ENCLOSURE 1

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COMMONWEALTH OF VIRGINIA

§ 110(a)(2) REQUIREMENTS IN THE 

VIRGINIA STATE IMPLEMENTATION PLAN

FOR THE 2008 OZONE NAAQS

A State Implementation Plan (SIP) is a plan for each state that identifies how that state 

will attain and maintain the primary and secondary National Ambient Air Quality 

Standards (NAAQS). The SIP contains regulations, source-specific requirements, nonregulatory items such as plans and inventories, and other types of submittals designed 

to satisfy requirements promulgated by the U.S. Environmental Protection Agency 

(EPA). The initial SIPs for states were approved on May 31, 1972. SIPs may be 

revised by the state with EPA approval. The federally enforceable SIP for the 

Commonwealth of Virginia is compiled in Subpart VV of 40 CFR Part 52.

Section 110(a) of the federal Clean Air Act (CAA) requires that each SIP provide for the 

implementation, maintenance, and enforcement of the NAAQS. This section also 

requires that within three years of the promulgation of a NAAQS, a state must adopt and 

submit such a plan to EPA. These infrastructure SIPs provide assurances of state 

resources and authorities. Where necessary, the infrastructure SIPs establish the basic 

state programs to implement, maintain, and enforce new or revised standards. Often, 

these SIPs simply reaffirm that the appropriate framework exists for any new NAAQS. 

The requirements of § 110(a)(2) of the federal CAA relevant to the 2008 ozone NAAQS

are already contained in Virginia’s current SIP, have been submitted to EPA, or are 

contained herein with the exception of § 110(a)(2)(D)(i)(I), which is pending EPA action.

EPA revised the primary and secondary ozone NAAQS from 0.08 parts per million 

(ppm) to 0.075 ppm on March 27, 2008 (73 FR 16436). On September 16, 2009, EPA 

announced a reconsideration of the 2008 ozone NAAQS, the purpose of which was to 

ensure that the standards were clearly grounded in science, protective of public health 

with an adequate margin of safety, and sufficient to protect the environment. Draft rules 

based on this reconsideration were subsequently withdrawn due to a presidential 

request, as announced on September 2, 2011. The CAA requires EPA to complete the 

initial designation process within two years of promulgating a new or revised NAAQS. If 

the Administrator has insufficient information to make these designations, EPA has the 

authority to extend the designation process by up to one year. Virginia submitted a 

designation recommendation letter to EPA on March 11, 2009, with recommendations 

based on monitoring data from years 2006, 2007 and 2008. Due to the reconsideration, 

additional quality-assured monitoring data became available for years 2009, 2010, and 

2011, which enabled the Commonwealth to update its original recommendations on

November 21, 2011. EPA published final designations for the 2008 NAAQS on May 19, 

2012 (77 FR 30088). All areas of Virginia, with the exception of Northern Virginia, were 

designated as attaining the standard. Northern Virginia, as part of the metropolitan 

Washington, DC area, was designated nonattainment, with a classification of marginal.
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Virginia has made several previous submittals regarding infrastructure requirements for 

the 1997 ozone NAAQS:

• § 110(a)(2)(D)(i) infrastructure requirements certification document for the 1997 

ozone NAAQS and the 1997 PM2.5 NAAQS; submitted November 13, 2007.

• § 110(a)(2) infrastructure requirements SIP revision for the 1997 ozone NAAQS; 

submitted December 10, 2007; approved on October 11, 2011 (76 FR 62635).

• § 110(a)(2) infrastructure requirements certification document for the 1997 ozone 

NAAQS; submitted December 13, 2007; approved on October 11, 2011 (76 FR 

62635).

Virginia has based this submittal on direction received from EPA Region III. The

following describes each specific EPA requirement and how each requirement is being 

met by the Commonwealth.

Section 110(a)(2)(A): “Each such plan shall include enforceable emission limitations 

and other control measures, means, or techniques (including economic incentives such 

as fees, marketable permits, and auctions of emissions rights), as well as schedules 

and timetables for compliance, as may be necessary or appropriate to meet the 

applicable requirements of this Act;”

Virginia’s enforceable emission limitations and other control measures are those 

provisions of the following chapters that have been approved in Virginia’s SIP in 

40 CFR 52.2420(c):

 9VAC5 Chapter 40 (Existing Stationary Sources), 

 9VAC5 Chapter 50 (New and Modified Stationary Sources),

 9VAC5 Chapter 91 (Motor Vehicle Inspection and Maintenance Program 

for Northern Virginia),

 9VAC5 Chapter 130 (Open Burning), and 

 9VAC5 Chapter 140 (Emissions Trading). 

