State air pollution regulatory agency (SAPRA) permit engineers are required to perform in-depth analyses of cotton gin emissions. This analysis may include calculations of emission rates and concentrations of all point sources using emission factors. The primary regulated pollutant emitted by cotton gins is particulate matter (PM) less than 10 micrometers aerodynamic equivalent diameter (AED), referred to as PM _10. In some states, emissions of total suspended particulate matter (TSP) are regulated. The results of a permit engineer’s analyses are incorporated into a permit so the facility may operate. The goal of the SAPRA is to protect the public. The permit approved by the SAPRA permit engineer specifies the allowable emission rate for the facility. Consulting engineers working with cotton ginners and permit engineers must develop air pollution abatement systems that comply with SAPRA regulations while minimizing cost. A proposed engineering practice standard was developed to define the operations of a cotton gin with engineering data that can be used by both consulting and permit engineers such that cotton gins are fairly and appropriately regulated.