text: An even larger number of entitiescould be swept into the CAATitle V operating permits program,which definesas major any sourcewith a potential to emit100 TPY of a CAA-regulated pollutant. Title V permits typically do not impose new obligations on sources,because the programs purposeis tofacilitate compliance with other CAA provisions. Butmost of theentitiespotentially subject to Title V for CO 2 haveno other CAA obligations.They would befilling out pointless paperwork. And for their pains, theyd also have to payemission fees (the going rate is $43.30 per ton) for every ton of CO 2 in excess of 100 tons.