Draft Permit Application Narrative Scenario 02

Skill: Draft Brownfield Redevelopment Air Quality Permit Application Narrative (PA DEP Plan Approval)

1. Subject-matter triage

• Treat the application narrative and the issues memorandum as separate deliverables; draft the narrative first, then prepare the memo once the narrative content can be checked against the source set.
• Read the agency-facing prompt materials first, especially any pre-application correspondence, then the engineering, emissions, modeling, and site-constraint documents.
• Identify whether the source set contains one project configuration or multiple variants; if multiple versions, enumerate them before analysis and reconcile each against the narrative scope.
• For brownfield projects, confirm whether remediation constraints, deed restrictions, or activity-use limitations affect the proposed operations before drafting any affirmative statement of site suitability.

2. Failure modes the skill is correcting

• Drafts a generic air permit narrative without answering the specific topics expected for a plan approval submission.
• Fails to reconcile emission calculations, dispersion modeling, equipment specifications, and engineering descriptions before writing the narrative.
• Omits auxiliary sources or support equipment from the permit scope because they are easy to overlook in redevelopment projects.
• Treats the issues memorandum as optional or as a summary instead of a separate advisory deliverable.
• Flags discrepancies without identifying their practical significance, the source conflict, or the corrective path.
• States regulatory conclusions without tying them to the controlling air permitting framework or the source documents that support them.
• Repeats a source document’s numbers or assumptions without checking whether they are internally consistent across the full record.

3. Legal frameworks / domain conventions that apply

• Pennsylvania air permitting practice for plan approvals governs the narrative structure, source coverage, and technical showing expected for new or modified emissions sources.
• Applicable federal and state air standards govern the treatment of combustion units, emergency generators, coating operations, and control devices.
• Brownfield redevelopment constraints may limit operations by area, use, or activity; the narrative should describe those limits only to the extent supported by the source set.
• Dispersion modeling conventions require consistent inputs for emissions, meteorology, receptors, downwash, and configuration assumptions.
• Emissions inventories generally rely on throughput, operating hours, emission factors, and control efficiencies that must match the engineering description and modeling inputs.
• Control technology discussion should reflect the described equipment and its stated performance basis rather than generalized best practices.
• Where the source documents identify a standard, permit condition, or regulatory citation, use that authority as the basis for the narrative and for any issue flag.

4. Analytical scaffolds

• Build a source map before drafting: project description, equipment list, emissions calculations, modeling file or summary, site plan, remediation constraints, and any agency meeting notes.
• For each required topic, compare the narrative draft against the underlying documents and flag any mismatch in scope, terminology, assumptions, or units.
• Reconcile the emissions story end-to-end: equipment inventory, operating assumptions, control assumptions, calculated emissions, and modeled emission rates.
• Check whether every source with air-emission relevance appears in both the narrative and the emissions inventory; if a source appears in one but not the other, treat that as a discrepancy.
• For modeling, verify that the modeled case tracks the same equipment configuration, emission assumptions, and site layout described elsewhere in the source set.
• For brownfield constraints, confirm that the proposed use description does not overstate permissions beyond what the remediation documents support.
• For each issue identified, capture: what conflicts, where it appears, why it matters, and what document or confirmation would resolve it.
• If the source set does not support a point needed for the narrative, mark it as a data gap rather than inferring the missing fact.

5. Vertical / structural / temporal relationships

• Keep the narrative aligned with the chronology in the source set: existing conditions, proposed redevelopment, permitting status, and any remediation milestones.
• If an agency pre-application memo exists, mirror its topic order only to the extent needed to show each topic is addressed; do not omit a topic just because it is discussed elsewhere.
• When multiple source documents describe the same equipment or control device, treat the most specific technical description as controlling unless another source expressly supersedes it.
• If a discrepancy affects both the narrative and the permit-supporting calculations, note the cross-document impact in the issues memorandum rather than in only one place.
• Distinguish between a true conflict, an unresolved gap, and a drafting choice; do not label all three the same way.

6. Output structure conventions

• Produce plan-approval-narrative.docx as the primary deliverable and ensure it contains operative narrative text, not placeholders or a table of contents only.
• Produce issues-memorandum.docx as a separate advisory deliverable after the narrative exists.
• In the narrative, use conventional section headings for a permit submission: project overview, source and equipment description, emissions basis, control measures, modeling or compliance demonstration, and site-constraint discussion as applicable.
• Draft the narrative in a permit-ready tone: factual, complete, and internally consistent, with clear references to the source documents used.
• In the issues memorandum, define a simple ordinal severity scale once at the top and apply it consistently to each entry.
• For each issue entry, state the source conflict or gap, identify the interacting document or assumption, and explain the practical consequence for permit preparation or review.
• End the issues memorandum with a short Recommended Actions section stating the next step, the responsible role, and the timing anchor drawn from the source set or the permitting milestone.
• Where the source documents identify a controlling statute, regulation, permit condition, or agency requirement, cite it by name and section in the relevant narrative or memo discussion.
• Before finalizing, confirm that both filenames match the task instructions exactly and that the narrative and memo are internally consistent with each other.