1

Completeness Determination

Phoenix 2012 5% Plan

Adopted and Submitted by ADEQ May 25, 2012

Adopted locally March 23, 2012 by MAG

Completeness Review Criteria 

(40 CFR part 51, appendix V)

Is 

Criterion 

Satisfied?

Reference in SIP document/comments

2.1 Administrative Materials

(a) A formal letter of submittal from 

the Governor or his designee, 

requesting EPA approval of the 

plan or revision thereof (hereafter 

“the plan”).

Y

Cover letter to Jared Blumenfeld, Regional Administrator, EPA Region 9

from Henry Darwin, Director, Arizona Department of Environmental 

Quality, dated May 25, 2012.

(b) Evidence that the State has 

adopted the plan in the State code 

or body of regulations; or issued 

the permit, order, consent 

agreement (hereafter “document”) 

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.

Y

Cover letter documents adoption of the SIP by ADEQ. 

May 23, 2012 letter from Dennis Smith, Executive Director of the 

Maricopa Association of Governments to Jared Blumenfeld, EPA Region 

9, and Adoption Certification in Appendix E of MAG Plan document,

MAG adoption and approval of plan on May 23, 2012.

(c) Evidence that the State has the 

necessary legal authority under 

State law to adopt and implement 

the plan.

Y Included Arizona statutes placing responsibility for SIP adoption with the 

Director of ADEQ. (49-404)

February 17, 1978 letter from the Governor of Arizona designating MAG 

as the lead planning agency for Phoenix area.
2

(d) A copy of the actual regulation, or 

document submitted for approval 

and incorporation by reference 

into the plan, including indication 

of the changes made other 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. 

Y Included in the package. 

(e) Evidence that the State followed 

all of the procedural requirements 

of the State’s laws and constitution 

in conduction and completing the 

adoption/issuance of the plan.

Y Relevant requirements: ARS 41-1021 to 41-1036; evidence of public 

notice, record of comments and response to comments at ADEQ and 

MAG level. 

The May 25, 2012 letter included documentation that the requirements 

were met for the plan. The June 22 and July 2, 2012 letters included 

documentation for the Dust Action General Permit. 

(f) Evidence that public notice was 

given of the proposed change 

consistent with procedures 

approved by EPA, including the 

date of publication of such notice.

Y Evidence of public notice at the MAG and ADEQ level is included in the 

submittal.

The May 25, 2012 letter included documentation that the requirements 

were met for the plan. The June 22 and July 2, 2012 letters included 

documentation for the Dust Action General Permit.

(g) Certification that public hearings 

were held in accordance with the 

information provided in the public 

notice and the State’s law and 

Y Included. Public hearing held by MAG on April 12, 2012 and by ADEQ 

on April 24, 2012. Public hearing on the Dust Action General Permit was 

held on December 28, 2011.
3

constitution, if applicable.

(h) Compilation of public comments 

and the State’s responses thereto.

Y Included, for both MAG and the ADEQ processes, including the Dust 

Action General Permit.

2.2 Technical Support

(a) Identification of all regulated 

pollutants affected by the plan.

Y PM-10 identified as regulated pollutant in title and submittal letters.

(b) 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 areas.

Y The plan identifies the impacted nonattainment area and details the 

baseline emissions and reduction in emissions from sources in the area. 

Also includes designation and status for the affected areas.

(c) 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 source 

through calculations of the 

differences between certain 

baseline levels and allowable 

emissions anticipate d as a result 

of the revision.

Y Projected emissions inventories for the base year and plan years are 

included.

(d) The State’s demonstration that the 

national ambient air quality

standards, prevention of 

significant deterioration 

increments, reasonable further 

progress demonstration, and 

Y This submittal contains an attainment demonstration, motor vehicle 

emission budgets, a 5% reduction demonstration and demonstrates 

reasonable further progress, including RFP contingency requirements.
4

visibility, as applicable, are 

protected if the plan is approved 

and implemented. For all requests 

to redesignate an area to 

attainment for a national primary

ambient air quality standard, under 

section 107 of the Act, a revision 

must be submitted to provide for 

the maintenance of the national 

primary ambient air quality

standards for at least 10 years as 

required by section 175A of the 

Act.

(e) Modeling information required to 

support the proposed revision, 

including input data, output data, 

models used, justification of model 

selections, ambient monitoring

data used, meteorological data 

uses, 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.

Y This information is included in the submittal.

(f) Evidence, where necessary, that 

emission limitations are based on 

continuous emission reduction 

technology.

N/A Not applicable in this case.

(g) Evidence that the plan contains 

emission limitations, work practice 

standards and 

recordkeeping/reporting 

N/A Not applicable in this case.
5

requirements, where necessary, to 

ensure emission levels.

(h) Compliance/enforcement 

strategies, including how 

compliance will be determined in 

practice.

Y Included. Specifically, the submittal includes a description of how 

compliance rates will be determined and compared against projected 

increases in rule effectiveness. It also includes a commitment to pursue 

additional measures if anticipated improvements are not realized.

(i) Special economic and 

technological justifications 

required by any applicable EPA 

policies, or an explanation of why 

such justifications are not 

necessary.

N/A Not applicable.

Reviewer: Greg Nudd Date of Review: July 2, 2012