US · Expiry & renewal tracking
File every Title V permit renewal on time
A Title V operating permit runs for a fixed term of 5 years for affected sources and at most 5 years for others (40 CFR 70.6(a)(2)). The renewal application is timely if filed at least 6 months, and never more than 18 months, before expiry (40 CFR 70.5(a)(1)(iii)); otherwise expiry ends the right to operate.
Title V of the Clean Air Act is carried out through State operating permit programs that must meet the minimum elements in 40 CFR part 70 (40 CFR 70.1(a)). These programs must cover, among others, every major source, sources subject to certain standards under sections 111 and 112 of the Act, and affected sources under the acid rain program (40 CFR 70.3(a)).
The permitting authority issues permits for a fixed term of 5 years for affected sources, and for a term not to exceed 5 years for all other sources. Permits for certain municipal waste combustion units may run up to 12 years but must be reviewed at least every 5 years (40 CFR 70.6(a)(2)).
For renewal, a timely application is one submitted at least 6 months before the permit expires, or an earlier date approved by the EPA Administrator that makes sure the permit does not expire before renewal, but never more than 18 months before (40 CFR 70.5(a)(1)(iii)). Permit expiration ends the source's right to operate unless a timely and complete renewal application has been submitted (40 CFR 70.7(c)(1)(ii)). Renewals go through the same procedures as a first permit, including public participation and review by affected States and EPA (40 CFR 70.7(c)(1)(i)).
At a glance
| Rules | 40 CFR 70.5, 70.6 and 70.7 (State operating permit programs) |
|---|---|
| Permit term | Fixed 5 years (affected sources); not more than 5 years (others) |
| Renewal application | At least 6 months before expiry |
| Earliest required date | Never more than 18 months before expiry |
| Timely and complete application | Operating without a permit is not a violation until final action |
| Final action | Within 18 months after a complete application |
Part 70 sets the minimum elements of State operating permit programs; States may set additional or more stringent requirements (40 CFR 70.1(a) and (c)).
Who is responsible?
The owner or operator of the source must submit a timely and complete permit application (40 CFR 70.5(a)), and a responsible official must certify the information submitted (40 CFR 70.5(a)(2)).
If the deadline passes
Permit expiration terminates the source's right to operate unless a timely and complete renewal application has been submitted (40 CFR 70.7(c)(1)(ii)). If one has, the source's failure to have a permit is not a violation until the permitting authority takes final action. This protection ends if the source misses the written deadline for additional information the authority requests (40 CFR 70.7(b)).
Other Title V dates to track
The permit requires reports of any required monitoring at least every 6 months (40 CFR 70.6(a)(3)(iii)(A)) and compliance certifications at least annually, or more often if the permit says so (40 CFR 70.6(c)(5)(i)). Monitoring data and support information must be kept for at least 5 years (40 CFR 70.6(a)(3)(ii)(B)).
Tracking it with ExpirySuite
- Add each Title V permit with its expiration date.
- Add a second record for the renewal-application deadline in your permit (at least 6 months and up to 18 months before expiry), so you are reminded before that date as well.
- Reminders arrive 60, 30, 14, 7 and 1 day before the due date and on the due date itself.
- Add the semiannual monitoring reports and the annual compliance certification as separate items.
- Assign a responsible person (for example your environmental manager) so the right person gets the reminder.
- If a date passes, managers get overdue reminders 3, 7 and 14 days later.
- Upload the renewal application confirmation and the new permit, or ask a consultant to send them through a secure upload link, valid for 14 days; no account is needed.
Frequently asked questions
- How long is a Title V permit valid?
- A fixed term of 5 years for affected sources and not more than 5 years for other sources (40 CFR 70.6(a)(2)).
- When must the renewal application be filed?
- At least 6 months before expiry, or an earlier date approved by the EPA Administrator, but never more than 18 months before (40 CFR 70.5(a)(1)(iii)). Check your permit for the exact date.
- Can we keep operating if the permit expires during renewal?
- Only if a timely and complete renewal application was submitted. Otherwise, expiration terminates the right to operate (40 CFR 70.7(b) and (c)(1)(ii)).
- How long does the permitting authority have to decide?
- State programs must provide for final action within 18 months after receiving a complete application, or a shorter time approved by EPA (40 CFR 70.7(a)(2)).
Sources
- eCFR: 40 CFR 70.5, Permit applications
- eCFR: 40 CFR 70.6, Permit content
- eCFR: 40 CFR 70.7, Permit issuance, renewal, reopenings, and revisions
- eCFR: 40 CFR 70.1, Program overview
- eCFR: 40 CFR 70.3, Applicability
Last checked: Sep 30, 2026 · This page summarises official sources for general information and is not legal advice. Check the linked sources for current rules and fees.
Made for title V air operating permit (EPA) (US)
A ready template for title V air operating permit (EPA) (US) with sensible validity defaults, so you enter less and track more.
Reminders on time
Email alerts at 60, 30, 14, 7 and 1 day before each title V air operating permit (EPA) (US) expires, plus overdue escalation to managers.
Assign an owner
Give each title V air operating permit (EPA) (US) an owner and let employees update their own via a secure link — no login needed.