart.”
What if your site has no street address yet because it is new construction? Then leave the street address blank and lean on the location description and latitude/longitude to pin the spot. The common mistake here is entering a P.O. Box as the facility address, which Ohio EPA rejects and which can misroute your file to the wrong district office. A frequent misconception is that the “facility” name and the “owner” name are the same thing; the facility is the real estate, while the owner is the company or person that holds it.
Cover Sheet, Fields 2 and 3: Owner and Operator Information
These fields ask who owns the regulated activity and who actually runs it day to day. You provide the owner’s name, effective date of ownership, mailing address, billing address, and phone, then repeat the same for the operator.
Enter the owner exactly as the company is registered, and if the owner and operator are the same, leave the operator’s effective-date line blank. For example, Buckeye Coatings LLC owns the site, so it is the owner; if it leases the building to Buckeye Coatings LLC itself, the operator block simply repeats the owner.
What if a separate management company runs the plant? Then list that company as the operator with its own mailing address. The common mistake is putting the consultant’s or contractor’s address in the billing block, which sends fee invoices to the wrong place and risks a missed payment. People often wrongly believe correspondence goes to the facility address; in fact, all official letters go to the owner’s mailing address.
Cover Sheet, Fields 4 and 5: Secondary ID Numbers and Supplemental Information
Field 4 asks for any existing Ohio EPA program ID numbers your facility already holds, such as a DAPC, NPDES, or RCRA number. Field 5 asks for supplemental data like your primary SIC code, NAICS code, D-U-N-S number, and the facility’s latitude and longitude.
Fill in any ID you already have and leave blank anything that does not apply or that you do not know. For example, Tri-State Forge with an existing wastewater permit enters its NPDES number, and a new greenfield site simply leaves Field 4 empty.
What if you have never had any Ohio EPA permit before? Then Field 4 is entirely blank, which is normal for first-time filers. The mistake to avoid is guessing at an ID number, because a wrong number links your application to another facility’s record. A common misconception is that Field 5 is required; it is optional and used only to improve Ohio EPA’s database, so a blank here will not make your application incomplete.
Section I, Line 1: Reason(s) for Application
This line asks why you are applying. You check every box that fits: a new installation, an initial PTI for a source that already exists, a modification, a reconstruction, or a restart of a shut-down source.
Check “new installation” only if construction has not begun, and check “modification” if you are changing an existing unit in a way that increases its allowable emissions. For example, Buckeye Coatings adding a brand-new spray booth checks New Installation, while a plant speeding up a line by 20% and exceeding its hourly limit checks Modification.
What if your equipment was installed before January 1, 1974, and never changed? Then no PTI is required at all, so you would not be filing. The common mistake is checking “new installation” for a unit that is already built and running, which misstates your compliance status and can expose a prior violation. Many filers wrongly think a “like-for-like” replacement is never a modification; under OAC 3745-31-01, if the swap raises potential emissions, it counts as a modification.
Section I, Line 2: Rules Applicability and Exemptions
This line asks which state and federal air rules apply to your source, such as New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAP). You list the rules you think apply and explain any exemption you are claiming.
Provide as much detail as you can, because applicability must be settled before the application can be processed. For example, a new natural-gas boiler operator notes that NSPS Subpart Dc may apply based on heat input and explains the size threshold that makes it apply or not.
What if you genuinely do not know which rules apply? You may check “unknown,” but that does not relieve you of having to comply later. The mistake here is leaving it blank with no explanation, which guarantees a follow-up letter and weeks of delay. A widespread misconception is that checking “unknown” shifts the research burden to Ohio EPA; it does not, and the cleanest path is to work the applicability out with your DO/LAA first.
Section I, Line 3: Registration Status
This line asks whether you want “registration status,” a faster track under OAC 3745-31-05(D) for very small sources. You check “Yes” only if you meet all five conditions, including maximum uncontrolled emissions under 5 tons per year for particulates, sulfur dioxide, nitrogen oxides, and organic compounds.
