# TECHNICAL SUPPORT DOCUMENT

Repeal and Replace Revisions to the Louisiana State Implementation Plan Submitted on February 23, 2016

Chapter 2 – Rules and Regulations for the Fee System of the Air Quality Programs Section 201. Scope and Purpose Section 203. Authority

Section 205. Definitions Section 207. Application Fees

Section 209. Annual Fees Section 211. Methodology

Section 213. Determination of Fee Section 215. Methods of Payment Section 217. Late Payment Fee Section 219. Failure to Pay

Section 221. Effective Date



## February 2016

FOR FURTHER INFORMATION CONTACT: Tracie Donaldson, United States Environmental Protection Agency Region 6, Ozone and Infrastru cture Section (6MM-AB), 1445 Ross Avenue, Dallas, Texas 75202-2733, (214) 665-6633.

### Contents:

I. Introduction

II. Technical Evaluation of SIP Submittal A. Review of Chapter 2 Replacement Provisions B. Part 51, Appendix V Completeness Checklist

III. Proposed Action

### I. Introduction

This technical support document (TSD) reviews a revision to the Louisiana State Implementation Plan (SIP), submitted on February 23, 2016. This review will determine if the proposed changes

to the Louisiana SIP are consistent with the re quirements of the Clean Air Act and EPA’s policy and guidance.

II. Technical Evaluation of the Louisi ana February 23, 2016 SIP Revision Submittal

The action accompanying this TSD addresses th e proposed revisions to the Fee Regulations found in Chapters 2 and 65 of the Louisiana SIP. Chapters 2 a nd 65 contain provisions regarding the fee terms, fee amounts, and fee payment sche dules that ensure that adequate fees are

collected to meet the needs of the Louisiana Department of E nvironmental Quality (LDEQ) to perform essential permitting, compliance, enforcem ent and monitoring activit ies. In the February 23, 2016 SIP revision submittal, Louisiana reques ted a repeal of the current SIP-approved provisions contained in Chapters 2 and 65 and re placement with the portions of Chapter 2 that were included in the SIP submittal as replacement fee regulation provisions that relate to the air program. These provisions are contained in Sections 201 through 221 of Chapter 2, which Louisiana submitted in full as part of the February 23, 2016 SIP revision submittal.

Since this rulemaking will act to repeal the current SIP provisions and replace with the proposed fee provisions. A line-by-line comparison is not in cluded in this analysis. Instead, the submitted replacement provisions contained in Chapter 2, which relate to the air program, are provided below, as well as, a summary of the provisions and evaluation against th e applicable federal requirements.

A. Review of LAC 33:III.Chapter 2 Replacement Provisions

Table I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

Section 201 201. Scope and Purpose A. It is the purpose of these regula tions to establish a fee system for funding the monitoring, investigation and other activities required to

be conducted for the maintena nce of a safe and healthful environment by the Department of Environmental Quality in

accordance with the Louisiana En vironmental Quality Act (R.S. 30:2001 et seq.). Fees are requ ired for all permits, licenses, registrations, and variances authorized by the Act. This language similar to current SIPapproved language in Chapter 65,

Section 6501.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable. Section 203. Authority A. These regulations provide fees as required by R.S. 30:2014. This language similar to current SIPapproved language in Chapter 65,

Section 6503.Table I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.

Section 205. Definitions
A. All terms used in these rules, unless the context otherwise requires or unless specifically defined in the Louisiana Environmental Quality Act, or in other regulations promulgated by the secretary of the Department of Environmental Quality or his predecessor, shall have their usual meaning. This language similar to current SIPapproved language in Chapter 65,

Section 6505.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable. Section 207. Application Fees A. No application or amendments thereto shall be processed prior to payment of a permit fee, when it is determined that a permit fee is due. No permit, license, registration, or variance, unless otherwise authorized by the secretary, sha ll be issued until the full amount of the fee has been paid and such check or draft has been accepted by the bank or drawee and the department's account has been credited with the amount of the fee, when it is determined that a permit fee is

due. This section specifies that the fee must be paid prior to the application being processed. It is reworded from the original Chapter 65, Section 6507 language but the meaning is the same.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.

