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Technical Support Document (TSD) for EPA’s Evaluation of Arizona’s Emergency Episode 

Plan for the 1997 8-Hour Ozone National Ambient Air Quality Standard 

Introduction

The Environmental Protection Agency (EPA) is proposing to take action on a submittal made by 

Arizona to meet the requirements of Clean Air Act (CAA or Act) section 110(a)(2)(G), 

commonly referred to as the Emergency Episode Plan (EEP) requirements, for the 1997 8-hour 

ozone National Ambient Air Quality Standards (NAAQS). Section 110(a)(2)(G) of the CAA 

requires each State Implementation Plan (SIP) to contain, among other things, adequate authority 

and measures to prevent ambient pollutant levels from reaching the significant harm level (SHL) 

for ozone, as defined in 40 CFR 51.150-153 (Subpart H). This technical support document 

(TSD) provides EPA’s evaluation of a revision to the SIP-approved Emergency Episode Plan 

submitted by Arizona to address the requirements of CAA section 110(a)(2)(G). For the reasons 

discussed below, we propose to approve fully Arizona’s Emergency Episode Plan as meeting the 

requirements of CAA section 110(a)(2)(G) and EPA’s implementing regulations at 40 CFR Part 

51, Subpart H for the 1997 8-hour ozone standard. 

Background

On July 18, 1997, EPA revised the NAAQS for ozone. 62 FR 38856. The ozone NAAQS is 

based on the 3-year average of the annual fourth-highest daily maximum 8-hour average ozone 

concentrations. The 8-hour averaging period replaced the previous 1-hour averaging period, and 

the level of the NAAQS was changed from 0.12 parts per million (ppm) to 0.08 ppm. 

Within three years after the promulgation of a new or revised NAAQS, section 110(a) of the 

CAA requires each State to submit a plan that provides for the implementation, maintenance, and 

enforcement of such NAAQS. Although States typically have met many of the basic program 

elements required in section 110(a)(2), commonly referred to as “infrastructure SIP” 

requirements, through earlier SIP submissions in connection with previous ozone standards, 

States were still required to submit SIP revisions that address section 110(a)(2) for the new 1997 

8-hour ozone NAAQS. These SIP revisions were due in July 2000. However, intervening 

litigation over the 1997 8-hour ozone standard created uncertainty about how to proceed and 

many States did not submit any SIP revisions to meet these infrastructure requirements by the 

July 18, 2000 deadline. 

As of 2004, States had not submitted complete SIPs to satisfy all of the section 110(a)(2) 

requirements for the 1997 8-hour ozone NAAQS revision. On March 4, 2004, Earth Justice 

submitted a notice of intent to sue regarding EPA's failure to issue findings of failure to submit 

related to these requirements. Subsequently, EPA entered into a Consent Decree with Earth 
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Justice which required EPA, among other things, to complete a Federal Register notice 

announcing EPA's determinations pursuant to section 110(k)(1)(B) as to whether each State has 

made complete submissions to meet the requirements of section 110(a)(2) for the 1997 8-hour 

ozone NAAQS by December 15, 2007. Subsequently, EPA received an extension of the date to 

complete this Federal Register notice until March 17, 2008, based upon an agreement to make 

the findings with respect to submissions made by January 7, 2008. 

On March 27, 2008 EPA published a final rule making a finding that Arizona had failed to make 

a complete submittal to satisfy the requirements of section 110(a)(2) by January 7, 2008. This 

finding became effective on April 28, 2008, which started a 24-month clock for EPA either to 

promulgate a federal implementation plan (FIP) addressing section 110(a)(2) requirements in 

Arizona or to approve the SIP revisions necessary to address these requirements. On April 28, 

2010 the 24-month clock expired and EPA was subsequently sued for failure to act within 24 

months of its failure to submit finding. 

On September 1, 2011 EPA published a notice of proposed settlement agreement to address the 

lawsuit filed by Sierra Club and WildEarth Guardians in the United States District Court for the 

Northern District of California: Sierra Club et al. v. Jackson, No. 3:10-cv-04060-CRB (N.D. 

