## UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103 DATE: June 29, 2016 SUBJECT: Technical Support Document for the District of Columbia Sta te Implementation

Plan Revision for Infrastructure Requirements for the 20 12 Fine Particulate Matter National Ambient Air Quality Standards FROM: Ruth Knapp /s/ , Environmental P r otection Specialist

Office of Air Program Planning TO: File for SIP Docket - EPA - R03 - OAR - 2016 - 0350 THRU: Cristina Fernández /s/ , Associate Director

Office of Air Program Planning I. INTRODUCTION The U.S. Environmental Protection Agency (EPA) is taking action on a state implementation plan (SIP) revision submittal made by the District of Columbia (the District) to meet the Clean Air Act (CAA) section 110(a)(2) infrastructure requirements for the 2012 annual fine particulate mat ter national ambient air quality standard s (NAAQS or standard s) . This technical support document (TSD) provides EPA’s rationale for approv ing the Dist rict’s infrastructure submittal dated December 28, 2015. II. BACKGROUND Particle pollution, also called particulate matter ( PM ) , is a complex mixture of extremely small particles and l iquid droplets in the air. When inhaled, these particles can reach the deepest regions of the lungs. Exposure to particle pollution is linked to a variety of significant health problems. Particle pollution also is the main cause of visibility impairment in the nation’s cities and national parks. Fine particles , or particles with a diameter eq ual to or less than 2.5 microns (PM 2.5 

## ) , can be emitted directly into the atmosphere , or they can form from chemical reactions of precursor gases including sulfur dioxide (SO 2 

## ) , nitrogen dioxide (NO 2 

## ) , certain volatile organic compounds (VOC) , and ammonia. On July 18, 1997, EPA promulgated PM 2.5 

## NAAQS for the first time, specifically a new 24 - hour standard of 65 micrograms per cubic meter (μg/m 3 

## ) and a new annual standard of at 15 μg/m 3 

## .

## 2

62 FR 38652. On October 17, 2006, EPA revised the standards for PM 2.5 

## , tightening the 24 - hour PM 2.5 

## standard to 35 μg/m 3 

## , and retaining the annual PM 2.5 

## standard at 15 μg/m 3 

## . 71 FR 61144. Subsequently, on December 14, 2012, the EPA revised the level of the primary annual PM 2.5 

## NAAQS to 12 μg/m 3 

## . 78 FR 3086 (January 15, 2013). 1 

## Pursuant to section 110(a) of the CAA, states are required to submit S IPs that provide for the implementation, maintenance, and enforcement of new or revised NAAQS within three years following the promulgation of such NAAQS. Section 110(a) of the CAA imposes the obligation upon states to make a SIP submission to EPA for a n ew or revised NAAQS. States typically have met many of the basic program elements required in section 110(a)(2) of the CAA through earlier SIP submissions in connection with previous standards of the same pollutant. Section 110(a)(2) of the CAA lists spe cific elements that states must meet or continue to meet in these SIP submissions. The requirements include SIP infrastructure elements such as requirements for modeling, monitoring, and emissions inventories that are designed to assure attainment and mai ntenance of the NAAQS. To satisfy CAA section 110(a), states must provide “infrastructure SIP submissions” or provide a certification that the existing SIP contains provisions addressing relevant infrastructure SIP elements from sections 110(a)(2)(A) thro ugh (M) of the CAA. On Septem ber 13, 2013, EPA issued guidance to help states to develop and submit their infrastructure SIP revisions to comply with the provisions of CAA section 110(a)(1) and (2). 2 

## The non - bi n ding guidance provides recommendations for air agencies to develop infrastructure SIP revisions for various existing NAAQS, including the 2012 annual PM 2.5 

## NAAQS, and any new or revised NAAQS promulgated in the future. On March 17, 2016 EPA also issued a memorandum related specifically to the 2012 PM 2.5 

## NAAQS and element 110(a)(2)(D)(i)(I) known as the “good neighbor” or interstate transport provision . 3 

## I II. EPA’s Approach to Reviewing Infrastructure SIPS EPA is acting upon the District’s December 28, 2015 SIP submission that addresses the infrastructure requirements of section 110(a)(1) and (2) of the CAA for the 2012 annual PM 2.5 

## NAAQS. The requirement for states to make a SIP submission of this type arises out of section 110(a)(1) of the CAA. Pursuant to section 110(a)(1), states mu st make SIP submissions “within 3 years (or such shorter period as the Administrator may prescribe) after the promulgation of a national primary ambient air quality standard (or any revision thereof),” and these SIP submissions are to provide for the “impl ementation, maintenance, and enforcement” of such NAAQS. The statute directly imposes on states the duty to make these SIP submissions, and the requirement to make the submissions is not conditioned upon EPA’s taking any action other than 1 

### In EPA ’ s 2012 PM 2.5 

### NAAQS revision, EPA left unchanged the existing secondary standards for PM 2.5 

### to address welfare PM - related effects such as visibility impairment, ecological effects, damage to materials and climate impacts. This includes an annual secondary standard of 15 μg/m 3 

### and a 24 - hour standard of 35 μg/m 3 

### . 2 

### EPA’s guidance is available online at: http://www3.epa.gov/airquality/urbanair/sipstatus/docs/Guidance_on_Infrastructure_SIP_Elements_Multipollutant_ FINAL_Sept_2013.pdf . 3 

### March 17, 2016 Memorandum from Stephen D. Page to Regional Air Division Directors, Subject: Information on the Interstate Transport “Good Neighbor” Provision for the 2012 Fine Particulate Matter National Ambient Air Quality Standards Under Clean Air Act 110(a)(2)(D)(i)(I).

## 3

promulgating a n ew or revised NAAQS. Section 110(a)(2) of the CAA includes a list of specific elements that “[e]ach such plan” submission must address. EPA has historically referred to these SIP submissions made for the purpose of satisfying the requirements of section 110(a)(1) and (2) as “infrastructure SIP” submissions. Although the term “infrastructure SIP” does not appear in the CAA, EPA uses the term to distinguish this particular type of SIP submission from submissions that are intended to satisfy other SIP requi rements under the CAA, such as “nonattainment SIP” or “attainment plan SIP” submissions to address the nonattainment planning requirements of part D of title I of the CAA, “regional haze SIP” submissions required by EPA rule to address the visibility prote ction requirements of section 169A of the CAA, and nonattainment new source review permit program submissions to address the permit requirements of CAA, title I, part D. Section 110(a)(1) of the CAA addresses the timing and general requirements for infrast ructure SIP submissions and section 110(a)(2) provides more details concerning the required contents of these submissions. The list of required elements provided in section 110(a)(2) contains a wide variety of disparate provisions, some of which pertain t o required legal authority, some of which pertain to required substantive program provisions, and some of which pertain to requirements for both authority and substantive program provisions. 4 

## EPA therefore believes that while the timing requirement in sec tion 110(a)(1) is unambiguous, some of the other statutory provisions are ambiguous. In particular, EPA believes that the list of required elements for infrastructure SIP submissions provided in section 110(a)(2) contains ambiguities concerning what is re quired for inclusion in an infrastructure SIP submission. The following examples of ambiguities illustrate the need for EPA to interpret some section 110(a)(1) and section 110(a)(2) requirements with respect to infrastructure SIP submissions for a given n ew or revised NAAQS. One example of ambiguity is that section 110(a)(2) requires that “each” SIP submission must meet the list of requirements therein, while EPA has long noted that this literal reading of the statute is internally inconsistent and would create a conflict with the nonattainment provisions in part D of title I of the CAA, which specifically address nonattainment SIP requirements. 5 

## Section 110(a)(2)(I) of the CAA pertains to nonattainment SIP requirements and part D addresses when attainmen t plan SIP submissions to address nonattainment area requirements are due. For example, section 172(b) of the CAA requires EPA to establish a schedule for submission of such plans for certain pollutants when the Administrator promulgates the designation o f an area as nonattainment, and section 107(d)(1)(B) of the CAA allows up to two years or in some cases three years, for such designations to be promulgated. 6 4 

### For example: Section 110(a)(2)(E)(i) of the CAA provides that states must provide assurances that they have adequate legal authority under state and local law to carry out the SIP; section 110(a)(2)(C) of the CAA provides that states must have a SIP approved program to address certain sources as required by part C of title I of the CAA; and section 110(a)(2)(G) of the CAA provides that states must have legal authority to address emergencies as well as contingency plans that are triggered in the event of such emergencies. 5 

### See, e.g ., “Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO x 

### SIP Call; Final Rule,” 70 FR 25162, at 25163 – 65 (May 12, 2005) (explaining relationship between timing requirement of section 110(a)(2)(D) versus section 110(a)(2)(I)). 6 

### EPA notes that this ambiguity within section 110(a)(2) of the CAA is heightened by the fact that various subparts of part D set specific dates for submission of certain types of SIP submissions in designated nonattainment areas for various pollutants. Note, e.g., that section 182(a)(1) of the CAA provides specific dates for submission of emissions inventories for the ozone NAAQS. Some of these spe cific dates are necessarily later than three years after

## 4

This ambiguity illustrates that rather than apply all the stated requirements of section 110(a)( 2) in a strict literal sense, EPA must determine which provisions of section 110(a)(2) are applicable for a particular infrastructure SIP submission. Another example of ambiguity within section 110(a)(1) and (2) with respect to infrastructure SIPs pertain s to whether states must meet all of the infrastructure SIP requirements in a single SIP submission, and whether EPA must act upon such SIP submission in a single action. Although section 110(a)(1) directs states to submit “a plan” to meet these requireme nts, EPA interprets the CAA to allow states to make multiple SIP submissions separately addressing infrastructure SIP elements for the same NAAQS. If states elect to make such multiple SIP submissions to meet the infrastructure SIP requirements, EPA can e lect to act on such submissions either individually or in a larger combined action. 7 

## Similarly, EPA interprets the CAA to allow it to take action on the individual parts of one larger, comprehensive infrastructure SIP submission for a given NAAQS without concurrent action on the entire submission. For example, EPA has sometimes elected to act at different times on various elements and sub elements of the same infrastructure SIP submission. 8 

## Ambiguities within section 110(a)(1) and (2) may also arise with respect to infrastructure SIP submission requirements for different NAAQS. Thus, EPA notes that not every element of section 110(a)(2) would be relevant, or as relevant, or relevant in the same way, for each new or revised NAAQS. The states’ attendant in frastructure SIP submissions for each NAAQS therefore could be different. For example, the monitoring requirements that a state might need to meet in its infrastructure SIP submission for purposes of section 110(a)(2)(B) could be very different for differ ent pollutants, for example because the content and scope of a state’s infrastructure SIP submission to meet this element might be very different for an entirely new NAAQS than for a minor revision to an existing NAAQS. 9 

## EPA notes that interpretation of s ection 110(a)(2) is also necessary when EPA reviews other types of SIP submissions required under the CAA. Therefore, as with infrastructure SIP submissions, EPA also has to identify and interpret the relevant elements of section 110(a)(2) that logically apply to these other types of SIP submissions. For example, section 172(c)(7) of the CAA requires that attainment plan SIP submissions required by part D have to meet the promulgation of the new or revised NAAQS. 7 

### See, e.g., “ Approval and Promulgation of Implementation Plans; New Mexico; Revisions to the New Source Review (NSR) State Implementation Plan (SIP); Preve ntion of Significant Deterioration (PSD) and Nonattainment New Source Review (NNSR) Permitting,” 78 FR 4339 (January 22, 2013) (EPA’s final action approving the structural PSD elements of the N ew Mexico SIP submitted by the s tate separately to meet the req uirements of EPA’s 2008 PM 2.5 

### NSR rule ), and “Approval and Promulgation of Air Quality Implementation Plans; New Mexico; Infrastructure and Interstate Transport Requirements for the 2006 PM 2.5 

### NAAQS,” 78 FR 4337 (January 22, 2013) (EPA’s final action on th e infrastructure SIP for the 2006 24 - hour PM 2.5 

### NAAQS). 8 

### On December 14, 2007, the State of Tennessee, through the Tennessee Department of Environment and Conservation , made a SIP revision to EPA demonstrating that the State meets the requirements of sec tions 110(a)(1) and (2). EPA proposed action for infrastructure SIP elements (C) and (J) on January 23, 2012 (77 FR 3213) and took final action on March 14, 2012 (77 FR 14976). On April 16, 2012 (77 FR 22533) and July 23, 2012 (77 FR 42997), EPA took sep arate proposed and final actions on all other section 110(a)(2) infrastructure SIP elements of Tennessee’s December 14, 2007 submittal. 9 

### For example, implementation of the 1997 annual PM 2.5 

### NAAQS required the deployment of a system of new monitors to measure ambient levels of that new indicator species for the new NAAQS.

