We’re leading an all-out national mobilization to defeat the climate crisis.

Join our work today to help us build a thriving and just clean energy future. 


We’re leading an all-out national mobilization to defeat the climate crisis.

Join our work today to help us build a thriving and just clean energy future. 

Accelerating the Clean Air Act's Innovation Engine

Opportunities to Reform Air Permitting Programs to Scale Up Clean Technology

Download the full report now.


For decades, Clean Air Act (CAA) air permitting programs have regulated harmful air pollution from industrial and power facilities. Congress designed the air permitting system to protect communities from local pollution and adopt cleaner technologies over time. However, the program is being held back by decades-old guidance documents that slow down progress. These documents allow industry to make minor improvements using older pollution controls, rather than using the truly clean technologies available today.


This report offers the Environmental Protection Agency (EPA) actionable recommendations to develop appropriate compliance plans that reduce pollution and can serve as the foundation for further federal efforts. It also provides state and local air permitting authorities a list of actions they can immediately take to simultaneously address air permitting concerns in overburdened communities alongside EPA. 



The Inflation Reduction Act (IRA) has supercharged zero-emission technologies; now it’s time for the air permitting programs that cover nearly every big pollution source to scale up clean technology everywhere. Ensuring air permit writers, who control these polluting facilities, can require zero-emission technologies will also help respond to urgent calls from environmental justice advocates to end the unfair pollution burden on low-income communities and communities of color. By combining IRA investments with modernized CAA tools, we can accelerate positive change at facilities nationwide and address the racist and classist pollution burdens too many still face.




What's Inside

Understanding—and—Fixing Air Permitting

    • Fundamentals of Air Permitting
    • What's Gone Wrong


    • Close Permitting Loopholes
    • Makes Clear That Clean Technology Must Be Required in Permits
    • Make it Easy to Identify Clean Technology
    • Increase Public Transparency
    • Prioritize Addressing Local Impacts

Technical Permitting Overview

    • Air Permitting Requirements
    • Climate Programs and Air Permitting
    • Environmental Justice Initiatives Related to Air Permitting
    • Civil Rights (Title VI) Requirements in Air Permitting

Flaws in Air Permitting—Technical Specifics and Examples

    • Loopholes Allowing Avoidance of Triggering Program Requirements
    • Insufficient Consideration of Clean Technologies
    • Reliance on Outdated and Insufficient Review Approaches
    • Inadequate Cost Evaluations
    • Dependency on Resource Intensive Enforcement Actions
    • No Clear Regulatory Mechanism to Address Adverse Impacts

Upcoming Actions Heightening the Need for Reform

    • Updates to Federal Ambient Air Quality Standards
    • Pending Federal and State Standards for Power

Technical Reform Recommendations

    • Recommended EPA Action
    • Recommended Local Action

State and Local Exemplar Reforms

    • California
    • New Jersey
    • New York