Cal.). The final settlement agreement was executed on November 30, 2011.1 Among other 

things, for Arizona the settlement agreement requires EPA to sign: (1) by March 31, 2012 a 

notice or notices of the Agency’s proposed action either approving a SIP, promulgating a FIP, or 

approving a SIP in part with promulgation of a partial FIP to meet the applicable requirements of 

section 110(a)(2)(G); and (2) by July 31, 2012, a notice or notices of the Agency’s final action 

either approving a SIP, promulgating a FIP, or approving a SIP in part with promulgation of a 

partial FIP to meet the applicable requirements of section 110(a)(2)(G).2 

Section 110(a)(2)(G) of the CAA requires that each SIP provide for authority comparable to that 

in CAA section 303 (“Emergency Powers”) and adequate contingency plans to implement such 

authority. EPA’s implementing regulations in 40 CFR part 51, subpart H establish a “priority” 

classification system under which each region in a state is classified separately for each of the 

following criteria pollutants, based on ambient concentrations of the pollutant: sulfur dioxide 

(SO2), particulate matter of 10 microns or less (PM10), carbon monoxide (CO), nitrogen dioxide 

(NO2), and ozone. Subpart H requires that each contingency plan for a “Priority I” area provide, 

 

1

Settlement Agreement between WildEarth Guardians/Sierra Club and Lisa Jackson, Administrator for the 

Environmental Protection Agency, November 30, 2011, available in the docket for today’s action. 

2

Id. at 7. On October 14, 2009, Arizona submitted an infrastructure SIP to address all other elements of CAA 

section 110(a)(2) for the 1997 8-hour ozone NAAQS. EPA intends to propose action on this submittal separately, by 

June 15, 2012, and to take final action on it by September 30, 2012, consistent with the terms of the settlement 

agreement. See Settlement Agreement between WildEarth Guardians/Sierra Club and Lisa Jackson, Administrator 

for the Environmental Protection Agency, November 30, 2011. 
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at a minimum, for taking action necessary to prevent ambient pollutant concentrations at any 

location in such region from reaching specified “significant harm levels” (SHL). 40 CFR 51.151. 

The SHL for ozone is 1,200 micrograms per cubic meter (ug/m3) or 0.60 ppm over a 2-hour 

average. Id. EPA promulgated priority classifications for Arizona in 1980. 45 FR 67345 (October 

10, 1980). Arizona currently has two regions classified as Priority I for Ozone: Pima and 

Maricopa counties. 40 CFR 52.121. EPA approved an Emergency Episode Plan for Arizona in 

1982. See R9-3-219, “Air Pollution Emergency Episodes” and 47 FR 42572 (September 28, 

1982). 

In the course of evaluating Arizona’s SIP-approved Emergency Episode Plan at R9-3-219, EPA 

was informed by the State that it had submitted a revised rule addressing the requirements of 

CAA section 110(a)(2)(G) (Revised EEP Rule or Arizona Emergency Episode Plan) in a SIP 

revision submitted on August 15, 1994,3 which EPA never acted on.4 The Revised EEP Rule is 

substantively identical to the current SIP-approved rule, except that it incorporates by reference 

the Arizona Department of Environmental Quality’s “Procedures for Prevention of Emergency 

Episodes,” amended as of October 18, 1988 (1988 Procedures). The 1988 Procedures are not 

currently incorporated into the current SIP approved rule but will be as a result of this action. 

The following sections provide our analysis of the Revised EEP Rule, including the 1988 

Procedures, and our bases for proposing to approve this submittal as satisfying the requirements 

of CAA section 110(a)(2)(G) and EPA’s implementing regulations in 40 CFR 51.150-153 for the 

1997 8-hour Ozone NAAQS. Should we finalize this proposed action, the Revised EEP Rule 

would supersede the current SIP-approved rule at R9-3-219. 

Applicable Requirements and EPA Evaluation

Section 110(a)(2)(G) of the CAA requires that each SIP provide for authority comparable to that 

in CAA section 303 (“Emergency Powers”) and adequate contingency plans to implement such 

authority. EPA’s implementing regulations in 40 CFR part 51, subpart H establish a “priority” 

classification system and require that each contingency plan for a “Priority I” area provide, at a 

minimum, for taking action necessary to prevent ambient pollutant concentrations at any location 

in such region from reaching specified “significant harm levels” (SHL). 40 CFR 51.151. The 

 

3 New Source Review and Prevention of Significant Deterioration (NSR/PSD) Program for Major Sources and 

Major Modifications and New Source Review (NSR) for Minor Sources, August 15, 1994, Attachment 6. In a later 

correspondence, Arizona clarified that they “intend for the air pollution emergency episode rule contained within the 

1994 NSR/PSD SIP submittal...to address the requirements of CAA 110(a)(2)(G) for the 1997 8-hour ozone 

standard.” See letter from Eric C. Massey, Director, Air Quality Division, Arizona Department of Environmental 

Quality, to Colleen McKaughan, Associate Director, Air Division, U.S. Environmental Protection Agency, March 

23, 2012. 