If you are unsure, check “No” and apply through the standard PTIO process. For example, a small woodworking shop with a single dust collector under 5 tons per year of particulate may check Yes to get a 60-day decision.
What if you barely exceed one of the 5-ton thresholds? Then you do not qualify and must check “No.” The mistake is claiming registration status without doing the emissions math, which leads Ohio EPA to reject the registration and restart your review as a normal permit. People often believe registration status frees them from ever applying for an operating permit; it does not, and you still must meet every applicable air requirement.
Section I, Line 4: Confidentiality Request
This line asks whether any information in your application is a trade secret you want shielded from public disclosure. If you claim confidentiality, you attach a separate sheet justifying the claim and submit two versions of the application.
State exactly which item numbers are secret, why they qualify under Ohio law, and what security measures protect them. For example, a specialty chemical maker claims its solvent blend ratios are confidential and submits one full version plus one “non-confidential” version with those ratios removed.
What if you only have one or two secret values? You still must submit a complete non-confidential version, or the application is not deemed complete. The mistake is emailing confidential data without protection, since email is not secure and Ohio EPA is not responsible for any breach. A common misconception is that everything can be marked confidential; only true trade secrets qualify, and emission rates themselves usually cannot be hidden.
Section II, Line 1: Company Identification of the Source
Section II repeats for every emissions unit. Line 1 asks what you call the source inside your plant. You enter your in-house name for the operation, such as a booth or line number.
Use the same name your operators and maintenance staff use, so everyone can match the permit to the real equipment. For example, Buckeye Coatings writes “Spray Booth #1” and Tri-State Forge writes “Natural Gas Boiler B001.”
What if you have several identical units? Give each a unique tag like Booth #1, Booth #2 rather than lumping them together. The mistake is using a vague label like “the equipment,” which makes the permit hard to enforce and hard for you to track. Filers sometimes think this name must match the manufacturer’s model number; it does not, and a clear plant nickname works best.
Section II, Line 2: Equipment List
This line asks for the specific hardware that makes up the source. You list each piece of process equipment tied to the unit.
Be concrete and itemize, because the reviewer uses this to understand your process. For example, a reactor system would read “2 weight tanks, 1 reactor vessel, 1 product drop tank,” and a roadway source would read “2 miles of unpaved roadway, 10,000 square feet of unpaved parking.”
What if some equipment is shared between two units? Note the sharing so the reviewer does not double-count emissions. The mistake is leaving out a control device or feeder, which produces an emissions estimate that does not match reality and triggers questions. A common misconception is that only the emitting machine matters; tanks, conveyors, and feeders all belong on the list because they shape the emissions picture.
Section II, Line 3: Installation or Modification Schedule
This line asks when you will install or modify the unit and when it will start operating. You enter the month and year for each, or check the box that says you will start as soon as the permit is issued.
Be realistic, since this date interacts with the rule that you must hold the permit before construction. For example, Tri-State Forge enters an install date of 09/2026 and an operating date of 11/2026, leaving roughly three months for permit processing.
What if your timeline is tight? Check the “begin as soon as PTI is issued” box and ask your DO/LAA about rush processing. The mistake is listing an install date that has already passed for new equipment, which signals you built before getting the permit, a violation of OAC 3745-31. People often assume they can break ground while the permit is “in review”; for a true PTI you cannot, and doing so is the classic enforcement trigger.
Section II, Line 4: Emissions Information
This is the heart of the application. The table asks for emissions before controls, actual emissions after controls, and the requested allowable limits you want in your permit, for each pollutant such as PM, NOx, SO2, CO, organic compounds (OC/VOC), lead, and HAPs.
Show every calculation, describe how you estimated each rate, and identify both total HAPs and your single highest HAP. For example, Buckeye Coatings calculates VOC from gallons of coating times the VOC content per gallon, then applies its booth’s capture and control efficiency to get actual emissions, and requests an allowable of 9.9 tons per year of VOC.
