UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Tommy Wells, Director 

District Department of Energy and Environment 

1200 First Street NE, 51h Floor 

Washington, District of Columbia 20002 

Dear Director Wells: 

MAY 1 1 2016 

On January 8, 2016, the U.S. Environmental Protection Agency (EPA) received a revision to the 

District of Columbia State Implementation Plan (SIP) dated December 28, 2015 from the District 

Department of Energy and Environment (DDOEE). The SIP revision addresses certain infrastructure 

elements specified in section I I O(a)(2) of the Clean Air Act (CAA) that are necessary to implement, 

maintain, and enforce the 2012 fine particulate matter (PM2.s) 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 11 O(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 11 O(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. 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 DDOEE 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 DDOEE from this incompleteness finding for the PSD related portions of 

section 11 O(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2010 S02 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 II O(k)(5). 

Conversely, EPA finds that the remainder of the December 28,20 15 SIP 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 

l l O(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 20 12 PM2.s NAAQS, until the District of Columbia 

through DDOEE 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 Direct Final 

Rulemaking (DFR) action. 

,. 

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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. Ruth Knapp from the 

Office of Air Program Planning, at 215-8 14-2191, or knapp.ruth@epa.gov. 

-;;;;;~f~ Nikos Singelis, Acting Director 

Air Protection Division 

cc: Cecily Beall, Associate Director, Air Quality Division 

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

n tJ Prill ted 011 I 00% recycled/recyclable paper with I 00% post-co11sumer fiber am/ process chlori11e free. 

Customer Service Hotline: 1-800-438-2474 
SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

(in accordance with 40 CFR Part 51 - App. V) 

SIP Submitted by: 

Date Submitted: 

Distri ct Department of Energy and Environment 

December 28,2015 

Subject: District of Columbia's Infrastructure SIP Revision for the 2012 Fine Particulate Matter Standards 

Completeness Review 

Completed by: 

Date Completed: 

Ruth Knapp Is/ 

May I, 2016 

Administrative Materials ACCEPTABLE 

I EPA REQUIREMENT I STATE SUBMITTAL I (J) I 

I. A formal signed, stamped, and dated letter of submittal from 

the Governor or his designee, requesting EPA approval of the 

an or revision thereof. If electing to submit a paper 

1

submission with a copy in electronic version, the submittal 

letter must verify that the electronic copy provided is an exact 

~uplicate of the paper submission. 

I. A formal letter dated December 28, 2015 from Tommy 

Wells, Director ofthe District Department of Energy and 

Environment (DDOE) to Shawn G. Garvin, Regional 

Administrator, U.S. Environmental Protection Agency (EPA) I P" 

Region III was included. The electronic version contains an 

exact copy of the letter. 

p. Evidence that the State has adopted the plan in the State code 2. The SIP revision consists of a plan to satisfy the 

~r body of regulations; or issued the permit, order, consent infrastructure requirements of section 11 O(a)(2) of the Clean 

greement in fmal form. That evidence shall include the date Air Act (CAA) for the fine particulate matter (PM2.s) national 

f adoption or final issuance as well as the effective date of the ambient air quality standards (NAAQS) for the District of 

ian, if different from the adoption/issuance date. Columbia (the District). The infrastructure plan dated 

December 2015 was provided as part of the submittal. State 

regulations referred in the submittal have already been adopted 

by the District and either have been submitted for approval or 1 p 

have already been approved by EPA into the SIP, as codified in 

40 CFR part 52, subpart J. 

Note: The submittal is incomplete for portions of the 

infrastructure elements in section 110(a)(2)(C), (D)(i)(II), 

(D)(ii), and (J) relating to the permitting program for PSD. DC 

does not have a SIP approved PSD program but a FIP 

addressing PSD is already in place. Further items on this 
EPA REQIDREMENT 

3. Evidence that the State has the necessary legal authority 

Iunder State law to adopt and implement the plan. 

STATE SUBMITTAL 

checklist do not pertain to the PSD portions of the elements 

which are incomplete. 

3. As specified in the trans~ittalletter dated December 28, 

2015, the District has authority to implement this plan into its 

SIP pursuant to the District of Columbia Air Pollution Control 

Act of 1984 (APCA), the District Department of Environment 

Establishment Act of2005, and Mayor Order's 2015-191. 

~- A copy of actual regulation, or document submitted for 4. The infrastntcture plan dated December 2015 was provided 

~pproval and incorporation by reference into the plan, including as part of the submittal. The submittal refers to provisions in 

indication of the changes made (such as redline/strikethrough) state regulations and state code. State regulations referred in 

to the existing approved plan, where applicable. The the submittal have already been adopted by the District, and 

submission shall include a copy of the official State either have been submitted for approval or have already been 

regulation/document signed, stamped, dated by the appropriate approved by EPA into the SIP, as codified in 40 CFR part 52, 

State official indicating that it is fully enforceable by the State. subpart J. In addition, the submittal provides copies of the 

The effective date of any regulation/document contained in the referenced state code provisions. 

submission shall, whenever possible, be indicated in the 

regulation/document itself; otherwise the State should include a 

letter signed, stamped, and dated by the appropriate State 

official indicating the effective date. If the 

regulation/document provided by the State for approval and 

incorporation by reference into the plan is a copy of an existing 

tpublication, the State submission should, whenever possible, 

include a copy of the publication cover page and table of 

contents. 