The maintenance plans, the reasonable further progress plans, and the 

attainment demonstrations for the 1991 1-hour ozone NAAQS and the 1997 8-

hour ozone NAAQS are plans that include enforceable emissions limits, control 

measures, fees, and compliance schedules by describing regulations upon which 

the plans rely. Plans were prepared for the following areas: Hampton Roads, 

Richmond-Petersburg, Fredericksburg, Shenandoah National Park, and the 

Washington DC-MD-VA area. Virginia also submitted early action plans for the 

Winchester and Roanoke 1997 ozone NAAQS early action compact areas. The 

approved plans are listed in 40 CFR 52.2420(e).

Section 110(a)(2)(B): “Each such plan shall provide for establishment and operation of 

appropriate devices, methods, systems, and procedures necessary to – (i) monitor, 
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compile, and analyze data on ambient air quality, and (ii) upon request, make such data 

available to the Administrator;”

Virginia maintains and operates a multi-station ozone network to measure 

ambient concentrations within the Commonwealth for comparison to the NAAQS. 

All data are measured using EPA approved methods as either reference or 

equivalent monitors; all monitors are subject to the quality assurance 

requirements of 40 CFR Part 58; and all samplers are located at sites that have 

met the minimum siting requirements of Part 58. The data are submitted to 

EPA’s Air Quality System (AQS) in accordance with the schedule prescribed by 

40 CFR Part 58.

In order to keep EPA informed of changes to the sampling network, Virginia

provides EPA Region III with prior notification of any planned changes to the 

network. As needed, details of these changes and anticipated approvals of the 

changes are communicated to EPA. On an annual basis, Virginia sends EPA a 

summary of all the changes to the network. This summary provides a description 

of each change, the reason for each change, and any other information relevant 

to the change.

Section 10.1-1306 of the Code of Virginia, Inspections, investigations, etc.,

states:

The Board shall make, or cause to be made, such investigations 

and inspections and do such other things as are reasonably 

necessary to carry out the provisions of this chapter, within the 

limits of the appropriations, study grants, funds, or personnel which 

are available for the purposes of this chapter, including the 

achievement and maintenance of such levels of air quality as will 

protect human health, welfare and safety and to the greatest 

degree practicable prevent injury to plant and animal life and 

property ...

This section of the Code of Virginia supports the development and maintenance 

of an adequate monitoring network to ensure the achievement and maintenance 

of healthy levels of air quality.

Section 110(a)(2)(C): “Each such plan shall include a program to provide for the 

enforcement of the measures described in paragraph (A), and regulation of the 

modification and construction of any stationary source within the areas covered by the 

plan as necessary to assure that national ambient air quality standards are achieved, 

including a permit program as required in parts C and D;”
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Enforcement provisions and permit provisions are found in those portions of Part 

V (Enforcement) of 9VAC5 Chapter 170 (General Administration) and 9VAC5 

Chapter 80 (Permits for Stationary Sources) that are listed in 40 CFR 52.2420.

The applicability section for Chapter 170 notes that the provisions of Chapter 

170, unless specified otherwise, shall apply in the administration of all regulations 

of the board to the extent not covered in a specific regulation of the board. In 

cases where the provisions of this chapter conflict with another regulation of the 

board, the provisions of the other regulation shall apply.

Construction and modification of stationary sources are covered under Article 8, 

Permits for Major Stationary Sources and Major Modifications Locating in 

Prevention of Significant Deterioration Areas (9VAC5-80-1605 et seq.) and 

Article 9, Permits for Major Stationary Sources and Major Modifications Locating 

in Nonattainment Areas or the Ozone Transport Region (9VAC5-80-2000 et seq.)