What if you run a batch process with uneven rates? Provide batch length, cycle time, and batches per year so Ohio EPA can set both short-term and annual limits. The mistake here is submitting numbers with no supporting math, which is the number-one reason applications are deemed incomplete. A major misconception is that “actual” and “potential to emit” are the same; potential to emit assumes the worst case at maximum operation, and confusing the two leads to limits you cannot meet.
Section II, Line 5: Add-on Emissions Control Information
This line asks about any pollution control device on the unit, such as a baghouse, scrubber, or thermal oxidizer. You check the device type and enter its operating parameters and control efficiency.
List the efficiency for each pollutant and the basis for it, such as stack test, design spec, or engineering estimate. For example, Tri-State Forge’s baghouse on its handling system lists “PM: 99%, basis: manufacturer design,” and a thermal oxidizer lists its minimum operating temperature in degrees Fahrenheit.
What if your device controls more than one pollutant? Spell out each one, for example “OC: 99%, CO: 95%.” The mistake is claiming a control efficiency you cannot demonstrate, because Ohio EPA will set your allowable limit assuming that efficiency, and you must meet it every day. Filers often think a control device removes the need for limits; instead, the device becomes an enforceable permit condition you must keep running and maintained.
Section II, Line 6: Process or Activity Flow Diagram
This line requires a diagram showing how material and pollution move through the unit. You include the source ID and company name, entry and exit points, all materials labeled, and all equipment, control devices, and egress points.
Draw it clearly and label every stack and fugitive release point, and if you have more than one control device, show the flow split to each. For example, Buckeye Coatings draws paint in → spray booth → dry filter (95% capture) → stack S001, with overspray labeled.
What if your diagram was made in CAD and will not paste into the Word form? Submit it as a separate file using the same naming convention so DAPC can link the two. The mistake is omitting the diagram entirely, which leaves the reviewer unable to understand your process and stalls the review. A common misconception is that a photo of the equipment is enough; Ohio EPA needs a flow diagram, not a picture.
Section II, Line 7: Emissions Egress Point
This line asks where emissions leave your building. You describe each egress point as a stack (vertical unobstructed, vertical obstructed, or non-vertical) or fugitive (door/window, other opening, or no building at all), and give stack dimensions and nearby building data.
Enter the correct egress code and, for stacks, the height, diameter, flow, and temperature, plus the largest nearby building’s dimensions for downwash modeling. For example, a rain-capped stack is coded B (vertical obstructed), and an open roof vent is coded E.
What if a building sits close to your stack? You must report it if it is within five times the stack height, because it affects how the plume disperses. The mistake is coding an obstructed (rain-capped) stack as unobstructed, which throws off air quality modeling and can produce a wrong impact result. Many filers think small stacks never need modeling; if total emissions exceed the thresholds in Engineering Guide 69, modeling is required regardless of stack size.
Section II, Line 8: Request for Federally Enforceable Limits
This line is where you ask Ohio EPA to cap your potential to emit so you can avoid Title V, major New Source Review, or a MACT standard. You attach a sheet listing the proposed limits, the method you will use to prove compliance, and the before-and-after facility-wide potential to emit.
Be specific about the limit and the recordkeeping, for example “hours of operation per 12-month rolling period” tracked in a monthly log. For example, a synthetic minor plant requests a federally enforceable VOC cap of 24 tons per year to stay just under the major-source threshold.
What if you are nowhere near a major threshold? Then you can leave this line blank and skip the extra recordkeeping. The mistake is requesting a limit you cannot actually monitor, because every federally enforceable limit comes with reporting and recordkeeping you must perform monthly. A common misconception is that these limits are penalties; they are voluntary advantages under OAC 3745-31 that keep smaller facilities out of the far more burdensome Title V program.
Section II, Lines 9-11: Monitoring, Portable Source, and the EAC Form
Line 9 asks whether you have continuous emissions monitoring systems (CEMS) that directly measure stack emissions, not parametric monitors like a thermometer. Line 10 asks whether the unit is a portable source designed to move between sites, such as a leased boiler or a stone-crushing plant. Line 11 directs you to attach the right Emissions Activity Category (EAC) form for the unit.