## 5

“applicable requirements” of section 110(a)(2). Thus, for example, attainment plan SIP submissions must meet the requirements of section 110(a)(2)(A) regarding enforceable emission limits and control measures and section 110(a)(2)(E)(i) regarding air agency resources and authority. By contrast, it is clear that attainment plan SIP submi ssions required by part D would not need to meet the portion of section 110(a)(2)(C) that pertains to the prevention of significant deterioration (PSD) program required in part C of title I of the CAA, because PSD does not apply to a pollutant for which an area is designated nonattainment and thus subject to part D planning requirements. As this example illustrates, each type of SIP submission may implicate some elements of section 110(a)(2) but not others. Given the potential for ambiguity in some of the statutory language of section 110(a)(1) and section 110(a)(2), EPA believes that it is appropriate to interpret the ambiguous portions of section 110(a)(1) and section 110(a)(2) in the context of acting on a particular SIP submission. In other words, EPA assumes that Congress could not have intended that each and every SIP submission, regardless of the NAAQS in question or the history of SIP development for the relevant pollutant, would meet each of the requirements, or meet each of them in the same way. Therefore, EPA has adopted an approach under which it reviews infrastructure SIP submissions against the list of elements in section 110(a)(2), but only to the extent each element applies for that particular NAAQS. Historically, EPA has elected to use gui dance documents to make recommendations to states for infrastructure SIPs, in some cases conveying needed interpretations on newly arising issues and in some cases conveying interpretations that have already been developed and applied to individual SIP sub missions for particular elements. 10 

## EPA most recently issued guidance for infrastructure SIPs on September 13, 2013 (2013 Guidance). 11 

## EPA developed this document to provide states with up - to - date guidance for infrastructure SIPs for any new or revised NAA QS. Within this guidance, EPA describes the duty of states to make infrastructure SIP submissions to meet basic structural SIP requirements within three years of promulgation of a new or revised NAAQS. EPA also made recommendations about many specific su bsections of section 110(a)(2) of the CAA that are relevant in the context of infrastructure SIP submissions. 12 

## The guidance also discusses the substantively important issues that are germane to certain subsections of section 110(a)(2). Significantly, EPA interprets section 110(a)(1) and (2) such that infrastructure SIP submissions need to address certain issues and need not address others. 10 

### EPA notes, however, that nothing in the CAA requires EPA to provide guidance or to promulgate regulations for infrastru cture SIP submissions. The CAA directly applies to states and requires the submission of infrastructure SIP submissions, regardless of whether or not E PA provides guidance or regulations pertaining to such submissions. EPA elects to issue such guidance i n order to assist states, as appropriate. 11 

### “Guidance on Infrastructure State Implementation Plan (SIP) Elements under Clean Air Act Sections 110(a)(1) and 110(a)(2),” Memorandum from Stephen D. Page, September 13, 2013. 12 

### EPA’s September 13, 2013, guid ance did not make recommendations with respect to infrastructure SIP submissions to address section 110(a)(2)(D)(i)(I). EPA issued the guidance shortly after the U.S. Supreme Court agreed to review the D.C. Circuit decision in EME Homer City , 696 F.3d 7 ( D.C. Cir. 2012) which had interpreted the requirements of section 110(a)(2)(D)(i)(I). In light of the uncertainty created by ongoing litigation, EPA elected not to provide additional guidance on the requirements of section 110(a)(2)(D)(i)(I) at that time. As the guidance is neither binding nor required by statute, whether EPA elects to provide guidance on a particular section has no impact on a state’s CAA obligations.

## 6

Accordingly, EPA reviews each infrastructure SIP submission for compliance with the applicable statutory provisions of section 110(a)(2), as appropriate. As an example, section 110(a)(2)(E)(ii) of the CAA is a required element of section 110(a)(2) for infrastructure SIP submissions. Under this element, a state must meet the substantive requirements of section 128, which pertain to state boards that approve permits or enforcement orders and heads of executive agencies with similar powers. Thus, EPA reviews infrastructure SIP submissions to ensure that the state’s SIP appropriately addresses the requirements of secti on 110(a)(2)(E)(ii) and section 128. The 2013 Guidance explains EPA’s interpretation that there may be a variety of ways by which states can appropriately address these substantive statutory requirements, depending on the structure of an individual state’ s permitting or enforcement program ( e.g., whether permits and enforcement orders are approved by a multi - member board or by a head of an executive agency). However they are addressed by the state, the substantive requirements of section 128 are necessari ly included in EPA’s evaluation of infrastructure SIP submissions because section 110(a)(2)(E)(ii) explicitly requires that the state satisfy the provisions of section 128. As another example, EPA’s review of infrastructure SIP submissions with respect to the PSD program requirements in sections 110(a)(2)(C), (D)(i)(II), and (J) focus upon the structural PSD program requirements contained in part C and EPA’s PSD regulations. Structural PSD program requirements include provisions necessary for the PSD prog ram to address all regulated sources and NSR pollutants, including green house gases (GHGs). By contrast, structural PSD program requirements do not include provisions that are not required under EPA’s regulations at 40 CFR 51.166 but are merely available as an option for the state, such as the option to provide grandfathering of complete permit applications with respect to the 2012 PM 2.5 

## NAAQS. Accordingly, the latter optional provisions are types of provisions EPA considers irrelevant in the context of an infrastructure SIP action. For other section 110(a)(2) elements, however, EPA’s review of a state’s infrastructure SIP submission focuses on assuring that the state’s SIP meets basic structural requirements. For example, section 110(a)(2)(C) of the CAA includes, inter alia, the requirement that states have a program to regulate minor new sources. Thus, EPA evaluates whether the state has an EPA approved minor new source review program and whether the program addresses the pollutants relevant to that NA AQS. In the context of acting on an infrastructure SIP submission, however, EPA does not think it is necessary to conduct a review of each and every provision of a state’s existing minor source program ( i.e., already in the existing SIP) for compliance wi th the requirements of the CAA and EPA’s regulations that pertain to such programs. With respect to certain other issues, EPA does not believe that an action on a state’s infrastructure SIP submission is necessarily the appropriate type of action in which to address possible deficiencies in a state’s existing SIP. These issues include: (i) Existing provisions related to excess emissions from sources during periods of startup, shutdown, or malfunction that may be contrary to the CAA and EPA’s policies add ressing such excess emissions (SSM); 13 

## (ii) 13 

### Subsequent to issuing the 2013 Guidance, EPA’s interpretation of the CAA with respe ct to the approvability of affirmative defense provisions in SIPs has changed. See “State Implementation Plans: Response to Petition for Rulemaking; Restatement and Update of EPA’s SSM Policy Applicable to SIPs; Findings of Substantial Inadequacy; and SIP Calls To Amend Provisions Applying to Excess Emissions During Periods of Startup, Shutdown and Malfunction,” 80 FR 33839 (June 12, 2015). As a result, EPA’s 2013 Guidance (p. 21 & n.30) no

## 7

existing provisions related to “director’s variance” or “director’s discretion” that may be contrary to the CAA because they purport to allow revisions to SIP - approved emissions limits while limiting public proces s or not requiring further approval by EPA; and (iii) existing provisions for PSD programs that may be inconsistent with current requirements of EPA’s “Final NSR Improvement Rule,” 67 FR 80186 (December 31, 2002), as amended by 72 FR 32526 (June 13, 2007) (NSR Reform). Thus, EPA believes it may approve an infrastructure SIP submission without scrutinizing the totality of the existing SIP for such potentially deficient provisions and may approve the submission even if it is aware of such existing provisions . 14 

## It is important to note that EPA’s approval of a state’s infrastructure SIP submission should not be construed as explicit or implicit re - approval of any existing potentially deficient provisions that relate to the three specific issues just described. EPA’s approach to review of infrastructure SIP submissions is to identify the CAA requirements that are logically applicable to that submission. EPA believes that this approach to the review of a particular infrastructure SIP submission is appropriate, because it would not be reasonable to read the general requirements of section 110(a)(1) and the list of elements in section 110(a)(2) as requiring review of each and every provision of a state’s existing SIP against all requirements in the CAA and EPA reg ulations merely for purposes of assuring that the state in question has the basic structural elements for a functioning SIP for a new or revised NAAQS. Because SIPs have grown by accretion over the decades as statutory and regulatory requirements under th e CAA have evolved, they may include some outmoded provisions and historical artifacts. These provisions, while not fully up to date, nevertheless may not pose a significant problem for the purposes of “implementation, maintenance, and enforcement” of a n ew or revised NAAQS when EPA evaluates adequacy of the infrastructure SIP submission. EPA believes that a better approach is for states and EPA to focus attention on those elements of section 110(a)(2) of the CAA most likely to warrant a specific SIP revi sion due to the promulgation of a new or revised NAAQS or other factors. For example, EPA’s 2013 Guidance gives simpler recommendations with respect to carbon monoxide than other NAAQS pollutants to meet the visibility requirements of section 110(a)(2)(D) (i)(II) of the CAA, because carbon monoxide does not affect visibility. As a result, an infrastructure SIP submission for any future new or revised NAAQS for carbon monoxide need only state this fact in order to address the visibility prong of section 110 (a)(2)(D)(i)(II) of the CAA. Finally, EPA believes that its approach with respect to infrastructure SIP requirements is based on a reasonable reading of section 110(a)(1) and (2) because the CAA provides other avenues and mechanisms to address specific sub stantive deficiencies in existing SIPs. These other statutory tools allow EPA to take appropriately tailored action, depending upon the nature and severity of the alleged SIP deficiency. Section 110(k)(5) of the CAA authorizes EPA to issue a “SIP call” w henever the Agency determines that a state’s SIP is substantially inadequate to attain longer represents the EPA’s view concerning the validity of affir mative defense provisions, in light of the requirements of section 113 and section 304. 14 

### By contrast, EPA notes that if a state were to include a new provision in an infrastructure SIP submission that contained a legal deficiency, such as a new exemption or affirmative defense for excess emissions during SSM events, then EPA would need to evaluate that provision for compliance against the rubric of applicable CAA requirements in the context of the action on the infrastructure SIP.

## 8

or maintain the NAAQS, to mitigate interstate transport, or to otherwise comply with the CAA. 15 

## Section 110(k)(6) of the CAA authorizes EPA to correct errors in past act ions, such as past approvals of SIP submissions. 16 

## Significantly, EPA’s determination that an action on a state’s infrastructure SIP submission is not the appropriate time and place to address all potential existing SIP deficiencies does not preclude EPA’s subsequent reliance on provisions in section 110(a)(2) as part of the basis for action to correct those deficiencies at a later time. For example, although it may not be appropriate to require a state to eliminate all existing inappropriate director’s di scretion provisions in the course of acting on an infrastructure SIP submission, EPA believes that section 110(a)(2)(A) may be among the statutory bases that EPA relies upon in the course of addressing such deficiency in a subsequent action. 17 

## I V . SUMMARY OF STATE SUBMITTAL On December 28, 2015 , the District submitted a SIP revision to satisfy the infrastructure requirements of section 110(a)(2) for the 201 2 annual PM 2 .5 

## NAAQS. The S IP revision s ubmittal addresses the following i nfrastructure eleme nts for the implementation of the 2012 annual PM 2.5 

## NAAQS : Section 110(a)(2)(A), (B), (C), (D)(i)(I), (D)(i)(II), (D)(ii), (E), (F), (G), (H), (J), (K), (L), and (M) of the CAA. The infrastructure SIP s ubm ittal d oes not address section 110(a)(2)(I) which pertains to the nonatta inment requirements of part D, t itle I of the CAA, since this element is not required to be submitted by the 3 - year submission deadline of CAA section 110(a)(1), and will be addressed in a separate process if necessary . V. EPA’s COMPLETENESS DE TERMINATION OF STATE SUBMITTAL EPA evaluated the District’s December 28, 2015 infrastructure SIP submittal for technical and administrative completeness, in accordance with 40 CFR part 51, appendix V. EPA found that the submittal is techni cally incomplete for the portions of the infrastructure elements in section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) relating to the permitting program for PSD, because the District has not adequately addressed the requirements of part C of t itle I of th e CAA for having a SIP approved PSD program. EPA found the remainder of the District’s infrastructure SIP submittal to be administratively and technically complete. On May 11 , 2016 , EPA sent a letter 15 

### For example, EPA iss ued a SIP call f o r Utah to address specific existing SIP deficiencies related to the treatment of excess emissions during SSM events. See “Finding of Substantial Inadequacy of Implementation Plan; Call for Utah State Implementation Plan Revisions,” 74 FR 21639 (April 18, 2011). 16 

### EPA has used this authority to correct errors in past actions on SIP submissions related to PSD programs. See “Limitation of Approval of Prevention of Significant Deterioration Provisions Concerning Greenhouse Gas Emitting - Sour ces in State Implementation Plans; Final Rule,” 75 FR 82536 (December 30, 2010). EPA has previously used its authority under CAA s ection 110(k)(6) to remove numerous other SIP provisions that the Agency determined it had approved in error. See, e.g., 61 FR 38664 (July 25, 1996) and 62 FR 34641 (June 27, 1997) (corrections to American Samoa, Arizona, California, Hawaii, and Nevada SIPs); 69 FR 67062, November 16, 2004 (corrections to California SIP); and 74 FR 57051 (November 3, 2009) (corrections to A rizona and Nevada SIPs). 17 

### See, e.g ., EPA’s disapproval of a SIP submission from Colorado on the grounds that it would have included a director’s discretion provision inconsistent with CAA requirements, including s ection 110(a)(2)(A). See, e.g ., 75 FR 42 342 at 42344 (July 21, 2010) (proposed disapproval of director’s discretion provisions); 76 FR 4540 (January 26, 2011) (final disapproval of such provisions).