Section 209. Annual Fees A. All parties conducting activities for which an annual maintenance fee is provided shall be subject to the payment of such fee by the due

date indicated on the invoice. The annual maintenance fees are based on a state fiscal year from July 1 to June 30. All major and all minor

sources that have been issued a permit for air pollution emissions shall pay an annual maintenance fee. This is a clarification and update of when the maintenance fees are due and is not a significant change from the SIP approved language in Chapter 65, Section 6509.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable Section 211. Methodology A. Formula to Apportion Fees

Air Toxics Permits Application

Fee for major sources of toxic

pollutants (based on type of

facility and on rated production
capacity/throughput) Surcharge of 10% of the permit

application fee to be charged

when there is an increase in

toxic air pollutant emissions

above the minimum emission

rates (MER) listed in LAC

33:III.5112, Table 51.1

Air Toxics Annual Emissions Fee

for major sources of toxic air

pollutants (based on air toxic

pollutants emitted) 1 Variable

Annual Maintenance Fee (based

on type of facility and on rated

production
capacity/throughput) Variable This section details the types of fees and surcharges required. The language has been updated and clarified from the last approval in 1989.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvableTable I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

New Application Fee (based on

type of facility and on rated

production
capacity/throughput) Variable

Major and Minor Modification

Modified Permit Fee (based on

type of facility and on rated

production
capacity/throughput) Variable

PSD Application Fee (based on

type of facility and on rated

production
capacity/throughput) Surcharge of 50% of the

application fee when a PSD

permit application is being

processed

"NESHAP" Maintenance Fee
(based on type of facility and on

rated production
capacity/throughput) Surcharge of 25% of the Annual

Maintenance Fee for that

particular process/plant to be

added to the Annual

Maintenance Fee

"NSPS" Maintenance Fee (based

on type of facility and on rated

production
capacity/throughput) Surcharge of 25% of the permit

application fee to be charged for

any permit application that

includes the addition of new
equipment subject to NSPS

regulation

1 Fees shall be assessed on major sources as defined in LAC

33:III.5103. Sources that have reduced emissions below major

source thresholds are not required to submit annual emissions

reports in accordance with LAC 33:III.5107.

B. Fee Methodology

1. All fees required by this Chapter are listed in LAC 33:III.223, Fee Schedule Listing, which shall be referred to as the Fee Schedule in the remainder of this Chapter. All persons required to obtain a new or modified permit shall be subject to a permit application fee (see Fee Schedule) unless otherwise exempted. This fee shall be submitted with any application for a new or modified permit. The annual maintenance fee for a new or modified source shall be paid during the fiscal year (July 1 to June 30) in which the process specified in the permit comes on line.

2. The Standard Industrial Classification (SIC) codes listed in

the Fee Schedule shall be used to assist in the determination of the proper fees to assess.

3. The permit fee for sources or facilities with multiple processes shall be equal to the total amounts required by theTable I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

individual processes involved, as listed in the Fee Schedule, unless the entire facility is covered by a single fee category.

4. All invoices for annual main tenance fees for major sources shall be submitted to those sources during the fiscal year. The annual maintenance fee shall be applicable to the fiscal year beginning July 1 of each year and ending the followi ng June 30. Failure to remit the

annual maintenance fee in accor dance with the above shall be considered grounds for revoking an existing permit. Maintenance fees not received for prior fiscal y ears are due upon receipt of new or duplicate invoices. Minor sources may or may not receive an annual compliance inspection. In this case the maintenance fee must be paid within 30 days after notification by the agency of the amount due. Only one such fee shall be charged annually.

5. If a conditional permit is issu ed in accordance with adopted procedures, fees submitted with that application for permit shall be retained and be applicable to the regular permit when it is acted

upon.

6. If a process is not listed in the Fee Schedule and is not a source type exempted from fees by this regulation, then the department shall assign a fee based on the most similar processes in the Fee Schedule and negotiated separately. If a process or facility is specifically listed in the Fee Schedule, then the fee cannot be negotiated. The department shall analyze each permit request to determine the number of processes involved and the permit fee

associated with each.

7. Annually, the department shall reevaluate the Fee Schedule based upon the previous fiscal year 's reasonable costs involved in the operation of the permit system and submit such revised schedule to the secretary for approval.

8. When a company withdraws its application and claims refund for the permit fee, no refund shall be made if the review of the application is essentially completed at the time of withdrawal. However, up to 50 percent refund may be made when the review has been initiated, but is not essentially completed.