Enter CEMS only if you truly measure emissions, check “portable” only for movable equipment, and pick the EAC that matches your operation, such as the coating, boiler, or material-handling EAC. For example, a leased package boiler checks portable on Line 10 and attaches the external combustion EAC.
What if your unit needs more than one EAC? Attach each one, since some sources span two activity categories. The mistake is attaching the wrong EAC, which gathers the wrong data and forces a do-over. Filers often confuse parametric monitors with CEMS; a temperature gauge is not a CEMS and belongs in the parametric discussion, not Line 9.
The Signature and Certification Page
The last critical piece is the signature page, where a responsible official certifies the application is true and complete. If you file the Word forms by email, you print this page, have the official sign it in ink, and mail it to your DO/LAA. If you file through Air Services, your OH|ID PIN serves as the electronic signature.
The official who signs must have authority to bind the company, such as a president, owner, or plant manager. For example, Tri-State Forge’s plant manager Janet Reyes signs the page and mails it the same day the email application goes out.
What if you forget to send the signed page? For an emailed application, the official receipt date is the date the signed page arrives, not the date of the email, so a forgotten page delays your whole timeline. The mistake is having someone without signing authority sign it, which makes the certification invalid. A common misconception is that the email submission alone counts as filed; it does not until the signature page is received.
Three Filled-Out Examples Using Real Scenarios
Below are three of the most common PTIO scenarios, each following one filer through the form. Use them as templates for your own entries.
Example 1: Carlos Mendez, Auto Body and Coating Shop
Carlos is adding one new spray booth at Buckeye Coatings LLC and needs a PTIO before he installs it.
| Form Section | What Carlos Enters |
|---|---|
| Cover Sheet, Legal Name | Buckeye Coatings LLC |
| Cover Sheet, County | Franklin |
| Section I, Line 1 Reason | New Installation |
| Section I, Line 3 Registration | No |
| Section II, Line 1 Company ID | Spray Booth #1 |
| Section II, Line 2 Equipment | 1 downdraft spray booth, dry filters |
| Section II, Line 4 Emissions | VOC potential 12 tpy before controls; requests allowable 9.9 tpy |
| Section II, Line 6 Diagram | Paint in → booth → dry filter → stack S001 |
| Section II, Line 11 EAC | Surface Coating EAC |
Example 2: Janet Reyes, New Natural Gas Boiler
Janet is installing one new boiler at Tri-State Forge to add process heat capacity.
| Form Section | What Janet Enters |
|---|---|
| Cover Sheet, Legal Name | Tri-State Forge Inc. |
| Cover Sheet, Existing ID (Field 4) | NPDES permit number on file |
| Section I, Line 1 Reason | New Installation |
| Section I, Line 2 Applicability | Notes possible NSPS Subpart Dc, explains heat input |
| Section II, Line 1 Company ID | Natural Gas Boiler B001 |
| Section II, Line 3 Schedule | Install 09/2026, operate 11/2026 |
| Section II, Line 4 Emissions | NOx, CO, PM from fuel-based emission factors with calculations shown |
| Section II, Line 7 Egress | Vertical unobstructed stack, code A |
| Section II, Line 11 EAC | External Combustion (Boilers) EAC |
Example 3: Aisha Okafor, Synthetic Minor Manufacturer
Aisha runs a growing plant at Lakeshore Plastics and wants to cap emissions to stay out of the Title V program.
| Form Section | What Aisha Enters |
|---|---|
| Cover Sheet, Legal Name | Lakeshore Plastics Co. |
| Section I, Line 1 Reason | Modification |
| Section I, Line 4 Confidentiality | Claims resin blend ratios, submits non-confidential copy |
| Section II, Line 4 Emissions | Facility-wide VOC potential 60 tpy uncontrolled |
| Section II, Line 5 Controls | Regenerative thermal oxidizer, OC 98%, basis stack test |
| Section II, Line 8 Federally Enforceable | Requests VOC cap of 24 tpy to avoid Title V |
| Section II, Line 8 Compliance Method | Monthly material usage records, 12-month rolling total |
| Section II, Line 9 Monitoring | Oxidizer temperature parametric monitoring |
| Section II, Line 11 EAC | Plastics/Process and Combustion EACs |
How to File the Completed Application
Ohio EPA gives you three filing channels, and the right one depends on your facility type and how fast you need a decision. Keep proof of whatever channel you use, because the official receipt date sets your processing clock.
