5365
450R78104
GUIDELINE SERIES
OAQPS NO. 1.2-
095
February 24, 1978
CRITERIA FOR APPROVAL OF 1979
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SIP REVISIONS
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C 20460
FEB 24 1978
OFFICE OF
AIR AND WASTE MANAGEMENT
SUBJECT: Criteria for Approval of 1
FROM: The Administrator (A-100)
TO: Regional Administrators, I-X
IP Revisions
The attachment to this memo summarizes the elements
which a 1979 State Implementation Plan (SIP) revision
for a non-attainment area must contain in order to be
approved by EPA as meeting the requirements of Part D of
the Clean Air Act.
In summary, the Act requires the demonstration of
attainment of the air quality standards (primary and ,
secondary) as expeditiously as practicable, but in the
case of national primary standards not later than
December 31, 1982. However, for carbon monoxide (CO) and
oxidants (Ox), if the State can demonstrate attainment
is not possible by 1982 despite the implementation of all
reasonable stationary source and transportation control
measures, the Act provides for up to a five-year extension.
In those cases the plan revisions must demonstrate
attainment as expeditiously as practicable but no later
than December 31, 1987. The extension is not automatic;
a demonstration of need must be made and the State must
fulfill the other statutory requirements.
It is the intent of the Agency to establish reasonable
and achievable goals for SIP submissions and to take a firm
posture on the imposition of sanctions where the reasonable
goals are not achieved. Accordingly, while the policy
requires a commitment to many specific strategies in the
1979 submissions (e.g., RACT on stationary sources, inspec-
tion/maintenance programs where attainment for carbon
monoxide or oxidants extends beyond 1982, other reasonable
transportation control measures, etc.) the memo also
requires (for carbon monoxide and oxidants) a commitment
to a continuing process. This process must be one which
extensively involves the public as well as State and local
elected officials and which ambitiously pursues a wide
range of alternatives.
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Since reliance on stationary controls and Federal
new car standards alone will not enable most areas with
oxidant and carbon monoxide problems to attain these
standards by 1982, each Regional Office will need to put
particular emphasis on additional measures to reduce
transportation system emissions. The process committed
t"> in the 1979 plan submission must lead to the
expeditious selection and implementation of comprehensive
transportation control measures. In judging the adequacy
of the 1979 plan submission for the transportation
sector, each Regional Administrator should ensure that
ambitious alternatives (as described in the draft
"Transportation Planning Guidelines" which have been
circulated) will be analyzed.
The Department of Transportation (DOT), Housing and
Urban Development (HUD) and EPA are seeking to integrate
the transportation/air quality planning and implementation
required by the Clean Air Act into existing planning and
programming procedures. The air planning activities should
be included in the Unified Work Program required by DOT
and the adopted transportation measures should be included
in the Transportation Improvement Program required by DOT.
In complying with the Clean Air Act requirements, the Regions
should also keep in mind the requirements of the HUD-EPA
Agreement which provides for coordination of air quality
planning and planning assisted under the HUD Comprehensive
Planning Assistance (701) Program. Integration of air
and transportation planning with comprehensive planning
which incorporates growth management concerns should improve
the effectiveness of air quality planning and could reduce
the need for enforcement measures in the future.
States will be provided some discretion regarding
the amount of emissions growth to be accommodated within
the SIP. EPA generally will not question the growth rates
desired by the State so long as reasonable further progress
is demonstrated and there is a demonstration of attainment
by the statutory deadline (1982 or 1987). However, the
growth rate identified in the SIP must be consistent with
growth rates used (or implied by) other planning programs
in the area (e.g., FWPCA §208, '201, HUD §701, FHWA
§134).
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You should note that there are other SIP revisions
which are not discussed in the attachment but which are
required by the 1977 Amendments. These include:
1. Section 128 (relating to State boards)
2. Section 126 (relating to interstate pollution)
3. Section 127 (relating to public notification)
4. Part C (relating to prevention of significant
deterioration)
5. Section 110(a)(2)(K) (relating to permit fees)
6. Section 123 (relating to stack heights for
existing source in other than non-attainment
areas)
7. Section 121 (relating to consultation)
Although incorporation of these provisions is required
by the law, failure to achieve final approval by
July 1, 1979 does not trigger the new source prohibition
of Section 110(a)(2)(I).