9. Annual maintenance fees (AMF) are not prorated. If a facility operates any part of a year or at a reduced rate during the year, the full annual maintenance fee is still charged. In order for the annual maintenance fee to be cancelled, the facility must not operate at all during the year and the permit to operate for the facility must be cancelled and/or changes must be made to the process or facility in order to make the process or facility not subject to regulation by the department. The cancellation of the permit shall require that a new permit be issued before the facility could be operated again. Failure to pay the annual maintenance fee will cause the permit for the facility covered by the fee to be cancelled.

10. When a permanent shutdown occurs and a company properly notifies the Office of Envi ronmental Services by official change in the Emission Inventory Questionnaire (EIQ) and permit,Table I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

then the maintenance fee would be dropped for that shutdown portion of the process/plant. This fee reduction or cancellation shall apply only in the fiscal years in which the shutdown portion of the plant or process did not operate at all. The EIQ and permit shall also need to be changed to delete the emissions from the shutdown portion of the plant or process before the start of the fiscal year in which the fee would have been charged.

11. For most fees listed in these regulations, the minor modification fee is equal to the annual maintenance fee (AMF). The major modification fee is three times the AMF, and the new application fee is five times the AMF. Minimum and maximum permit fees shall apply to all categories that have minimum and maximum AMF according to the followi ng table. If the ratio was not used to establish the major modification and the new application fees for a category, then the actual ratio of major modification and new application fee to AMF shall be used.

Permit	Fees Minimum Maximum

Minor Modification min. AMF max. AMF

Major Modification 3 x min. AMF 3 x max. AMF

New Application 5 x min. AMF 5 x max. AMF

12. NSPS fees may be waived when a PSD application fee is imposed.

13. The department shall determine the type of fee. This determination shall be based on the work load created by the permit application and shall be determined based on the factors described as

follows.

a. New Application Fee. The new application fee shall be based on the new capacity when a new process or operation is added or the incremental increase in capac ity when the capacity is increased by more than 80 percent. It applies when:

i. a new facility is added;

ii. a new operation in an existing facility is added; or

iii. an existing operation is expanded by more than 80 percent in capacity.

b. Major Modification Fee. The major modification fee shall be based on the existing capacity when the capacity is increased by more than 40 percent and less than 80 percent. The applicant has the option to choose to base the major modification fee on the incremental capacity increase and using the new permit application rate in cases where the incremental increase is small compared to the existing ca pacity. In that case, the applicantTable I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

can choose the smaller fee as long as it is larger than the minimum major modification fee listed for the category. In all cases, the

minimum amount of the fee would be equal to or greater than the minimum major modification fee for the category. The major modification fee applies when:

i. the modification will trigger PSD review;

ii. the modification would have triggered PSD review without the use of contemporaneous emission reductions or banked emissions;

iii. the modification will increase emissions by 25 tons/year or more of nonattainment pollutant;

iv. the modification will change emissions over 100 tons/year of a criteria pollutant for which the standard has been attained; or

v. the modification will increase capacity of an existing operation at least by 40 percent and less than 80 percent.

c. Minor Modification Fee. The minor modification fee (based on existing capacity) applies when a modification is not qualified under new application fee or major modification fee. The minor modification fee shall be based on the existing capacity when the capacity is increased by less than 40 percent. The applicant has the option to choose to base the minor modification fee on the incremental capacity increase and using the new permit application

rate in cases where the incremental increase is small compared to the existing capacity. In that case, the applicant can choose the smaller fee as long as it is larger than the minimum minor modification fee listed for the category. In all cases, the minimum amount of the fee would be equal to or greater than the minimum minor modification fee for the category.

d. If a permit modification is such that it does not increase capacity and changes emissions by less than 25 tons/year of all nonattainment pollutants, by less than 10 tons/year of an individual toxic air pollutant, by less than 25 tons/year of total toxic air pollutants, and by less than 100 tons/year of all other criteria (attainment) pollutants, then the permit fee shall be charged equal to the minimum minor modification permit fee for each f ee process category involved. If no minimum minor modification permit fee is listed in LAC 33:III.223,

then the minimum minor modificati on fee is calculated as follows:

i. if the minor modification fee is greater than $800, then the minimum minor modification fee is equal to 25 percent of the minor modification fee;

ii. if the minor modification fee is $200 to $800, then the minimum minor modification fee is $200; andTable I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

iii. if the minor modification fee is less than $200, then the

minimum minor modification fee is the same as the minor

modification fee.

