TABLE 1 

Overview of How Connecticut's State Implementation Plan Satisfies the 

CAA Section 110(a)(1) and (2) Program Infrastructure Elements for PM2,5* 

CAA Section 

110(a)(2)(A) 

Required CAA Element 

. . . "include enforceable emission limitations and 

Corresponding Connecticut Program Element(s) 

CGS Section 22a-6(a)(1). The Commissioner is empowered to "adopt, amend or Emission limits 

and other control 

other control measures, means, or techniques 

(including economic incentives such as fees, 

repeal . . . such environmental standards, criteria, and regulations . . . as are necessary 

and proper to carry out his functions, powers and duties ." It is under this general measures marketable permits, and auctions of ertrnissions grant of authority that the Commissioner has adopted emissions standards and control rights), as well as schedules and timetables for measures for a variety of sources and pollutants. 

compliance. . ." CGS Section 22a-174g. California motor vehicle emission standards , including 

exhaust emission standards for precursors of PM and sources of black carbon . 

CGS Section 22a-174. Establishes the Commissioner's general authority to adopt 

regulations and issue permits to control air pollution . 

CGS Section 22a-174(f). Limitations on open burning . 

CGS Section 22a-174k. Restrictions on operation of outdoor wood-burning 

furnaces. 

The sections of the air quality regulations that establish specific emissions limits 

related to the control of PM2.5 and PM2.5 precursors include RCSA: 

22a-174-3a(i) - (1) Nonattainment new source review and prevention of 

significant deterioration . 

22a-174-1$ Control of particulate matter and visible emissions. 

22a-174-19 Control of sulfur compound emissions. 

22a-174-19a Control of sulfur compound emissions from power plants. 

22a-174-22 NOx emissions (also included in many single source SIP revisions). 

22a-174-22b Post-2002 NOx budget program. 

22a-174-22c CAIR NOx ozone season trading program . 

22a-174-27 Periodic motor vehicle inspection and maintenance . 

CAA refers to the Clean Air Act 

CGS refers to the Connecticut General Statutes 

RCSA refers to Regulations of Connecticut State Agencies 

CFR refers to the U.S . Code of Federal Regulations 

CTDEP refers to the Connecticut Department of Environmental Protection 

Commissioner refers to the Commissioner of the CTDEP 

Table 1, page 1 
CAA Section Required CAA Element Corresponding Connecticut Program Element(s) 

22a-174-20 Control of organic compound emissions. 

22a-174-30 Gasoline vapor recovery . 

22a-17432 VOC RACT (also included in many single source SIP revisions). 

22a-174-36 Low emission vehicles . 

22a-174-36a Heavy-duty diesel engines . 

22a-174-36b Low emission vehicles II program . 

, 22a-174-38 Municipal waste combustors. 

22a-174-40 Consumer products . 

22a-174-41 AIM coatings . 

22a-174-43 Portable fuel containers. 

22a-174-44 Adhesives and sealants . 

110(a)(2)(B) . . . "provide for establishment and operation of 40 CFR 53; 40 CFR 58. A comprehensive air quality monitoring plan, intended to 

Ambient air appropriate devices, methods, systems, and meet requirements of 40 CFR 58, is submitted to EPA each year. The 2009 Annual 

quality procedures necessary to (i) monitor, compile, Air Monitoring Network Plan was submitted on June 26, 2009. 

monitoring/data and analyze data on ambient air quality, and (ii) 

system upon request, make such data available to the CGS Section 22a-174(d) provides the commissioner with all incidental powers 

Administrator." necessary to control air pollution. 

110(a)(2)(C) . . . "include a program to provide for the CGS Section 22a-6(a)(5). "The commissioner may, in accordance with 

Program for enforcement of the measures described in constitutional limitations, enter at all reasonable times, without liability, upon any 

enforcement of subparagraph (A), and regulation of the public or private property, except a private residence, for the purpose of inspection 

control measures modification and construction of any stationary and investigation to ascertain possible violations of any statute, regulation, order or 

source within the areas covered by the plan as permit administered, adopted or issued by him and the owner, managing agent or 

necessary to assure that national ambient air occupant of any such property shall permit such entry . . . " 

quality standards are achieved, including a CGS Section 22a-6b. Imposition of civil penalties by the commissioner. 

permit program as required in parts C and D;" CGS Section 22a-7(d) . Civil actions . 

CGS Section 22a-171. "The commissioner shall . . . (4) adopt, amend, repeal and 

enforce regulations . . . and do any other act necessary to enforce the provisions of 

[Chapter 446c, entitled "Air Pollution Control," which encompasses CGS Sections 

22a-170 through 22a-2061." 