4

See e-mail from Diane Arnst to Noah Smith, RE: 110(a)(2)(G) Emergency Episode Plans - Infrastructure SIP, 

January 24, 2012, 02:59 PM. 
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SHL for ozone is 1,200 micrograms per cubic meter (ug/m3) or 0.60 ppm over a 2-hour average, 

which has not changed since Arizona submitted its Revised EEP Rule in 1994. Id. 

On October 2, 2007, EPA issued guidance (2007 Guidance) to assist States in developing and 

evaluating SIP elements required under sections 110(a)(1)-(2) for the 1997 8-hour Ozone and 

PM2.5 NAAQS.5 The 2007 Guidance stated that the SHL for the 1997 8-hour ozone NAAQS 

would remain unchanged at 0.60 ppm over a 2-hour average, as indicated in 40 CFR section 

51.151, and that the existing ozone-related provisions of 40 CFR part 51, subpart H remained 

appropriate for purposes of implementing the 1997 8-hour ozone standard. See 2007 Guidance at 

5. EPA has also provided States with recommendations for EEPs through the “Example 

Regulations for Prevention of Air Pollution Emergency Episodes” in 40 CFR part 51, Appendix 

L (EPA Model Rule or Appendix L). 

Additionally, CAA section 110(l) prohibits EPA from approving any SIP revision that would 

interfere with any applicable requirement concerning attainment and reasonable further progress 

or any other applicable requirement of the Act, and CAA section 193 prohibits the modification, 

in a nonattainment area, of any SIP-approved control requirement in effect before November 15, 

1990, unless the modification “insures equivalent or greater emissions reductions of such air 

pollutant.” 

We address these requirements below. 

CLASSIFICATION OF REGIONS FOR EPISODE PLANS – 40 CFR 51.150 

This section lays out the standards for priority classifications for each pollutant. A Priority I 

region means any area with ambient concentrations greater than 0.10 ppm over a 1-hour average. 

40 CFR 51.150(b). Within Arizona, EPA classified Maricopa and Pima counties as “Priority I” 

regions for ozone purposes in 1980. See 40 CFR 52.121. Arizona is therefore required to have a 

SIP-approved emergency episode plan for these two counties that satisfies the applicable 

requirements of 40 CFR 51.151-152. 

SIGNIFICANT HARM LEVELS – 40 CFR 51.151 

This section states that each plan for a Priority I region (such as Maricopa and Pima) must 

include a contingency plan that at a minimum provides for measures to prevent ambient pollution 

concentrations from reaching “significant harm levels.” Section 51.151 also establishes the 

significant harm level (SHL) for specific pollutants. The SHL for ozone is 0.60 ppm over a two-

 

5 Memorandum from William T. Harnett, Director, Air Quality Policy Division, OAQPS, “Guidance on SIP 

Elements Required Under Sections 110(a)(1) and (2) for the 1997 8-Hour Ozone and PM2.5 National Ambient Air 

Quality Standards,” October 2, 2007. 
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hour average. Arizona’s Revised EEP Rule establishes an ozone SHL of 0.6 ppm over a onehour average, which is more stringent than the level required by section 51.151. See Arizona 

Administrative Code, title 18, Article 2, section 220 (R18-2-220); Arizona Administrative Code, 

title 9, Article 3, section 219 (R9-3-219). EPA proposes to conclude that the Revised EEP Rule 

satisfies the requirements of 40 CFR 51.151. 

CONTINGENCY PLANS – 40 CFR 51.152 

Section 51.152(a)(1) states that each contingency plan must “[s]pecify two or more stages of 

episode criteria such as those set forth in Appendix L to this part, or their equivalent.” The 

Revised EEP Rule specifies three stages of episode criteria: Alert, Warning, and Emergency. 