It is important to emphasize to the States that all
current SIP requirements remain in effect despite the
development of the 1979 revisions. Any suspension or
discontinuance of an existing SIP provision must be
submitted for EPA approval. This should be done as part
of the revision submitted in January 1979. Exceptions
to this procedure may be found in certain new provisions
of §110 relating to reduction of on-street parking, bridge
tolls, and other measures.
The development of the January 1979 SIPs to meet the
minimum requirements of the Clean Air* Act Amendments of
1977 is a complex and demanding program. It will require
the commitment of significant resources on the part of the
air programs staff of the Regional Office to ensure that
the States develop and submit a comprehensive and
approvable plan. We are working with your staff to develop
the necessary guidance and follow-up programs which will
assist your office and the State to carry out this very
difficult but important part of the overall air program.
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Attachment
cc: Air § Hazardous Division Directors
Air Branch Chiefs
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Criteria for Approval of 1979 State Implementation Plan Revisions
for Non-Attainment Areas
Purpose
The purpose of this document is tc define the criteria by which
State Implementation Plan (SIP) revisions for non-attainment areas
required by the Clean Air Act Amendments of 1977 (the Act) will be
approved. These revisions are to be submitted to EPA by January 1, 1979.
Categories of SIP Revisions
SIP revisions submitted by January 1, 1979 can be divided into
two categories:
1. Those which provide for attainment of the Primary Ambient
Air Quality Standards (primary standards) for all criteria pollutants
on or before December 31, 1982.
2. Those which provide for attainment of the primary standards
for sulfur dioxide, nitrogen oxides, and particulate matter on or before
December 31, 1982 but show that despite the implementation of all
reasonable transportation and stationary source emission control measures
attainment of the primary standards for carbon monoxide and/or oxidants
cannot be achieved until after this date. In these cases, the revisions
must demonstrate attainment as expeditiously as practicable but no later
than December 31, 1987.
In order for an adequate SIP revision to fall into the second
category, the State has an affirmative responsibility to demonstrate
to the satisfaction of EPA that attainment of the primary carbon
monoxide and/or oxidants standards is not possible in an area prior
to December 31, 1982.
It should be noted that SIP revisions of either category should
also provide for attainment of Secondary Ambient Air Quality Standards
(secondary standards) as expeditiously as practicable although there is
no specific deadline contained in the Act.
General Requirements of All 1979 SIP Revisions
Each 1979 SIP revision must contain the following:
1. A definition of the geographic areas for which control
strategies have been or will be developed. Consideration should be
given to the practical benefits of defining areas which correspond
whenever possible to those substate districts established pursuant
to Part IV, Attachment A of OMB Circular No. A-95.
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2. An accurate, comprehensive, and cunent (1977 calendar year)
inventory of existing emissions.
3. A determination of the level of control needed to demonstrate
attainment by 1982 (including growth). This demonstraLion should bt
made by the application of modal ing techniques as set iurth in EPA's
Guideline on Ai> Quality Models, For ox-ldan^, any legitimate modeling
technique (e.g., those referenced in "Use, Limitation and Technical
Basis of Procedures for Qualifying Relationships Between Photochcryi :al
Oxidants and Precursors." EPA 450/2-77-021d. November 1977) can be
used. Consideration of background and transport for oxidants should
generally be in accordance with the procedures documented in "Procedures
for Quantifying Relationships Between Photochemical Oxidants and
Precursors." In developing photochemical oxidant control strategies
for a particular area, states may assume at a minimum that the standard
will be attained in adjacent states.
If a state can demonstrate that the level of control necessary for
attainment of the primary standards for carbcn monoxide and/or oxidant
is not possible by 1982 despite the application of all reasonable
measures, an extension past 1982 (but not beyond 19877 is authorized.
4. Adoption in legally enforceable form! of all measures necessary
to provide for attainment by the prescribed date or, where adoption of
all such measures by 1979 is not possible, (e.g., certain transportation
control measures, and certain measures to control the oxides of nitrogen
and total suspended particulate) a schedule for expeditious development,
adoption, submittal, and implementation of these measures. The
situations in which adoption of measures may be scheduled after 1979_
are discussed in the pollutant specific sections of this document. Each
schedule must provide for implementation of all reasonably available
control measures as expeditiously as practicable. During the period
prior to attainment, these measures must be implemented rapidly enough
to provide at a minimum for reasonable further progress (see discussion
^Written evidence that the State, the general purpose local
government or governments, or a regional agency designated by general
purpose local governments for such purpose, have adopted by statute,
regulation, ordinance or other legally enforceable document, the
necessary requirements and schedules and timetables for compliance,
and are committed to implement and enforce the appropriate elements
of the plan. The relevant organizations shall provide evidence that
the legally enforceable attainment measures and the "criteria,
standards and implementing procedures necessary for effectively guidinc
and controlling major decisions as to where growth shall and shall not
.ake place," prepared by State and local governments in compliance with
Section 701 of the Housing Act of 1954, as amended, are fully coordinated
in the attainment and maintenance of the NAAQS.