CGS Section 22a-174. Orders to correct violations. 

CGS Section 22a-175. Penalties for violations. 

CGS Section 22a-176. Consideration in making regulations and issuing orders . 

CGS Section 22a-177. Enforcement of regulations . Complaints . 

CGS Section 22a-178. Orders to correct violations. 

RCSA section 22a-3a-6(c). Orders, rulings and decisions - procedures in contested 

cases. i 

Table 1, page 2 
CAA Section 

110(a)(2)(D) 

Interstate 

transport 

Required CAA Element 

. . . "contain adequate provisions - (i) prohibiting, 

consistent with the provisions of this title, any 

source or other type of emissions activity within 

the State from emitting any air pollutant in 

amounts which will - (I) contribute significantly 

to nonattainment in, or interfere with 

maintenance by, any other State with respect to 

any such national primary or secondary ambient 

air quality standard, or (11) interfere with 

measures required to be included in the 

applicable implementation plan for any other 

State under part C to prevent significant 

deterioration of air quality or to protect visibility, 

(ii) insuring compliance with the applicable; 

requirements of sections 126 and 115 (relating to 

interstate and international pollution 

abatement) ;" 

RCSA section 22a-174-3a. Permit to construct and operate stationary sources . This section provides a permit program for enforceable emission limits and control 

measures. 

RCSA section 22a-174-12 . Violations and enforcement of the Regulations of 

Connecticut State Agencies . This section provides that "The Commissioner shall 

designate employees of DEP to be known as enforcement personnel, who shall, 

acting with or without complaints, conduct investigations and ascertain whether the 

Commissioner's regulations are being complied with.' 

Revision to the Connecticut State Implementation Plan -Addressing the Interstate Air Pollution Transport Requirements of Clean Air Act Section 110(a)(2)(D)(i), was submitted to EPA on March 13, 2007. EPA approved the SIP revision on May 7, 2008 (73 FR 25516). 

CTDEP will revisit the analysis concerning Connecticut's significant contribution to 

any nearby state 24-hour PM2.5 nonattainment areas once EPA has made final nonattainment area designations for the 2006 PM2.5 NAAQS. 

Connecticut's draft Regional Haze SIP is available at 

httn:l/www.ct.gov/dep/cwp/view asp?a=2684&0-433312&denNav- GID=1619 

Table 1, page 3 

Corresponding Connecticut Program Element(s) 
CAA Section Required CAA Element Corresponding Connecticut Program Element(s) 

I10(a)(2)(E) . . . "provide (i) necessary assurances that the CGS Section 22a-171. Duties of Commissioner of Environmental Protection . "The 

Adequate State (or, except where the Administrator deems commissioner shall (1) initiate and supervise programs for the purposes of 

resources inappropriate, the general purpose local determining the causes, effect and hazards of air pollution ; (2) initiate and supervise 

government or governments, or a regional state-wide programs of air pollution control education; (3) cooperate with and receive 

agency designated by the State or general money from the federal government and, with the approval of the Governor, from any 

purpose local governments for such purpose) other public or private source; (4) adopt, amend, repeal and enforce regulations as 

will have adequate personnel, funding, and provided in section 22a-174 and do any other act necessary to enforce the provisions 

authority under State (and, as appropriate, local) of this chapter and section 14-164c; (S) advise and consult with agencies of the 

law to carry out such implementation plan (and United States, agencies of the state, political subdivisions and industries and any 

is not prohibited by any provision of Federal or other affected groups in furtherance of the purposes of this chapter ." 

State law from carrying out such implementation Air Quality Implementation Plan, Chapter 11, Parts A-E (March 3,1972). 

plan or portion thereof), (ii) requirements that Describes the (A) existing organizations ; (B) manpower; (C) funding; (D) physical 

the State comply with the requirements resources and (E) local agencies. It stated, in part, "The Department of 

respecting State boards under section 128, and Environmental Protection will secure appropriations sufficient, in conjunction with 

(iii) necessary assurances that, where the State federal assistance, to maintain the projected state funding levels ." 

has relied on a local or regional government, 

agency, or instrumentality for the CTDEP is the sale authority implementing the SIP and does not rely on local or 

implementation of any plan provision, the State regional governments or agencies t© carry out this responsibility. 

has responsibility for ensuring adequate 

im lementation of such plan provision," 

110(a)(2)(F) . . . "require, as may be prescribed by the CGS Section 22a-6(a)(S) . "The commissioner may, in accordance with 