e. Small Source Permit. The sm all source permit, as defined by LAC 33:III.503.B.2, applies wh en a permitted source is not a Part

70 source as defined in LAC 33:III.502. The permitted source must also emit or have the potential to emit less than 25 tons/year of any criteria pollutant, and less than 10 tons per year of any toxic air pollutant. For permit applications with processes specifically listed in the fee schedule that would also qualify for the small source permit fee, the permit fee shall be the lesser of these listed fees.

14. Air Toxics Annual Emissions Fees based on actual annual emissions that occurred during the previous calendar year shall be

assessed on major sources as defined in

LAC 33:III.5103.

Section 213. Determination of Fee A. These regulations apply to a ll registrants, specific licenses, permittees and other persons subject to charges concerned with one or more of the various programs of the Department of Environmental Quality. This language similar to current SIPapproved language in Chapter 65,

Section 6513.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable. Section 215. Methods of Payment A. All payments made by check, draft, or money order shall be made payable to the Department of Environmental Quality, and mailed to the department at the addres s provided on the invoice.

B. Electronic Methods of Payment

1. Persons wishing to make payments using the electronic pay (e-pay) method shall access the depa rtment’s website and follow the instructions provided on the website.

2. Persons wishing to make payments using the electronic funds transfer (EFT) method shall contact the Office of Management

and Finance for further instructions.

C. Cash is not an accept able form of payment. The changes to this section merely update the payment methods (eliminates cash payment and adds electronic payment methods).

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.

Section 217. Late Payment Fee A. Payments not received within 15 days of the due date will be charged a late payment fee. Any late payment fee shall be calculated

from the due date indicated on the invoice.

1. Payments not received by th e department by the fifteenth day from the due date will be assessed a 5 percent late payment fee on the original assessed fee. The new language updates and clarifies when payments are late and the consequences of late payment of fees.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.Table I. –Chapter 2

Revisions to the LA SIP Submitted to the EPA on February 23, 2016 Comments

2. Payments not received by th e department by the thirtieth day from the due date will be assessed an additional 5 percent late payment fee on the original assessed fee.

3. Payments not received by the department by the sixtieth day from the due date will be assessed an additional 5 percent late payment fee on the original assessed fee.

Section 219. Failure to Pay A. Failure to pay the prescribed application fee or annual fee as provided herein, within 90 days after the due date, will constitute a violation of these regulations and shall subject the person to applicable enforcement actions un der the Louisiana Environmental Quality Act including, but not limited to, revocation or suspension of the applicable permit, license , registration, or variance. This language similar to current SIPapproved language in Chapter 65,

Section 6519.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.

Section 221. Effective Date A. The application fees prescribed herein shall be effective upon publication in the Louisiana Register as adopted.

B. The annual fees prescribed here in shall be effective for the state fiscal year in which these fee regulations are published in the Louisiana Register as adopted and each state fiscal year thereafter. Fees submitted to the department in accordance with previous fee regulations for the state fiscal year in which these fee regulations are published in the Louisiana Register as adopted shall be credited against the fees due and payabl e under these fee regulations. This language similar to current SIPapproved language in Chapter 65,

Section 6521.

Revision does not impact the regulation’s ability to meet the applicable federal requirements for fees and is approvable.



### The analysis presented above in Table I. demonstr ates that the revisions to Louisiana Chapter 2 submitted on February 23, 2016, are approvable.

