Administrative Materials for SIP submittal dated: February 2015

1. A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof (hereafter “the plan”). The cover letter transmitting this proposed 2008 Ozone Inventory SIP Revision is

the formal letter of submission.

2. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter “document”)

in final form. That evi dence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date.

The state is submitting an emission inventory, consistent with §182(a)(1) of the Clean Air Act (the Act ) for the 15

- county Atlanta 8

- hour Ozone Nonattainment Area

for 2008 8

- hour Ozone National Ambient Air Quality Standard (NAAQS)

.

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. The Georgia Air Qual ity Act, Article 1: Air Quality (O.C.G.A. 12

- 9, et. seq.) provides the necessary legal authority under State law to adopt and implement the revisions. The Act, in its entirety, is located at http ://www.lexis

nexis.com/hottopics/gacode/ under Title 12, Chapter 9, Article 1.

4. A copy of the actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication of the changes made to the existing approved plan, where applicable. The submittal shall be a copy of the official State regulation/ document signed, stamped, dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date of the regulation/ document shall, whenever possible, be indicated in the document

itself.

Enclosed is a c opy of the affected p lan for approval and incorporation into the State Implementation Plan.

5. Evidence that the State followed all of the procedural requirements of t he State’s laws and Constitution in conducting and completing the adoption/issuance of the plan and compilation of public comments and the State’s response thereto. The procedural requirements associated with this plan and public comment period

are include d in the submittal to EPA.

6. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date of publication of such notice and Certification that public hearings(s) were held in accordance with the information provided in the public notice and the State's laws and constitution, if applicable. Documentation for the public notice, hearing and comment requirements is

included in the submittal to EPA.Technical Support for SIP Submittal dated: February 2015

1. Identification of all regulated pollutants affected by the plan. The proposed plan includes all emissions as required by§182(a)(1) of the Act

which requires States to submit a “comprehensive, accurate, current inventory from

all sources , as described in §172(c)(3) for the relevant pollutants for the area, in accordance with guidance p rovided by the Administrator.”

2. Identification of the locations of affected sources including the EPA

attainment/non

- attainment designation of the locat ions and the status of the attainment plan for the affected areas(s). The plan covers the 15

- county Atlanta 8

- hour Ozone Nonattainment Area for 2008

8

- hour Ozone National Ambient Air Quality Standard (NAAQS)

.

3. Quantification of the changes in plan allo wable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences between cer tain baseline levels and allowable emissions anticipated as a result of the revision.

Emissions are discussed in Attachment A.

4. The State’s demonstration that the national ambient air quality standards, prevention of significant deterioration increment s, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented. For all requests to redesignate an area to attainment for a national primary ambient air quality standard, under section 10 7 of the Act, a revision must be submitted to provide for the maintenance of the national primary ambient air quality standards for at least 10 years as required by section 175A of

the Act. The proposed plan is consistent with §182(a)(1) of the Act

.

5. M odeling information required to support the proposed revision, including input data, output data, models used, justification of model selections, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), mo des of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis.

GA EPD ran the MOVES model for the onroad mobile sector and EPA ran the

NONROAD mode l for the nonroad mobile secto r

.

6. Evidence, w here necessary, that emission limitations are based on continuous emission reduction technology. This requirement is not applicable for this revision.7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/r eporting requirements, where necessary, to ensure emission

levels. The proposed plan is consistent with §182(a)(1) of the Act.

8. Compliance/enforcement strategies, including how compliance will be determined in practice.

Enforcement will be carried out a s described in the State/EPA Enforcement Agreement.

9. Special economic and technological justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary. No special economic or technological justifi cations are required for this proposed

p lan.