Printed on 100% recycled/recyclable paper with 100% post

- consumer fiber and process chlorine free.
Customer Service Hotline: 1

- 800

- 438

- 2474 November 4, 2014

The Honorable Keith A. Anderson

, Director

District Department of the Environment

1 2 00 First Street NE, 5 th Floor Washington, District of Columbia 2 0 002

Dear Director Anderson :

On J une 18 , 201 4 , the U.S. Environmental Protection Agency (EPA) received revision s to the

District of Columbia State Implementation Plan (SIP) from the District Department of the Environment ( DDO E) . The submittal includes a SIP revision address ing certain infrastructure elements specified in section 110(a)(2) of the Clean Air Act (CAA) that are necessary to implement, maintain, and enforce the

20 08 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 Emer gency Episode Plan, to meet certain infrastructure elements as well as EPA’s requirements of 40 CFR 51, Subpart H. EPA has

determine d 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 submi ttal for the portions

of the infrastructure element s 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 address ing the requirements of part C of title I of the CAA for having a SIP

- approved PSD program. Conversely, EPA

finds t he 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 20 08 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

Rulemak ing (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 PSD

related portions of sect ion 110(a)(2) (C), (D)(i)(II) , (D)(ii), and (J) for the 2 008 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).Printed on 100% recycled/recyclable paper with 100% post

- consumer fiber and process chlorine free.
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.go v

.

Sincerely,

/s/

David L. Arnold Acting Director

Air Protection Division

cc: Cecily Beall

, Associate Director, Air Quality Division, DDOE Rama S. Tangirala, Branch Chief, M onitoring and Assessment Branch, Air Quality Division, DDOE