IMHO, the only reason to file for a variance during the application period for the Air Construction Permit is if you already have the project funding money IN HAND and are ready to spend the money on “permanent construction.” There is way too much prep work that needs to be accomplished in advance that there should be no need to apply for a “variance.”
There would be NO reason to borrow money (and start the interest clock), until this Air Construction Permit is filed and almost in hand. You cannot start "permanent construction" without it. If they do borrow the funds, get project funding, and receive the funds prior to the permit being issued, then it might make sense to apply for the variance. But with the shortened timeline, I doubt the variance will happen or even be needed. I would think the prep work needed will extend way past the time the Air Construction Permit is issued and in hand.
I would think with this now shortened ACP timeline, there would not be a need to apply for a variance. In my opinion, one way to think about it is, filing for a variance is like using a hammer on the DEE. If the company didn’t feel the state was making much progress on the application, one might file the variance. That variance would put the responsibility for meeting all the ACP requirements in the air permit completely on the company. Personally, I believe we will have the Air Construction Permit in hand long before there is any “permanent construction” started.
Could I be wrong, maybe, but I doubt it. And, project funding could happen at any time – SOON.
News 
Market Data 
Discover 
