Assessing the effectiveness of Title V permitting as a compliance tool in Texas

This paper is a study to determine whether the Title V program, as implemented in Texas, fulfills one of the goals of the Clean Air Act. That goal is to provide an effective compliance tool for particular sources (major sources of air contaminants). The study will include a description of elements that are a direct or indirect result of the Title V program including regulations, programs, permit and related documents, enforcement cases and violation data, etc. that will result in measurements or logical arguments to support the claim that the program is an effective compliance tool as compared to any system in place before it. I discuss Title V program elements that appear to detract from the compliance effectiveness, and explore the impact of these elements on compliance determination.