Identify Issues In Draft Permit Application

---
name: identify-issues-in-draft-permit-application
task_id: environmental-esg/identify-issues-in-draft-permit-application
description: Guides preparation of a Title V permit application issues memorandum by identifying legal, technical, and data deficiencies in a draft application that could result in agency rejection, permit conditions adverse to the facility, or compliance risk.
activates_for: [planner, solver, checker]
---

# Skill: Identify Issues in Draft Title V Permit Application for Specialty Plastics Manufacturing Facility

## 1. Subject-matter triage

- Treat the draft application as a regulated filing package, not a standalone form.
- Separate what is required by the permit application rules from what is only helpful background.
- Identify whether the package involves one source, multiple emission units, or multiple regulatory pathways; if only one pathway is actually in scope, say so expressly before analyzing.
- Prioritize issues that could drive rejection, incomplete-submission findings, adverse permit conditions, or incorrect source-status classification.

## 2. Failure modes the skill is correcting

- Baseline reviews the application form without cross-checking against the supporting technical record and regulatory summary to identify inconsistencies and technical deficiencies.
- Baseline does not assess whether the corporate organization chart has been used to identify the correct responsible corporate entity for certification and compliance purposes.
- Baseline treats the application as a standalone document rather than measuring it against the governing air permitting requirements that define what must be disclosed.
- Baseline omits the compliance monitoring and testing plan as a source of inconsistency with the application’s emission-limit representations.
- Baseline describes a defect but does not tie it to the governing rule, the interacting document, and the practical consequence.
- Baseline fails to distinguish defects that are purely clerical from defects that may change source status, applicable requirements, or permit limits.

## 3. Legal frameworks / domain conventions that apply

- Title V operating permit requirements under Clean Air Act Title V and implementing state permitting rules govern completeness, disclosure, and certification.
- The application must identify each applicable requirement for each relevant emission unit, including monitoring, recordkeeping, and reporting obligations.
- Responsible Official certification must satisfy the applicable air permitting definition; corporate structure and authority documents control who may certify.
- Emissions calculations must be documented with clear methodology, input assumptions, and control assumptions; errors may affect potential-to-emit, major source status, and fee or applicability determinations.
- Compliance certification must disclose compliance status for each applicable requirement and identify any deviations or unresolved noncompliance where required by law.
- RACT analysis, where applicable, must be supported by source-category-specific technical analysis and reflected consistently across the application package.
- State-specific air permitting rules may add more stringent or more detailed requirements than the federal Title V minimum.
- The controlling authority for each issue should be named at the point of analysis; do not state a rule-based conclusion without citing the rule, statute, or regulation supporting it.

## 4. Analytical scaffolds

- Review the application form against the regulatory requirements summary: identify every required element that is missing, internally inconsistent, or insufficiently supported.
- Cross-reference emission calculations against the technical support materials: test throughput, emission factor, control efficiency, and operating-hour assumptions for consistency.
- Review the compliance monitoring and testing plan against the application’s limits and representations: flag mismatches in parameter selection, frequency, or method.
- Review the RACT discussion against the emission-unit inventory: determine whether each potentially applicable unit was analyzed and whether the conclusion follows from the technical record.
- Review the corporate organization chart and certification pages together: verify that the named certifier fits the responsible-official definition and has authority to sign for the facility.
- Review the cover letter and narrative summaries against the application form and technical attachments: flag any characterization that narrows, expands, or redefines the source beyond the operative forms.
- Review the package as a set of interacting documents: if one document corrects or contradicts another, identify the conflict and state which document should be conformed.
- For each issue, state: the application section, the governing authority, the deficiency, the document interaction, the downstream consequence, and the recommended correction.
- Where an issue involves a quantity, limit, or threshold in the source documents, anchor the analysis to that figure rather than using abstract language.
- If multiple emission units, pollutants, periods, or regulated programs are implicated, analyze each separately rather than collapsing them into one generalized point.

## 5. Vertical / structural / temporal relationships

- Emission calculation → potential-to-emit → major source status: calculation errors can change whether Title V applies and can alter the scope of required disclosures.
- Applicability determination → monitoring and testing obligations: an incomplete applicability analysis can omit required monitoring, recordkeeping, or reporting terms.
- RACT analysis → applicable requirements list: a weak RACT conclusion can leave required limits or controls out of the application.
- Corporate authority → certification validity → filing completeness: a defective certifying officer designation can make the application vulnerable to rejection or resubmission.
- Federal baseline → state-specific overlay: the more stringent rule controls for the affected aspect of the application.
- Technical attachment → form entry → narrative summary: inconsistencies among these layers are often the fastest route to an incomplete or misleading filing.

## 6. Output structure conventions

- Draft the deliverable as an issue memorandum with a short executive summary, a grouped issue analysis, a compact issues table, and a final recommended actions section.
- Define one ordinal severity scale at the top and apply it uniformly to every issue entry; use the same labels throughout.
- For each issue entry, include: severity, application section, governing authority, deficiency, linked document or schedule, consequence if not corrected, and recommended fix.
- Make the consequence concrete: identify whether the risk is rejection, permit condition tightening, compliance exposure, delayed issuance, or inaccurate source classification.
- Do not rely on conclusory labels alone; every legal conclusion must be tied to the cited authority.
- End with an explicit Recommended Actions section that assigns the action to the relevant role and gives a timing anchor tied to the filing or resubmission milestone.
- Use industry-conventional memorandum headings rather than mirroring any hidden checklist language.
- Keep the memo focused on operative defects and revision priorities; avoid background exposition that does not advance the correction plan.