The OCS permit application process begins when a project sponsor determines that a proposed activity is likely to require an OCS permit and, after initial consultation, notifies EPA of its intent to file an application (if the project is within 25 miles of the state’s seaward boundary). Per the OCS permitting implementing regulations at 40 CFR Part 55, the Notice of Intent (NOI) target date is no earlier than 18 months before a permit application is submitted. For FAST-41 purposes, EPA projects this milestone and all subsequent project milestones ahead of the receipt of the NOI and works with the permit applicant to refine these milestones as the project moves through the OCS permitting process.

The permit application must demonstrate compliance with all applicable requirements before it is submitted to the air permitting authority. Those requirements are stated in 40 CFR Part 55, which include but are not limited to, New Source Review (NSR) permitting, title V permitting, New Source Performance Standards (NSPS), National Emissions Standards for Hazardous Air Pollutants (NESHAPs) and any applicable state and local requirements.

Ahead of this milestone, EPA and the project developer conduct pre-application meetings as necessary to identify data and information needs, applicable OCS permitting requirements (e.g., air pollution control requirements, air quality modeling requirements) and policy issues for the proposed project. It is recommended that preapplication meetings start to occur 9 months ahead of this milestone’s target date. The air quality modeling protocol required as part of the permit application submittal is recommended to be sent to the permitting authority 6 months prior to this milestone.

In accordance with 40 CFR 124.3(c), EPA notifies the permit applicant whether the permit application is complete or incomplete within 30 days after receiving such application. If incomplete, EPA will ask the permit applicant to submit any additional information necessary to make the permit application complete.

Once the permit application addresses all EPA requirements, EPA will send a letter in writing to the permit applicant confirming that the permit application is complete. The milestone will be checked (on the dashboard) when completeness is confirmed.

The target date for this milestone is one year after the date EPA determines that the OCS air permit application is complete. This milestone also reflects timely receipt of BOEM’s Record of Decision (ROD) for the project, which must occur prior to issuance of a final permit. EPA generally estimates final permit issuance will occur 90 days after BOEM’s ROD issuance.