The Fee Regulations contained in Chapter 2 ar e specifically reviewed with respect to the requirements for fees under Secti on 110(a)(2) of the Clean Air Act (CAA or the act herein), as requirements of the State implementation plans for national primary and secondary ambient air quality standards (42 U.S.C. 7410, et seq. ). Section 110(a)(2) of th e Act requires that fees

collected be sufficient to cover the costs of re viewing and acting on permit applications and the costs of implementing and enforcing the terms and conditions of the issued permits. Specifically, Section 110(a)(2)(E)(i) requires that the SIP shall “provide necessa ry assurances that the State will have adequate personnel, funding, and au thority under State law to carry out such implementation plan”. Section 110(a)(2)(L) states that the SIP shall “require the owner or operator of each major stationary source to pay to the permitting authority, as a condition of any permit required under this chapter, a sufficient fee to cover – (i) the reasonable costs of reviewing and acting upon any appl ication for such a permit and (i i) if the owner or operator receives a permit for such source, the reasonabl e costs of implementing and enforcing the terms and conditions of any such permit (not incl uding any court costs a ssociated with any

### enforcement action”, until such fee requirement is superseded with respect to such sources by the Administrator’s approval of a fee program unde r subchapter V of this chapter”. The fee assessment provisions contained in Chapter 2 and submitted to EPA are a portion of the regulatory scheme of LDEQ's construction perm itting program, and provide for permitting fees to cover the cost of reviewing, approving, implementing and enforcing a permit under the permitting program. EPA has previously reviewed the LDEQ regulations for the Nonattainment New Source Review Program, Prevention of Si gnificant Deterioration Permitting, and Minor NSR program, and has approved these programs as being consistent with the federal requirements. Based on our evaluation of these f ee assessment rules and revisions described in this TSD, EPA finds they meet the fee relate d requirements of secti on 110(a)(2) regarding revised costs for these previously approved prog rams, and thus approves the rules and revisions as explained in Table I.

### B. Part 51, Appendix V Completeness Checklist

The criteria for completeness determination ar e found in Appendix V to Part 51 – Criteria for
determining the completeness of plan submissions and are outlined below:

1.0 Purpose: This appendix V sets forth the mi nimum criteria for determining whether a state
implementation plan submitted for consideration by the EPA is an official submission for
purposes of review under § 51.103.

1.1 The EPA shall return to the submitting official any plan or revision thereof which fails to
meet the criteria set forth in this appendix V, and request corrective action, identifying the
component(s) absent or insufficient to perform a review of the submitted plan.

1.2 The EPA shall inform the submitting official whether or not a plan submission meets the
requirements of this appendix V within 60 days of the EPA’s receipt of the submittal, but

no later than 6 months after the date which the State was required to submit the plan or
revision. If a completeness de termination is not made by 6 months from receipt of a
submittal, the submittal shall be deemed complete by operation of law on the date 6 months
from receipt. A determination of completeness under this paragraph means that the

submission is an official s ubmission for purposes of § 51.103.

The attached checklist outlines the basic crit eria included under 2.1, 2.2, and 2.3 of Appendix V.

### Administrative Materials (2.1)

1. The package is sent with a formal submittal lett er from the Governor or his or her designee
requesting the EPA’s approval of the revision.

The SIP revisions addressed in this action were submitted via letter from Secretary Brown
dated February 23, 2016.

2. Evidence is included that the State has adopted the revision in the St ate code or body of
regulations, or that the State has issued the permit, order, consent agreement (hereafter
document) in final form. This evidence would in clude the date of adoption or final issuance

and the effective date of revision, if di fferent from the adopt ion/issuance date.

The submitted regulations cont ained in the SIP revision addre ssed in this action were
effective on February 23, 2016.

3. Evidence is included that the St ate has necessary legal author ity under State law to adopt
and implement the revision, e.g., a citati on of the appropriate State authority.

The authority for promulgating changes to th e Louisiana State Implementation Plan is in
accordance with Louisiana R.S. 30:2019 of th e Louisiana Administra tive Procedure Act.
See http://www.legis.stat e.la.us/lss/lss.asp?doc=87054.

4. A copy is included of the actual regulati on or document submitted for approval and
incorporation by reference into the SIP includin g an indication of the changes made to the
existing approved place where applicable. The submittal shall be a copy of the official
State regulation document signed, stamped, and dated by the appropriate State official
indicating that it is fully enforceable by the St ate. The effective date of the regulation
document shall, whenever possible, be indicated in the document itself.

The SIP submittal included a copy of the official State regulation document.

5. Evidence is included that the State followed all of the procedural requirements of its laws
and/or its constitution in the conducting and completing the adoption/issuance of the plan.

The SIP submittal package included a certifi cation demonstrating the SIP submittal was
developed pursuant to 40 CFR 51.104.