R18-2-220(B)(1)-(3). The ozone levels that trigger each episode are consistent with the EPA 

Model Rule as they use the same triggering levels as each episode in Appendix L. R18-2-

220(B)(4); see also 40 CFR Part 51, Appendix L section 1.1(b)-(d). The 1988 Procedures also 

meet this requirement as they contain the same episode criteria as the Revised EEP Rule and 

Appendix L. 1988 Procedures at 3.0-5.0. EPA proposes to conclude that the Revised EEP Rule 

satisfies the requirements of 40 CFR 51.152(a)(1). 

Section 51.152(a)(2) states that each contingency plan must “[p]rovide for public announcement 

whenever any episode stage has been determined to exist.” Sections 1-3 of the Revised EEP Rule 

state that if 48 hours after an alert or warning is declared, air pollution concentrations and 

meteorological conditions do not improve, the warning stage shall be “declared” and its control 

actions implemented. R18-2-220. The control actions are contained in the “current edition” of 

the Department’s manual entitled “Procedures for Prevention of Emergency Episodes.” 1988 

Procedures at 2.0-2.2. The 1988 Procedures provide that air quality advisories will be issued “for 

public information purposes” when pollutant concentrations are significantly elevated, and 

specifies information that the advisories should contain. Id. at 2.0. Section 2.1 specifies that 

“urban” advisories will be “prepared by the local pollution control agencies in consultation with 

the Department.” Section 2.2 specifies that “rural/industrial” advisories will be “issued by the 

Department in consultation with local air pollution control agencies, health departments, and 

industries.” More specifically, each episode stage has a requirement that a news release be issued 

within 24-48 hours of an episode stage being declared. Id. at 3.0-4.0.6Section 5 on Emergency 

Stages specifies that “control directives and press releases shall come from the Office of the 

Governor.” EPA proposes to conclude that these requirements in the Revised EEP Rule 

“[p]rovide for public announcement whenever any episode stage has been determined to exist” 

and meet the requirements of 40 CFR 51.152(a)(2). 

 

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E.g. “The Assistant Director will prepare a news release in which the affected area, the pollutant concentrations, 

emissions, and the meteorology are described. The general public will be urged to remain indoors whenever possible 

and avoid prolonged or strenuous exertion. A statement that the applicable sources have been asked to further curtail 

their emissions will be included in the press release.” 1988 Procedures at 4.0. 
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Section 51.152(a)(3) states that each contingency plan must “[s]pecify adequate emission control 

actions to be taken at each episode stage.” The Revised EEP Rule specifies control actions, 

contained in the 1988 Procedures and incorporated by reference, to be taken at each episode 

stage. R18-2-220. Specifically, sections 3.0-5.0 in the 1988 Procedures provide for control 

actions at each stage. These include restricting or banning the use of non-emergency 

automobiles, encouraging people to stay indoors, postponing athletic events, and closing all 

industrial, construction, commercial, governmental and institutional facilities and activities, 

depending on the severity of the episode stage. R18-2-220 at 3.0-5.0. EPA proposes to conclude 

that these emission control actions are adequate to satisfy the requirements of 51.152(a)(3). 

Section 51.152(b)(1) states that each contingency plan for a Priority I region must provide for 

“[p]rompt acquisition of forecasts of atmospheric stagnation conditions and of updates of such 

forecasts as frequently as they are issued by the National Weather Service.” Paragraph B in the 

introduction to the Revised EEP Rule provides that “the declaration of any stage, and the area of 

the State affected, shall be based on air quality measurements and meteorological analysis and 

forecast.” In addition, sections 1-3 of the Revised EEP Rule mention air pollution concentrations 

and meteorological conditions as triggering factors for implementing control actions. R18-2-220. 

The introduction to the 1988 Procedures states that “Meteorology will be monitored continuously 

by the National Weather Service and the State to detect potential episodes caused by atmospheric 

stagnation conditions.” Sections 3.0-5.0 of the 1988 Procedures provide that after an episode has 

been triggered, a “meteorologist will evaluate air quality and meteorological data to evaluate the 

effectiveness of additional control actions and to forecast air quality.” EPA proposes to conclude 

that these requirements in the Revised EEP Rule provide for “[p]rompt acquisition of forecasts of 

atmospheric stagnation conditions and of updates of such forecasts as frequently as they are 

issued by the National Weather Service” and meet the requirements of 40 CFR 51.152(b)(1). 

