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Customer Service Hotline: 1-800-438-2474

November 4, 2014

The Honorable Keith A. Anderson, Director

District Department of the Environment

1200 First Street NE, 5th Floor

Washington, District of Columbia 20002

Dear Director Anderson:

On June 18, 2014, the U.S. Environmental Protection Agency (EPA) received revisions to the 

District of Columbia State Implementation Plan (SIP) from the District Department of the Environment 

(DDOE). The submittal includes a SIP revision addressing certain infrastructure elements specified in

section 110(a)(2) of the Clean Air Act (CAA) that are necessary to implement, maintain, and enforce the 

2008 ozone national ambient air quality standards (NAAQS) in the District of Columbia. The submittal 

also includes as a SIP revision the District of Columbia’s Air Quality Emergency Episode Plan, to meet 

certain infrastructure elements as well as EPA’s requirements of 40 CFR 51, Subpart H. EPA has 

determined that the submittal is technically incomplete for some of the relevant infrastructure elements 

of section 110(a)(2) of the CAA. 

EPA finds that the District of Columbia has failed to make a complete submittal 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 Prevention of Significant Deterioration (PSD), by not adequately addressing the 

requirements of part C of title I of the CAA for having a SIP-approved PSD program. Conversely, EPA 

finds the remainder of the June 18, 2014 submittal, including the Air Quality Emergency Episode Plan,

to be administratively and technically complete. As a result of this finding, EPA can only proceed in 

reviewing the complete portions of the submittal, but cannot approve the PSD-related portions of section 

110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2008 ozone NAAQS, until the District of Columbia 

through DDOE submits a SIP to address the PSD permit program requirements of part C of title I of the 

CAA. EPA is reviewing the complete portions of the submittal to prepare a Notice of Proposed 

Rulemaking (NPR) action.

EPA recognizes that the District of Columbia is already subject to a Federal Implementation Plan 

(FIP) containing the Federal PSD program to correct the SIP deficiency and that DDOE would not have 

to take further action for the FIP-based permitting process to continue operating. Thus, EPA anticipates 

that there will be no adverse consequences to DDOE from this incompleteness finding for the PSDrelated portions of section 110(a)(2)(C), (D)(i)(II), (D)(ii), and (J) for the 2008 ozone NAAQS.

Mandatory sanctions would not apply to the District of Columbia under CAA section 179 because the 

failure to submit a PSD SIP is neither with respect to a submission that is required under CAA title I part 

D, nor in response to a SIP call under CAA section 110(k)(5).
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Customer Service Hotline: 1-800-438-2474

If members of your staff have any questions, they may direct them to Ms. Emlyn Vélez-Rosa, 

Office of Air Program Planning, at (215) 814-2038, or velez-rosa.emlyn@epa.gov. 

Sincerely, 

/s/

 David L. Arnold

Acting Director

Air Protection Division 

 

cc: Cecily Beall, Associate Director, Air Quality Division, DDOE

 Rama S. Tangirala, Branch Chief, Monitoring and Assessment Branch, Air Quality Division, DDOE