### Farngalo, Zuri From: Sent: To: Cc: Subject: Attachments: Jerry_Beasley@deq.state.ms.us Thursday, May 08, 2014 5:08 PM Benjamin, Lynorae; Bradley, Twunjala; Ward, Nacosta maya_rao@deq.state.ms.us MDEQ Infrastructure SIP Revisions 2011 lead Infrastructure SIP - 2014 Revision - 1.doc; 2011 Ozone Infrastructure SIP - 2014 Revision - l.doc; 2010 Nitrogen Dioxide Infrastructure SIP - 2014 Revision - l.doc; 2010 Sulfur Dioxide Infrastructure SIP - 2014 Revision.docx
Attached arethe revised lead, ozone, nitrogen dioxide, and sulfur dioxide infrastructure SIPs. The revisions are summarized below in bold red. Ifyou have any questions or need more information, let me know. 

### Overarching comment for all infrastructure submissions and elements. Please submit an electronic copy ofany statutes, state law, orstateregulations that are referenced in MDEQ's infrastructure submissions/elements for compliance (but not submitted for incorporation/not currently approved into the SIP). These statutes, state laws, and/or state regulations are not being submitted for incorporation into the SIP. For example any state law or statuereferenced in an Appendix should beprovided electronically. Additionally, please clarifythat Appendix A-8 and A-9 are both documentation ofMississippi Code Title 49. All statutes, state laws, or state regulations are now linked in the documents

. Additionally, Appendix A-9 was the correct reference for Mississippi Code Title 49. 110(a)(2)(C) Please clarify that Mississippi has a SIP-approved minor new source review permittingprogram which is governed at APC-S-2 and covers compliance with 110(a)(2)(C) for all relevant NAAQS infrastructure SIP submissions (i.e. ozone, Pb, S02 and N02). Each infrastructure SIP has been revised to includethis statement: SIP Section APC-S-2, Section 1.0. lists permitting requirements including thosefor minor new source review permitting. 110(a)(2)(L) In addition to the current title 

### V information provided in MDEQ's existing infrastructure submissions for 2008 ozone & lead and 2010 N02 & S02 NAAQS, pleaseprovidemore detailed information on the state's permitting fee structure with regards to the PSD and NNSR byproviding responses and documentation to the questions belowto demonstrate MDEQ's compliance with 110(a)(2)(L). Please be sureto clarify that documentation covers compliance for all relevant NAAQS infrastructure SIP submissions (i.e. ozone, Pb, S02 and N02).

• Identify the funding source(s) for the reasonable cost ofreview, approval, implementation and enforcement ofPSD and nonattainment new source review (NNSR) permits (i.e. single orcombination of permit-specific fee charged to the applicant, a state tax, legislative appropriations, title 

### V operating fee program etc.) 1• Ide ntify how this funding source is mandated orwhat gives the agency the authority to charge a fee or require funding (i.e. state law, SIP-approved regulation, legislation, statute)
. Please consider citing (and providing an electronic copy) all relevant state and SIP· approved regulations or statutes that require/mandate funding for processing PSD and NNSR permits. Please note specific fee amounts are not required for documentation.

• Document ifpossible that the current permitting fee structure in place for PSD and NNSRreflect the reasonable cost ofreview, approval, implementation and enforcement ofPSD and NNSR permits and are sufficient to operate the state's permitting program.
• Additionally, include a statement that the tit1e V operating program fees coverthe reasonable cost of implementation and enforcement ofPSD and NNSR permits after they have been issued. Each infrastructure SIP has been revised to include this information: SIP Appendix A-9, Section 49-17-30, provides for the assessment ofTitle V permitfees to coverthese costs. SIP Appendix A-9, Section 49-2-9(c) authorizes MDEQ to applyfor, receive, and expend federal orstatefunds in order to operate its programs. MDEQ uses state legislative appropriations, federal105 grantfunds, and TitleV fees for the reasonable cost of review, approval, implementation, and enforcement ofaUair permitting programs. SIP Appendix A-9, Section 49-17-14 allows MDEQ to expend or utilize monies in the Mississippi Air Operating Permit Program Fee Trust Fund to pay all reasonable direct and indirect costs associated with the development and administration oftheTitle V program including, but not limited to, the reasonable costs of performing activities related to theTitle V program. These funding mechanisms reflect the reasonable cost of review, approval, implementation, and enforcement ofthe state• s air permitting program. TheTitle Voperating program fees cover the reasonable cost of implementation and enforcement of PSD permits afterthey have been issued. Jerry Beasley, Ph.D., P.E. Chief, Air Quality Management Branch Mississippi Dept. of Environmental Quality 515 East Amite Street Jackson, Mississippi 39201 (601) 961-5134

2