We manage energy project development, environmental permitting, remediation and compliance, industrial hygiene, health & safety, auditing, environmental management, government relations. We solve your problems in all of these areas. We move quickly and dig deeply to reach your goals. We work wherever you are.

How can SMG help you?


Whoever said “what you don’t know won’t hurt you” would be pretty awful at project management.  Often our success as a consultant hinges on the ability to anticipate an environmental permitting hurdle early in the process.  Nobody finishes the race unscathed by blindly barreling through every hurdle in the way.  But just knowing where the hurdles are isn’t enough, you need to know when to jump and how high.  The details matter.

I recently completed an advanced course on wetland hydrology and one slide on the dynamic relationship between water viscosity and air temperature reminded me of the importance of anticipating hurdles.  Bear with me, it’s more important than you think.    While wetland delineation and permitting is highly technical, it is also subject to seasonal fluctuations in hydrology, vegetation and soil conditions. Since water viscosity is highest at colder temperatures, it tends to persist longer on the ground during the winter.  This dynamic can play tricks on consultants and regulators alike, seemingly telling two different wetland stories depending on the season.

A wetland scientist’s ability to quickly differentiate between temporary and persistent hydrologic conditions and other factors, can make a significant difference in permit review time and mitigation costs.  Considering seasonal variability early on results in better site planning and documentation while mitigating regulatory uncertainty.  Because what you don’t know about seasonal wetland variability can hurt you, but it doesn’t have to.

If you have questions about potential stream and wetland delineation or permitting, please contact me at josiahf@smithmanage.com. Josiah is an Environmental Scientist at Smith Management Group.

March 5, 2019

WOTUS Rule: Permitting Changes Set Up Busy Spring

January 23, 2019


January 16, 2019





A permitted manufacturing facility in Kentucky had stopped using equipment and wanted to make operational changes which were not reflected on their air permit. Large old boilers which had not been used for several years were still active on the site’s air permit. Additionally, the facility wanted to increase operating hours for certain affected facilities.
The old boilers were the reason that the site had federally enforceable limits for sulfur dioxide in their permit and were subject to the National Emission Standard for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. This status resulted in additional requirements, higher monitoring and reporting costs, and higher fees to the regulatory agency. Changes to operations required a reevaluation of the site’s potential emissions.


Smith Management Group evaluated the permit requirements and operational data. SMG calculated the potential to emit without the large boilers and with the expanded hours. SMG’s assisted the facility in updating the correspondence and permit with the regulatory authority to change the facility status to minor source.


SMG helped the source update their air permit to represent current site conditions and allow for expanded operations. The source fully decommissioned the large oil boilers in place, successfully transitioned from a permit with federal limits (FEDOOP/FESOP) to a minor source permit and updated their potential-to-emit calculations to represent new operating parameters. These changes saved the facility money in monitoring, reporting, and fees and also allowed for expanded operations in compliance with air regulations.