Supporting Aerospace Innovation: Air Permitting Solutions for a Rapidly Evolving Industry

The successful splashdown of Artemis II marked a historic moment for humanity, showcasing what we can achieve when we work together. From Mission Control in Houston, Texas, to the countless teams across the globe, this mission exemplified the power of collaboration, innovation and shared purpose. As we look back on this incredible achievement and forward to the next steps in space exploration, the aerospace industry continues to grow—creating new opportunities for advanced manufacturing, propulsion testing and cutting-edge technologies here on Earth.

Aerospace Growth is Driving New Air Permitting Needs

The aerospace sector is expanding rapidly, fueled by increased commercial spaceflight, defense modernization, advanced manufacturing and the development of new propulsion systems. With this growth comes a complex regulatory landscape. Aerospace operations often involve specialized processes, such as engine and thruster testing, fuel handling, coating operations and high-energy combustion systems, that require careful evaluation under federal, state and local air quality regulations.

Facilities may require different permitting approaches depending on the scale and nature of their operations. Some projects may qualify for streamlined permitting pathways, while others require more complex construction permits, emissions modeling or regulatory negotiations.

For example, the Texas Commission on Environmental Quality’s (TCEQ) Air Permit by Rule (PBR) 106.224 offers a streamlined pathway for aerospace manufacturing facilities to operate efficiently while maintaining compliance with air quality regulations. Companies operating in Texas would benefit from reviewing the eligibility criteria early to establish a permitting strategy that delivers compliance without sacrificing schedule.

State-level approaches can also vary significantly and may materially affect project design and permitting strategy. In some jurisdictions, emission calculation methodologies are more conservative than others and can drive applicability determinations that may not align with actual operating conditions.

For example, in Oklahoma, certain air permitting applicability determinations for intermittent or short-duration testing scenarios, such as rocket or thruster firing events, may require emissions to be evaluated on a continuous-operation basis (i.e., assuming 8,760 hours per year), even if actual operation is limited to brief, infrequent test events such as 15 seconds once per week. In addition, these applicability determinations are often required to be performed on an uncontrolled basis before considering any emission control equipment.

These types of jurisdiction-specific interpretations can significantly influence permitting strategy, emissions calculations and facility design decisions. As a result, early-stage regulatory planning is critical to avoid redesigns, delays or unexpected permitting triggers later in the project lifecycle.

Certain operations common in aerospace manufacturing such as chromium anodizing may trigger federal hazardous air pollutant standards under EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAPs), such as requirements found in 40 CFR Part 63, Subpart N. While not a permitting program itself, these federal standards can impose emission limitations, as well as control requirements and compliance obligations that must be evaluated alongside state air permitting requirements during project development.

Early planning and experienced technical support are essential to keep projects on schedule. To avoid costly delays, take these key actions:

• Determine your equipment and operations early. Changes are common in aerospace, but eliminating unknowns early facilitates better planning and faster response.
• Calculate your Potential To Emit (PTE). This determines which permits are required. Account for emissions during startup, shutdown, and maintenance — not just normal operations.
• Apply for air permits early. Unlike most environmental permits, air permit applications must be approved before construction begins.