Air Quality

Ninyo & Moore offers expert air quality services for clients in the manufacturing, industrial, and public sectors. As a leading environmental sciences and engineering consulting firm, we are fully committed to being responsive, cost-efficient, and thorough in meeting our client's project needs and objectives. Ninyo & Moore's wide range of air quality consulting services includes:

  • Federal PSD/NSR permitting
  • Titles IV and V permitting
  • Due diligence
  • Compliance audits
  • NEPA/CEQA technical studies
  • Regulatory negotiations
  • Litigation and expert witness
  • Risk assessments
  • Dispersion modeling
  • Ambient and source air monitoring
  • Continuous Emission Monitoring Systems project (CEMS) design and implementation
  • Emission credit consultation
  • Emission trading consultation
  • Monitoring, record-keeping, reporting
  • Emission inventories
  • Pollution control evaluations
  • BACT/RACT/LAER determinations
  • Agency liaison


Ninyo & Moore's reputation for effective environmental permitting and licensing is undeniably unsurpassed throughout the southwest and nationwide. Our environmental engineers and regulatory experts have completed hundreds of projects to obtain agency approvals for a wide variety of facilities, activities, and associated environmental releases. Our extensive knowledge of the application requirements, combined with a systematic approach to preparing administratively complete application documents after close consultation with the permitting agency, has allowed our clients to minimize the lead-time prior to commencement of construction or operations.

We have extensive experience with a full range of air quality permitting assignments, from local agency minor source permitting to federal preconstruction New Source Review projects. Our recent experience includes dozens of major source permitting efforts under the federal Prevention of Significant Deterioration (PSD) and Non-attainment Area New Source Review (NNSR) involving emissions quantification, off-site impact dispersion modeling, emission offsets and in-plant netting exercises, control technology (e.g. BACT/LAER/MACT) evaluations, and identification of monitoring, record keeping and reporting requirements. In addition, we have prepared numerous Title IV (acid rain) and Title V (state operating permit) applications for a wide variety of industrial, commercial, military, and governmental sources throughout the United States.

Compliance Audits

Due to our long-term involvement with Environmental Health and Safety (EH&S) rules and regulations, we are well prepared to perform regulatory compliance audits and assessments. However, knowledge of a particular regulatory program is not sufficient to ensure that effective compliance audits techniques are properly used. Our professional staff has undergone formal training in the systematic implementation of regulatory compliance audits and has extensive experience supporting in-house and external legal counsel with confidential investigation and documentation of client facility compliance postures.

Due Diligence

Complex industrial facilities often must integrate multiple regulatory compliance obligations with growth and expansion plans, or long-term compliance strategies must be developed for comprehensive issues. Since the experience and capabilities of our professional staff cover all EH&S disciplines and apply to the full range of regulated facility operations, we have been instrumental in helping our clients chart a prudent course toward their ultimate business objectives, while minimizing the magnitude of regulatory impacts on the process. Our understanding of industrial processes and the importance of avoiding unnecessary bureaucratic interference with production and expansion have proven to be crucial elements of our EH&S Compliance Services.


The NEPA process consists of an evaluation of the environmental effects of a federal undertaking including its alternatives. There are three levels of analysis depending on whether or not an undertaking could significantly affect the environment. These three levels include: categorical exclusion determination; preparation of an environmental assessment/finding of no significant impact (EA/FONSI); and preparation of an environmental impact statement (EIS). If the EA determines that the environmental consequences of a proposed federal undertaking may be significant, an EIS is prepared. An EIS is a more detailed evaluation of the proposed action and alternatives. The public, other federal agencies, and outside parties may provide input into the preparation of an EIS and then comment on the draft EIS when it is completed. Ninyo & Moore staff have complete numerous air quality evaluations for the inclusion in both EA's and EIS.


Most industrial facilities and commercial operations that are subject to permit conditions and/or federal, state, or local rules are required to systematically carry out periodic and episodic monitoring and sampling of their emissions and discharges, as well as various operational parameters, in order to be able to demonstrate compliance with the standards, limitations, and other requirements provided in the permit(s) and rules. Some of the information gathered must simply be maintained for inspection by agency staff. Other information, however, must be evaluated, formatted, and submitted to the agency for their review. It is critical that regulated facilities establish a central compliance documentation and control program to ensure that the required monitoring and sampling is performed; that unacceptable results are corrected quickly; that agency submittals are prepared completely, efficiently, accurately, and on time; and that all of this is effectively documented. Ninyo & Moore can assist you with the development or improvement of your compliance documentation program, in a manner designed to maximize assurance of compliance, yet minimize the cost impacts on the facility's operating budget.

Continuous Emission Monitoring Systems Project (CEMS)

Due to our extensive involvement with electric utilities and independent power producers, Ninyo & Moore's experience with the federal acid rain program requirements is unsurpassed throughout the nation. We have been involved in hundreds of projects involving acid rain permit applications, allocation, consumption, and trading of S02 allowances, NOx control technology, and existing source retrofits. In addition, we have substantial experience with all aspects of continuous emissions monitoring systems (CEMS) and parametric (or predictive) emissions monitoring systems (PEMS), including the design, procurement, and installation of monitoring devices, initial certification and periodic QA measurements, preparation of Monitoring Plans and other required documents, and the preparation and submittal of quarterly electronic data reports (EDRs).

Emission Trading

Emissions trading was introduced on a national scale by the 1990 Clean Air Act Amendments (CAAA), but for at least two decades, economists have championed the concept as a means of producing cleaner air at a lower cost than the “command and control” approach that characterized early environmental control programs. In addition to these programs, a greenhouse gas (GHG) emissions trading program is developing as companies increasingly adopt GHG emissions reduction strategies. Tradable emissions credits become available when a source shuts down or when it applies control technologies more stringent than permits require. In addition, facilities may generate temporary emissions reductions due to market conditions, and these surplus credits can be sold as well. Brokers typically auction credits to facilities that find it more cost-effective to buy credits than to invest in controls.

Ninyo & Moore can help your facility optimize emissions in a variety of ways. We understand how the emission trading programs work and can assist you in educating your organization. We have prepared emission inventories for our clients ranging from military institutions to fossil-fueled power plant, and we can do the same for you. We understand the regulations in great detail, allowing us to identify creditable emissions reductions. We can assist you with the emission credits registration process. While we are not brokers, we can recommend a reputable broker for your facility.

Agency Liaison

As part of a well-planned compliance program, it is often critical to ensure that communications with government regulatory agencies are conducted or directed by experienced professionals who know the proper protocol for such interactions. The Ninyo & Moore EH&S Compliance Services staff have years of experience working closely with federal, state, and local agencies on behalf of our clients; know how to work with the agency staff to effectively achieve our client's objectives; and have an excellent track record with negotiation of permit conditions and enforcement resolutions.

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