Section 51.152(b)(2) states that each contingency plan for a Priority I region must provide for 

“[i]nspection of sources to ascertain compliance with applicable emission control action 

requirements.” Section 1.0 in the introduction to the 1988 Procedures states that “[a]ir quality 

surveillance will be maintained by the State, local agencies, and private industries to check 

compliance with air quality and emission standards and detect potential episodes.” In addition, 

we note that other rules that EPA previously approved into the Arizona SIP also provide for 

authority to monitor and inspect sources for compliance with air quality and emissions standards. 

For example, section A in Arizona’s SIP approved rule R9-3-313 (“Existing Source Emission 

Monitoring”) states that “[e]very source subject to an existing source performance standard as 

specified in this chapter shall install, calibrate, operate, and maintain all monitoring equipment 

necessary for continuously monitoring the pollutants and other gases specified in this section for 

the applicable source category.” SIP approved rule R9-3-312 (“Performance Tests”) requires 

facilities subject to installation and operating permits to conduct performance test(s) and furnish 
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written reports of the test(s) to the Director. Section B.5 in the rule states that “nothing in this 

section shall be construed to abrogate the Director’s authority to require testing.” R9-3-

312(B)(5). These additional inspection authorities further strengthen Arizona’s Emergency 

Episode Plan. We propose to conclude that section 1.0 in the 1988 Procedures, coupled with the 

inspection authority approved into other parts of the Arizona SIP, provides adequate inspection 

authority and meets the requirements of 40 CFR 51.152(b)(2). 

Section 51.152(b)(3) states that each contingency plan for a Priority I region must provide for 

“[c]ommunications procedures for transmitting status reports and orders as to emission control 

actions to be taken during an episode stage, including procedures for contact with public 

officials, major emission sources, public health, safety, and emergency agencies and news 

media.” The Revised EEP Rule provides for a “declaration” and implementation of control 

actions whenever an episode stage is triggered. R18-2-220(B)(1)-(3). Section 2.0 in the 1988 

Procedures states that: “Advisories shall include information regarding the affected areas, 

pollutant concentrations, sources of the pollutant, meteorology and a warning that sensitive 

persons should avoid undue exposure.” In addition, each episode stage has specific procedures 

for transmitting information and control actions specific to the episode.7For Warning Stage 

actions, a statement that the applicable sources have been asked to further curtail their emissions 

(beyond what is required by actions at the Alert Stage) will be included in a press release. 1988 

Procedures at 3.0. For Warning and Alert stages, the Director of ADEQ is charged with 

coordinating with local control agencies and health departments to “inform them of the situation 

and request emission reduction by applicable sources under their jurisdiction.” Id. at 3.0-4.0. 

EPA proposes to conclude that these sections satisfy the requirements of 40 CFR 51.152(b)(3). 

Section 51.152(c) states that “Each plan for a Priority IA and II region must include a 

contingency plan that meets, as a minimum, the requirements of paragraphs (b)(1) and (b)(2) of 

this section. Areas classified Priority III do not need to develop episode plans.” As currently 

classified, Arizona contains only Priority I and Priority III regions. 40 CFR 52.121. Because 

Arizona does not have any Priority IA or II regions, the State is not obligated to develop 

contingency plans meeting the requirements of 40 CFR 51.152(c). 

Section 51.152(d)(1) states that “Notwithstanding the requirements of paragraphs (b) and (c) of 

this section, the Administrator may, at his discretion (1) Exempt from the requirements of this 

section those portions of Priority I, IA, or II regions which have been designated as attainment or 

 

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E.g. Section 4.0 on Warning stages in the 1988 Procedures: “In the case of automotive-related pollutants, the 

Assistant Director will requests schools and industrial, business and government facilities to curtail activities as 

much as possible to restrict motor vehicle traffic. He will request that athletic events such as football and basketball 

games be postponed. For other pollutants, he will request increased emission reduction by applicable sources under 

State jurisdiction. He will contact local control agencies and health departments in the affected area and request 

increased emission reduction by applicable sources under their jurisdiction.” 
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unclassifiable for national primary and secondary standards under section 107 of the act.” The 

Administrator has not taken any action to exempt any Priority I, IA, or II regions in Arizona 

from the requirements of 40 CFR 51.152. This provision therefore does not apply to our 

evaluation of Arizona’s Revised EEP Rule. 