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below). Each schedule will be considered part of the applicable
implementation plan and thus will represent a commitment on the part
of the State to meet the key milestones set forth in the submitted
schedule.
5. Emission reduction estimates for each adopted or scheduled
control measure or for related groups of control measures where
estimates for individual measures are impractical. It is recognized
that reduction estimates may change as measures are more fully
analyzed and implemented. As such estimates change, appropriate
responses will be required to insure that the plan remains adequate
to provide for attainment and for reasonable further progress.
6. Provision for- reasonable further progress toward attainment
of the primary and secondary standards in the period prior to the
prescribed date for attainment. Reasonable further progress is defined
as annual incremental reductions in total emissions (emissions from
new as well as existing sources) to provide for attainment by the
prescribed date. The plan shall provide for substantial reductions in
the early years with regular reductions thereafter.
Reasonable further progress will be determined for each area
by dividing the total emission reductions required to attain the appli-
cable standard by the number of years between 1979 and the date pro-
jected for attainment (not later than 1987). This is represented
graphically by a straight line drawn from the emissions inventory sub-
mitted in 1979 to the allowable emissions on the attainment date.
However, EPA recognizes that some measures cannot result in immediate
emission reduction. Therefore, if a State can show that some lag in
emissions reduction is necessary, a SIP will be acceptable even though
reductions sufficient to produce decreases at the "straight-line rate"
are not achieved for a year or two after 1979. This lag in achieving
the "straight-line rate" for emissions reduction is to be accepted
only to accommodate the time required for compliance with the first set
of regulations adopted on or before January 1, 1979, if immediate
compliance is not possible. It does not authorize delays in adoption
of control requirements.
The requirement to demonstrate reasonable further progress will,
in most areas designated non-attainment for oxidant or carbon monoxide,
necessitate a continuous, phased implementation of transportation
control measures. In areas where attainment of all primary ambient
standards by 1982 is not possible EPA will not accept mere reliance on
the Federal Motor Vehicle Control Program by itself as a demonstration
of reasonable further progress.
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In determining "reasonable further progress", those emission
reductions obtained from compliance between August 7, 1977, and
December 31, 1979, with (1) SIP revisions that have been submitted
after August 7, 1977, and (2) regulations which were approved by the
Agency prior to the enactment of the 1977 Clean Air Amendments, can
be treated as having been achieved during 1979. There should be an
assurance, however, that these are real emission reductions and hot
just "paper" ones.
7. An identification and quantification of an emissions growth
increment which will be allowed to result from the construction and
operation of major new or modified stationary sources within the area
for which the plan has been developed. Alternatively, an emissions
offset regulation can be adopted to provide for major new source growth.
The growth rates established by states for mobile sources and new
minor stationary sources should also be specified, and in combination
with the growth associated with major new or modified stationary sources
will be accepted so long as they do not jeopardize the reasonable further
progress test and attainment by the prescribed date. However, the growth
rate identified in the SIP must be consistent with the growth rates used
(or implied by) the other planning programs in the area (e.g., FWPCA
Section 208 [201], HUD Section 701, FHWA Section 134). A system for
monitoring the emission growth rates from major and minor new stationary
sources and from transportation sources and assuring that they do not
exceed the specified amounts must also be provided for in the revision.
8. Provision for annual reporting on the progress toward meeting
the schedules summarized in (4) above as well as growth of mobile
sources, minor new stationary sources, major new or modified stationary
sources, and reduction in emissions from existing sources to provide for
reasonable further progress as in (6) above. This should include an
updated emission inventory.
9. A requirement that permits be issued for the construction and
operation of new or modified major sources in accordance with Section
173 and 110(a)(2)(D).
10. An identification of and commitment to the financial and
manpower resources necessary to carry out the plan. The commitment
should be made at the highest executive level having responsiblity for
SIP or that portion of it and having authority to hire new employees.
