Final 2.26.2019
2015 Ozone National Ambient Air Quality Standard
Quick Start Guide
for Early Engagement between EPA and Air Agencies
This Checklist lays out a sample timeline of key milestones intended to help EPA and state and local air
agencies collaborate early and throughout the state implementation plan (SIP) development process for
the 2015 8-hour ozone standard. This tool stems from process improvement discussions between EPA
and air agencies where early and frequent communications were identified as key to success in the SIP
process. This document seeks to "operationalize" effective communication by providing a timeline for
ensuring such discussions occur at pivotal points throughout the SIP process. This "early engagement" is
a critical component to supporting air agencies in the development of approvable SIPs and EPA in taking
timely action on SIPs. This document is intended to promote efficiency through the SIP process, for both
EPA and air agencies.
The Guide is set up as three tables - one for each year different SIP requirements are due (2020, 2021
and 2022) with reference to each other when the timing overlaps (color coded). What is listed below is
intended to provide high level suggestions on timing and milestones. Regions are encouraged to use
this checklist as a guide and should discuss target dates with air agencies to help air agencies submit
approvable SIPs and help EPA act on those SIPs within the statutory timeframes. To the extent this
timeline recommends submission of draft SIPs, in addition to the formal submittal, air agencies should
use the State Plan Electronic Collaboration System or SPeCS for that purpose.
Table 1. - Checklist for Requirements Due August 3, 2020: Emissions
Inventory, Emissions Statements (all areas) and RACT (Moderate &
higher)

Action
Responsible
Target Date
Notes
Date

Person


Completed




Emissions inventory and emission statements (all areas), RACT (Moderate and higher)
SIP Assignment Subprocess


2015 Ozone Designations Effective Date

8/3/2018


Final SIP Requirements Rule Published

12/6/2018


Assign SIP Lead.
Air Program
Manager at
EPA (APM)
Oct/Nov
2018


Initial Discussions for SIPs due August 2020
SIP Lead at
Dec 2018


between Headquarters and Regions:
EPA



Regions schedule call with OAQPS contact to




review EACH nonattainment area and




discuss expectations around control strategy




and plan development challenges and




opportunities.




Assign SIP Team
APM
Dec 2018

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Final 2.26.2019

(i.e., legal, modeling, inventory)





SIP Preparation Subprocess


Conceptual Discussions with Air Agency:
SIP
Jan 2019


Emissions inventory, emission
Lead/Team



statements, RACT (due August 2020)
and Air



Consider beginning discussions on
Agency



control strategy and attainment




demonstration modeling (due August




2021)




Ongoing Discussions:
SIP
Jan 2019-


(i.e., Establish regular meetings as
Lead/Team
submittal of


appropriate; Air agency submits pieces of SIP
and Air
early draft


for informal review as they are completed.)
Agency



Agree on schedule for SIP development:
SIP
March 2019


SIP Team should work with air agencies to
Lead/Team



establish schedule based off of suggested
and Air



timelines in this Guide.
Agency



SIP Team:
EPA HQ
Prior to


Determine if OAQPS and/or OGC should
Point of
getting draft


review draft in addition to SIP Team.
Contact
(POC) and
SIP Lead
SIP for
review


Early Engagement Draft Submitted:
Air Agency
August 2019
One year prior to

SIP Lead distributes to SIP Team to review.

- March
2020
Anticipated
review time:
30 days -
most SIPs
60 days -
more
complex SIPs
regulatory due date is
a recommended
target. Regions
should negotiate with
air agencies to
establish a schedule:
a - sooner for
certification SIPs
b - based on air
agency's regulatory
adoption process if
state needs to write a
regulation (i.e., RACT)
c - considering air
agency resources.

Identification of Approvability Issues:
APM
Sept 2019-


SIP Lead brief APM on any potential

April 2020


approvability issues identified by SIP Team

(1-2 weeks


and review written comments as necessary.

before end
of review
time)


Feedback on Early Engagement Draft:
SIP Lead
Sept 2019-
May 2020

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Final 2.26.2019

SIP Lead provides comments to Air Agency




and offers to set up conference call.




Ongoing discussions
SIP



(e.g., Discuss how Air Agency is addressing
Lead/Team



EPA comments, go over schedule.)
and Air
Agency



Reminder: Begin discussions for 2021

Dec 2019


requirements, see Table 2: 15% ROP, NNSR,




Attainment Demonstration, RACM, and Basic




l/M (Moderate).




Air Agency Public Comment Period Draft
SIP Lead
Jan - May
Target dates

Submitted to EPA:

2020
negotiated based on

SIP Lead distributes to SIP Team for review

(2 weeks
SIP element

for possible comment during comment

prior to
complexity and/or air

period.

publication)
agency regulatory
process.