## 9

to the District Department of Energy and Environment (DDOE E ) notifying the District of th is determination . As a result of th is incompleteness finding , EPA is not taking rulemaking action on the PSD related portions of section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 201 2 annual PM 2 .5 

## NAAQS , until the District through DDOE E submits a SIP to address the PSD permit program requirements of part C of title I of the CAA. EPA recognizes, however, that the District is already subject to a Federal Implementation Plan (FIP) containing the Federal PSD program to correct the SIP deficiency and that DDOE E would not have to take further action for the FIP based permittin g process to continue operating , as incorporated by reference in the District SIP in 40 CFR 52.499 . 18 

## EPA’s PSD FIP for the District consi sts of the implementation of the Federal PSD program as codified in 40 CFR 52.21. EPA does not anticipate any adverse consequences to DDOE E as a result of th is inc ompleteness finding for the PSD related portions of section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the District’s 201 2 annual PM 2 .5 

## infrastructure SIP revision . Mandatory sanctions would not apply to the District under CAA section 179 because this submission is not required und er t itle I part D of the CAA , nor was it required in response to a SIP call under section 110(k)(5) of the CAA . EPA is not subject to any further FIP dut y from our finding of incompleteness because of the PSD FIP that is already been approved, which addresses the SIP deficiency. V I . EVALUATION OF STATE SUBMITTAL EPA is approv ing in this rulemaking action the remainder of the District’s SIP revision submittal address ing the remaining applicable infrastructure requirements for the 2012 annual PM 2.5 

## NAAQS. This section of the TSD describes EPA’s rationale for taking action on the complete portions of the District’s infrastructure SIP revision in addressing the implementation of the 2012 annual PM 2.5 

## NAAQS under section 110(a)(2 ) . A. Section 110(a)(2)(A) To satisfy section 110(a)(2)(A), the state s shall identify existing SIP provisions approved by EPA or new provisions that the states have adopted and submitted for EPA approval that limit emissions of pollutants relevant to the subject NAAQS, including precursors of the relevant NAAQS pollutant, where applicable. EPA has de termined that the District has adopted regulations applicable to the implementation of the 201 2 annual PM 2 .5 

## NAAQS that include enforceable emissions limitati ons and other control measures, means or techniques, as well as schedules and timetables for compliance to meet the applicable requirements of the CAA. For the 201 2 annual PM 2 .5 

## NAAQS , the District controls direct emission of the PM 2.5 

## as well as other po llutants as p recursors for secondary formation of PM 2.5 

## , including nitrogen oxides (NO X 

## ) , 18 

### On August 7, 1980 (45 FR 52676, at 52741). EPA disapproved a number of states SIPs for PSD purp oses, including the District of Columbia, and incorporated by reference portions of the Federal PSD provisions in 40 CFR 52.21 into the implementation plans for those states. This FIP was subsequently amended to reflect amendments to the Federal PSD rule, on March 10, 2003 (68 FR 11316, at 11322) and December 24, 2003 (68 FR 74483, at 74488). The PSD FIP, incorporated by reference in the District SIP in 40 CFR 52.499, specifically contains the provisions of 40 CFR 52.21, with the exception of paragraph (a )(1).

## 10

volatile organic compounds (VOC) , and SO 2 . 

## Table 1 list s all enforceable control measures that are contained in the District’s adopted regulations and approved into the District SIP, as codified in 40 CFR 52.470(c) for the 201 2 annual PM 2 .5 

## NAAQS . EPA acknowledges that emissions limitations and other control measures needed to attain the NAAQS in areas designated nonattainment for that NAAQS (under part D of title I of the CAA) are due on a different schedule from the section 110 infrastructure elements and thus EPA will review and act upon any such submissions for nonattainment areas within the District separately as necessary. Table 1. C ontrol Measures in the District SIP for the 

## 2012 A nnual PM 2.5 

## NAAQS District Regulation Control Measure Affected Pollutant State

Effective Date EPA’s

Approval Date 20 DCMR section 600 Fuel - Burning PM 2.5 

## 4/16/ 20 04 12/28/2004 ( 69 FR 77645 ) 20 DCMR section 602 Incinerators PM 2.5 

## 3/15/ 19 85 8/28/ 1995 ( 60 FR 44431 ) 20 DCMR section 603 P articulate P rocess Emissions PM 2.5 

## 3/15/ 19 85 8/28/ 1995 ( 60 FR 44431 ) 20 DCMR section 604 Seasonal Open Burning Restrictions PM 2.5 

## 2/1/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 605 Control of Fugitive Dust PM 2.5 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 606 Visible Emissions (Opacity) PM 2.5 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 700 Miscellaneous VOC VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 701.1 to 701.13 Storage of Petroleum Products VOC 3/15/1985 10/27/1999 ( 64 FR 57777 ) 20 DCMR section 702 Control of VOC Leaks from Petroleum Refinery Equipment VOC 3/15/1985 10/27/1999 ( 64 FR 57777 ) 20 DCMR sections 703.2 and 703.3 Terminal Vapor Recovery – Gasoline or VOC VOC 9/30/1993 10/27/1999 ( 64 FR 57777 ) 20 DCMR section 704 Stag e I Vapor Recovery VOC 3/15/1985 10/27/1999 ( 64 FR 57777 ) 20 DCMR section 705 Stage II Vapor Recovery VOC 3/15/1985 9/30/1993 10/27/1999

( 64 FR 57777 ) 20 DCMR section 706 Petroleum Dry Cleaners VOC 3/15/1985 10/27/1999 ( 64 FR 57777 ) 20 DCMR section 709 Asphalt Operations VOC 3/15/1985 10/27/1999 ( 64 FR 57777) 20 DCMR section 710 Graphic Arts Controls VOC 12/30/2011 4/29/2013 ( 78 FR 24992 )

## 11

20 DCMR section 711 Pumps and Compressors VOC 3/15/1985 10/27/1999 ( 64 FR 57777 ) 20 DCMR section 712 Waste Gas Disposal from Ethylene Producing Plants VOC 3/15/1985 10/27/1999 (64 FR 57777) 20 DCMR section 713 Waste Gas Disposal from Vapor Blow - Down Systems VOC 3/15/1985 10/27/1999 (64 FR 57777) 20 DCMR section 714 VOC RACT based on Control Techniques Guidelines (CTG) VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR section 715 Non - CTG VOC RACT VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR section 716 Graphic Arts Controls VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR section 718 Surface Cleaning/ Degreasing for Machinery/ Automobile Repair VOC 11/26/2004 12/23/2005 ( 69 FR 76855 ) 20 DCMR sections 719 to 737 Reformulated Consumer Products Rule, Phase I VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 743 to 749 Industr ial Adhesives and Sealants Rule VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 751 to 758 Portable Fuel Containers Rule, Phase I VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 763 to 769 Solvent Cleaning Operations Rule VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 770 and 771 Reformulated Industrial Cleaning Solvents VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR sections 773 to 778 Architectural and Industrial Maintenance Coatings Rule VOC 12/30/2011 4/29/2013 ( 78 FR 24992 ) 20 DCMR section 801 19 

## Sulfur Content of Fuel Oil 1 

## SO 2 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 802 Sulfur Content of Coal SO 2 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 803 Sulfur Process Emissions SO 2 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 20 DCMR section 804 Nitrogen Oxide Emissions from Steam Generating Units NO X 

## 3/15/1985 8/28/1995 ( 60 FR 44431 ) 19 

### The District submitted amendments to this rule as a revision to the SIP on January 27, 2016.

## 12

20 DCMR section 805 NOx RACT NO X 

## 4/16/2004 12/28/2004 ( 69 FR 77645 ) 20 DCMR section 915 National Low Emissions Vehicle Program NO X 

## , VOC 2/11/2000 7/20/2000 (65 FR 44981) 20 DCMR chapter 10 NO X 

## SIP Call Requirements NO X 

## 12/8/2000 12/22/2000 ( 65 FR 80783 ) Regional Haze Plan, codified in 40 CFR 52.470 Includes s ource - specific requirements for PEPCO Benning NO X 

## , SO 2 

## 10/27/2010 2/2/2012 ( 77 FR 5191 ) 18 DCMR sections 4, 6, 7, 11, 26, and 99 (portions) High - Tech (Enhanced) Inspections and Maintenance PM 2. 5 

## , VOC (various ) 4/10/1986 ( 51 FR 12322 ); 6/11/1999 (64 FR 31498) 

## EPA is not approv ing or disapprov ing any existing provisions in the District SIP with regard to excess emissions during startup, shutdown, and malfunction (SSM) of operations at a facility. EPA also does not intend to reapprove any existing District SIP provisions which may address excess emissions during SSM by this infrastructure SIP rulemaking. EPA believes that a number of states have SSM provisions which are contrary to the CAA and existing EPA guidance . On June 12, 2015, EPA issued a finding t hat certain SIP provisions in 36 states (applicable in 45 statewide and local jurisdictions) are substantially inadequate to meet CAA requirements and thus issued a “SIP call” for each of those 36 states. 80 FR 33840. See also 78 FR 12460 (February 22, 2 013) (proposed finding for SIP call) . The District was among the 36 states for the SIP call. EPA established a due date for states subject to the SIP call to submit corrective SIP revi sions. The June 12, 2015 final action also embodied EPA ’ s updated SSM policy (2015 SSM Policy) as it applies to SIP provisions. 20 

## The 2015 SSM Policy provides guidance to states for compliance with CAA requirements for SIP provisions applicable to excess emissions during SSM events. Thus EPA is addressing such state regula tions in a separate rulemaking and not during review of infrastructure SIP submittals. In the meantime, EPA encourages any state having a deficient SSM provision to take steps to correct it as soon as possible. Also in this action, EPA is not proposing to approve or disapprove any existing District rules (nor reapprove any such rules already in the District S IP) with regard to director’s discretion or variance provisions. EPA believes that a number of states including the District have such provisions which are contrary to the CAA and existing EPA guidance, and EPA is addressing such regulations in separate rulemaking action via its June 12, 201 5 SIP Call. See 80 FR 33840 . In the meantime, EPA encourages any state having director’s discretion or varia nce provisions which are contrary to the CAA and EPA guidance to take steps to correct the deficiency as soon as possible. 20 

### Previous EPA guidance on SSM in SIPs was in the August 11, 1999 Steven Herman and Robert Perciasepe Guidance Memorandum, “State Implementation Plans: Policy Regarding Excess Emissions During Malfunctions, Startup, and Shutdown.”