This commitment should include written evidence that the State, the
general purpose local government or governments, and all state, local or
regional agencies have included appropriate provision in their respective
budr ts and intend to continue to do so in future years for which budgets
ha not yet been finalized, to the extent necessary.
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11. Evidence of public, local government, and state legislative
involvement and consultation. It shall also include an identification
and brief analysis of the air quality, health, welfare, economic,
energy, and social effects of the plan revisions and of the alternatives
considered by the State, and a summary of the public comment on such
analysis.
12. Evidence that the SIP was adopted by the state after reasonable
notice and public hearing.
Additional Requirements for Carbon Monoxide and Oxidant SIP Revisions
which Provide for Attainment of the Primary Standards Later than 1982
For those SIP revisions which demonstrate that attainment of the
primary standards for carbon monoxide and/or oxidants is not possible
in an area prior to December 31, 1982 despite the implementation of all
reasonable emission control measures the following items must be
included in the January 1, 1979 submission in addition to all the
general requirements listed above:
1. A program which requires prior to issuance of any permit for
construction or modification of a major emitting facility an analysis
of alternative sites, sizes, production processes, and environmental
control techniques for such proposed source which demonstrates that
benefits of the proposed source significantly outweigh the environmental
and social cost imposed as a result of its location, construction, or
modification.
2. An inspection/maintenance program or a schedule endorsed by
and committed to by the Governor for the development, adoption, and
implementation of such a program as expeditiously as practicable.
Where the necessary legal authority does not currently exist, it must
be obtained by June 30, 1979. Limited exceptions to the requirement
to obtain legal authority by June 30, 1979 may be possible if the state
can demonstrate that (a) there was insufficient opportunity to conduct
necessary technical analyses and/or (b) the legislature has had no
opportunity to consider any necessary enabling legislation for inspection/
maintenance between enactment of the 1977 Amendements to the Act and
June 30, 1979. In addition, where a legislature has adequate opportunity
to adopt enabling legislation before January 1, 1979, the Regional
/^arcinistrator should require submission of such legal authority by
January 1, 1979. In no case can the schedule submitted provide for
obtaining legal authority later than July 1, 1980.
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Actual implementation of the inspection/maintenance program must
proceed as expeditiously as practicable. EPA considers two and one half
years from the time of legislative adoption to be the maximum time
required to implement a centralized inspection/maintenance program and
one and one half years to implement a decentralized proqr?m. In no case
may "implementation of the program, i.e., mandatory inspection and
mandatory repair of failed vehicles be delayed beyond 1982 in the case
of a centralized program (either state lanes or contractor lanes) or
beyond 1981 in the case of a decentralized (private garage) system.
3. A commitment by the responsible government official or
officials to establish, expand, or improve public transportation
measures to meet basic transportation needs as expeditiously as is
practicable.
4. A commitment to use insofar as is necessary Federal grants,
state or local funds, or any combination of such grants and funds as
may be consistent with the terms of the legislation providing such
grants and funds, for the purpose of establishing, expanding or
improving public transportation measures to meet basic transportation
needs.
Note that HUD has prepared guidelines for local development codes
and ordinances to provide special requirements for areas which for
significant periods of time may exceed the primary standards. These
guidelines specify criteria for new construction operation of buildings
which minimize pollutant concentrations to ensure a healthy indoor and
outdoor environment. States are encouraged to adopt such measures as
part of the SIP.
Pollutant Specific Requirements
Sulfur Dioxide
Specifically, with regard to item (4) of the General Requirements,
the January 1979 plan revisions dealing with sulfur dioxide must contain
all the necessary emission limitations and legally enforceable procedures
to provide for attainment by no later than December 31, 1982 (i.e.,
schedules for the development, adoption, and submittal of regulations
will not be acceptable).
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Nitrogen Oxides
For NOX» the January 1979 plan must contain all the necessary
emission limitations and the legally enforceable procedures, or as a
minimum, the appropriate schedules to adopt and submit the emission
limitations and legally enforceable procedures which provide for
implementation so that standards will be attained by no later than
December 31, 1982. EPA is currently evaluating the need for a short
term N0£ standard and expects to promulgate such a standard during
1978. If such a standard for air quality is promulgated, a new and
separate SIP revision will be required for this pollutant.