The first channel is the online Air Services portal inside the eBusiness Center. You log in with your OH|ID, complete the forms on screen, sign with your PIN, pay the fee by electronic check or card, and submit. The portal gives you a confirmation receipt, which is your proof of filing, and it is the fastest and most accurate route because it checks your entries as you go.
The second channel is email for the Word-based application. You email the collated application to the air application inbox listed in the PTI instructions, with the subject line naming your DO/LAA and county and no body text, then mail the signed signature page to your DO/LAA. You get an automated reply confirming receipt, but remember the receipt date is the day the signed page arrives, so keep the mailing receipt.
The third channel is paper or in person through your DO/LAA or a local air agency such as the Cleveland Division of Air Quality. You mail or deliver the full application and signed certification to the office that covers your county, and you keep a stamped copy as proof.
On fees, Ohio EPA charges based on facility type and emissions. Non-Title V emission fees run from $100 per year for sources under 10 tons per year up to higher tiers, per the Non-Title V Emission Fee Program. Beginning in mid-October 2025, Title V and synthetic minor (FEPTIO) facilities pay a new $5,000 annual base fee, the agency’s first air fee increase in nearly 30 years, as reported by the Ohio Manufacturers’ Association. Confirm your exact fee with your DO/LAA before you pay, since fee tiers depend on your final emissions.
What Happens After You File
Once Ohio EPA confirms your application is complete, the review clock starts. The DO/LAA reviews your application, checks that the source will comply with the rules, and drafts permit terms and conditions, a step that usually takes one to three months depending on the office’s backlog.
The DO/LAA then sends a recommendation to Ohio EPA Central Office, which does a technical review and either issues the permit or sends it back for corrections. For larger or certain sources, Ohio EPA issues a draft permit, publishes a newspaper notice, and opens a 30-day public comment period before issuing the final permit.
When you receive your final PTI or PTIO, you may begin construction. A PTIO lets non-Title V sources operate for up to 10 years and synthetic minor sources for 5 years, while a true PTI allows construction and operation for testing, after which Title V facilities may need a revised Title V permit before normal operation.
Mistakes to Avoid When Filling Out the Application
- Building before the permit is issued. This is an enforcement violation that can force you to stop and remove equipment you already installed.
- Submitting emissions numbers with no calculations. Ohio EPA will deem the application incomplete and the review clock never starts.
- Confusing actual emissions with potential to emit. You can end up with limits you cannot meet during peak production.
- Entering a P.O. Box as the facility address. Ohio EPA rejects it and your file may route to the wrong district office.
- Forgetting to mail the signed signature page. For emailed applications, your receipt date is delayed until the signed page arrives.
- Claiming a control efficiency you cannot prove. Your allowable limit gets set to that efficiency and you must meet it every day.
- Leaving Line 2 applicability blank with no explanation. It guarantees a request-for-information letter and weeks of delay.
- Omitting the process flow diagram. The reviewer cannot understand your operation and stalls the review.
- Attaching the wrong EAC form. The form collects the wrong data and forces you to start that part over.
- Coding a rain-capped stack as unobstructed. It produces a wrong air quality modeling result and a flawed impact analysis.
- Requesting a federally enforceable limit you cannot monitor. Every such limit comes with monthly recordkeeping you must actually perform.
- Sending confidential data by unsecured email. Ohio EPA is not responsible for any breach during email transmission.
Do’s and Don’ts
Do:
- Do call your DO/LAA early, ideally months before construction, because that conversation shapes your permit limits.
- Do show all your emissions math, since calculations are what make an application complete.
