GOA Review Process

What is a General Order of Approval (GOA )?
The Department of Ecology has developed guidelines (WAC 173-400-560) on how a local air pollution authority, such as The Spokane Regional Clean Air Agency, may issue General Orders of Approval (GOA).  These GOAs will cover specific air pollution source categories, and will incorporate conditions that must be followed for an emission unit to be covered under that specific GOA.  The GOA may allow a portable stationary source to operate at multiple locations without having to obtain a new approval each time the equipment is moved, or it may allow all emission units of specific stationary source category to operate under a single GOA, instead of having to apply for a Notice of Construction for each individual emission unit. To download a copy of the GOA form, access the forms section of this site by clicking here.

What is the process for obtaining coverage under an existing GOA?
Applicability Checklist

The Spokane Regional Clean Air Agency either has, or will, developed an applicability checklist for each GOA.  The owner and/or operator that wishes for his or her emission unit to be covered under a GOA  must first complete an applicability checklist to determine whether or not the emission unit qualifies for coverage under the GOA.The applicability checklist contains criteria that the emission unit must meet to be considered for coverage under the GOA.  If the emission unit does not meet all of the criteria listed in the checklist, then it can not be considered for coverage under the GOA.  Just because an emission unit meets the applicability checklist criteria does not mean that it will be covered by the GOA.  It just means that if it does meet all of the criteria, then the owner and/or operator of the emission unit may apply for coverage under the GOA.

Application Form

The application form requests relevant information about the emission unit so that The Spokane Regional Clean Air Agency may consider whether the emission unit meets the conditions of the GOA.  If The Spokane Regional Clean Air Agency’s review reveals information that would disqualify an emission unit from being covered under the GOA, or the application is not complete, then The Spokane Regional Clean Air Agency may deny the application.  If the application form is not complete, then the owner and/or operator may provide the information requested in The Spokane Regional Clean Air Agency’s application denial letter and resubmit it to The Spokane Regional Clean Air Agency for further review.  If a complete application is not ultimately submitted to The Spokane Regional Clean Air Agency, then The Spokane Regional Clean Air Agency is required by law to deny coverage of the emission unit under the GOA.

GOA Coverage Process

1. On the 31st day after The Spokane Regional Clean Air Agency determines that the owner and/or operator of the PASCO(s) has submitted a complete application, coverage under the GOA is in effect, except for those:
   1. PASCOs that have been denied coverage, and
   2. Applications that The Spokane Regional Clean Air Agency has deemed incomplete.
2. The Spokane Regional Clean Air Agency must issue a postmarked letter within 30 days of receipt of the application for those emission units that have been denied coverage under the GOA and for those applications that have been deemed incomplete.  The letter must explain the reason(s) for the denial(s) or identify the areas where the application is incomplete.
3. Thirty one days after The Spokane Regional Clean Air Agency has received a complete application, the owner and/or operator of the emission unit may check The Spokane Regional Clean Air Agency’s website (www.spokanecleanair.org) to see if his or her emission unit has been added to the list of those covered under the specific GOA.  The owner and/or operator of a new emission unit or modification of an existing emission unit that qualifies for coverage under the GOA may not begin actual operations until the 31st day after The Spokane Regional Clean Air Agency receives its complete application for coverage.

What information must be submitted with an application?
The application must be submitted on the relevant GOA application form provided by The Spokane Regional Clean Air Agency.  Because of the variant nature of emission units, where a GOA could be developed, the information requested on the application form would not be the same for every GOA.  Instead, for the most part, the information requested will be specifically relevant to that source category.  However, there will be general information that is needed for any application’s review, such as:· 

• A description of the emission unit, any connected equipment, and its operation,
• Relevant position of the emission unit to the property line,
• Possibly a set of plans that fully describes the proposed source, including distance and height of buildings within 200 feet of the source,
• Either expected or potential annual throughput, or the estimated emissions that will result from the proposal, or sufficient information for The Spokane Regional Clean Air Agency to calculate the expected emissions.

In addition, The Spokane Regional Clean Air Agency may require additional information to demonstrate that the proposed source will meet the regulatory requirements.

Do I need to submit a SEPA Checklist?
No, an environmental checklist is required to be submitted by The Spokane Regional Clean Air Agency during the development of the GOA.  According to the requirements of the State Environmental Policy Act (SEPA), Chapter 43.21C RCW, as long as The Spokane Regional Clean Air Agency does not perform an “action”, then a SEPA is not required.  The Spokane Regional Clean Air Agency has elected to not issue an approval to each applicant.  Instead The Spokane Regional Clean Air Agency has set up its GOA program such that an emission unit is automatically covered under the specific GOA after 30 days from the receipt of a complete application, except if either The Spokane Regional Clean Air Agency rejects the application because it is in complete or if The Spokane Regional Clean Air Agency denies coverage under the GOA.

How does the permit review process work?
The Spokane Regional Clean Air Agency reviews the application to ensure that the source meets all applicable local, state and federal air pollution regulations, including, but not limited to New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPS) and Prevention of Significant Deterioration (PSD). The Washington State regulation for air contaminant sources also requires that new sources implement the Best Available Control Technology (BACT), and in some cases, the Lowest Achievable Emissions Rate (LAER).  However, an emission unit required to meet LAER would not be allowed to be covered under a GOA .

Coverage under a GOA is automatic on the 31st day after The Spokane Regional Clean Air Agency receives a complete application, except when:

1. Coverage under the GOA  has been denied, and
2. The Spokane Regional Clean Air Agency has deemed and applications incomplete.

The Spokane Regional Clean Air Agency must issue a postmarked letter within 30 days of receipt of the application for those emission units that have been denied coverage under the GOA and for those applications that have been deemed incomplete.  The letter must explain the reason(s) for the denial(s) or identify the areas where the application is incomplete.

After 31 days the owner and/or operator of the emission unitmay check The Spokane Regional Clean Air Agency’s website (www.spokanecleanair.org) to see if his or her emission unit has been added to the list of those covered under the GOA.  The owner and/or operator of a new emission unit or modification of an existing emission unit that qualifies for coverage under the GOA may not begin actual operations until the 31st day after The Spokane Regional Clean Air Agency receives its complete application for coverage.

The owner and/or operator of the covered emission unit may be required to keep records and present them to The Spokane Regional Clean Air Agency staff upon request. 

The owner and/or operator of an emission unit covered under a GOA must keep sufficient information to prove that his or her emission unit is covered.  Satisfactory evidence may include a printout of the list of covered businesses from The Spokane Regional Clean Air Agency’s web site.

The owner and/or operator of a covered emission unit must register each emission unit with The Spokane Regional Clean Air Agency and pay an annual registration fee for each emission unit, under common ownership or operation, that is covered.

How long does the review process take?
After The Spokane Regional Clean Air Agency receives a complete application, an owner and/or operator of a covered emission unit must wait 30 days before the emission unit can be installed or in the case of a portable source be operated.  On the 31st day except as described above, the owner and/or operator of the emission unit may check The Spokane Regional Clean Air Agency’s website www.spokanecleanair.org to see if his or her emission unit is listed as covered under the applicable GOA.

How much will the General Order of Approval cost?
Presently, there is no filing or review fee for a application for coverage under a GOA; however, future revisions to The Spokane Regional Clean Air Agency’s Fee Regulation (Article X) will most likely be revised to include these fees.  It is expected that the filing fee would be the same as that required for a Notice of Construction, which is presently $150 fee which must be submitted with the application. As far as the GOA review fee is concerned, it is expected that it will be a either flat fee, or one based on an hourly rate.