Particulate Matter
The January 1979 plan revisions dealing with particulate matter
must contain all the necessary emission limitations and legally enforce-
able procedures for traditional sources. These emission limitations and
enforceable procedures must provide for the control of fugitive
emissions, where necessary, as well as stack emissions from these
stationary sources. Where control of non-traditional sources (e.g.,
urban fugitive dust, resuspension, construction, etc.) is necessary for
attainment, the plan shall contain an assessment of the impact of these
sources and a commitment on the part of the state to adopt appropriate
control measures. This commitment shall take the form of a schedule to
develop, submit, and implement the legally enforceable procedures, and
programs for controlling non-traditional particulate matter sources.
These schedules must include milestones for evaluating progress and
provide for attainment of the primary standards by no later than
December 31, 1982, and attainment of the secondary standards as expe-
ditiously as practicable. States should initiate the necessary studies
and demonstration projects for controlling the non-traditional sources
as soon as possible.
Carbon Monoxide and Oxidant
An adequate SIP for oxidant is one which provides for sufficient
control of volatile organic compounds (VOC) from stationary and mobile
sources to provide for attainment of the oxidant standard. Accordingly,
the 1979 plan revision must set forth the necessary emission limitations
and schedules to obtain sufficient control of VOC emissions in all non-
attainment areas. They must be directed toward reducing the peak
concentrations within the major urbanized areas to demonstrate attainment
ar expeditiously as practicable but in no case later than December 31, 1987.
This should also solve the rural oxidant problem by minimizing VOC
emissions and more importantly oxidants that may be transported from
urban to rural areas. The 1979 submission must represent a comprehensive
strategy or plan for each non-attainment area; plan submissions that
address only selected portions of non-attainment are not adequate.
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For the purpose of oxidant plan development, major urban areas are
those with an urbanized population of 200,000 or greater (U.S. Bureau
of Census, 1970). A certain degree of flexibility will be allowed in
defining the specific boundaries of the urban area. However, the areas
must be large enough to cover the entire urbanized? area and adjacent
fringe areas of development. For non-attainment urban areas, the highest
pollutant concentration for the entire area must be used in determining
the necessary level of control. Additionally, uniform modeling .tech-
niques must be used throughout the non-attainment urban area. These
requirements apply to interstate as well as intrastate areas.
Adequate plans must provide for the adoption of reasonably
available control measures for stationary and mobile sources.
For stationary sources, the 1979 oxidant plan submissions for
major urban areas must include, as a minimum, legally enforceable
regulations to reflect the application of reasonably available control
technology (RACT)3 to those stationary sources for which EPA has
published a Control Techniques Guideline (CTG) by January 1978, and
provide for the adoption and submittal of additional legally enforce-
able RACT regulations on an annual basis beginning in January 1980, for
those CTGs that have been published by January of the preceeding year.
For rural non-attainment areas, the Ox plan must provide the
necessary legally enforceable procedures for the control of large HC
sources (more than 100 ton/year potential emissions) for which EPA
has issued a CTG by January 1978, and to adopt and submit additional
legally enforceable procedures on an annual basis beginning in
January 1980, after publication of subsequent CTGs as set forth above.
For mobile sources in urbanized area (population 200,000) SIPs
must provide for expeditious implementation of reasonably available
control measures. Each of the measures for which EPA will publish
information documents during 1978 is a reasonably available control
measure. These measures are listed on the following page:
2As defined by the U.S. Bureau of Census, urbanized area generally
include core cities plus any closely settled suburban areas.
3while it is recognized that RACT will be determined on a case-by-
case basis, the criteria for SIP approval rely heavily upon the
information contained in the CTG. Deviations from the use of the CTG
must be adequately documented.
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1. To be published by February 1978
a. inspection/maintenance
b. vapor recovery
c. improved public transit
d. exclusive bus and carpool lanes
e. area wide carpool programs
2. To be published by August 1978
a. private car restrictions
b. long range transit improvements
c. on street parking controls
d. park and ride and fringe parking lots
e. pedestrian malls
f. employer programs to encourage car and van pooling,
mass transit, bicycling and walking
g. bicycle lanes and storage facilities
h. staggered work hours
i. road pricing to discourage single occupancy auto trips
j. controls on extended vehicle idling
k. traffic flow improvements
1. alternative fuels or engines and other fleet
vehicle controls
m. other than light duty vehicle retrofit
n. extreme cold start emission reduction programs
The above measures (either individually or combined into packages
of measures) should be analyzed promptly and thoroughly and scheduled
for expeditious implementation. EPA recognizes that not all analyses
of every measure can be completed by January 1979 and, where necessary,
schedules may provide for the completion of analyses after January 1,
1979 as discussed below. (If analysis after January 1979 demonstrates
that certain measures would be unnecessary or ineffective, a decision
not to implement such measures may be justifiable. However, decisions
not to implement measures will have to be carefully reviewed to avoid
broad rejections of measures based on conclusory assertions of
infeasibility.)