Section 51.152(d)(2) states that the Administrator may, at his discretion “Limit the requirements 

pertaining to emission control actions in Priority I regions to – (i) Urbanized areas as identified 

in the most recent United States Census, and (ii) Major emitting facilities, as defined by section 

169(1) of the Act, outside the urbanized areas.” The Administrator has not taken any action to 

limit the requirements pertaining to emission control actions in Priority I regions in Arizona. 

This provision therefore does not apply to our evaluation of the Revised EEP Rule. 

REEVALUATION OF EPISODE PLANS – 40 CFR 51.153 

This section provides that states should periodically reevaluate priority classifications of all 

regions within their borders. The reevaluation must consider the three most recent years of air 

quality data. If the reevaluation indicates a change to a higher priority classification, appropriate 

changes in the episode plan must be made as expeditiously as practicable. Section 51.153 does 

not define “periodically,” but given that Arizona’s priority classifications have not been 

evaluated since EPA promulgated the existing classifications in 1980, we recommend that 

Arizona reevaluate its priority classifications at the next opportunity. EPA does not expect a 

reevaluation will indicate any changes to a higher priority classification for ozone, as ozone 

levels in Arizona have generally declined since the 1980s.8 We note, however, that should ozone 

air quality data indicate a change to a lower classification for Maricopa or Pima counties, 

Arizona may be relieved of its obligation to implement an ozone contingency plan that satisfies 

the requirements for Priority I regions. See 40 CFR 51.152(c). 

REQUIREMENTS FOR SIP REVISIONS IN CAA SECTIONS 110(l) and 193 

CAA section 110(l) prohibits EPA from approving any revision of a SIP “if the revision would 

interfere with any applicable requirement concerning attainment and reasonable further progress 

[RFP]. . . or any other applicable requirement of [the Act].” CAA section 193 includes a savings 

clause which provides: “No control requirement in effect, or required to be adopted by an order, 

settlement agreement, or plan in effect before November 15, 1990, in any area which is a 

nonattainment area for any air pollutant may be modified after November 15, 1990, in any 

 

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See EPA AQS Data Report, “Pima and Maricopa County 1-Hour Ozone Quicklook Report, 2000-2011,” February 

13, 2012. 
9 

manner unless the modification insures equivalent or greater emissions reductions of such air 

pollutant.” 

The Revised EEP Rule is substantively identical to the CAA section 110(a)(2)(G) program 

currently approved into Arizona’s SIP (R9-3-219, “Air pollution emergency episodes”), which 

EPA approved in 1982 (47 FR 42572, September 28, 1982), except that it incorporates by 

reference the Arizona Department of Environmental Quality’s “Procedures for Prevention of 

Emergency Episodes,” amended as of October 18, 1988 (1988 Procedures). The SIP-approved 

program at R9-3-219 states that the procedures and actions required for the “alert,” “warning,” 

and “emergency” stages are “described in the current edition of the Department’s Manual 

entitled ‘Procedures for Prevention of Emergency Episodes,’” but it does not incorporate by 

reference any particular edition of these procedures. See R9-3-219 at section B. Because the 

1988 Procedures contain the specific procedures for notifying the public and appropriate 

State/local agencies when ambient pollutant levels are expected to be high, in addition to 

provisions regarding emission control actions and monitoring ambient air quality, it is critical to 

the implementation of the program that these specific procedures be enforceable. The 

incorporation by reference of the 1988 Procedures into the Revised EEP Rule strengthens the 

program by establishing these procedures as enforceable requirements. We propose to determine 

that our approval of this submittal would comply with CAA section 110(l), because the proposed 

SIP revision would not interfere with the on-going process for ensuring that requirements for 

RFP and attainment of the NAAQS are met, and the Revised EEP Rule is more stringent than the 

rule previously approved into the SIP. 

Although it is not clear whether our proposed action modifies any SIP-approved “control 

requirement” subject to CAA section 193, we have evaluated the submitted SIP revision for 

compliance with section 193 because portions of Arizona are currently designated nonattainment 

for the 1997 8-hour ozone NAAQS, among other standards. See 40 CFR 81.303. The Revised 

EEP Rule is more stringent than the rule previously approved into the SIP and insures equivalent 

or greater emission reductions (compared to the SIP-approved rule) because it incorporates 

provisions in the 1998 Procedures as enforceable procedures, whereas the SIP-approved rule 

only generically references procedures contained in a separate manual. We therefore propose to 

conclude that, to the extent that CAA section 193 applies to this action, our approval of the 

submitted SIP revision would comply with it.