of Part II of 9VAC5 Chapter 80 (Permits for Stationary Sources). Article 8 

provides that construction and modification of major stationary sources will not 

cause or contribute to a violation of any NAAQS (see 9VAC5-80-1635, Ambient 

Air Increments and 9VAC5-80-1645, Ambient Air Ceilings). This regulation also 

requires the application of Best Available Control Technology to new or modified 

sources of ozone precursor emissions (see 9VAC5-80-1705, Control Technology 

Review). Virginia has a minor new source review permitting program under 

Article 6 of Part II of 9VAC5 Chapter 80. Virginia’s PSD program applies to 

greenhouse gases (GHG) through 9VAC5 Chapter 85, Permits for Stationary 

Sources of Pollutants Subject to Regulation (Greenhouse Gas Tailoring), which 

implements EPA’s Tailoring Rule. Other aspects for enforcement are found in 

the source monitoring, source testing and test methods, and recordkeeping and 

reporting provisions of 9VAC5 Chapters 40, 50, and 140 that are listed in 40 CFR 

52.2420.

Section 110(a)(2)(D)(i)(II): “Each such plan shall contain adequate provisions

prohibiting, consistent with the provisions of this title, any source or other type of 

emissions activity within the State from emitting any air pollution in amounts which will 

interfere with measures required to be included in the applicable implementation plan 

for any other State under Part C to prevent significant deterioration of air quality or to 

protect visibility”

Major stationary sources for ozone precursors in Virginia are currently subject to 

nonattainment NSR and PSD permitting programs. These provisions to 

implement Part C may be found in Article 8 of 9VAC5 Chapter 80 and in 9VAC5 

Chapter 85. Virginia submitted its regional haze SIP to EPA Region III on 

October 4, 2010, and on June 13, 2012 (77 FR 35287), EPA finalized a limited 

approval/limited disapproval of the submittal
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Section 110(a)(2)(D)(ii): “Each such plan shall contain adequate provisions insuring 

compliance with the applicable requirements of §§ 126 and 115 (relating to interstate 

and international pollution abatement)”

Section 126(a) directs each SIP to include provisions requiring a new or modified 

source to notify neighboring states of potential impacts from that source. Major 

stationary sources of ozone precursors in Virginia are currently subject to PSD 

NSR permitting programs. These provisions to implement Part C may be found 

in Article 8 of 9VAC5 Chapter 80 and in 9VAC5 Chapter 85, which have been 

approved in Virginia’s SIP in 40 CFR 52.2420(c). 9VAC5-80-1775 specifically 

requires notification to local air pollution control agencies and any state whose 

lands may be affected by emissions from the source or modification. Virginia is 

not subject to any active finding or petitions regarding ozone under §§ 115, 

126(b), or 126(c).

Section 110(a)(2)(E)(i): “Each such plan shall provide necessary assurances that the 

State (or, except where the Administrator deems inappropriate, the general purpose 

local government or governments, or a regional agency designated by the State or 

general purpose local governments for such purpose) will have adequate personnel, 

funding, and authority under State (and, as appropriate, local) law to carry out such 

implementation plan (and is not prohibited by any provision of Federal or State Law 

from carrying out such implementation plan or portion thereof).”

Code of Virginia, Title 10.1, Chapter 13, Air Pollution Control Board, gives broad 

authority to develop, implement, and enforce the implementation plan. Section

10.1-1308 provides the board adequate legal authority to adopt emission 

standards and compliance schedules applicable to regulated entities. This 

section provides authority to adopt emission standards, limitations, and any other 

measures necessary for attainment and maintenance of national standards. 

Sections 10.1-1307, 10.1-1307.3, 10.1-1309, 10.1-1316, 10.1-1320, and 10.1-

1322 provide the board adequate legal authority to enforce applicable laws, 

regulations standards, and compliance schedules. The provisions also allow for 

injunctive relief. In addition, § 10.1-1186.10 provides the department legal 

authority to enforce applicable laws, regulations, standards, and compliance 

schedules.

The resources to carry out the implementation plan are provided through general 

funds, Title V funds, and the §§ 103 and 105 grant process. Title V fees are 

collected under the authority of § 10.1-1322.

Virginia has adequate personnel to carry out the SIP with respect to the 2008 

ozone NAAQS requirements. Should EPA determine that Virginia lacks

adequate personnel to carry out the SIP, EPA may issue a finding with respect to 

that deficiency. Virginia would then have a legal obligation to correct that 

deficiency.
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Section 110(a)(2)(E)(ii): “Each such plan shall provide requirements such that the 

State comply with the requirements respecting State boards under § 128.”