## 13

Based upon EPA’s review of the District’s December 28, 2015 infrastructure SIP submittal, EPA finds that the District has met its obligations pursuant to 110(a)(2)(A) for the 201 2 annual PM 2 .5 

## NAAQS . B. Section 110(a)(2)(B) To satisfy section 110(a)(2)(B), states need to have statutory or regulatory provisions that provide the authority and responsibility to perform air quality monitoring activities in accordance with EPA’s requirements. EPA concurs with the District’s statement that it has the authority to conduct ambient air quality monitoring under the Distr ict of Columbia Air Pollution Control Act of 1984 (APCA) (D.C. Official Code section 8 - 101.05 (b)(1)(A ) ). The District’s authority under the APCA is then delegated to DDOE E under the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07) and Mayor’s Order 2006 - 61 (June 14, 2006) . The District’s most relevant existing SIP provisions regarding air quality monitoring activities are found in 20 DCMR section 400. As required by these provisions, public reportin g of air pollution levels are based on the results of air quality monitoring. DDOE E monitors air quality for t he 201 2 annual PM 2 .5 

## NAAQS at appropriate locations, in accordance with EPA’s ambient air quality monitoring network requirements. See EPA’s Amb ient Monitoring Technology Information Center (AMTIC) website, 40 CFR part 53 , 40 CFR part 58 , and 40 CFR 51.190. DDOE E is responsible for operating and maintaining the District’s air quality monitoring stations and sends collected air samples to EPA appr oved laboratories for analysis. DDOE E performs quality - assurance checks and submits the data to EPA’s Air Quality System (AQS) quarterly, in accordance with 40 CFR part 58. Thus, EPA finds that the District has established and currently operates appropri ate devices, methods, systems, and procedures necessary to monitor, compile, and analyze data on ambient air quality, and upon request, makes such data available to EPA. The District provides information to EPA regarding air quality monitoring activities, including a description of its compliance with EPA’s monitoring requirements and an explanation of any proposed changes to the air monitoring network. DDOE E submits annually to EPA an air quality monitoring network plan and a periodic network assessment every five years, consistent with 40 CFR 58.10. In each annual network plan, DDOE E provides notification to EPA of any proposed changes to the monitoring network or the measurement methods, consistent with the applicable requirements in 40 CFR 58.14. EPA Region III’s Regional Administrator sends a letter annually to the District indicating whether the network p lan and any proposed change s to the network , as substantiated in the plan, meet all applicable monitoring requirements. The District’s 2015 Annual Ambient Air Monitoring Network Plan submitted on June 19, 2015 was approved by EPA i n a November 12 , 201 5 letter to DDOE E . EPA’s approval of the District’s 201 5 monitoring n etwork p lan confirms that the District’s air monitoring program contin ues to meet f ederally established monitoring and data assessment criteria for the respective pollutant. Based upon EPA’s review of the District’s December 28, 2015 infrastructure SIP submittal, EPA finds that the District has met its obligations pursuan t to 110(a)(2)(B) for the 201 2 annual PM 2 .5 

## NAAQS .

## 14

C. Section 110(a)(2)(C) This infrastructur e element consists of three sub elements: Enforcement ; state - wide regulations of new and modified minor sources and minor modifications of majors sources ; and preconstruction permitting of major sources and major modifications within areas designated attainment or unclassifiable for the subject NAAQS. The District provisions that provide for enforcement of the emission limits and control measures 

## previously identified to satisfy CAA section 110(a)(2)(A) include the monitoring, recordkeeping, and reporting requirements found in certain sections of 20 DCMR Chapters 1 and 5, all of which have been approved into the District SIP. Consistent with 40 CFR 51.160 through 51.164, the District’s minor preconstruction permitting program is codified in Title 20 DCMR chapter 2 and approved into the District SIP. The District’s minor permitting program applies to all regulated pollutants under the CAA, includ ing PM 2.5 

## , NO X 

## , VOC, and SO 2 

## , regardless of nonattainment status. This satisfies the subelement for preconstruction of the construction and modification of minor stationary sources and the minor modification of major stationary sources. As explained earl ier, EPA has determined that the portions of the District’s infrastructure SIP s ubmittal addressing the subelement of section 110(a)(2)(C) related to the PSD permitting requirements under part C of Title I of the CAA are technically incomplete. As a result, EPA is not taking rulemaking action on the PSD - related portions of the submittals for section 110(a)(2)(C) for the 201 2 annual PM 2 .5 

## NAAQS . EPA does not anticipate any adverse consequences to the District, as the Federal PSD rules fully addre ss this requirement through EPA’s FIP which covers the District. With respect to 110(a)(2)(C) and a PSD permit program, EPA interprets the CAA to require each state to make an infrastructure SIP submission for a new or revised NAAQS that demonstrates that the air agency has a complete PSD permitting program meeting the current requirements for all regulated NSR pollutants. Because the District is subject to EPA’s FIP for PSD which implements 40 CFR 52.21, the PSD program currently in place through the FIP covers all regulated NSR pollutants, including GHGs as appropriate. On June 23, 2014, the United States Supreme Court issued a decision addressing the application of PSD permitting requirements to GHG emissions. Utility Air Regulatory Group v. Environm ental Protection Agency , 134 S.Ct. 2427. The Supreme Court said that EPA may not treat GHGs as an air pollutant for purposes of determining whether a source is a major source required to obtain a PSD permit. The Court also said that EPA could continue to require that PSD permits, otherwise required based on emissions of pollutants other than GHGs, contain limitations on GHG emissions based on the application of Best Available Control Technology (BACT). In order to act consistently with its understanding of the Court’s decision pending further judicial action to effectuate the decision, EPA is not continuing to apply EPA regulations that would require that SIPs include permitting requirements that the Supreme Court found impermissible. Specifically, EPA i s not applying the requirement that a state’s SIP - approved PSD program require that sources obtain PSD permits when GHGs are the only pollutant (i) that the source emits or has the potential to emit above the major source thresholds, or (ii) for which

## 15

ther e is a significant emissions increase and a significant net emissions increase from a modification ( e.g. 40 CFR 51.166(b)(48)(v)). EPA anticipates a need to revise Federal PSD rules in light of the Supreme Court opinion. In addition, EPA anticipates that many states will revise their existing SIP - approved PSD programs in light of the Supreme Court’s decision. The timing and content of subsequent EPA actions with respect to the EPA regulations and state PSD program approvals are expected to be informed by additional legal process before the United States District Court for the District of Columbia Circuit. At this juncture, EPA is not expecting states to have revised their PSD programs for purposes of infrastructure SIP submissions and is only evaluating such submissions to assure that the state’s program correctly addresses GHGs consistent with the Supreme Court’s decision. At present, b ecause the District is subject to the PSD FIP, the Federal PSD p rogram within the District continues to require that PSD permits (otherwise required based on emissions of pollutants other than GHGs) contain limitations on GHG emissions based on the application of BACT. Although t he PSD FIP implementing the federal pr ovisions of 40 CFR 52.21 may currently contain provisions that are no longer necessary in light of the Supreme Court decision , the FIP will automatically update when or if EPA updates these provisions . Meanwhile, the PSD FIP contains the necessary PSD req uirements at this time, and the application of those requirements is not impeded by the presence of other previously - approved provisions regarding the permitting of sources of GHGs that EPA does not consider necessary at this time in light of the Supreme C ourt decision. Accordingly, the Supreme Court decision does not affect the determination that the PSD FIP for the District addresses the deficiency in the District’s SIP as required under section 110(a)(2)(C) and part C of t itle I of the CAA. Based upo n EPA’s review of the District ’s December 28, 2015 infrastructure SIP submittal , EPA finds that the District has met its obligations pursuant to 110(a)(2)(C) for the 201 2 annual PM 2 .5 

## NAAQS , with the exception of the portions related to PSD for which the District is subject to a FIP. D. Section 110(a)(2)(D) 1. Section 110(a)(2)(D)(i)(I) Section 110(a)(2)(D)(i)(I) addresses emissions activity in one state that contributes significantly to nonattainment, or interferes with maintenance, of the NAAQS in another state. EPA sometimes refers to these requirements as “good neighbor” provisions o r prong 1 (significant contribution to nonattainment) and prong 2 (interference with maintenance). The District’s December 28, 2015 infrastructure SIP submittal for the 201 2 annual PM 2 .5 

## NAAQS include s a component to address section 110(a)(2)(D)(i)(I) relating to interstate transport. EPA ’s memorandum regarding the 2012 PM 2 .5 

## NAAQS and the “good neighbor” provisions indicates that there are a few areas in the continental US where transported emission s might potentially impact attainment and/ or maintenance of the NAAQS. These areas are primarily in Califo r nia along with an area in Idaho, and one location in southwestern Pennsylvania. The District is located approximately 200 miles from the closest out of state location (Allegheny

## 16

County PA) that may have issues with maintenance of the NAAQS. The PA location is northwest of t he District. Generally , the predominant wind direction would be from east to west in and around the District which is not in the direction of the PA location. A ir quality data indicates that ambient concentrations of both annual and daily PM 2 .5 

## have declined significantly in the District and annual design values have been at or below the 2012 standard since 2010. The District no longer has large sources of PM 2 .5 

## such as electric generating units and anticipates additional reductions in precursor emissions as its new regulation reducing SO 2 

## in fuels is implemented. The information in the District’s submittal regarding air quality trends inside the D istrict as well as information about emissions of direct PM 2 .5 

## and precursors discussed herein provide a strong weight of evidence argument that emissions from this very small geographic area (i.e., the District) are not interfering with attainment or maintenance of the 2012 PM 2 .5 

## NAAQS in any areas outside of the Dist r i c t. In addition, EPA has approved a maintenance plan for the 1997 PM 2 .5 

## NAAQs for this area. The notice which proposed approval of this maintenance plan includes a table (Table 6) of direct PM 2 .5 

## and precursor emissions projected in 2017 and 2025 which indicates that emissions of direct PM 2 .5 

## and precursors will continue to d ecline over the next several years. See 79 FR 45735 ( August 6, 2014 ) . Based upon EPA’s review of t he December 28, 2015 infrastructure SIP submittal in conjunction with the EPA “good neighbor” memo on the 2012 PM 2 .5 

## NAAQS and information in EPA’s approval of a 1997 PM 2 .5 

## NAAQS maintenance plan , EPA finds that the District has met its obligations pursuant to 110(a)(2)(D)(i)(I) and finds that emission within the Dist rict do not cont r ibute significantly to nonattainment, n or interfere with maintenance, of the NAAQS in another state. 2. Section 110(a)(2)(D)(i)(II) The infrastructure element in section 110(a)(2)(D)(i)(II) requires SIPs to include provisions prohibiting any source or other type of emissions activity in one state from interfering with measures required of any other state to prevent significant deterior ation of air quality or from interfering with measures required of any other state to protect visibility in Class I areas. EPA sometimes refers to these requirements as prong 3 (interference with PSD) and prong 4 (interference with visibility protection). Prong 3 of section 110(a)(2)(D)(i)(II) requires states SIPs to have provisions prohibiting emissions that would interfere with measures required to be in any other state SIP under part C of the CAA to prevent significant deterioration of air quality. Because part C of t itle I of the CAA requires a state’s PSD program to address all pollutants subject to regulation under the CAA, EPA interprets prong 3 to mean that infrastructure SIP submissions should provide SIP provisions containing a comprehensive P SD permitting program. As explained earlier, EPA has determined that the portions of the District’s infrastructure SIP submittals for addressing the subelement in section 110(a)(2)(D)(i)(I I ) related to the PSD permitting requirements under part C of t itle I of the CAA are technically incomplete. As a result, EPA is not taking rulemaking action on the PSD - re lated portions of the submittal for section 110(a)(2)(D)(i)(I I ) for the 201 2 annual PM 2 .5 

## NAAQS . EPA does not anticipate any adverse consequences to the District from

## 17

this lack of full approval, as the Federal PSD rules fully address this requirement through EPA’s FIP for the District. Prong 4 of section 110(a)(2)(D)(i) (II) requires that SIPs cont ain adequate provisions prohibiting any source or other type of emissions activity in one state from emitting air pollutants in amounts which will interfere with measures required to be included in the applicable implementation plan for any other state und er part C of title I of the CAA to protect visibility. EPA interprets prong 4 to be pollutant - specific, such that an infrastructure SIP submission need only address potential interference with protection of visibility caused by the pollutant, including p recursors, to which the subject NAAQS applies. Further, EPA interprets prong 4 to be satisfied for any relevant NAAQS by confirmation that the states has an approved Regional Haze SIP that fully satisfies the requirements of 40 CFR 51.308 or 51 .309. 21 

## As indicated in the infrastructure submittal, t he District’s Regional Haze Program to address visibility impairment requirements in Class I areas was fully approved into the District SIP by EPA. See 77 FR 5191 (February 2, 2012). The District’s Regional Haz e SIP is consistent with EPA’s requirements in 40 CFR 51.308 and 51.309, addressed any contribution to visibility impairment related to emissions of PM 2.5 

