How to Create and Update Clean Air Act SIPs

Posted on 12/12/2016 by Anthony Cardno

In April, we posted a Quick Guide on National Air Quality Standards, which covered how the Environmental Protection Agency (EPA) reviews and changes National Ambient Air Quality Standards (NAAQS) under the Clean Air Act (CAA). This guide also discussed how EPA works with states to implement changes to an NAAQS.

The Clean Air Act (CAA) §107 makes each state responsible for the air quality within its entire geographic area. This includes working towards attaining the NAAQS. Each state is required to create and submit to the EPA a State Implementation Plan (SIP) that delineates how each NAAQS will be achieved in each Air Quality Control Region (AQCR) within the state’s borders.

But what exactly goes into creating and revising a Clean Air Act SIP?

What’s In a Clean Air Act State Implementation Plan?

When EPA revises an existing NAAQS standard—or creates a new one—the states must revise their SIPs to reflect the changes necessary to:
  • Maintain the new standard in AQCRs that are already in attainment; and
  • Improve air quality in AQCRs that are now deemed to be in non-attainment of the new standard.
For example, EPA updated its NAAQS for ozone in October 2015. Last month, on November 2, 2016, EPA proposed State Implementation Plan requirements.

The EPA has issued guidance on how they plan to work with the State, tribal, and Federal air agencies to implement the new Ozone NAAQS.

The EPA provides information on all of the Ozone NAAQS (1997, 2008, and 2015) and how they were developed and implemented, here.

Where Are the Rules for Clean Air Act SIPs?

SIPs must be prepared and submitted to the EPA for approval. The SIPs requirements can be found at 40 CFR 51. These Clean Air Act State Implementation Plan requirements include:
  • Procedural requirements;
  • Control strategies that the state will implement;
  • teps to prevent air pollution emergency episodes;
  • Procedures for reviewing new sources and modifications of existing sources under the New Source Review (NSR) program;
  • Surveillance of ambient air quality;
  • Reporting, recordkeeping, testing, and monitoring of emissions within each AQCR;
  • Demonstration of adequate enforcement authority and resources; and
  • Enforceable compliance schedules.

Redesignation of AQCRs

When a NAAQS changes, EPA and the states must meet the following deadlines:
  • Within two years of NAAQS promulgation, EPA must designate AQCRs as meeting (“attainment”) or not meeting (“non-attainment”) the new standard.
  • Within three years of NAAQS promulgation, states must submit revised SIPs to the EPA.

Development and Review of Clean Air Act SIPs

When EPA promulgates a new NAAQS or updates an existing one, the states must develop their SIPs using public input. They then formally adopt the plan before submitting it to the EPA.

After reviewing SIPs submitted by states, EPA issues a Proposed Rule to approve/disapprove all or part of the SIP in the Federal Register. Each proposed rule comes with a period of public comment, and EPA considers those comments before promulgating a Final Rule regarding the SIP.

The redesignation of AQCRs is not a swift process, but it does ultimately have a potential impact on facilities within a region that has been redesignated as “non-attainment.” Revisions to the SIP resulting from this redesignation may impact the facility’s requirements under the New Source Review (NSR) program, as well as under any Title V permit.

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