Texas Natural Resource Conservation Commission Interoffice Memorandum To: Distribution From: Jeanne Philquist, Manager, Compliance Section, Air Quality Enforcement Division Bill Zeis, Senior Staff Attorney, Legal Services Division Date: September 20, 1994 Subject: Enforcement Policy on Standard Exemptions This memo is to document agreements reached during our August 23, 1994 meeting among the Directors of New Source Review, Permitting, Air Quality Enforcement, members of their staffs and representatives of Legal Services, Field Operations and the Small Business Advocate's Office. The issue being considered was the agency's policy on treatment of facilities that: 1) were constructed under standard exemptions that required registration at the time of construction; and 2) met all the conditions of the original standard exemption, except the owner/operator failed to register the facility at the time of construction and 3) the standard exemption since has been revised to become more stringent. It was agreed that the owners/operators of such facilities may achieve compliance by submitting the registration form that was originally required. The agency will not require that such facilities meet the more stringent requirements now in effect, provided the facility was constructed in compliance with all of the substantive provisions of the original exemption except for the registration requirement. Please let me or any of the meeting participants know if you have any questions or need additional information. cc: Air Program Managers Debra Barber, Air Program Director, Field Operations Division Kerry Drake, Manager, Small Business Assistance Program August 23, 1994 Meeting Participants Compliance Staff