Georqia Department of Natural Resources 

Environmental Protection Division Air Protection Branch 

4244 International Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

Noel Holcomb, Commissioner 

Carol A. Couch, Ph.D., Director 

December 13,2007 

Mr. James I. Palmer, Jr. 

Regional Administrator 

U.S. EPA, Region IV 

61 Forsyth Street, SW 

Atlanta, Georgia 30303-31 04 

Re: SIP Elements Under Clean Air Act Sections 110(a)(l) and (2) 

8-hour Ozone National Ambient Air Quality Standard 

Dear Mr. Palmer: 

Under Clean Air Act [CAA] sections 110(a)(l) and (2), Georgia is required to 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 1 lO(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 1 lO(k)(l)(A), whether Georgia has 

made submissions necessary to meet the remaining CAA section 110(a)(l) and (2) 

requirements by December 15, 2007. 

CAA Section 1 lO(a)(2)(D)(i) - Interstate Transport Requirements as 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 transport and 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 1 lO(a)(2)(D)(i) in its entirety on October 9, 2007 [72 FR 57202 - 572071 and the 

effective date 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-hour ozone NAAQS under CAA Section 1 lO(a)(2)(D)(i). 
Mr. Jimmy Palmer, Jr 

December 13, 2007 

Page 2 

Infrastructure Elements of CAA Sections 1 1 O(a)(l) and 1 10(a)(2) 

Many of the required section 11 O(a)(l) and (2) SIP elements relate to 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 recognizes that 

EPA does not believe that Georgia EPD has a Section 110(a)(2)(G) "Emergency power" 

program, and Georgia EPD plans to address this as follows: 

Georgia EPD will work with U.S. EPA Region 4 to determine what, if any, changes are 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 submitted to 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 

1 1 O(a)(2)(G)- 

Conclusion 

If you have any questions or need more information, please contact Jimmy Johnston at (404) 

363-7014 or via email at jimmyjohnston@dnr.state.ga.us. 

Sincerely, 

Carol A. Couch 

Director 

c: Kay Prince, EPA Region IV 

Dick Schutt, EPA Region IV 

Heather Abrams, Branch Chief, EPD, Air Protection Branch