You should not even be discussing housing permitting with regard to P20, as housing does not emit or have the potential to emit anything during operation.
Well-established industrial plants are not the same either, because it is already known what they will emit if built to specs.
I look at our P20 as more similar to new emission control devices. In turn, I would bet my house that no fed or state environmental agency would certify our P2O process until one is actually built and an approved 3rd party had done the analysis and documented everything from internal pressure, heat production, output, gas emissions, etc.