Permit Management System

A. Definition of stationary sources

Air pollution sources refer to physical or chemical operating units that emit air pollutants, roughly divided into two categories: stationary sources and mobile sources. Stationary sources are pollution sources that do not change their location due to their own power, including factories, chimney emissions, in-plant emissions, dust emissions from construction, and open burning. From power plants to small individuals using sprays, as long as they emit air pollutants, they are regarded as stationary sources regardless of their size.

B. Promotion history

Taiwan has been implementing air quality management since the 1990s, for example, introducing air quality zone management, implementing counties and cities air pollution prevention plans, and promoting various administrative control measures, simultaneously supplemented by economic incentives to reduce pollution in public and private premises. To achieve the management strategy of the prevention of newly established sources and the continuous improvement of established sources, preventive management system was built up, including regulating the installation of stationary sources, verifying stationary sources before operation which facilitates the follow-up management. The draft amendment to the Air Pollution Control Act in 1987 introduced the Permit System from the United States which had been adopted for many years and had considerable control effects. The system required public and private premises to honestly report pollution status before installation and operation. The installation and operation will be permitted after verification and certification. In addition, the relevant equipment and records must be operated in accordance with the approved permit content, and the environmental protection unit shall conduct the inspection of the permit content accordingly.

Before the Permit System was promoted, many related operations were carried out separately. For example, in August 1988, the Ministry of Economic Affairs announced the implementation of the "Key Points for Pollution Prevention Verification of Newly-Established Factories", which stipulated that principal of new or expanded sources must submit a pollution control plan through the technician visa and permit registration verification. In order to promote the Permit System, it was necessary to obtain information on the current state of sources across the country, which benefited the management of sources in batches. The Environmental Protection Administration of Executive Yuan (EPA) had promoted the "Expanded Management of Stationary Sources Supervision and Improvement Plan" in July 1989. The number of public and private premises has been expanded from 200 to 5,000. They were required improvement to comply with the stricter emission standards year by year. Furthermore, with promotion of data digitization, database of source equipment, control equipment and current emissions in public and private premises was established.

Pursuant to Article 14 Item 3 of the Air Pollution Control Act of the Republic of China, the central competent authority is authorized to formulate the "Stationary Pollution Source Installation and Operating Permit Management Regulations" (abbreviation as the Permit Regulations). After referencing the permit regulations of Bay area and South Coast Air Quality Management District, amendments were revised through six article consultation meetings, three public hearings, and the opinions from all parties and sent to the Executive Yuan in February 1993. Then the amendments were passed in April and finally implemented on May 7. Its contents were divided into general rules, application, issuance and management of installation and operating permits, and supplementary articles. However, the overall permits management regulations had been revised 7 times in 1997, 1999, 2001, 2003, 2007, 2017 and 2019 in response to the adjustment of various control strategies.

C. Permits management of batches

Due to the large number of public and private premises under management across the country, priority of industries was selected considering the work load of the competent authority. According to Article 24 of the Air Pollution Control Act with the manufacturing process and the types of pollution sources, priority has been given to the designation of major pollution sources since 1993, including the electric power industry, petrochemical industry, steel industry, electric arc furnace industry, cement industry and non-ferrous metal manufacturing industry. These industries were included in the announcement of the categories of installation, modification and operation permits in batches and phases. As of March 2, 2021, 8 batches of 89 industries and 390 manufacturing processes have been announced continuously. In other words, a total of nearly 8,000 public and private premises have been included in the permit system.

D. Application of permits

Stationary pollution sources in public and private premises that are required to apply for permits after the designated announcement should fill in the application form with the relevant documents before the installation, and submit the permits application to the competent authority. The sources can only be set up or operated after the approval of the competent authority and the issuance of the permits with paying the examination fee and certificate fee. Among them, the installation permit application for newly established pollution sources are demanded with technician visa and control equipment for sources to build up the permit management regulation.

Public and private premises should check relevant documents when applying for permits. Taking operating permits as an example, they mainly include relevant certification documents approved by the competent authority for registration or approval of operations, technician visas, air pollution control measures instructions, air pollution emission analysis plans, etc. The contents of air pollution control measures include control objectives, environmental location diagrams, plant layout diagrams, production process flow chart, raw materials, fuels and product quantities, material transportation, storage, stacking methods, the species, composition, concentration and emission amount of the air pollutants, the efficiency of the control equipment, information of the processing equipment and emission pipeline. In addition, after the competent authority has approved the air pollution emission analysis plan and notified the emission test, an air pollutant emission analysis report which meets the emission standards shall be submitted.

In order to coordinate with the integration of permit baseline data for the flow management of air, water, waste, and poison pollution sources, the application of the installation, modification and operation permit of air pollution sources would be accepted online, which were promoted in two stages; The first stage involved the first category of stationary pollution sources for permit online, and the second stage included for the second category of stationary pollution sources online as well. After the implementation of the online application for permits, the application information was available for industry operators for the purpose of search and use. Furthermore, the permit website also provided the functions of preliminary verification data and progress status, which was combined with the EPA's air, water, waste, and poison management information system to provide further information for the industry.