As described previously, annual incremental reductions in total
emissions must occur in order to achieve reasonable further progress
during the period prior to attainment of the standards. Therefore,
not all transportation measure implementation activities should wait
until the comprehensive analyses of control measures are completed.
Demonstration studies are important and should accompany or precede
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full scale Implementation of the comprehensive strategy. It is EPA's
policy that each area will be required to schedule a representative
selection of reasonable transportation measures (as listed above) for
implementation at least on a pilot or demonstration basis prior to the
end of 1980.
Every effort must be made to integrate the air quality related
transportation plan and implementation required by the Clean Air Act
into planning and programming procedures administered by DOT. EPA will
publish "Transportation Planning Guidelines" which will, if followed
carefully, insure that an adequate transportation planning process
exists.
EPA recognizes that the planning and implementation of very
extensive air quality related transportation measures can be a complicated
and lengthy process, and in areas with severe carbon monoxide or oxidant
problems, completion of some of the adopted measures may extend beyond
1982. Implementation of even these very extensive transportation
measures, however, must be initiated before December 31, 1982.
In the case of plan revisions that make the requisite showing to
justify an extension of the date for attainment, the portion of the 1979
plan submittal for transportation measures must:
1. Contain procedures and criteria adopted into the SIP by which
it can be determined whether the outputs of the DOT Transportation
planning process conform to the SIP.
2. Provide for the expeditious implementation of currently
planned reasonable transportation control measures. This includes
reasonable but unimplemented transportation measures in existing SIPs
and transportation controls with demonstrable air quality benefits
developed as part of the transportation process funded by DOT.
3. Present a program for evaluating a range of alternative
packages of transportation options that includes, as a minimum, those
measures listed above for which EPA will develop information documents.
The analyses must identify a package of transportation control measures
to attain the emission reduction target ascribed to it in the SIP.
4. Provide for the evaluation of long range (post-1982) trans-
portation and growth policies. Alternative growth policies and/or
development patterns must be examined to determine the potential for
modifying total travel demand. One of the growth alternatives evaluated
should be that prepared in response to Section 701 of the Housing Act of
1954, as amended.
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5. Include a schedule for analysis and adoption of transportation
control measures as expeditiously as practicable. The comprehensive
analysis of alternatives (item 2 above) must be completed by July 1980
unless the designated planning agency can demonstrate that analysis
of individual components (e.g., long range transit improvements) may
require additional time. Adopted measures must be implemented as
expeditiously as practicable and on a continuous schedule that demonst*
reasonable further progress from 1979 to the attainment date. Deter-
minations of the reasonableness of a schedule will be based en the
nature of the existing or planned transportation system and the com-
plexity of implementation of an individual measure.
Additional Carbon Monoxide and Oxidant Monitoring Requirements
It is EPA's policy to require that all SIPs which provide for
attainment of the oxidant standard after December 31, 1982, must con-
tain commitments to implement a complete oxidant monitoring program in
major urbanized areas in order to adequately characterize the nature
and extent of the problem and to measure the effectiveness of the
control strategy for oxidants. The 1979 plan submittal must provide
for a schedule to conduct such CO monitoring as necessary to correct
any deficiencies as identified by the Regional Office.
SIPs for Unclassified Areas Redesignated Non-Attainment
With respect to unclassified areas which are later found to be
non-attainment areas the state will be required to submit a plan
within nine months of the non-attainment determination. During plan
development, the state will be required to implement the offset policy
for that area. However, it should be noted that in many cases, because
of previous plan revisions or adoption of previous control regulations,
the baseline for offsets will be more restrictive and thus offsets may
be more difficult to obtain. For oxidants, state-wide regulatory
development (for at least all sources greater than 100 tons/year),
however, would permit the state to utilize the regulations developed
for the entire state as the applicable plan for the newly designated
non-attainment area. This wo^ild normally constitute an approvable SIP
per the above criteria and could essentially accommodate the proposed
growth within the previously submitted state plan and not require
offsets once the area is designated as non-attainment.
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