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in conducting 

and completing the adoption/issuance of the plan. 

5. The transmittal letter dated December 28, 2015 indicates 

that the District has followed all procedural requirements for 

adoption and implementation of the plan, as provided in 40 

CFR part 51. Additional documentation was provided to 

support this, as explained below (see entries 6 and 7). 

(J) 

p 

p 

p 

6. Evidence that public notice was given of the proposed 16. Copies of the public hearing notices published in the District

~hange 1 consistent with procedures approved by EPA, including of Columbia Register and in DDOEE's website on November p 
EPA REQUIREMENT STATE SUBMITTAL (J) 

he date of publication of such notice. 20, 2015 were included. Both notices directed the public to 

provide comments by December 2 1, 2015, and announced a 

public hearing for the proposed SIP revision to be held on such 

date. 

7. Certification that public hearings were held in accordance 7. A copy of the Hearing Officer's Certification dated 

[with the information provided in the public notice and the December 22, 2015 was provided, certifying that a public ~ State's laws and constitution, if applicable. hearing was held as proposed on December 21 , 2015, and 

indicating no attendance. 

8. Compilation of public comments and the State's response 8. No public comments were provided. ~ 

thereto. 

Technica - l S 

EPA REQUIREMENT STATE SUBMITTAL (J) 

I. Identification of all regulated pollutants affected by the plan. 1. Regulated pollutant is PM2.s pertaining to the 2012 PM2.s 

NAAQS, but plan also related to PM2.s precursors, including ~ nitrogen oxides (NOx), sulfur dioxide (S02), volatile organic 

compounds (VOC), and ammonia. I 

! 

2. Identification of the locations of affected sources including 2. This plan applies statewide; the infrastructure requirements 

the EPA anainment/nonattainment designation of the locations are not related to specific nonattainrnent areas with respect to p 

and the status of the attainment plan for the affected area(s). the 2012 PM2.s NAAQS. 

3. Quantification of the changes in plan allowable emissions 3. The plan does not relate to any control measures that would 

from the affected sources; estimates of changes in current result in additional emissions changes. All control measures 

actual emissions from affected sources or, where appropriate, identified in this plan have already been adopted by the District 

quantification of changes in actual emissions from affected as part of state regulations that either have been submitted for ~ 

sources through calculations of the differences between certain approval or have already been approved by EPA into the SIP, 

baseline levels and allowable emissions anticipated as a result as codified in 40 CFR part 52, subpart J. Quantifications of 

of the revision. emissions changes were provided in the particular SIP 

submittals. ---------- ----- --------·····------- - ~-
EPA REQUIREMENT STATE SUBMITTAL (J) 

~- The State's demonstration that the national ambient air 4. The plan does not relate to any control measures that would 

quality standards, prevention of significant deterioration result in additional emissions changes; therefore it will not 

P" increments, reasonable further progress demonstration, and affect any of these aspects. 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

5. Modeling information required to support the proposed 5. Not applicable. 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, p ~u stitication for use of offsite data (where used), modes of 

!models used, assumptions, and other information relevant to 

the determination of adequacy of the modeling analysis. 

6. Evidence, where necessary, that emission limitations are 6. Not applicable. All control measures identified in this plan 

based on continuous emission reduction technology. have already been adopted by the District as part of state 

regulations, that either have been submitted for approval or p 

have already been approved by EPA into the SIP, as codified in 

40 CFR 52, subpart J. 

7. Evidence that the plan contains emission limitations, work 7. Not applicable. All control measures identified in this plan 

!Practice standards and recordkeeping/reporting requirements, have already been adopted by the District as part of state 

!Where necessary, to ensure emission levels. regulations, that either have been submitted for approval or p 

have already been approved by EPA into the SIP, as codified in 

40 CFR 52, subpart J. 

8. Compliance/enforcement strategies, including how 8. Not applicable. All control measures identified in this plan 

compliance will be determined in practice. have already been adopted by the District as part of state 

regulations that either have been submitted for approval or have p 

already been approved by EPA into the SIP, as codified in 40 

CFR 52, subpart J. 

9. Special economic and technological justifications required 9. Not applicable. 

p by any applicable EPA policies. (If a policy is not appropriate, 

explain why.) 
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EPA REQUIREMENT STATE SUBMITTAL (J) 

10. A Section I 07 request must be accompanied by a 

10. Not applicable. maintenance plan demonstrating maintenance to the relevant p 

NAAQS for at least 10 years after redesignation.