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Customer Service Hotline: 1-800-438-2474

November 4, 2014

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:

On July 22, 2014, the U.S. Environmental Protection Agency (EPA) received a revision to the 

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

(DDOE). The SIP revision addresses certain infrastructure elements specified in section 110(a)(2) of the 

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

(SO2) national ambient air quality standards (NAAQS) in the District of Columbia. EPA has determined

that the submittal is technically incomplete for some of the relevant infrastructure elements of section 

110(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 of the CAA for having a SIP-approved PSD program. Conversely, EPA 

finds that the remainder of the July 22, 2014 submittal is 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

SO2 NAAQS, until the District of Columbia through DDOE submits a SIP to address the PSD permit 

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

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 SO2 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 110(k)(5).
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Customer Service Hotline: 1-800-438-2474

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

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

Sincerely, 

/s/

 David L. Arnold,

Acting 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