SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

(In accordance with 40 CFR Part 51 - App. V)

SIP Submitted by: District Department of the Environment 

Date Received: July 22, 2014

Subject: District of Columbia’s Infrastructure State Implementation Plan Revision for the 2010 Sulfur Dioxide (SO2) National 

Ambient Air 

Quality Standard (NAAQS)

Completeness Review 

Completed by: Emlyn Vélez-Rosa 

Date Completed: October 27, 2014

Administrative Materials

ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his 

designee, requesting EPA approval of the plan or revision 

thereof.

1. A letter dated July 17, 2014 from Keith A. Anderson, 

Director of the District Department of the Environment (DDoE) 

to Shawn M. Garvin, EPA Regional Administrator.

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, or consent 

agreement in final form. That evidence 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.

Check to see if the regulation, permit, order or consent decree 

has a sunset or expiration date. If so it is not acceptable as a 

SIP submission. 

2. Not a regulatory change, however applicable portions of 

section 110(a)(2) of the Clean Air Act (CAA) are adopted in

the District of Columbia’s State Implementation Plan (SIP)

under 40 CFR Part 52 Subpart J.

X

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. The District of Columbia (the District) has the authority 

pursuant to the District of Columbia Air Pollution Control Act 

of 1984.

X

4. A copy of actual regulation, or document submitted for 4. State regulations have been previously adopted and are X
EPA REQUIREMENT STATE SUBMITTAL (X)

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.

being certified or referenced in the submittal. 

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in conducting 

and completing the adoption/issuance of the plan.

5. The submittal letter dated July 17, 2014 confirms that all 

required administrative procedures were properly followed for 

this SIP revision. A copy of public hearing notice and 

transcript were included.

X

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.

6. Provided is a copy of the notice of public hearing and 

evidence of its publication on the DDoE website on April 18, 

2014. In the notice DDoE requested both public written and 

oral comments by May 19, 2014. 

X

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State's laws and constitution, if applicable.

7. A hearing officer’s certification for the public hearing was 

provided. The public hearing was held on May 19, 2014, as 

described in the notice. 

X

8. Compilation of public comments and the State’s response 

thereto.

8. A compilation of public written comments and DDoE’s 

response was provided. No public comments were received at 

the hearing. 

X

 Technical Materials

1. Identification of all regulated pollutants affected by the plan. 1. Sulfur dioxide (SO2); specifically, the 2010 SO2 National 

Ambient Air Quality Standard (NAAQS)

X

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

and the status of the attainment plan for the affected area(s).

2. Most of the State regulations certified or referenced in the 

SIP submittal apply statewide.

X
EPA REQUIREMENT STATE SUBMITTAL (X)

3. Quantification of the changes in plan allowable 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 certain 

baseline levels and allowable emissions anticipated as a result 

of the revision.

3. Not applicable. The SIP revision addresses necessary 

elements for implementation of the 2010 SO2 NAAQS. This 

SIP submittal does not relate to modification of existing

emission limits. 

X

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

4. The SIP revision addresses necessary elements for 

implementation of the 2010 SO2 NAAQS. The SIP revision 

submittal certifies existing air pollution control programs in the 

District’s SIP, as provided in 40 CFR Part 52 Subpart J.

 

X

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

justification for use of offsite data (where used), modes of 

models used, assumptions, and other information relevant to the

determination of adequacy of the modeling analysis.

5. Not applicable. No modeling required to support SIP 

revision. 

X

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. The SIP revision addresses necessary elements for 

implementation of the 2010 SO2 NAAQS. The SIP revision 

submittal certifies that the District has adopted in the SIP 

control measures and emission limitations for SO2, as provided

in 40 CFR Part 52 Subpart J.

X

7. Evidence that the plan contains emission limitations, work

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The SIP revision addresses necessary elements for 

implementation of the 2010 SO2 NAAQS. The SIP revision 

submittal certifies that the District has adopted in the SIP 

control measures and emission limitations for SO2, as provided 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

in 40 CFR Part 52 Subpart J.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. The SIP revision addresses necessary elements for 

implementation of the 2010 SO2 NAAQS. The SIP revision 

submittal certifies that the District has adopted in the SIP 

compliance/enforcement measures for SO2, as provided in 40 

CFR Part 52 Subpart J. 

X

9. Special economic and technological justifications required by

any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. Not applicable. No special justifications are required. X

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Not applicable. Not a Section 107 request. X