Air Agency Public Comment Period.
Air Agency
Jan - May
2020
Typically 30 days

Air Agency Public Comment Period
APM
15 days prior


Identification of Approvability Issues:

to end of


SIP Lead briefs APM on any issues, APM

comment


decides to comment on record or not.

period


Air Agency Public Comment Period
SIP Lead
June 2020 at


Feedback:

the latest


SIP Lead gives Air Agency a head's up, EPA




comments on record as appropriate.




Air Agency shares any substantive comments
Air Agency
June - July


received during public comment period with

2020


EPA.




Ongoing discussions regarding any changes
SIP
June - July


to proposed SIP.
Lead/Team
and Air
Agency
2020


Emissions inventory, emissions statements,
Air Agency
August 3,


RACT SIP(s) submitted to EPA

2020

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Final 2.26.2019
Table 2. - Checklist for Requirements Due August 3, 2021: 15% ROP,
NNSR, Attainment Demonstration, RACM, and Basic l/M (Moderate)
v'
Action
Responsible
Target Date
Notes
Date

Person


Completed




15% ROP, NNSR, Attainment Demonstration, RACM, and Basic l/M (Moderate)

Assign SIP Lead (if different)
APM
October 2019


Initial Discussions for Attainment Plans
SIP Lead
Dec 2019


between Headquarters and Regions:




Regions schedule call with OAQPS contact




to review EACH nonattainment area and




discuss expectations around control




strategy and plan development challenges




and opportunities.




Assign SIP Team
APM
Dec 2019


(i.e., legal, modeling, inventory)



SIP Preparation Subprocess

Conceptual Discussions with Air Agency:
SIP Lead/Team
Dec 2019


15% ROP, NNSR, other attainment plan
and Air Agency



elements required for Moderate areas




(due August 2021).




Consider beginning discussions on




control strategy and attainment




demonstration modeling for Serious




areas & above (due August 2022).




Ongoing Discussions:
SIP Lead/Team
Jan 2020-


(i.e., Establish regular meetings as
and Air Agency
submittal of


appropriate; Air agency submits pieces of

early draft


SIP for informal review as they are




completed.)




Agree on schedule for SIP development:
SIP Lead/Team
March 2020


SIP Team should work with air agencies to
and Air Agency



establish schedule based off of suggested




timelines in this Guide.




SIP Team:
EPA HQPOC
Prior to getting


Determine if OAQPS or OGC should review
and SIP Lead
draft SIP for


draft in addition to SIP Team.

review


Early Engagement Draft Submitted: SIP
Air Agency
August 2020 -
One year prior to

Lead distributes to SIP Team to review.

March 2021
Anticipated
review time:
30 days - most
SIPs
60 days - more
complex SIPs
regulatory due is a
recommended
target. Regions
should negotiate
with air agencies to
establish a
schedule:
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Final 2.26.2019




a - sooner for




certification SIPs




b - based on air




agency's regulatory




adoption process if




air agency needs to




write a regulation




c - considering air




agency resources.

Identification of Approvability Issues:
APM
Sept 2020 -


SIP Lead brief APM on any potential

April 2021


approvability issues identified by SIP Team

(1-2 weeks


and review written comments as

before end of


necessary.

review time)


Feedback on Early Engagement Draft:
SIP Lead
Sept 2020 -


SIP Lead provides comments to Air Agency

May 2021


and offers to set up conference call.




Ongoing discussion
SIP Lead/Team



(e.g., Discuss how state is addressing EPA
and Air Agency



comments, go over schedule.)




Reminder: Begin discussions for 2022

Dec 2020


requirements, see Table 3: Attainment




Plan, RFP with 3% reduction, Enhanced l/M




(serious and higher).




Air Agency Public Comment Period Draft
SIP Lead
Jan - May 2021
Target dates

Submitted to EPA:

(2 weeks prior
negotiated based

SIP Lead distributes to SIP Team for review

to publication)
on SIP element

for possible comment during comment


complexity and/or

period.


air agency reg
process.

Air Agency Public Comment Period.
Air Agency
Jan - May 2021
Typically 30 days

Air Agency Public Comment Period
APM
15 days prior to


Identification of Approvability Issues:

end of


SIP Lead briefs APM on any issues, APM

comment


decides to comment on record or not.

period


Air Agency Public Comment Period
SIP Lead
June 2021 at


Approvability Feedback: SIP Lead gives Air

the latest


Agency a head's up, EPA comments on




record as appropriate.




Air Agency shares any substantive
Air Agency
June - July 2021


comments received during public comment




period with EPA.




Ongoing discussion regarding any changes
SIP Lead/Team
June - July 2021


to proposed SIP.
and Air Agency



15% ROP, NNSR, attainment plan
Air Agency
August 3, 2021


(Moderate) SIP(s) submitted to EPA.



