National Clothesline

The Environmental Protection Agency announced plans to permanently exempt drycleaners from requirements for Title V permits under the Clean Air Act.

Over the past few years, cleaners have been temporarily exempt from obtaining Title V permits, a process that can be both costly and time consuming. The temporary deferment expired in December, 2004, and, without the permanent exemption EPA proposed in March, cleaners could have faced the full force of the Title V burden. Trade association leaders have been working with EPA over the past few years to gain the permanent exemption and were gratified when the announcement finally came.

“EPA has finally gone on record with its proposal to exempt area source drycleaners from Title V permitting,” IFI said in notifying its members. “We’ve been working with EPA on this issue for a long time and provided critical information that helped the agency formulate its final proposal.”

The agency will be taking comments on its proposed exemption until May 25. Drycleaning is one of five industry groups included in the proposal. The others are halogenated solvent degreasers, chrome electroplaters, ethylene oxide sterilizers and secondary aluminum smelters.

EPA gave three broad reasons for exempting drycleaners: the regulatory burden; the costs associated with Title V permitting; and the expectation that such permits would not improve compliance.

EPA noted that drycleaners typically are very small establishments and have limited technical and economic resources.

“Unlike the larger major sources, drycleaners would typically have no staff trained in environmental requirements and would find it difficult to hire outside professionals to help them understand and assure compliance,” EPA said.

Second, EPA cited the cost of obtaining the permits.

“Even if costs for drycleaners were only half the average cost for a major source, the costs would still represent an excessively high percentage of sales for the average drycleaner,” EPA noted.

Nor does EPA believe that Title V permitting would improve compliance with the Clean Air Act.

“Permitting is not a necessary element for achieving high levels of compliance with the NESHAP for area sources when states have other options available to them, such as inspection and oversight programs,” EPA said.

EPA noted that based on its outreach programs, most state and local agencies report high level compliance rates among cleaners without Title V permits.

Requiring drycleaners to obtain permits would place a burden on the regulatory system itself, EPA also noted.

Currently there are about 18,000 major sources subject to Title V permitting. Including drycleaners would add another 30,000 to the roles.

“In some jurisdictions, the number of drycleaners needing permits would dwarf the current Title V sources universe,” EPA said. In one example, EPA noted that in Sacramento County there are 15 Title V sources; including the drycleaners there would create an additional 400 major sources to be regulated.

“Resources to permit area source drycleaners would likely compete with the resources needed for the permitting of major sources,” EPA said.