## and its precursors, and included measures to address emissions that would interfere with reasonable progress goals of neighboring states set to protect Class I areas. Based upon EPA’s review of t he December 28, 2015 infrastructure SIP submittal , EPA finds that the District has met its obligations pursuant to 110(a)(2)(D)(i)(II) for visibility protection for the 201 2 annual PM 2 .5 

## NAAQS . 3. Section 110(a)(2)(D)(ii) Section 110(a)(2)(D)(ii) is satisfied when an infrastructure SIP ensures compliance with the applicable requirements of se ction 126(a), 126(b), 126(c), and 115 of the CAA. Under section 126(a)(1) of the CAA, each SIP must contain provisions requiring each new or modified major source, that is either (a) subject to PSD under CAA title I part C, or (b) that may significantly contribute to levels of pollution in excess of a NAAQS in any other region outside of the state in which the source is located, to notify neighboring states of potential impacts from the source. 22 

## Because the Distri ct lacks a SIP - approved PSD program, EPA has determined that the portions of the District’s December 28, 2015 infrastructure submittal addressing the subelement in section 110(a)(2)(D)(ii) related to the PSD permitting requirements are technically incomple te. Thus, EPA is not taking rulemaking action on the PSD - re lated portion of the submittal for section 110(a)(2)(D)(ii) for the 201 2 annual PM 2 .5 

## NAAQS . EPA concurs w ith the assertions in the infrastructure SIP sub mission that the District has no pending obligations at this time for the 201 2 annual PM 2 .5 

## NAAQS pursuant to CAA sections 21 

### Because of the impacts on visibility from the interstate transport of pollutants, EPA has interpreted this provision of CAA section 110 as requiring states to include in their SIPs measures to prohibit emissions that would interfere with the reasonable progress goals set to pro tect Class I areas in other states. See 76 FR 52388 (August 22, 2011) (disapproval of a portion of New Mexico SIP related to 110(a)(2)(D)(i)(II) and promulgation of FIP to address deficiency) and 76 FR 491 (January 5, 2011) (proposed action on same). 22 

### EPA notes that the requirement in CAA section 126(a)(2) was a one - time obligation on states that does not apply to EPA’s review of infrastructure SIP submissions.

## 18

126(b) and (c) . EPA also concurs with the District’s statements in the infrastructure SIP submittal that there are no findings under CAA section 115 against t he District with respect to the 201 2 annual PM 2 .5 

## NAAQS . EPA also finds that the District’s SIP has adequate provisions insuring future compliance with the requirements of sections 126(b), 126 (c), and 115 of the CAA, as may be necessary. Based upon EPA’s review of the December 28, 2015 infra structure SIP submittal , EPA finds that the District’ s SIP submittal meet the requirements of CAA section 110(a)(2)(D)(ii) for the 201 2 annual PM 2 .5 

## NAAQS , with excep tion of the PSD - related portion for which the District’s SIP submission is incomplete. E. Section 110(a)(2)(E) 1. Section 110(a)(2)(E)(i) For section 110(a)(2)(E)(i), the infrastructure SIP submission should provide necessary assurances that the state has adequate personnel and funding to implement the relevant NAAQS. As indicated in the SIP submissions, DDOE E is responsible for carrying out any SIP obligations for implementation of the NAAQS, including the 201 2 annual PM 2 .5 

## NAAQS . In accordance with 40 CFR part 51, subpart M, the District has identified the Metropolitan Washington Air Quality Committee (MWAQC) and the Interstate Air Quality Council (IAQC) as participating organizations in planning and developing SIP provisions for the District. A s indicated, a copy of the inter - or ganizational agreements between MWAQC and DDOE E were approved into the District’s SIP in the approved infrastructure SIP revision for the 2008 lead standard. See 78 FR 62455 (October 22, 2013). In accordance with 40 CFR part 51, subpart L, the District has adequate authority to carry out its SIP obligations under state law pursuant to the District APCA (D.C. Official Code section 8 - 101.05(b)( 1)(C) ) and its delegation of authority to DDOEE under the District Department Establishment Act of 2005 (D.C. Official Code section 8 - 151.07 ). At present, the District states it fulfills its SIP obligations by virtue of having adequate personnel and funding . The District has the authority to receive and administer grants or donations for its air pollution control program, pursuant to the District APCA (D.C. Official Code section 8 - 101.05(c)(3)). Funding resources are acquired through the CAA sections 103 and 105 grant processes ( federal grant funds) , the District Department of Transportation (DDOT), and the District Department of Motor Vehicle motor vehicle inspection fees. These funding resources were available as of the date of the infrastructure SIP submission and are expected to be adequate for f ive years following the submissions. DDOE E anticipates both adequate personnel and funding to meet any changes in the implementation of the 201 2 annual PM 2 .5 

## NAAQS . Based upon EPA’s review of t he District’s December 28, 2015 infrastructure SIP submittal , EPA finds that the District has met its obligations pursuant to 110(a)(2)(E)(i) for the 201 2 annual PM 2 .5 

## NAAQS . 2. Section 110(a)(2)(E)(ii)

## 19

Section 110(a)(2)(E)(ii) requires SIP s to include approved provisions that comply with requirements of CAA sec tion 128 with respect state boards. The District is in compliance with the applicable requirements of section 128 through its conflict of interest provisions in the D.C. Official Code section 1 - 1161.01, 1 - 1162.23, 1162.24 and 1162.25, which have been appr oved into the District SIP. See 78 FR 62455 (October 22, 2013). EPA notes that the District does not have a “board or body” to approve permits or enforcement orders, therefore the requirements under paragraph (a)(1) of CAA Section 128 are not applicable. EPA finds that the District has met its obligations pursuant to 110(a)(2)(E)(ii ) for the 2012 annual PM 2.5 

## NAAQS . 3. Section 110(a)(2)(E)(iii) Section 110(a)(2)(E)(ii) requires the infrastructure SIP to provide necessary assurances that, when the state relies on any local or regional government for implementation of the SIP, it has responsibility for ensuring adequate implementation of the SIP. As indicated in th e infrastructure SIP submission , the District does not rely on localities for implementation of the SIP for the 201 2 annual PM 2 .5 

## NAAQS . Thus, EPA finds that the requi rements of section 110(a)(2)(E)(iii) are not applicable to the District. EPA fin ds the District’s December 28, 2015 infrastructure SIP submittal meet s obligations pursuant to 110(a)(2)(E)(iii) for the 201 2 annual PM 2 .5 

## NAAQS . F. Section 110(a)(2)(F) 1. Section 110(a)(2)(F)(i) and (ii) To satisfy sections 110(a)(2)(F)(i) and (ii), states need to provide statutory or regulatory provisions to perform stationary source monitoring and emissions reporting in accordance with EPA’s regulations. Specifically , EPA’s source monitoring requirements are contained in 40 CFR 52.212 and EPA’s requirements for periodic reporting of emissions requirements are provided in 40 CFR 51.211, 40 CFR 51.321 through 51.323, and 40 CFR part 51, subpart A. EPA notes that in pra ctice, the reporting requirements of 40 CFR 51.321 have been superseded by 40 CFR 51.45(b) for electronic submission of emissions reports. EPA concurs with the District’s statement in the infrastructure SIP submittal that it has the adequate authority to conduct stationary source monitoring and to require periodic reporting under the District APCA (D.C. Official Code sections 8 - 101.05( b )(1) (A) ). This authority is delegated to DDOE E under the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07 ) and Mayor’s Order 2006 - 61 (June 14, 2006) . In accordance with 40 CFR 51.212, the District’s source monitoring requirements, including periodic testing and inspection requirements, are found throughout the District ’s SIP approved provisions of 20 DCMR chapter 1, chapter 2, chapter 3, section 307, and chapter 5, section 502. These regulations are included and codified in the District SIP in 40 CFR 52.470(c) and are applicable to the 201 2 annual PM 2 .5 

## NAAQS . Consistent with EPA’s source emissions reporting r equirements, the District’s SIP approved provisions of 20 DCMR chapter 2 require sources to submit to DDOE E emissions and emissions - related data on an annual basis.

## 20

The District complies with 40 CFR 51.45(b) by submitting emissions inventory data to EPA’s National Emissions Inventory (NEI) System . T he District provides in the infrastructure submittal the necessary assurance that it will make any necessary changes to emissions inventory reporting relevant to the 201 2 annual PM 2 .5 

## NAAQS , as required. 2. Section 110(a)(2)(F)(iii) Section 110(a)(2)(F)(iii) is satisfied by the states having provisions in place that provide for correlation of source emission reports with applicable emission limitations or standards and provide public availability of such reports. The District has the author ity to review emissions reports submitted by stationary sources under the District APCA (D.C. Official Code section 8 - 101.05( b )(1) (A) ). This authority is delegated to DDOE E under the District Department of the Environment Establishment Act of 2005 (D. C. Official Code section 8 - 151.07 ) and Mayor’s Order 2006 - 61 (June 14, 2006) . DDOE E air quality inspectors correlate the emissions data with any applicable emissions limitations or standards. Data reported would reflect the applicable test methods and averaging periods used consistent with the applicable emissions limitations and standards, as required by permits. The District’s source emissions reports are available for public inspection through the District’s normal administrative procedures, such as described under the District’s Freedom of Information Act (D.C. FOIA) (D.C. Official Code section 2 - 532 et seq . (2013 Repl.)). Based upon EPA’s review of the December 28, 2015 infrastructure SIP submittal, EPA finds that the District has met its obligations pursuant to 110(a)(2)(F)(i), (ii) and (iii) for the 201 2 annual PM 2 .5 

## NAAQS . G. Section 110(a)(2)(G) and the District’s Air Quality Emergency Plan Section 110(a)(2)(G) req uires states to provide authority comparable to that of the EPA Administrator under section 303 of the CAA and adequate contingency plans to implement such authority. Specifically, CAA section 303 provides authority to the EPA Administrator to seek a cour t order to restrain any source from causing or contributing to emissions that present an imminent and substantial endangerment to public health, welfare, or the environment. The District has the authority to implement SIP - approved provis ions under the D istrict APCA ( D.C. Official Code section 8 - 101.05( c)(4 ), which is delegated to DDOE E through the District Department of the Environment Establishment Act of 2005 (D.C. Official Code 8 - 151.07). The District has authority comparable to EPA’s imminent and su bstantial endangerment authority in CAA section 303 under the SIP - approved provisions in 20 DCMR chapter 4, section 401. EPA’s requirements for contingency plans to implement the state’s emergency episode authority are found in 40 CFR part 51, subpart H (40 CFR 51 . 150 through 51.153). Subpart H includes criteria for classification of areas into priority regions, based on ambient air concentrations of the partic ular pollutant being addressed. Specifically, if an area is classified as a Priority I region for a specified pollutant, the state would need to provide a contingency plan (with respect to that pollutant) that would need to include provisions that trigger actions to prevent air quality

## 21

concentrations from reaching a “significant harm level” (SHL), which represents an imminent and substantial endangerment to public health. The currently applicable priority classification for regions in each state are incorporated into the SIPs. Contingency plan requirements are specified in 40 CFR 51. 1 51 and 51.15 2, and an example of a plan is provided in appendix L to 50 CFR part 51. As specified in 4 0 CFR 52.471, the entire District is part of the National Capital Interstate Air Quality Control Region, which is classified as a Priority I region for PM , sulfur oxides (S O X 

## ), carbon monoxide (CO) , and ozone . On April 13, 2015, EPA approved as a SIP revision the District’s 

## Air Quality Emergency Episode Plan addressing the current requirements of 40 CFR part 51, subpart H for all applicable pollutants. 80 FR 19538 . This plan provides the public adequate communication regarding air quality data forecasts and h ealth effects of air pollution regarding the applicable pollutants , including PM . 

