Common Title V Questions

When are the applications due?

  • Initial Part 70 applications are due within one year of becoming a major source. 
  • Renewal Part 70 applications are due at least 12 months months prior to the expiration date of the current Part 70 permit.  


Is there a list of Title V sources?

Information on individual Part 70 (Title V) sources may be obtained through Shannon Heafey, Title V Coordinator at 410-537-4433 or Information about multiple sources, or data other than Air Quality permits may also be requested through a Public Information Act (PIA) request.  This request can be submitted to Dan Davis, at


What types of facilities are included?

See COMAR for applicable sources. 


Does Maryland have electronic submittal?

The Department does not have an electronic application at this time, however the application packages are available in Word format.  The Applications are also available in .pdf format on this website.   


How do I become a Synthetic Minor?

Facilities may request a limitation via a federally enforceable permit to construct.  Please contact the Permits Program for further information.  The Permits Program may be reached at 410-537-3230.


What is an Insignificant Activity?  Explain the Exempted Units Section in the Application-

The Department developed a list of emissions units and activities exempt from the permit application in order to lessen the burden of the emissions certification requirements of the Part 70 permit application. This list is called the Insignificant Activity List.  The purpose of the list was not to provide a loophole by which facilities with actual total facility-wide emissions of regulated air pollutants could avoid the requirements of Part 70. The Department generally believes that when emissions from units and activities on the exemption list are quantified, the quantity will not cause a facility to be a major source or that the quantity would significantly change the fees.

There may be cases in which the emissions from the list of exempted units and activities when added to the total facility wide emissions will cause a facility to be a major source. In these cases, the emissions from the units and activities need to be quantified and reported.

In order to reduce the effort a company spends attempting to quantify emissions from units and activities on the exemption list, the Department policy will be to divide the exemption list into two subgroups.

The Department's policy for the exempted unit and activity list is summarized as follows:
  1. If a facility is a major source before considering the emissions from units/activities on the exemption list, the applicant need only to follow the instructions that came with the application form. The emissions from the exempted units/activities do not have to be quantified.
  2. If a facility is not a major source but has a large number of units/activities, the applicant must consider the actual emissions of the these units for applicability of Part 70. If the actual emissions cause the facility to become major, the emissions will be used for fees.


How can I obtain a copy of Maryland's Regulations? 

The Code of Maryland Regulations (COMAR) is available on-line from the Division of State Documents at  For a complete set of the regulations please refer the person making the request to:

Division of State Documents,  PO Box 2249,  Annapolis, MD 21404


What about Asbestos Regulations?

If a source is subject to any asbestos regulations they must be identified in the Title V application, along with the related emissions unit(s) or plant-wide association.


How many copies of the application must be submitted?

The applicant must submit three (3) copies of the permit application to the Department. Two copies must be in paper format, and one on a CD.  If there is confidential information, it must be included in a paper version, and clearly marked confidential.


What in the Permit to Construct is federally enforceable?

Any permit condition that is based on a requirement of the Clean Air Act is a federally enforceable requirement. Generally, the conditions which are not federally enforceable are those which prevent odors or nuisances, or enforce the state air toxics regulations.


Explain the sections of COMAR that are in the State Implementation Plan (SIP).

There are references to sections of COMAR regulations in the State Implementation Plan (SIP) where only part of a regulation has been included in the SIP. Only that portion of a regulation included in the SIP should be recorded in the federally enforceable section of the Title V application.

Where there has been an amendment to a Maryland state regulation included in the SIP for which the amendment has not yet been approved into the SIP, the original regulation is federally enforceable; the amendment is state enforceable only.


Contact Information

For additional information, contact Shannon Heafey at (410)537-4433 or email

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