Title V of the Clean Air Act (Act) requires major air emission sources to obtain a federal operating permit that includes all applicable emissions limitations and regulations. The Act allows the issuance of Title V permits for numerous similar sources under one general operating permit (GOP). A project for industry to partner with the Texas state regulatory agency to develop a GOP for oil and gas sources was funded by American Petroleum Institute (API). The advantages of GOPs for the regulatory agency and industry are: 1) Economy - A single proposed GOP, not individual applications, is subjected to public notice and comment. 2) Consistency - Facilities with identical equipment have identical permit terms. 3) Certainty - GOP applicants know what the permit terms will be since the permit was negotiated prior to the call for applications. Additionally, a survey was conducted to identify potential states to be targeted in a second phase of the project. This paper will discuss the mechanics of how the GOP was developed, some unique features of the Texas GOP and lessons learned that can be applied to development of GOPs in other states.

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