## While EPA’s subpart H regulations provide specific ambient levels for contingency plan purposes for most applicable pollutants , the regulations currently do not specifically address PM 2.5 

## as a subset of PM . EPA has recommended through guidance specific ambient levels for contingency purposes for the 1997 and 2006 24 - hour PM 2.5 

## NAAQS, including a SHL. 23 

## EPA also recognizes that a specific SHL or other contingency levels have not yet been established for the 2012 annual PM 2.5 

## NAAQS. See 78 FR 3086 (January 15, 2 013). In the absence of a SHL, EPA continues to believe that the central components of a contingency plan would be to reduce emissions from the PM 2.5 

## source(s) at issue and public communication as needed EPA recommended to states in previous guidance to develop PM 2.5 

## emergency episode plans for any area that had monitored and recorded 24 - hour PM 2.5 

## levels greater than 140 μg/m 3 

## from 2006 (i.e., “Priority I Level”) to meet the requirements of section 110(a)(2)(G) for the 1997 annual and 2006 24 - hour PM 2.5 

## NAAQS. If this level was never exceeded in any area of the state, EPA recommended the state to certify that it has appropriate general emergency powers to address PM 2. 5 

## related episodes, and that no specific emergency episode plans are necessary at this time, given the existing monitored level. T he District asserts in its December 28, 2015 infrastructure submittal that no specific contingency provisions are needed for the PM 2.5 

## NAAQS , based on its evaluation of air quality monitoring data for PM 2.5 

## . The District also certifies that its general emergency powers under 20 DCMR chapter 4, section 401 are adequate to address any potential PM 2.5 

## related episodes as necessary . EPA reviewed historical 24 - hour PM 2.5 

## monitoring data for the District since 2006. See AQS report (AMP 440 ) dated June 6, 2016 attached . EPA finds that 24 - hour PM 2.5 

## concentrations have been well below 140 μg/m 3 

## between 2006 and 2015. Given this fact, and because the District has demonstrated that it has appropriate general emergency powers to address PM 2.5 23 

### See a memorandum from William T. Harnett, Director, Air Quality Policy Division, OAQPS, t o Regional Air Division Directors, Regions I through X, “Guidance on SIP Elements Required Under Sections 110(a)(1) and (2) for the 2006 Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS).” (September 25, 2009). In this guidance document , EPA recommended SHLs, priority levels, and action levels for both the 1997 annual and 2006 24 - hour PM 2.5 

### NAAQS.

## 22

related episodes and PM 2.5 

## sources, EPA finds that no specific or additional emergency episode plans are necessary at this time to meet the applicable requirements for PM 2.5 

## . Further , EPA finds that the District’s existing contingency plan continues to adequately meet the requirements of 40 CFR 51 subpart H for all applicable pollutants. Based upon EPA’s review of the December 28, 2015 infrastructure SIP submittal and a review of the monitoring data , EPA finds that the District has met its all pending obligations pursuant to 110(a)(2)( G ) for the 201 2 annual PM 2 .5 

## NAAQS. H. Section 110(a)(2)(H) Section 110(a)(2)(H) requires that SIPs provide for revision of the plan from time to time as may be necessary to take account of revisions of the NAAQS or the availability of improved or more expeditious methods of attaining the standards and to revise th e plan whenever EPA finds that the SIP is substantially inadequate to attain the NAAQS or to otherwise comply with any additional requirements under the CAA. Through its infrastructure SIP submittal , the District has demonstrated that it has adequate au thority to revise its SIP as necessary under the District APCA ( D.C. Official Code section s 8 - 101.05(b)( 1 ) (D) and 8 - 101.06) , which is delegated to DDOE E under the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07) and Mayor’s Order 2006 - 61 (June 14, 2006) . As necessary, the District submits revisions to its SIP for EPA approval to account for revisions of primary and/or secondary NAAQS or to adopt improved or more expeditious control methods for attainmen t of such standards, or in the event that EPA finds the SIP to be substantially inadequate to either attain the NAAQS or to otherwise comply with any additional requirements. Based upon EPA’s review of t he District’s December 28, 2015 infrastructure SIP submittal , EPA finds that the District has met its obligations pursuant to 110(a)(2)(H) for the 201 2 annual PM 2 .5 

## NAAQS . I. Section 110(a)(2)(I) The District ’s infrastructure SIP submittal for the 201 2 annual PM 2 .5 

## NAAQS d oes not include or address CAA section 110(a)(2)(I). As indicated earlier, EPA does not expect infrastructure SIP submissions to address this element, because nonattainment area plans required under part D of title I of the CAA are required on a different sc hedule from section 110(a)(2) infrastructure elements of the CAA and thus, will be reviewed and acted upon through a separate process. J. Section 110(a)(2)(J) Section 110(a)(2)(J) requires SIPs to meet the applicable requirements of CAA section 121 and 127, as well as part C of title I of the CAA. EPA interprets this infrastructure elemen t to contain four separable sub elements: consultation with identified off icials on certain air agency actions as listed under CAA section 121; public notification; prevention of significant deterioration, and visibility protection.

## 23

1. Sub element: Consultation (CAA Section 121) Consistent with the consultation requirements of CAA s ection 121, the District assures that it has an established consultation process for consultation with general - purpose local governments, designated organizations of elected officials of local governments, and Federal land managers as appropriate. Th e consultation process takes place through MWA Q C according to a set of bylaws that are reviewed and adopted annually, as previously discussed for section 110(a)(2)(E). The District has the authority for such consultation processes under the District APCA ( D.C. Official Code section 8 - 101.05( b )( 1)(c) ), which is delegated to DDOE E through the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07 ) and the Mayor’s Order 2006 - 61 (June 14, 2006) . The District’s interagency and public consultation provisions specifically associated with the transportation conformity process, are included in 20 DCMR chapter 15, sections 1506 and 1507. Additionally, consultation with Federal land managers takes place separately as required by CAA section 169A and 40 CFR 51.308, as specified in the District’s SIP approved Regional Haze SIP. See 77 FR 5191 (February 2, 2012). 2. Sub element: Public Notification (CAA Section 127) To satisfy this sub element, the District must ensure that DDOE E regularly notifies the public of instances or areas in which the new or revised NAAQS are exceeded; advises the public of the health hazards associated with such exceedances; and enhances public awareness of measures that can prevent such exceedances and of ways the public can participate. The District assures that the general public is regularly notified of and educated about NAAQS e xceedances . In accordance with title 20 DCMR ch apter 4, section 400 and 40 CFR 51.285, the District is required, in coor dination with MWCOG, to ensure air pollution levels are reported to the public. Additionally, the District relies on Clean Air Partners, a nongovermental organization that works with businesses, organizations, and individuals to raise awareness and reduce air pollution through voluntary activities. 24 

## Clean Air Partners provides air quality forecasts and related information to the public. 3. Sub element: Prevention of Significant Deterioration (CAA Title I, Part C) Approvability of this sub element is intrinsically related to approvability of the state’s PSD program, in accordance with part C of t itle I of the CAA. As explained earlier, EPA has determined that the portions of the District’s infrastructure SIP submittals for addressing the su belement in section 110(a)(2)(J) related to the PSD permitting requirements under part C of t itle I of the CAA are technically incomplete. As a result, EPA is not taking rulemaking action on the PSD - related portions of the submittals for section 110(a)(2) (J) for the 201 2 annual PM 2 .5 

## NAAQS . EPA does not anticipate any adverse consequences to the District from this lack of full approval, as the Federal PSD rules fully address this requirement through EPA’s FIP for the District. 24 

### Clean Air Partners is a nonprofit (501 c - 3) partnership chartered by the MWCOG and the Baltimore Metropolitan Council.

## 24

4. Sub element: Visibility Protection With regard to visibility protection, EPA recognizes that states are subject to visibility and regional haze progra m requirements under part C of t itle I of the CAA (sections 169A and 169B). In the event of the establishment of a new NAAQS, however, the visibility and regional haze program requirements under part C do not change. Thus, EPA finds that there are no new applicable visibility protectio n obligations under section 110(a)(2)(J) when a new NAAQS is effective, and accordingly there are no applicable infrastructure requirements for the 201 2 annual PM 2 .5 

## NAAQS . EPA approved the District’s Regional Haze SIP revision on February 2, 2012 (77 FR 5191). Therefore, EPA previously found the District’s SIP addressed visibility protection and regional haze program requirements under part C of t itle I of the CAA. Based upon EPA’s review of t he District’s December 28, 2015 infrastructure SIP submitta l , EPA finds that the District has met its obligations pursuant to 110(a)(2)(J) for the 201 2 annual PM 2 .5 

## NAAQS , with the exception of the PSD - related requirements for which we previously found the District’ s infrastructure SIP submittal incomplete. K. Section 110(a)(2)(K) To satisfy section 110(a)(2)(K), states need to provide the authority and responsibility to perform air quality modeling to predict the effect on ambient air quality of any emissions of any air pollutant for which a NAAQS has been prom ulgated and to provide such modeling results to EPA upon request. The infrastructure SIP submission provide s that the District has the authority to conduct air quality modeling in order to assess the effect on ambient air quality from relevant pollutant emissions under the District APCA (i n D.C. Official Code section s 8 - 101.05( b )(1) (A) ), 8 - 101.05( c)(3) and 8 - 101 .05( c)(4)), which is delegated to DDOE E under the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07 ) and the Mayor’s Order 2006 - 61 (June 14, 2006) . The District commit ted to continue submit ting to EPA th e air quality modeling data as part of permitting and NAAQS implementation, as outlined in 20 DCMR chapter 3, section 303. Based upon EPA’s review of the December 28, 2015 infrastructure SIP submittal , EPA finds that the District has met its obligations p ursuant to 110(a)(2)(K) for the 201 2 annual PM 2 .5 

## NAAQS . L. Section 110(a)(2)(L) Section 110(a)(2)(L) requires SIPs to require the owner or operator of each major stationary source to pay to the permitting authority, as a condition of any permit required by the CAA, a fee sufficient to cover: (i) T he reasonable costs of reviewing and a cting upon any application for such a permit; and (ii) if the owner or operator receives a permit for such source, the reasonable costs of implementing and enforcing the terms and conditions of any such permit, until such fee requirement is superseded with respect to such sources by EPA's approval of a fee program under t itle V of the CAA.

## 25

In its infrastructure SIP submittal, the District satisfies section 110(a)(2)(L) by explaining that its approved t itle V permitting program provides for collection of adequate permitting fees, consistent with 40 CFR 70.9 and 40 CFR p art 70, a ppendix A . EPA approved the District’s t itle V program on August 7, 1996 (60 FR 40101) and its subsequent amendments on April 1 6, 2003 (68 FR 18548). The District’s t itle V program permitting fees provisions are found in 20 DCMR chapter 3, sections 305 and 307. 25 

## The District’s t itle V program fees are used to fund permitting (including reviewing and acting upon permit applicatio ns) and implementation and enforcement of permit terms for new and existing major stationary sources of air pollution. Based upon EPA’s review of t he December 28, 2015 infrastructure SIP submittal , EPA finds the District has met its obligations pursuant to 110(a)(2)(L) for the 201 2 annual PM 2 .5 

## NAAQS . M. Section 110(a)(2)(M) To satisfy the infrastructure element in CAA section 110(a)(2)(M), the SIP should provide for consultation with affected local political subdivisions. According to the submittal t he District has the authority for consultation with local entit ies under the District APCA ( in D.C. Official Code section 8 - 101.05( b )( 1 ) (C) ) , which is delegated to DDOEE under the District Department of the Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07) and the Mayor’s Order 2006 - 61 (June 14, 2006). Th e District’s consultation process takes place through MWA Q C accor ding to a set of bylaws that are reviewed and adopted annually. Additionally, the District’s interagency and public consultation provisions specifically associated with the transportation conformity process are included in 20 DCMR chapter 15, sections 150 6 and 1507. Finally, as specified under the District Administrative Procedure Act (D.C. Official Code section 2 - 505) and the District Department of Environment Establishment Act of 2005 (D.C. Official Code section 8 - 151.07(3)), each SIP undergoes a public notice and hearing process before its submission to EPA. According to the infrastructure SIP submission, leaders of political subdivisions may participate in this public process. Based on our review of the December 28, 2015 infrastructure SIP submi ttal, EPA finds t hat the District has met its obligations pursuant to 110(a)(2)(M) for the 201 2 annual PM 2 .5 

## NAAQS . VI I . RECOMMENDED AGENCY ACTION EPA finds that the District ’s infrastructure SIP submittal dated December 28, 2015 for the 201 2 annual PM 2 .5 

## NAAQS meet s the requirements of section 110(a)(2)(A), (B), (C), (D)(i)(I), (D)(i)(II) , (D)(ii), (E), (F), (G), (H), (J), (K), (L), and (M) of the CAA for the applicable NAAQS , with the exception of the specific PSD related requirements in section 110(a)(2 )(C), (D) and (J). The Dist rict’s infrastructure submittal for the 201 2 annual PM 2 .5 

## NAAQS d oes not address section 110(a)(2)(I) pertaining to the nonattainment requirements of part D, t itle I of the CAA because this element is not required to be submitted by the 3 - year submission deadline of CAA section 110(a)(1) and will be addressed in a separate process where necessary. 25 

### EPA notes that s tates title V programs are not required to be approved into the SIP. For that reason, the District’s title V permitting fees provisions are not approved into the SIP, however the program in its entirety has been approved by EPA.