The board has the authority to approve regulations, enforcement actions, and 

permits. Section 10.1-1302 is as stringent as § 128(a)(1) of the Clean Air Act 

and ensures that at least a majority of the members of the board represent the 

public interest and do not derive any significant portion of their income from 

persons subject to permits or enforcement orders of the board as required by § 

128(a)(1) of the Clean Air Act. In addition, the State or Local Government

Conflict of Interests Act (§ 2.2-3100 et seq.) provides the means for disclosure of 

potential conflicts of interest as required by § 128(a)(2) of the Clean Air Act.

Section 110(a)(2)(E)(iii): “Each such plan shall provide necessary assurances that, 

where the State has relied on a local or regional government, agency, or instrumentality 

for the implementation of any plan provision, the State has responsibility for ensuring 

adequate implementation of such plan provision;”

9VAC5 Chapter 130, Regulation for Open Burning, allows localities, after 

receiving approval from the State Air Pollution Control Board, to adopt the open 

burning requirements of the regulation (see Part II of 9VAC5-130). For the 

monitoring program and for this regulatory requirement, Virginia continues to 

provide the oversight necessary to ensure that data is collected and reported in 

accordance with current guidance; that open burning regulations are 

appropriately implemented by localities; and that other assurances for adequate 

implementation exist. Other than monitoring requirements and open burning 

requirements, Virginia does not rely on localities to implement SIP provisions.

Section 110(a)(2)(F)(i): “Each such plan shall require, as may be prescribed by the 

Administrator, the installation, maintenance, and replacement of equipment, and the 

implementation of other necessary steps, by owners or operators of stationary sources 

to monitor emissions from such sources;” 

These requirements are included in those provisions of 9VAC5 Chapters 20, 40 

and 50 that are approved in the SIP under 40 CFR 52.2420. 

Section 110(a)(2)(F)(ii): “Each such plan shall require, as may be prescribed by the 

Administrator, periodic reports on the nature and amounts of emissions and emissionsrelated data from such sources;”

Requirements for periodic reports on the nature and amounts of emissions and 

emissions-related data are included in 9VAC5-20-160 (Registration) of 9VAC5 
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Chapter 20 (General Provisions). Such data are also required by Part I of 

9VAC5 Chapter 40 (Existing Stationary Sources) as well as Parts I and II of 

9VAC5 Chapter 50 (New and Modified Stationary Sources). These SIP 

provisions are approved under 40 CFR 52.2420.

Section 110(a)(2)(F)(iii): “Each such plan shall require, as may be prescribed by the 

Administrator, correlation of such reports by the State agency with any emission 

limitations or standards established pursuant to this Act, which reports shall be available 

at reasonable times for public inspection;”

The correlation of such reports is included in Part I of 9VAC5 Chapter 40 and 

Part II of 9VAC5 Chapter 50. 9VAC5-170-60 (Availability of information) in Part II 

of 9VAC5 Chapter 170 (Regulation for General Administration) requires that 

these reports be publicly available. These SIP provisions are approved under 40 

CFR 52.2420.

Section 110(a)(2)(G): “Each such plan shall provide for authority comparable to that in 

§ 303 and adequate contingency plans to implement such authority;”

Section 10.1-1309 B under Code of Virginia, Title 10.1, Chapter 13, Air Pollution 

Control Board, authorizes the board to declare a state of emergency and issue 

without hearing an emergency special order directing the owner to cease such 

pollution immediately upon finding that any owner is unreasonably affecting the 

public health, safety or welfare; the health of animal or plant life; or property. 

Section 10.1-1309.1 authorizes the board to issue special orders requiring plans 

to abate, control, prevent, remove, or contain any substantial and imminent threat 

to public health or the environment that is reasonably likely to occur if such 

source ceases operations. 

Virginia has appropriate general emergency powers to address ozone related 

episodes. Virginia’s emergency plans are found in 9VAC5 Chapter 70 (Air 

Pollution Episode Prevention) and are approved in 40 CFR 52.2420.

