UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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REGION Ill 1650 Arch Street Philadelphia, Pennsylvania 19103-2029

The Honorable Keith A. Anderson, Director District Department ofthe Environment 1200 First Street NE, 5th Floor Washington, District ofColumbia 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 ofColumbia State Implementation Plan (SIP) from the District Department ofthe Environment (DDOE). The SIP revision addresses certain infrastructure elements specified in section IIO(a)(2) ofthe 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 ofColumbia. On June 18,2014, EPA determined that the submittal was administratively and technically complete. Throughthis 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 ofthe relevant infrastructure elements ofsection 110(a)(2) ofthe CAA. EPA finds that the District ofColumbiahas failed to make a complete submittal for the portions ofthe infrastructure elements in section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) relating to the permitting program for Prevention ofSignificantDeterioration (PSD), by not adequately addressing the requirements ofpart C oftitle I ofthe CAA for having a SIP-approved PSD program. EPA finds the remainder ofthe 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 ofthe submittal, but cannot approve the PSD-related portions ofsection 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2010 NOz NAAQS, until the District ofColumbiathrough DDOE submits a SIP to address the PSD permit program requirements ofpart C oftitle I ofthe CAA. EPA is reviewing the complete portions ofthe submittal to prepare a Notice ofProposed Rulemaking (NPR) action. EPA recognizes that the District ofColumbia 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 ofsection 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2010 NOz NAAQS. Mandatory sanctions would not apply to the District ofColumbia 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 Ipart D, nor inresponse to a SIP call under CAA section 11O(k)(5).

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**~J** Printed Oil 100% recycled/recyclablepaper with 100%post-consumer fiber andprocess chlorine free. Customer ServiceHotline: 1-800-438-2474.: : Ifmembers ofyour staffhave any questions, they may direct them to Ms. Emlyn Velez-Rosa, Office ofAir 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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