## 26

EPA is not taking rulemaking action on the portions of the sub mittal addressing CAA section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) with respect t o the PSD permitting requirements of part C of t itle I of the CAA, because EPA has deemed these portions incomplete regarding the PSD elements due to the EPA FIP for PSD permitting requirements for the District. Thus, it is recommended that a notice of proposed rulemaking be prepared approving the relevant portions of the District’s December 28, 2015 SIP revision submittal for the 201 2 annual PM 2 .5 

## NAAQS .UNITED STATES ENVIRONMENTAL PROTECTION AGENCY MAXIMUM VALUES REPORT Jun. 6, 2016 Report Request ID: 1452034 Report Code: AMP440

Selection Criteria Page 1 User ID: HXN State County City Site Parameter POC AQCR UAR CBSA CSA EPA Region 11 GEOGRAPHIC SELECTIONS PROTOCOL SELECTIONS Parameter Classification Parameter Method Duration CRITERIA 88101

SELECTED OPTIONS MERGE PDF FILES EVENTS PROCESSING AGENCY ROLE Option Type Option Value YES REPORT ALL EVENT RECORDS

PQAO SORT ORDER 1 2 3 4 5 6 7 8 Order Column

PARAMETER_CODE STATE_CODE DURATION_CODE DATES COUNTY_CODE SITE_ID POC EDT_ID DATE CRITERIA 2006 Start Date End Date 2015 Tribal Code

APPLICABLE STANDARDS Standard Description PM25 Annual 2013EXCEPTIONAL DATA TYPES EDT DESCRIPTION 0 1 2 5 NO EVENTS EVENTS EXCLUDED EVENTS INCLUDED EVENTS WITH CONCURRENCE EXCLUDEDUNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 2 of 22 District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Secondary: Secondary: 2011 2012 1 HOUR 1 HOUR Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: 11-001-0043 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 7353 8398 8400 0 1 2 4 4 4 54.0 71.0 126.0 07/20:13 06/21:20 07/04:20 170 170 170 Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 53.0 54.0 106.0 07/04:20 01/23:12 07/04:21 50.0

54.0 71.0 06/11:09 06/21:16 06/21:20 50.0

54.0 54.0 07/21:04 12/01:21 01/23:12 48.0

53.0 54.0 03/27:22 01/23:11 06/21:16 48.0 52.0 54.0 07/04:22 12/02:02 12/01:21 48.0

51.0 53.0 07/20:12 06/02:22 01/23:11 47.0

51.0 52.0 07/21:03 12/02:01 12/02:02 45.0

49.0 51.0 08/13:19 07/08:15 06/02:22 44.0

49.0 51.0 07/20:15 12/02:00 12/02:01 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

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Page 3 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2012 2013 2014 1 HOUR 1 HOUR 1 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0043 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 8400 8427 8595 5 0 1 4 4 4 126.0 99.0 66.0 07/04:20 07/04:20 07/04:22 170 170 170 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 106.0 83.0 42.0 07/04:21 07/04:21 12/21:20 71.0

54.0 40.0 06/21:20 07/04:22 06/17:21 54.0

44.0 39.0 01/23:12 01/26:22 01/05:17 54.0

44.0 38.0 06/21:16 12/18:04 01/05:16 54.0 40.0 38.0 12/01:21 01/26:23 02/01:07 53.0

39.0 38.0 01/23:11 12/03:09 02/09:21 52.0

39.0 38.0 12/02:02 12/04:09 03/02:18 51.0

38.0 37.0 06/02:22 01/12:16 02/09:20 51.0

38.0 37.0 12/02:01 11/15:07 03/02:19 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

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Page 4 of 22 District Of Columbia

District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary:

Primary: Primary: Secondary:

Secondary: Secondary: 2014

2015 2015 1 HOUR

1 HOUR 1 HOUR Duration:

Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit:

Unit: Unit: 11-001-0043 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 8597 8597 8646 2 5 0 4 4 4 129.0 129.0 117.0 07/04:20 07/04:20 07/04:21 170 170 170 Year:

Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 111.0 111.0 103.0 07/04:21 07/04:21 07/04:22 66.0

66.0 75.0 07/04:22 07/04:22 07/04:23 42.0

42.0 75.0 12/21:20 12/21:20 09/03:09 40.0

40.0 74.0 06/17:21 06/17:21 06/29:18 39.0 39.0 51.0 01/05:17 01/05:17 07/04:20 38.0

38.0 45.0 01/05:16 01/05:16 12/06:08 38.0

38.0 43.0 02/01:07 02/01:07 07/05:00 38.0

38.0 42.0 02/09:21 02/09:21 09/02:14 38.0

38.0 40.0 03/02:18 03/02:18 12/12:04 1st Max 1st Max 1st Max 2nd Max

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State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 5 of 22 District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Secondary: Secondary: 2015 2006 1 HOUR 24 HOUR Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: 11-001-0051 11-001-0041 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 5115 351 352 0 1 2 1 1 1 239.0 45.0 74.1 07/04:21 08/02:00 07/04:00 170 120 120 Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 116.0 39.6 45.0 07/04:20 08/01:00 08/02:00 77.0

37.6 39.6 07/04:22 08/03:00 08/01:00 70.0

37.1 37.6 07/04:23 05/30:00 08/03:00 49.0

37.0 37.1 07/05:00 07/11:00 05/30:00 47.0 35.5 37.0 12/09:08 09/08:00 07/11:00 47.0

35.0 35.5 12/12:04 07/18:00 09/08:00 47.0

34.0 35.0 12/12:05 11/28:00 07/18:00 45.0

33.9 34.0 12/11:23 08/25:00 11/28:00 45.0

33.4 33.9 12/12:00 06/18:00 08/25:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

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Page 6 of 22 District Of Columbia

District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary:

Primary: Primary: Secondary:

Secondary: Secondary: 2006

2006 2006 24 HOUR

24 HOUR 24 HOUR Duration:

Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit:

Unit: Unit: 11-001-0041 11-001-0041 11-001-0042 Washington Washington Washington District of Columbia District of Columbia District of Columbia 352 59 118 5 0 0 1 2 1 74.1 75.8 35.2 07/04:00 07/04:00 09/08:00 120 120 120 Year:

Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 45.0 38.6 33.6 08/02:00 08/03:00 08/03:00 39.6

36.1 33.0 08/01:00 09/08:00 07/31:00 37.6

30.5 32.6 08/03:00 07/10:00 07/10:00 37.1

23.6 31.6 05/30:00 01/11:00 08/24:00 37.0 23.2 31.1 07/11:00 05/29:00 11/28:00 35.5

22.5 29.2 09/08:00 02/16:00 07/04:00 35.0

21.5 25.9 07/18:00 08/15:00 06/01:00 34.0

21.0 25.4 11/28:00 07/28:00 06/19:00 33.9

20.6 24.5 08/25:00 06/22:00 05/29:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

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Page 7 of 22 District Of Columbia District Of Columbia

District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) Primary: Primary:

Primary: Secondary: Secondary:

Secondary: 2006 2007

2007 24 HOUR 24 HOUR

24 HOUR Duration: Duration:

Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit:

Unit: 11-001-0043 11-001-0041 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 352 334 57 0

0 0 1 1 2 41.1 45.6 42.1 08/01:00 08/07:00 08/04:00 120 120 120 Year: Year:

Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 40.8 45.4 29.2 07/04:00 06/19:00 10/09:00 38.3

42.7 27.4 07/11:00 08/04:00 12/08:00 35.3

38.6 26.9 09/08:00 06/18:00 08/16:00 34.6

34.9 26.0 05/30:00 07/09:00 07/04:00 34.2 34.3 24.1 06/18:00 12/09:00 11/20:00 33.6

32.8 23.9 08/25:00 08/05:00 07/29:00 33.2

32.5 22.5 08/03:00 08/06:00 12/26:00 32.8

31.9 22.1 11/28:00 06/26:00 06/17:00 31.9

31.6 22.0 09/09:00 08/08:00 07/17:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State:

State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 8 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2007 2007 2008 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0042 11-001-0043 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 117 338 353 0 0 0 1 1 1 41.2 45.6 45.2 08/04:00 06/19:00 07/04:00 120 120 120 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 30.6 45.5 34.9 05/27:00 08/07:00 06/06:00 28.7

40.8 33.8 07/08:00 08/04:00 06/07:00 28.5

37.3 32.3 10/09:00 06/18:00 07/29:00 27.4

35.3 31.4 06/26:00 12/09:00 07/16:00 26.8 34.3 31.1 12/08:00 12/20:00 07/17:00 26.5

33.1 29.4 08/13:00 08/06:00 07/18:00 25.7

32.4 29.2 12/26:00 07/09:00 07/28:00 25.5

31.7 28.8 08/16:00 08/05:00 06/14:00 24.7

31.4 27.5 06/08:00 06/26:00 08/05:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 9 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2008 2008 2008 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0041 11-001-0042 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 59 119 344 0 0 0 2 1 1 44.2 32.8 36.3 07/04:00 07/17:00 06/06:00 120 120 120 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 32.0 31.6 32.0 07/17:00 07/29:00 06/07:00 31.2

31.4 31.8 07/29:00 06/14:00 07/17:00 23.2

26.2 31.8 07/11:00 08/01:00 07/29:00 23.2

25.5 31.3 09/03:00 01/28:00 06/14:00 20.8 25.5 30.8 04/18:00 09/03:00 07/18:00 18.2

23.9 28.4 09/21:00 08/19:00 07/28:00 17.4

23.6 27.6 10/15:00 07/05:00 08/18:00 17.2

22.2 27.2 08/04:00 06/26:00 09/22:00 17.1

21.9 26.8 09/09:00 02/03:00 07/12:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 10 of 22 District Of Columbia

District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary:

Primary: Primary: Secondary:

Secondary: Secondary: 2009

2009 2009 24 HOUR

24 HOUR 24 HOUR Duration:

Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit:

Unit: Unit: 11-001-0041 11-001-0041 11-001-0042 Washington Washington Washington District of Columbia District of Columbia District of Columbia 360 62 117 0 0 0 1 2 1 37.3 37.7 40.9 01/19:00 01/19:00 01/19:00 120 120 120 Year:

Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 31.4 26.4 25.2 11/10:00 11/09:00 11/09:00 29.4

20.0 22.7 03/16:00 01/13:00 03/17:00 28.6

18.0 20.6 01/27:00 03/14:00 01/04:00 27.4

15.6 20.2 08/27:00 08/05:00 08/26:00 26.7 15.5 19.6 11/09:00 08/23:00 08/08:00 25.2

15.3 18.9 06/26:00 07/30:00 03/05:00 24.3

14.7 18.6 08/09:00 08/11:00 01/22:00 23.8

14.3 18.1 01/20:00 05/13:00 01/10:00 23.0

14.2 17.8 01/23:00 08/17:00 03/14:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State:

State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 11 of 22 District Of Columbia District Of Columbia

District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) Primary: Primary:

Primary: Secondary: Secondary:

Secondary: 2009 2010

2010 24 HOUR 24 HOUR

24 HOUR Duration: Duration:

Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit:

Unit: 11-001-0043 11-001-0041 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 349 339 59 0

0 0 1 1 2 36.6 62.2 37.1 01/19:00 07/04:00 07/07:00 120 120 120 Year: Year:

Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 31.7 36.8 25.8 03/16:00 07/07:00 01/14:00 29.2

35.9 20.1 11/10:00 07/06:00 08/30:00 28.4

35.1 19.3 01/27:00 07/05:00 09/23:00 27.7

31.6 18.4 08/27:00 08/11:00 08/12:00 24.8 28.8 18.2 11/09:00 12/18:00 08/06:00 24.0

28.3 17.4 06/26:00 02/03:00 02/01:00 23.8

28.1 17.2 03/17:00 12/11:00 11/16:00 23.5

27.4 17.0 08/09:00 08/10:00 07/31:00 22.6

26.5 16.8 01/20:00 02/02:00 03/21:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State:

State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 12 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2010 2010 2011 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0042 11-001-0043 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 116 336 340 0 0 0 1 1 1 35.1 34.1 34.0 07/07:00 07/07:00 07/04:00 120 118 120 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 120 25.2 33.0 28.1 12/19:00 07/06:00 06/01:00 23.2