Section 110(a)(2)(H)(i): “Each such plan shall provide for revision of such plan from 

time to time as may be necessary to take account of revisions of such national primary 

or secondary ambient air quality standard or the availability of improved or more 

expeditious methods of attaining such standard;”

Virginia’s SIP is a compilation of regulations, plans, and submittals that act to 

improve and maintain air quality at the national standards. The authority to 

develop or revise the SIP is based on the authority to adopt new regulations, 

revise existing regulations, and conduct business in a manner to meet the 

NAAQS. Code of Virginia, Title 10.1, Chapter 13, Air Pollution Control Board,
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gives broad authority to perform these functions. Specifically § 10.1-1306 

provides authority for the board to act reasonably to achieve and maintain levels 

of air quality that will protect human health, welfare, and safety. Also, § 10.1-

1307 provides for the development of a comprehensive program for the study, 

abatement, and control of all sources of air pollution in the Commonwealth. 

Section 10.1-1308 provides authority to promulgate regulations to abate, control, 

and prohibit air pollution throughout the Commonwealth in accordance with the 

provisions of Virginia’s Administrative Process Act. 

Section 110(a)(2)(H)(ii): “Each such plan shall provide for revision of such plan except 

as provided in paragraph (3)(c), whenever the Administrator finds on the basis of 

information available to the Administrator that the plan is substantially inadequate to 

attain the national ambient air quality standard which it implements or to otherwise 

comply with any additional requirements established under this Act;”

As noted in the prior paragraph, § 10.1-1306 provides authority for the board to 

act reasonably to achieve and maintain levels of air quality that will protect 

human health, welfare, and safety. Virginia affirms that the state implementation 

plan may be revised should the Administrator find that the plan is substantially 

inadequate to attain a standard or to comply with any additional requirements 

under the Act.

Section 110(a)(2)(J): “Each such plan shall meet the applicable requirements of 

section 121 (relating to consultation), section 127 (relating to public notification), and 

part C (relating to prevention of significant deterioration of air quality and visibility 

protection);”

Section 121: All SIP revisions undergo public notice and hearing, if requested, 

which provides for comment by the public and includes local political 

subdivisions. Further, all regulations promulgated in Virginia are subject to the 

Administrative Process Act (Code of Virginia, Title 2.2, Administration of 

Government, Chapter 40). Regulations promulgated by the State Air Pollution 

Control Board are also governed by 9VAC5 Chapter 5, Public Participation 

Guidelines.

During attainment and maintenance plan development, local planning 

organizations (LPOs) are organized as the forum for consultation and 

cooperative air quality planning decision making. LPOs are the organizations 

certified by the state as being responsible for the preparation of control strategy 

implementation plan revisions for nonattainment areas under § 174 of the Clean 

Air Act. The organizations include elected officials of local governments in the 

affected nonattainment area, and representatives of DEQ, Virginia Department of 

Transportation (VDOT), the metropolitan planning organizations (MPOs) for the 

affected area, and other agencies and organizations that have responsibilities for 
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developing, submitting, or implementing any of the plan revisions. All LPO 

documentation is submitted with each plan for the pertinent jurisdiction. Virginia’s 

plan submittals specify the organizations responsible for implementing and 

enforcing the plans.

Consultation for transportation conformity purposes is governed by 9VAC5 

Chapter 151 (Regulation for Transportation Conformity). This regulation was 

originally approved by EPA into the SIP on November 20, 2009 (74 FR 60194); 

subsequent amendments made to ensure consistency with EPA rule changes 

were later approved on October 19, 2011 (74 FR 60194). Consultation for 

general conformity purposes is governed by 9VAC5 Chapter 160 (Regulation for 

General Conformity). This regulation was originally approved into the SIP on 

October 21, 1997 (62 FR 54585); subsequent amendments made to ensure 

consistency with EPA rule changes were later approved on December 12, 2011 

(76 FR 77150). 

Therefore, the Commonwealth’s public participation requirements and 

procedures fulfill the requirements of the § 121 consultation process.

Section 127: Air quality data from Virginia’s monitoring network is published on 

the Department of Environmental Quality website. As part of the § 105 grant 

process, Virginia is required to submit monitoring data to the AQS in a timely 

manner. Virginia publishes an annual summary of all monitoring data on the 

DEQ website, including monitoring locations, exceedances, and violations of 

standards. The VDOT and the MPOs use electronic signs in the nonattainment 

and maintenance areas to alert motorists to predicted air quality values so that 

mitigating episodic measures can be implemented.