Stationary source Administrator - (i) the installation, maintenance, constitutional limitations, enter at all reasonable times, without liability, upon any 

emissions and replacement of equipment, and the public or private property, except a private residence, for the purpose of inspection 

monitoring and implementation of other necessary steps, by and investigation to ascertain possible violations of any statute, regulation, order or 

reporting owners or operators of stationary sources to permit administered, adopted or issued by him and the owner, managing agent or 

monitor emissions from such sources, (ii) occupant of any such property shall permit such entry . . ." 

periodic reports on the nature and amounts of CGS Section 22a-174(c). Various powers of the commissioner related to permitting, 

emissions and emissions-related data from such inspections, and recordkeeping. 

sources, and (iii) correlation of such reports by RCSA section 22a-174-4 . Source monitoring, record keeping and reporting. 

the State agency with any emission limitations or Paragraph (d)(1) states: "The commissioner may, by written notice, require the owner 

standards established pursuant to this Act, which or operator of any source to create, maintain and submit data, records or reports of , 

reports shall be available at reasonable times for monitoring data and other information deemed necessary by the commissioner to 

public inspection;" evaluate compliance with chapter 446c of the Connecticut General Statutes and I, 

regulations promulgated thereunder. Such information shall be recorded, compiled 

and submitted on forms furnished or prescribed by the commissioner. The written I 

notice shall provide the date by which such data, records or reports shall be submitted j 

to the commissioner." i 

Table 1, page 4 
CAA Section Required CAA Element Corresponding Connecticut Program Element(s) 

RCSA section 22a-174-5 . Methods for sampling, emission testing, sample analysis, 

and reporting. 

(e)(1) states : "The owner or operator of a stationary source of air pollution with 

maximum uncontrolled emissions of any particular air pollutant greater than one 

hundred (100) tons per year shall be required to carry out emission tests as prescribed 

by the Commissioner . Such test or tests shall be conducted at such intervals as the 

Commissioner may specify for an individual stationary source." Subsection (e)(2) 

states "In addition to the emission tests required in subdivision 22a-174-5(e)(1), the 

commissioner may require the owner or operator of any stationary source to conduct 

emission tests of emissions:" 

RCSA section 22a-174-10. Public availability of information . Paragraph (a) states : 

Any records, reports or other information obtained by the Commissioner or on file 

with the department shall, pursuant to the provisions of sections 1-7 through 24 of the 

General Statutes, as amended, be made available to the public. 

I10(a)(2)(G) . . . "provide for authority comparable to that in CGS Section 22a-181. Emergency action to protect public health or safety . 

Emergency section 3©3 and adequate contingency plans to RCSA section 22a-174-6. Air pollution emergency episode procedures. 

power implement such authority ;" This section describes the existing emergency episode procedures in place, which are 

consistent with the significant harm levels as indicated in 40 CFR Part 51 .151 . 

Connecticut expects to be classified as a Priority III region, and, therefore, an 

emergency episode plan for PM2.5 is not required. 

110(a)(2)(H) . . . "provide for revision of such plan - (i) from Air Quality Implementation Plan, Chapter 13, (March 3,1972). "This 

Future SIP time to time as may be necessary to take account implementation plan is intended to be dynamic, not static . To this end, it will be 

revisions of revisions of such national primary or revised when necessary." 

secondary ambient air quality standard or the 

availability of improved or more expeditious CGS section 22a-174(d). The Commissioner is authorized with all incidental powers 

methods of attaining such standard, and (ii) necessary to control and prohibit air pollution . 

except as provided in paragraph (3)(C), 

whenever the Administrator finds on the basis of 

information available to the Administrator that 

the plan is substantially inadequate to attain the 

national ambient air quality standard which it 

implements or to otherwise comply with any 

additional requirements established under this 

Act;" 

Table 1, page 5 
CAA Section Required CAA Element Corresponding Connecticut Program Element(s) 

110(a)(2)(J) . . . "meet the applicable requirements of section CGS Section 22a-171 . Duties of Commissioner of Environmental Protection. "(5) 

Consultation with 121 (relating to consultation) advise and consult with agencies of the United States, agencies of the state, political 

government subdivisions and industries and any other affected groups in furtherance of the 

officials purposes of this chapter :" 

CGS Section 22a-174(d). "The commissioner shall have all incidental powers to 

carry out the purposes of [Chapter 446c, entitled "Air Pollution Control," which 

encompasses Conn. Gen. Stat. Sections 22a-170 through 22a-2061 . . . 

CGS Chapter 54. Uniform Administrative Procedures Act. 

State Implementation Plan Revision Advisory Committee (SIPRAC) established 

in 1972 and generally meets each month . 

110(a)(2)(J) 

-- 

. . . "meet the applicable requirements of section CGS Section 4-168. Notice prior to action on regulations . 

Public 127 (relating to public notification), CGS Section 22a-171. Duties of Commissioner of Environmental Protection . 

" notification . . ."(2) Initiate and supervise state-wide programs of air pollution control education; 

CGS Section 22a-174(d). "The commissioner shall have all incidental powers to 

carry out the purposes of [Chapter 446c, entitled "Air Pollution Control," which 

encompasses Conn. Gen. Stat. Sections 22a-170 through 22a-206] . . . 

110(a)(2)(J) . . . "meet the applicable requirements of part C RCSA section 22a-1743a(k). Permit Requirements for Attainment Areas: 

PSD and visibility (relating to prevention of significant Prevention of Significant Deterioration of Air Quality (PSD) Program. This section 

Protection deterioration of air quality and visibility addresses the prevention of significant deterioration of air quality and visibility 

protection ) ;" protection. _ 

110(a)(2)(K) . . . "provide for - (i) the performance of such air RCSA section 22a-174-3a(i). Ambient Air Quality Analysis: "The commissioner 

Air quality quality modeling as the Administrator may may request any owner or operator to submit an ambient air quality impact analysis 

modeling/data prescribe for the purpose of predicting the effect using applicable air quality models and modeling protocols approved by the 

on ambient air quality of any emissions of any commissioner." 

air pollutant for which the Administrator has EPA PM2.5 NSR Rule: CTDEP recognizes that it must update its program 

established a national ambient air quality infrastructure with respect to its nonattainment and minor source NSR permit and 

standard, and (ii) the submission, upon request, prevention of significant deterioration PSD programs. Such a SIP revision is 

of data related to such air quality modeling to the scheduled for submission no later than May 16, 2011 . 

Administrator ;" 

With respect to its NSR permit program, Connecticut is now implementing 40 CFR 

51 Appendix S for PM2,5 in Fairfield and New Haven counties and the transitional 

PSD program far PM2.5, which is set out in an interim policy available at the 

following link: 

p:!/www ct gov/dep/Iib/deplairlcompliance monitorin~slmodeling/pm 2 5 modeli htt _ 

n rocedures. df 

Table 1, page 6 
CAA Section Required CAA Element Corresponding Connecticut Program Element(s) 

110(a)(2)(L) . . . "require the owner or operator of each major CGS Section 22a-6(a)(10). The commissioner may . . . by regulations adopted in 

Permitting fees stationary source to pay to the permitting accordance with the provisions of chapter 54 require the payment of a fee sufficient 

authority, as a condition of any permit required to cover . . . the reasonable cost of reviewing and acting upon an application for and 

under this Act, a fee sufficient to cover - (i) the monitoring compliance with the terms and conditions of any state or federal permit, 

reasonable costs of reviewing and acting upon license, registration, order, certificate or approval required . . . 

any application for such a permit, and (ii) if the CGS Section 22a-6f. Authorizes the commissioner to require annual fees. 

owner or operator receives a permit for such CGS Section 22a-1'74(g). "The commissioner shall require, by regulations adopted 

source, the reasonable costs of implementing and in accordance with the provisions of chapter 54, the payment of a permit application 

enforcing the terms and conditions of any such fee sufficient to cover the reasonable costs of reviewing and acting upon an 

permit (not including any court costs or other application for, and monitoring compliance with the terms and conditions of, any 

, costs associated with any enforcement action), state or federal permit, license, order, certificate or approval required pursuant to this 

i until such fee requirement is superseded with section. . . ." 

respect to such sources by the Administrator's RCSA section 22a-174-26(c)(1) . "Each person to whom the commissioner issues a 

approval of a fee program under permit, or a modification or renewal thereto, under section 22a-174-3a, section 22atitle V;" 174-2a and section 22a-174-19 of the Regulations of Connecticut State Agencies 

shall pay a permit fee as prescribed in the fee schedule in subdivision (2) of this 

subsection." The fee schedule is set forth in Table 26-1 of subsection 2. 

RCSA section 22a-17433(j)(1)(Z). Requires Title V source to pay all fees due 

under RCSA section 22a-174-26. (Approved as satisfying 40 CFR 70.6(a)(7) . See 

- -- - 

67 FR 31966 (Ma 13, 2002)). 

I 110(a)(2)(M) - - . . . "provide for consultation and participation by CGS Section 4-168. Notice prior to action on regulations . 

I Consultation local political subdivisions affected by the plan." Connecticut Air Quality Implementation Plan, Chapter 12 "Intergovernmental 

~ with! Relations" (March 3, 1972). "The State will take immediate action in coordinating 

participation by and delegating new responsibilities to local agencies that are prepared to accept the 

affected local responsibility." 

entities 

Table 1, page 7