31.1 27.8 08/21:00 07/05:00 07/21:00 22.5

30.3 26.8 08/09:00 08/11:00 05/31:00 21.5

28.3 26.8 06/22:00 12/18:00 06/09:00 20.9 26.8 25.0 01/14:00 08/10:00 06/08:00 20.5

26.2 24.7 09/02:00 12/11:00 02/01:00 20.2

25.1 24.5 01/17:00 02/02:00 07/24:00 19.6

24.5 24.3 08/30:00 06/26:00 07/22:00 19.1

24.4 24.1 06/16:00 01/16:00 01/30:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 13 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2011 2011 2011 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0041 11-001-0042 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 60 124 336 0 0 0 2 1 1 29.2 30.7 30.6 07/04:00 06/04:00 06/01:00 120 118 118 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 25.0 26.9 30.2 06/08:00 07/20:00 07/21:00 20.7

26.2 27.4 07/20:00 07/29:00 05/31:00 18.1

24.7 27.3 08/13:00 01/30:00 06/09:00 17.7

20.8 26.0 12/05:00 07/06:00 07/20:00 17.2 20.8 25.5 07/02:00 07/23:00 02/01:00 14.3

20.2 25.2 08/19:00 07/03:00 06/08:00 13.3

19.7 24.8 07/08:00 06/14:00 01/01:00 13.2

18.8 24.8 06/20:00 01/18:00 06/10:00 12.4

18.8 24.1 01/15:00 07/04:00 01/24:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 14 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2012 2012 2012 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0041 11-001-0042 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 331 112 360 0 0 0 1 1 1 35.5 31.2 34.1 11/27:00 12/02:00 12/01:00 118 118 118 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 33.8 27.7 31.9 08/05:00 11/23:00 12/02:00 31.6

24.3 28.4 07/04:00 06/23:00 01/23:00 30.8

22.5 26.1 11/16:00 03/16:00 06/21:00 29.0

20.2 24.3 11/28:00 11/26:00 07/08:00 27.9 19.1 24.0 06/21:00 07/20:00 03/16:00 27.8

19.1 23.8 01/23:00 12/17:00 08/07:00 26.3

18.9 23.6 03/22:00 08/22:00 06/20:00 25.0

17.8 22.6 07/08:00 11/11:00 07/07:00 24.3

17.6 22.6 06/20:00 01/25:00 08/08:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 15 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2012 2013 2013 24 HOUR 24 HOUR 24 HOUR Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0043 11-001-0041 11-001-0042 Washington Washington Washington District of Columbia District of Columbia District of Columbia 120 355 126 0 0 0 2 1 1 31.0 27.6 25.7 12/02:00 12/02:00 01/28:00 118 118 118 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 23.6 25.8 18.7 06/20:00 01/28:00 09/10:00 23.5

25.0 18.6 03/16:00 01/27:00 10/31:00 22.0

24.6 18.1 06/29:00 12/03:00 02/06:00 20.5

23.2 17.9 12/17:00 12/16:00 11/15:00 19.7 23.1 15.7 07/04:00 12/01:00 05/22:00 18.3

23.0 15.4 07/17:00 01/12:00 02/03:00 18.2

22.6 15.3 11/26:00 11/15:00 08/29:00 18.0

22.4 14.8 12/14:00 01/26:00 12/18:00 17.8

22.1 14.7 11/11:00 01/25:00 06/09:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 16 of 22 District Of Columbia

District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary:

Primary: Primary: Secondary:

Secondary: Secondary: 2013

2014 2014 24 HOUR

24 HOUR 24 HOUR Duration:

Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit:

Unit: Unit: 11-001-0043 11-001-0043 11-001-0041 Washington Washington Washington District of Columbia District of Columbia District of Columbia 358 110 83 0

0 0 1 2 1 27.3 27.6 30.7 12/03:00 12/03:00 02/09:00 118 118 145 Year:

Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 26.7 26.0 24.7 01/28:00 01/28:00 03/02:00 25.5

19.4 23.8 11/16:00 07/18:00 02/01:00 24.6

19.0 20.9 12/04:00 09/10:00 02/11:00 24.0

18.8 19.2 12/02:00 11/15:00 01/02:00 23.9 17.0 19.0 12/17:00 02/06:00 01/08:00 22.9

16.6 18.8 01/27:00 02/03:00 02/02:00 22.3

15.7 18.4 07/19:00 05/22:00 02/15:00 22.1

15.7 18.0 12/01:00 10/04:00 03/05:00 21.6

15.2 17.6 01/26:00 04/10:00 02/08:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State:

State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 17 of 22 District Of Columbia District Of Columbia

District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) Primary: Primary:

Primary: Secondary: Secondary:

Secondary: 2014 2014

2015 24 HOUR 24 HOUR

24 HOUR Duration: Duration:

Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit:

Unit: 11-001-0042 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 116 347 111 0 0 0 1 1 2 24.6 30.1 24.0 12/22:00 02/09:00 12/20:00 145 145 145 Year: Year:

Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 22.5 25.8 22.5 12/16:00 03/02:00 12/16:00 21.1

24.4 20.2 12/13:00 01/10:00 12/13:00 17.3

24.3 19.1 01/02:00 12/22:00 02/01:00 16.8

22.7 18.7 01/05:00 12/16:00 01/02:00 16.6 22.6 18.4 02/10:00 12/23:00 07/04:00 15.7

21.5 18.1 02/08:00 12/21:00 01/05:00 15.6

20.0 17.2 07/15:00 12/13:00 02/10:00 15.6

19.9 15.6 08/09:00 06/18:00 08/10:00 15.3

19.7 15.5 11/22:00 02/11:00 08/27:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State:

State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 18 of 22 District Of Columbia District Of Columbia

District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) Primary: Primary:

Primary: Secondary: Secondary:

Secondary: 2015 2015

2015 24 HOUR 24 HOUR

24 HOUR Duration: Duration:

Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit:

Unit: 11-001-0042 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 120 342 116 0 0 0 1 1 2 26.4 27.7 27.2 06/11:00 06/11:00 06/11:00 145 145 145 Year: Year:

Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 23.8 27.1 25.2 01/21:00 12/06:00 01/21:00 21.6

25.0 24.8 01/15:00 01/21:00 07/04:00 20.9

24.9 21.4 07/02:00 12/12:00 02/08:00 20.3

24.6 21.1 02/26:00 07/04:00 01/15:00 19.9 21.8 20.5 01/03:00 02/08:00 12/11:00 19.5

21.8 20.2 02/08:00 02/09:00 02/26:00 18.8

21.8 19.3 03/10:00 09/02:00 07/03:00 18.8

21.6 18.7 07/04:00 09/04:00 02/17:00 18.6

21.2 18.7 12/11:00 01/15:00 12/08:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State:

State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 19 of 22 District Of Columbia District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Primary: Secondary: Secondary: Secondary: 2015 2011 2012 24 HOUR 24-HR BLK AVG 24-HR BLK AVG Duration: Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: Unit: 11-001-0051 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 73 303 349 0 0 1 2 4 4 32.5 32.4 37.3 07/04:00 07/21:00 06/21:00 145 170 170 Year: Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 26.9 30.1 37.0 06/11:00 07/20:00 12/01:00 25.0

30.0 34.7 12/11:00 06/09:00 07/08:00 24.7

26.3 33.8 07/02:00 09/04:00 12/02:00 23.7

26.0 31.0 12/05:00 05/26:00 07/07:00 23.2 25.0 29.1 12/08:00 06/10:00 06/20:00 21.9

24.2 27.2 07/03:00 05/30:00 06/22:00 20.5

23.8 26.9 08/01:00 07/24:00 06/29:00 19.8

23.5 26.5 07/05:00 07/22:00 07/18:00 19.7

22.3 26.4 09/03:00 06/11:00 08/23:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State: State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 20 of 22 District Of Columbia

District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary:

Primary: Primary: Secondary:

Secondary: Secondary: 2012

2013 2014 24-HR BLK AVG

24-HR BLK AVG 24-HR BLK AVG Duration:

Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit:

Unit: Unit: 11-001-0043 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 349 349 350 2 5 0 4 4 4 37.3 37.3 31.0 06/21:00 06/21:00 12/03:00 170 170 170 Year:

Year: Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 37.0 37.0 29.4 12/01:00 12/01:00 01/28:00 34.7

34.7 28.8 07/08:00 07/08:00 12/04:00 33.8

33.8 27.8 12/02:00 12/02:00 11/16:00 31.0

31.0 27.0 07/07:00 07/07:00 12/02:00 29.1 29.1 26.7 06/20:00 06/20:00 01/27:00 28.4

28.4 26.2 07/04:00 07/04:00 12/01:00 27.2

27.2 26.1 06/22:00 06/22:00 07/19:00 26.9

26.9 25.5 06/29:00 06/29:00 12/17:00 26.5

26.5 24.2 07/18:00 07/18:00 10/31:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State:

State: State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 21 of 22 District Of Columbia

District Of Columbia PM2.5 - Local Conditions (88101)

PM2.5 - Local Conditions (88101) Primary:

Primary: Secondary:

Secondary: 2014

2015 24-HR BLK AVG

24-HR BLK AVG Duration:

Duration: Micrograms/cubic meter (LC)

Micrograms/cubic meter (LC) Unit:

Unit: 11-001-0043 11-001-0043 11-001-0043 Washington Washington Washington District of Columbia District of Columbia District of Columbia 357 357 357 1 2 5 4 4 4 30.5 30.5 30.5 02/09:00 02/09:00 02/09:00 170 170 170 Year:

Year: Site ID Site ID Site ID POC

POC POC EDT ID EDT ID EDT ID Num Obs Num Obs Num Obs County Name County Name County Name City Name City Name City Name Methods Methods Methods Maximum Values Maximum Values Maximum Values Num Exc Num Exc Num Exc 26.3 26.3 26.3 03/02:00 03/02:00 03/02:00 24.0

24.0 24.0 12/22:00 12/22:00 12/22:00 23.6

23.6 23.6 01/10:00 01/10:00 01/10:00 22.4

22.4 22.4 06/18:00 06/18:00 06/18:00 21.9 21.9 21.9 02/11:00 02/11:00 02/11:00 21.8

21.8 21.8 12/21:00 12/21:00 12/21:00 21.1

21.1 21.1 02/01:00 02/01:00 02/01:00 21.0

21.0 21.0 12/16:00 12/16:00 12/16:00 20.8

20.8 20.8 12/23:00 12/23:00 12/23:00 1st Max 1st Max 1st Max 2nd Max

2nd Max 2nd Max 3rd Max

3rd Max 3rd Max 4th Max

4th Max 4th Max 5th Max

5th Max 5th Max 6th Max 6th Max 6th Max 7th Max

7th Max 7th Max 8th Max

8th Max 8th Max 9th Max

9th Max 9th Max 10th Max

10th Max 10th Max State:

State:UNITED STATES ENVIRONMENTAL PROCTECTION AGENCY AIR QUALITY SUBSYSTEM Jun. 6, 2016 MAXIMUM VALUES REPORT

Page 22 of 22 District Of Columbia District Of Columbia PM2.5 - Local Conditions (88101) PM2.5 - Local Conditions (88101) Primary: Primary: Secondary: Secondary: 2015 2015 24-HR BLK AVG 24-HR BLK AVG Duration: Duration: Micrograms/cubic meter (LC) Micrograms/cubic meter (LC) Unit: Unit: 11-001-0043 11-001-0051 Washington Washington District of Columbia District of Columbia 361 214 0 0 4 1 30.2 34.0 06/11:00 07/04:00 170 170 Year: Year: Site ID Site ID POC

POC EDT ID EDT ID Num Obs Num Obs County Name County Name City Name City Name Methods Methods Maximum Values Maximum Values Num Exc Num Exc 27.0 30.8 12/12:00 12/12:00 26.9

28.7 07/04:00 09/04:00 26.5

28.6 12/09:00 06/11:00 25.4

27.8 12/06:00 12/09:00 25.3 27.0 09/04:00 12/10:00 24.6

26.7 01/21:00 12/11:00 24.5

26.2 02/08:00 07/02:00 23.5

26.2 09/02:00 09/02:00 23.3

24.0 02/09:00 12/05:00 1st Max 1st Max 2nd Max

2nd Max 3rd Max

3rd Max 4th Max

4th Max 5th Max

5th Max 6th Max 6th Max 7th Max

7th Max 8th Max

8th Max 9th Max

9th Max 10th Max

10th Max State: State: