## Georqia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia 30354 4041363-7000 Fax:4041363-7100 Noel Holcomb, Commissioner CarolA. Couch, Ph.D., Director

December 13,2007

Mr. James 

### I. Palmer,Jr. RegionalAdministrator U.S. EPA, Region IV 61 Forsyth Street, SW Atlanta, Georgia 30303-3104

Re: SIP Elements Under CleanAir Act Sections 110(a)(l) and (2) 8-hour Ozone NationalAmbient Air Quality Standard
Dear Mr. Palmer:
Under Clean Air Act [CAA] sections 110(a)(l) and (2), Georgia is requiredto submit a plan to provide for the implementation, maintenance, and enforcement of the 8-hour ozone National Ambient Air Quality Standard. EPA was obligated by Consent Decree to determine whether Georgia has made the required SIP submissions to meet CAA section 1lO(a)(2)(D)(i) relating to interstate transport by no later than March 15, 2005. The Consent Decree also obligates EPA to make a determination, pursuant to CAA section 1lO(k)(l)(A), whether Georgia has made submissions necessary to meet the remaining CAA section 110(a)(l) and (2) requirementsby December 15, 2007.
CAA Section 1lO(a)(2)(D)(i)

### - InterstateTransport Requirementsas thev relate to the 8-Hour Ozone NAAQS CAA Section 110(a)(l) requires the submittal of a SIP that contains the necessary elements

. .. . found in Section 1 1 0(a)(2): CAA Section 1 1 0(a)(2)(D) pertains to interstate transportand this section prohibits activities andlor emissions which will (1) contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to any NAAQS; or (2) interfere with attainment or visibility, and (3) insure compliance with the applicable requirements of sections 126 and 115 (relating to interstate and international pollution abatement). Georgia received full approval of its SIP revision implementing CAA section 1lO(a)(2)(D)(i) in its entirety on October 9, 2007 [72 FR 57202 

## - 572071 and the effectivedate of this SIP revision is November 8, 2007.

With that in mind, Georgia certifies that its existing SIP contains provisions that address the requirements for the 8-hourozone NAAQS under CAA Section 1lO(a)(2)(D)(i).

### Mr.Jimmy Palmer, Jr December 13, 2007 Page 2

Infrastructure Elementsof CAA Sections 1 1 O(a)(l) and 110(a)(2) Many of the requiredsection 11 O(a)(l) and (2) SIP elements relateto the general information and authorities that constitute the "infrastructure" of the ozone air quality management program. Georgia has reviewed EPA's memo dated October 2, 2007 and entitled, "Guidance on SIP Elements Required Under Sections 110(a)(l) and (2) for the 1997 8-hour Ozone and PM2.5 National Ambient Air Quality Standards" and its ozone SIP. Upon review, Georgia believes that it has an existing ozone air quality management program that satisfies the requirements of CAA Sections 110(a)(l) and the Section 110 SIP elements listed in Attachment A of the October 2, 2007 guidance. On the other hand, Georgia recognizesthat EPA does not believe that Georgia EPD has a Section 110(a)(2)(G) "Emergency power" program, and Georgia EPDplansto addressthis asfollows: Georgia EPDwillworkwith U.S. EPA Region 4 to determinewhat, if any, changesare required to Georgia's SIP in order to satisfy the requirements of Section 110(a)(2)(G). If changes are necessary, EPD will make any necessary regulatory changes in accordance with the Georgia Administrative Procedures Act and policies and procedures set forth by Georgia's Board of Natural Resources. Such procedures will also conform to U.S. EPA administrative requirements for SIP revisions. Once adopted, such changes will be submittedto EPA Region 4 for incorporation into Georgia's SIP.
With that in mind, Georgia certifies that its existing SIP contains provisions that address the requirements for the 8-hour ozone NAAQS including the CAA Sections 110(a)(l) and 110(a)(2)elements listed in Attachment A of the October 2,2007 guidance except for Section 11 O(a)(2)(G)-
Conclusion Ifyou have any questions or need more information, please contact Jimmy Johnston at (404) 363-7014 or via emailatjimmyjohnston@dnr.state.ga.us.



### Sincerely,

CarolA. Couch Director

c: Kay Prince, EPA Region IV Dick Schutt, EPA Region IV HeatherAbrams, Branch Chief, EPD,Air Protection Branch