6. Evidence is included that public notice was give n of the proposed chan ges consistent with
the procedures approved by the EPA, including th e date of publication of such notice (e.g.,

### notarized or certified copies of any public no tices published in newspapers). (The notice
should be at least 30 days pr ior to the public hearing(s).

The SIP submittal addressed in this action included a summary of the Public Notices
published for the rule revisions, as well as , copies showing evidence of the published
notices. These public notices included info rmation regarding the public comment period
and upcoming public hearings.

7. A certification is included indicating that pub lic hearing(s) was/were held in accordance
with the information provided in the public not ice(s) and the State’s laws and constitution,
if applicable.

The SIP submittal contained a signed affidavit th at certified that the required procedures
were followed with respect to public noti ce, public hearing, and public participation.

8. A compilation of public comments and the State’s response is included.

The SIP submittal addressed in this action includ ed copies of comments received from the
public on the State regulation, as well as, as the State’s responses to the comments

received.

### Technical Support (2.2)

1. Identification of all regulated polluta nts affected by the revision included.

The SIP submittal addresses revisions to the provisions related to the air permitting
program fees; therefore, the SIP submittals have the potential to address all regulated
pollutants.

2. Identification of the locations of affected sources including the EPA
attainment/nonattainment designation of the loca tions and the status of the attainment plan
for the affected area(s) is included.

The provisions evaluated as part of this action can be applied statewide.

3. Quantifications of the changes in SIP allowa ble emissions from the affected sources is
included. (Examples include estimates of changes in current actual emissions from
affected sources and/or, where appropriate, qua ntification of changes in actual emissions
from affected sources through calculations of the differences between certain baseline
levels and allowable emissions anticipat ed if the revisions were approved.)

Not applicable to this SIP revision. The new re gulation only affects th e fees paid in order to emit pollutants, but does not affect emi ssion levels directly.

4. Demonstration is included that the NAAQS /PSD increments/RFP demonstration and
visibility as applicable woul d be protected if the revision were approved and implemented.

Not applicable to this SIP revision. This pl an revision does not pe rtain to redesignating an area to attainment for a national primary ambient air quality standard. Nor does this revision pertain to prevention of signifi cant deterioration (PSD) increments and demonstrations of reasonable further progress. The new regulation on ly affects the fees paid in order to emit pollutants, but doe s not affect emission levels directly.

5. FOR REDESIGNATIONS:

a. Is there a fully approved maintenance pl an for the primary ambient air quality
standards for at least 10 years as requ ired by § 175A of the Clean Air Act?

Not applicable.

b. Are contingency measures included?

Not applicable.

### 6. Modeling information, if app licable, is required to s upport the proposed revision.

Not applicable.

7. Evidence is included where necessary, that emission limitations are based on continuous
emission reduction technology (e.g., add-on controls, industrial/ process equipment
designs, reformulated materials, etc.).

Not applicable.

8. Evidence is included indicating that a SIP re vision contains emission limitations, work
practice standards and recordk eeping/reporting requirements to ensure stated emission

levels.

Not applicable.

9. Compliance/enforcement strategies including how compliance will be determined in
practice (including at what frequency).

Not applicable.

10. As appropriate, special economic and techno logical justificati ons are included per
applicable EPA policies or an explanation why such justificat ions are not necessary should
be included. For example, requests for altern ative RACT may require such justification.

Not applicable. No special economic and technical justifications are required by other applicable EPA policies are necessary because no such policies are relevant in this case.

The February 23, 2016 SIP submittal meets the completeness criteria established in 40 CFR
part 51, Appendix V.

### III. Proposed Action

It is recommended that the EPA approve the adopti on of the repeal and replacement of Chapter 2 – Rules and Regulations for the Fee System of the Air Quality Programs submitted February 23, 2016. Chapter 65 will be removed from the SIP as the fee provisions have all been moved to Chapter 2 and Chapter 65 no longer exists. See discussion regarding basis for approval in Sections II of this TSD and in Section III of the Federal Register.

This technical support document has evaluated the revisions to the Louisiana fee program submitted as a revision to the Louisiana SIP on February 23, 2016.

It is recommended that the EPA propose approv al of the February 23, 2016 revision. Because

these are noncontroversial revisions the EPA s hould consider a direct final approval. This approval includes sections 201, 203, 205, 207, 209, 211, 213, 215, 217, 219 and 221.