E. Verification of permits

Before applying, public and private premises should check the stationary pollution sources and related facilities. All stationary pollution sources corresponded with the announcement for applying necessary installation and modification should submit the form and assessed if processing units follow the future emissions regulation. The applications from public and private premises will be verified by the environmental protection bureau of each county and city. In addition, to promote the development of the industry, the EIA competent authorities entrusted by EPA also carry out the verification load of stationary pollution sources permits. Five units have been entrusted to verify efficiently the permits so far, including the Science Park Administration, the Tainan Science Park Administration, the Export Processing Zone Administration Office and its branches, Central Science Park Administration, and the Pingtung Agricultural and Biological Park Administration.

  1. (1) Verification of installation permits
    After the public and private premises submitting the application documents, the verification agencies shall complete the formal verification within 7 days and notify the premises to submit the substantive verification within 35 days after the paying the verification fee. The substantive verification period of the first category of stationary pollution sources may be extended by 15 days; for those who need to verify the best available control technology or model simulation specifications, the period may be extended by 45 days. If the application documents are found with irregular form or lacking information, the verification agencies shall notify the deadline for correction immediately. Three times for correction are available if the corrections are still irregular or the content is lacking. The number of days for each correction is not included in the verification period, and the total number of days for formal and substantive verification should not exceed 14 and 90 days, respectively. The application shall be rejected if the corrections are not able to be done and the verification & certification fee are not paid by the deadline. Public and private premises should receive the installation permit in 14 days since the verification passed.
  2. (2) Verification of operation permits
    After the public and private premises submitting the application documents, the verification agencies shall complete the formal verification within 7 days and notify the premises to submit the substantive verification within 35 days after the paying the verification fee. For those who pass the substantive verification, the agencies shall notify the public and private premises to conduct a test run or air pollutants emission test. The substantive verification period of the first category of stationary pollution sources may be extended by 30 days; for those who need to verify the best available control technology or model simulation specifications, the period may be extended by 45 days.
    If the application documents and emission test report are found with irregular form or lacking information, the verification agencies shall notify the deadline for correction immediately. Notification will be delivered again if the corrections are still irregular or the content is lacking. The number of correction days shall not be included in the verification period, however, with a total number of 90 days as a limit. The application shall be rejected if the corrections are not able to be done and the verification & certification fee are not paid by the deadline.
    Public and private premises should receive the operation permit in 14 days since the verification passed. If the applicant applies for an operation permit in accordance with Article 24 of the Air Pollution Control Act, he/she should submit the registration or operation permit documents verified by the EIA competent authorities, and receive the operation permit from the verification agency.

F. Management and issuance of permits

With the promotion of the permit regulations, as of February 28, 2021, more than 95% of particulate pollutants (except for construction projects and road dust emissions) and more than 96% of sulfur oxides and nitrogen oxides and 80% of volatile organic compounds emitted from stationary pollution sources across the country are under management in the system, including 7,987 public and private premises with a total of 11,539 permits.

G. Permits check

After public and private premises obtaining the permits for stationary pollution sources, they shall operate in accordance with the contents in the permits. To ensure no violation of the pollution sources, the environmental protection units shall conduct permit check annually for the pollution sources with the permits. Check list includes daily operation and maintenance of pollution sources, records and process operation verified in the permits.

To comply with the regulations, the industries has made dedicated to maintain the operation of equipment. Due to the permit check, public and private premises prefer promotion of self-management and continuous improvement to perfunctory response to audit. The improvement also laid a solid foundation for total quantity control.

H. Future plan

A complete set of control modes for stationary pollution sources has been established since promotion of permit system in 1993. However, due to the air quality in some areas affected by topographical and climatic factors, national air quality improvement goals are hard to achieve with diffusion issues and recent regulatory tools. Therefore, the amendments of the Air Pollution Control Act revised in 1999 added regulations of the total quantity control in class 3 control regions. These regions were required to obtain sufficient trade-off for exceeded pollution, reduce the pollution of mobile sources, or street cleaning for extra allowable emissions. In response to approving pollution sources conditions as the last control tool of the overall air quality management strategy, the permit regulations will be appropriately revised. The directions for future work as follows:

  1. (1) Promotion of integrated regulations of emission management
    The permit regulations are the foundation of prevention management of pollutions. Potential maximum emissions set as the declared emissions of stationary pollution sources. However, some public and private premises were found with duplicate declaration issues. Therefore, in the future, the regulations of emissions control will be integrated and revised. Moreover, to effectively implement the overall management, the complete control regulations of hazard air pollutants will be involved in the permit regulations as well.
  2. (2) Strengthening the audit and control operations
    To ensure pollution sources following the related regulations, the competent authorities check the operating conditions of pollution sources with the permits. According to the investigation of check results, the content of permit is not corresponded to the actual usage of raw materials and fuels. Furthermore, changing of processing equipment and control equipment is not submitted as the modification application, which displays the insufficient awareness of stationary pollution sources to related regulations. Thus, advocacy control regulation and check operation should be improved to prompt the industry operators follow the regulations. At the same time, to implement the spirit of pollution prevention management, quality control such educational training, supervision and technical enhancement of management for auditors is the necessary work in the future.
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