SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: District Department of the Environment (DDOE)

Date Submitted: July 17, 2014

Subject: 2011 Base Year Emissions Inventory for the District of Columbia portion of the Washington DC-MD-VA 

Nonattainment Area (DC Area) for the 2008 Ozone Standard

Completeness Review 

Completed by: Marilyn Powers

Date Completed: September 25, 2014

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his 

designee, requesting EPA approval of the plan or revision 

thereof.

1. Submittal letter dated July 17, 2014 from DDOE Director 

Keith A. to EPA Regional Administrator Shawn Garvin. 

Submittal letter was received on July 22 2014.

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, consent 

agreement in final form. That evidence shall include the date 

of adoption or final issuance as well as the effective date of the 

plan, if different from the adoption/issuance date.

2. The base year emissions inventory was finalized as proposed 

on May 12, 2014 (no comments were received on the proposed 

inventory).

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. As stated in the submittal letter, DDOE has authority under 

District of Columbia Air Pollution Control Act of 1984 as 

amended (DC Law 5-165; DC Official Code 8-101.01 et seq.), 

the DDOE Establishment Act of 2005, as amended (DC Law 

16-51; DC Official Code 8-151.01 et seq.), and Mayor’s orders 

98-44, 98-45, and 2006-6. 

X
4. A copy of actual regulation, or document submitted for 

approval and incorporation by reference into the plan, including 

indication of the changes made to the existing approved plan, 

where applicable. The submittal shall be a copy of the official 

State regulation/document signed, stamped, dated by the 

appropriate State official indicating that it is fully enforceable 

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself.

4. A copy of the 2011 base year emissions inventory for the 

District of Columbia portion of the DC Area was included in 

the submittal. 

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 submittal letter and a memorandum dated July 19, 2014 

provide information that DDOE followed the District of 

Columbia laws and procedures.

X

6. Evidence that public notice was given of the proposed 

change consistent with procedures approved by EPA, including 

the date of publication of such notice.

6. The submittal includes a copy of the Metropolitan Council 

of Governments website page that makes the emissions 

inventory publicly available. The notice of the public hearing 

was published in the D. C. Register on April 11, 2014 (61 DCR 

16: 003782, Notice ID 4842548)

X

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State's laws and constitution, if applicable.

7. A memorandum dated July 19, 2014 provides the Hearing 

Officer’s Certification that the Public Hearing was held on May 

12, 2014 in accordance with the public notice.

X

8. Compilation of public comments and the State's response 

thereto.

8. No comments were received. X
EPA REQUIREMENT STATE SUBMITTAL 

1. Identification of all regulated pollutants affected by the plan. 1. Section 1.1 of the 2011 Base Year Emissions Inventory 

indicates that typical ozone season day emissions were 

developed for VOC, NOx, and CO.

 X

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

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

2. The base year inventory affects the District of Columbia 

portion of the Washington DC nonattainment area for the 2008 

ozone NAAQS.

 X

 

3. Quantification of the changes in plan allowable emissions 

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

of the revision.

3. Not applicable. X

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

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

and implemented. 

4. Not applicable. X

5. Modeling information required to support the proposed 

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

ambient monitoring data used, meteorological data used, 

justification 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.

5. Not applicable. 

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable.

7. Evidence that the plan contains emission limitations, work 7. Not applicable. X
practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Not applicable. 

X

9. Special economic and technological justifications required 

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

explain why.)

9. Not applicable. 

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Not applicable. 

X