Part C: Article 8, Permits for Major Stationary Sources and Major Modifications 

Locating in Prevention of Significant Deterioration Areas (9VAC5-80-1605 et 

seq.) of 9VAC5-80 (Permits for Stationary Sources) and 9VAC5-85 (Permits for 

Stationary Sources of Pollutants Subject to Regulation (Greenhouse Gas 

Tailoring) include procedures for the permitting of major stationary sources. 

Section 110(a)(2)(K)(i) and (ii): “Each such plan shall provide for (i) the performance 

of such air quality modeling as the Administrator may prescribe for the purpose of 

predicting the effect on ambient air quality of any emission of any air pollutant for which

the Administrator has established a national ambient air quality standard and (ii) the 

submission, upon request, of data related to such air quality modeling to the 

Administrator”

Article 8, Permits for Major Stationary Sources and Major Modifications Locating

in Prevention of Significant Deterioration Areas (9VAC5-80-1605 et seq.) of 

9VAC5-80 (Permits for Stationary Sources) contains requirements for preconstruction and post-construction monitoring and modeling. Such data is 
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routinely provided to EPA upon request. This regulation is included as part of the 

Virginia SIP as noted in 40 CFR 52.2420. Regional air quality modeling inputs 

and results have been provided in numerous SIP submittals.

Section 110(a)(2)(L)(i) and (ii): “Each such plan shall require the owner or operator of 

each major stationary source to pay to the permitting authority, as a condition of any 

permit required under this Act, a fee sufficient to cover (i) the reasonable costs of 

reviewing and acting 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 (not including any court costs or 

other costs associated with any enforcement action), until such fee requirement is 

superseded with respect to such sources by the Administrator’s approval of a fee 

program under title V;”

These requirements are located in Article 2, Permit Program Fees for Stationary 

Sources (9VAC5-80-310 et seq.) of 9VAC5-80 (Permits for Stationary Sources). 

These regulations are part of Virginia’s federally approved Title V program and 

are codified in Appendix A of 40 CFR Part 70, Approval Status of State and Local 

Operating Permits Programs.

Section 110(a)(2)(M): “Each such plan shall provide for consultation and participation 

by local political subdivisions affected by the plan;”

During attainment and maintenance plan development, LPOs are organized as 

the forum for consultation and cooperative air quality planning decision making. 

LPOs are the organizations certified by the state as being responsible for the 

preparation of control strategy implementation plan revisions for nonattainment 

areas under § 174 of the Clean Air Act. The organizations include elected 

officials of local governments in the affected nonattainment area, and 

representatives of DEQ, VDOT, the MPOs for the affected area, and other 

agencies and organizations that have responsibilities for developing, submitting, 

or implementing any of the plan revisions. All LPO documentation is submitted 

with each plan for the pertinent jurisdiction. Virginia’s plan submittals specify the 

organizations responsible for implementing and enforcing the plans.

Consultation for transportation conformity purposes is governed by 9VAC5 

Chapter 151 (Regulation for Transportation Conformity). This regulation was 

originally approved by EPA into the SIP on November 20, 2009 (74 FR 60194); 

subsequent amendments made to ensure consistency with EPA rule changes 

were later approved on October 19, 2011 (74 FR 60194). Consultation for 

general conformity purposes is governed by 9VAC5 Chapter 160 (Regulation for 

General Conformity). This regulation was originally approved into the SIP on 

October 21, 1997 (62 FR 54585); subsequent amendments made to ensure 
11

consistency with EPA rule changes were later approved on December 12, 2011 

(76 FR 77150).

All SIP revisions undergo public participation following the procedures stipulated 

by 40 CFR 51.102, providing for comment by the public that includes local 

political subdivisions. Additionally, the Code of Virginia under § 10.1-1307A 

requires advising, consulting, and cooperating with all agencies of the 

Commonwealth, political subdivisions, private industries, and any other affected 

groups when developing programs to improve or maintain air quality. 

Further, all regulations in Virginia are subject to the Administrative Process Act 

(Code of Virginia, Title 2.2, Administration of Government, Chapter 40). 

Regulations promulgated by the State Air Pollution Control Board are also 

governed by 9VAC5 Chapter 5, Public Participation Guidelines. The 

Commonwealth’s public participation requirements and procedures fulfill the 

requirements for consultation with local political subdivisions affected by the SIP.

SIP\ASSESSMENT\HS-SIP-1.DOC