Flexible Air Permitting Pilot Evaluation Report

In 2000-2003 Ross & Associates provided policy evaluation and analytic support to a partnership between EPA’s Office of Policy Analysis and Review (OPAR), Office of Air Quality Planning and Standards (OAQPS), and Office of Policy, Economics and Innovation (OPEI) to conduct a comprehensive evaluation of the implementation experience with innovative flexible air permits. Ross & Associates facilitated and supported a cross-EPA evaluation team that reviewed six pilot permitting projects. Ross & Associates managed all aspects of the evaluation, including writing and preparation of the resulting evaluation report, Evaluation of Implementation Experiences with Innovative Air Permits: Results of the U.S. EPA Flexible Permit Implementation Review. The evaluation was cited by the DC Circuit Court of Appeals as key evidence in the court’s decision to uphold EPA’s rulemaking related to Plantwide Applicability Limits (PALs). In addition, the evaluation has provided a foundation for the development of EPA’s flexible air permitting rulemaking activities. Ross & Associates provided additional services to support EPA activities to disseminate and diffuse flexible air permitting approaches through development of materials and training workshops.