UNITED STATES ENVIRONMENTAL PROTECTION AGENCY cc ~ flf 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

The Honorable Keith A. Anderson, Director 

District Department of the Environment 

1200 First Street NE, 5th Floor 

Washington, District of Columbia 20002 

Dear Director Anderson: 

JUL 2 1 2014 

On June 9, 2014, the U.S. Environmental Protection Agency (EPA) received a revision to the 

District of Columbia State Implementation Plan (SIP) from the District Department ofthe Environment 

(DDOE). The SIP revision addresses certain infrastructure elements specified in section II O(a)(2) of the 

Clean Air Act (CAA) that are necessary to implement, maintain, and enforce the 2010 nitrogen dioxide· 

(NOz) national ambient air quality standards (NAAQS) in the District of Columbia. On June 18,2014, 

EPA determined that the submittal was administratively and technically complete. Through this letter, 

EPA is notifying DDOE that there was an error in our June 18, 2014 completeness determination and 

EPA is therefore withdrawing that determination. 

After re-evaluating the June 9, 2014 submittal, EPA determines the submittal to be technically 

incomplete for some of the relevant infrastructure elements of section 11 0( a)(2) of the CAA. EPA finds 

that the District of Columbia has failed to make a complete submittal for the portions of the 

infrastructure elements in section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) relating to the permitting 

program for Prevention of Significant Deterioration (PSD), by not adequately addressing the 

requirements of part C of title I ofthe CAA for having a SIP-approved PSD program. EPA finds the 

remainder of the June 9, 2014 submittal to be administratively and technically complete. As a result of 

this finding, EPA can only proceed in reviewing the complete portions of the submittal, but cannot 

approve the PSD-related portions of section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2010 NOz 

NAAQS, until the District of Columbia through DDOE submits a SIP to address the PSD permit 

program requirements of part C of title I ofthe CAA. EPA is reviewing the complete portions ofthe 

submittal to prepare a Notice of Proposed Rulemaking (NPR) action. 

EPA recognizes that the District of Columbia is already subject to a Federal Implementation Plan 

(FIP) containing the Federal PSD program to correct the SIP deficiency and that DDOE would not have 

to take further action for the FIP-based permitting process to continue operating. Thus, EPA anticipates 

that there will be no adverse consequences to DDOE from this incompleteness finding for the PSDrelated portions of section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2010 NOz NAAQS. 

Mandatory sanctions would not apply to the District of Columbia under CAA section 179 because the 

failure to submit a PSD SIP is neither with respect to a submission that is required under CAA title I part 

D, nor in response to a SIP call under CAA section 11 O(k)(5). 

#. 

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If members of your staff have any questions, they may direct them to Ms. Emlyn Velez-Rosa, 

Office of Air Program Planning, at (215) 814-2038, or velez-rosa.emlyn@epa.gov. 

Sincerely, 

Diana Esher, Director 

Air Protection Division 

cc: Cecily Beall, Associate Director, Air Quality Division, DDOE 

Rama S. Tangirala, Branch Chief, Monitoring and Assessment Branch, Air Quality Division, DDOE 

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