Under the Clean Air Act cotton gins are subject to the requirements for particulate matter (PM) and Title V federal operating permits (FOP). Following its own interpretation of the federal guidelines, each state has developed its own State Implementation and Permit Program. Due to these variations in the interpretation of federal guidelines, gins in different states have different requirements. It is, therefore, necessary to know what your local state regulators are doing and have input into the process. There are many issues affecting the timing and requirements for Title V, which are discussed as well as the EPA review and potential updating of the air quality criteria for PM.