- Do use clear in-plant names for each source so the permit is easy to track and enforce.
- Do submit a non-confidential version whenever you claim a trade secret, or the application is not complete.
- Do keep your proof of filing, because the receipt date sets your entire processing timeline.
- Do consider a federally enforceable cap if you are near a major-source threshold, to avoid Title V.
Don’t:
- Don’t break ground before the permit issues, because that is the most common enforcement trigger.
- Don’t guess at ID numbers, since a wrong number links you to another facility’s record.
- Don’t lump identical units together, because each emissions unit needs its own Section II.
- Don’t mark everything confidential, since only true trade secrets qualify and emission rates rarely do.
- Don’t ignore nearby buildings on Line 7, because downwash affects your modeling result.
- Don’t sign with someone who lacks authority, or the certification is invalid.
Pros and Cons of Filing on Your Own vs. With Help
| Filing on Your Own (Pro Se) | Filing With a Consultant |
|---|---|
| Saves consultant fees, a real benefit for a single small source | Costs more, but consultants know which EAC and limits to request |
| You learn your own process and permit deeply, which helps at renewal | Saves your staff time, useful when you lack an in-house EHS person |
| Works well for simple sources like one booth or one small boiler | Worth it for complex sources, modeling, or synthetic minor caps |
| Direct control over your timeline and communications with the DO/LAA | Reduces the risk of an incomplete application and request letters |
| Free help is available from your DO/LAA representative | Strong PTE and applicability analysis can lower your final limits |
FAQs
Do I need a PTI before I start construction?
Yes. A permit-to-install must be issued before you build or modify the source. Installing first is an enforcement violation that can force you to stop work or remove equipment.
Do small businesses like dry cleaners need a permit?
Yes. Dry cleaners, gas stations, and small coating shops routinely need a PTIO because they emit regulated air contaminants, unless a specific de minimis or rule exemption applies.
Do I file a PTI or a PTIO?
No single answer fits all. Most non-Title V facilities now receive a combined PTIO, while Title V facilities get a PTI plus a separate Title V operating permit.
Do I enter the P.O. Box or the street address in the facility field?
No P.O. Boxes are allowed for the facility location. You must enter the physical street address, since Ohio EPA uses it to route and locate your file.
Do I list the owner’s address or the facility address for correspondence?
No, correspondence does not go to the facility. All official letters go to the owner’s mailing address, and invoices go to the billing address you provide.
Do I report actual emissions or potential to emit on Line 4?
Yes, you report both. The table asks for emissions before controls, actual emissions after controls, and your requested allowable, each backed by calculations.
Do I need to attach an EAC form for every unit?
Yes. Each emissions unit needs at least one Emissions Activity Category form, and some units need more than one to cover all their activities.
Do I have to send the signature page separately when I email the forms?
Yes. For emailed Word applications, you print and sign the signature page and mail it, and the receipt date is the day that signed page arrives.
Do federally enforceable limits on Line 8 hurt my facility?
No. They are a voluntary advantage that caps your potential to emit so you can avoid Title V or major New Source Review and their heavier requirements.
Do I qualify for registration status under Line 3?
No, unless you meet all five conditions, including uncontrolled emissions under 5 tons per year for PM, SO2, NOx, and organic compounds, and no NSPS or NESHAP applicability.
Do I have to do air quality modeling for a small stack?
No, not always, but you must if total emissions exceed the thresholds in Engineering Guide 69, regardless of how small the stack is.
Do I include the process flow diagram if I made it in CAD?
Yes. If the CAD diagram will not paste into the Word form, submit it as a separate file using the same naming convention so Ohio EPA can link it.
Do I check “modification” for a like-for-like equipment swap?
Yes, if the swap increases potential emissions. Under OAC 3745-31-01, any change that raises potential to emit counts as a modification even if the equipment looks similar.
Do I need a separate Title V permit after my PTI?
Yes, for Title V facilities. A true PTI covers construction and testing, and Title V sources may need a revised Title V operating permit before normal operation begins.
Related reading
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