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Final 2.26.2019
Table 3. Checklist for Requirements Due August 3, 2022: Attainment
Demonstrations, RFP Showing 3% Reduction, Enhanced Vehicle l/M
(Serious and higher)
v/
Action
Responsible
Target Date
Notes
Date

Person


Completed




Attainment demonstration SIPs and RACM, RFP's with 3% reduction, Enhanced l/M (serious and higher)

Assign SIP Lead (if different).
APM
October 2020


Initial Discussions for Attainment Plans
SIP Lead
Dec 2020


between Headquarters and Regions:




Regions schedule call with OAQPS contact to




review EACH nonattainment area and




discuss expectations around control strategy




and plan development challenges and




opportunities.




Assign SIP Team.
APM
Dec 2020


(i.e., legal, modeling, inventory)



SIP Preparation Subprocess

Conceptual Discussions with Air Agency:
SIP
Dec 2020


Attainment plan, RFP with 3% reduction,
Lead(s)/Air



other attainment plan elements required for
Agency



Serious areas and higher.




Ongoing Discussions:
SIP
Jan 2021-


(i.e., Establish regular meetings as
Lead/Team
submittal of


appropriate; Air agency submits pieces of SIP
and Air
early draft


for informal review as they are completed.)
Agency



Agree on schedule for SIP development:
SIP
March 2021


SIP Team should work with air agencies to
Lead/Team



establish schedule based off of suggested
and Air



timelines in this Guide.
Agency



SIP Team:
EPA HQPOC
Prior to getting


Determine if OAQPS or OGC should review
and SIP Lead
draft SIP for


draft in addition to SIP Team.

review


Early Engagement Draft Submitted:
Air Agency
August 2021 -
One year prior to

SIP Lead distributes to SIP Team to review.

March 2022
Anticipated
review time:
30 days - most
SIPs
60 days - more
complex SIPs
regulatory due is a
recommended
target. Regions
should negotiate
with air agencies to
establish a
schedule:
a - sooner for
certification SIPs
b - based on air
agency's regulatory
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Final 2.26.2019




adoption process if




air agency needs to




write a regulation




c - considering air




agency resources.

Identification of Approvability Issues:
APM
Sept 2021 -


SIP Lead brief APM on any potential

April 2022


approvability issues identified by SIP Team

(1-2 weeks


and review written comments as necessary.

before end of
review time)


Feedback on Early Engagement Draft:
SIP Lead
Sept 2021 -


SIP Lead provides comments to Air Agency

May 2022


and offers to set up conference call.




Ongoing discussion
SIP



(e.g., Discuss how state is addressing EPA
Lead/Team



comments, go over schedule.)
and Air
Agency



Air Agency Public Comment Period Draft

Jan - May 2022
Target dates

Submitted to EPA:

(2 weeks prior
negotiated based

SIP Lead distributes to SIP Team for review

to publication)
on SIP element

for possible comment during comment


complexity and/or -

period.


air agency
regulatory process.

Air Agency Public Comment Period.
Air Agency
Jan - May 2022
Typically 30 days

Air Agency Public Comment Period
APM
15 days from


Identification of Approvability Issues:

receipt of draft


SIP Lead briefs APM on any issues, APM




decides to comment on record or not.




Air Agency Public Comment Period
SIP Lead
June 2022 at


Feedback:

the latest


SIP lead gives Air Agency a head's up, EPA




comments on record as appropriate




Air Agency shares any substantive comments
Air Agency
June - July 2022


received during public comment period with




EPA.




Ongoing discussion regarding any changes to
SIP
June - July 2022


proposed SIP.
Lead/Team
and Air
Agency



Attainment plan, RFP with 3% reduction
Air Agency
August 3, 2022


(serious and higher) SIP(s) submitted to




EPA.



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Final 2.26.2019
Resources
2015 Ozone Implementation SIP Requirements Rule (83 FR 62998, December 6, 2018):
•	https://www.epa.gov/ground-level-ozone-pollution/implementation-2015-national-
ambient-air-qualitv-standards-naaqs-ozone#rule-summary
•	https://www.epa.gov/sites/production/files/2018-
ll/documents/2015 o3 srr frn public webinar 112018.pdf (November 20, 2018
Webinar)
•	Additional Policies and Programs for Achieving Emissions Reductions (83 FR
63027)
•	Additional Requirements Related to Enforcement and Compliance (83 FR 63028)
•	Ambient Monitoring Requirements (83 FR 63008)
•	Applicability (83 FR 63009)
•	Applicability of Final Rule to Tribes (83 FR 63028)
•	Background Ozone (83 FR 63027)
•	Determining Eligibility for 1-Year Attainment Date Extensions for the 2015 Ozone
NAAQS Under CAA Section 181(a)(5) (83 FR 63002)
•	Emissions Inventory and Emissions Statement Requirements (83 FR 63021)
•	Environmental Justice Considerations (83 FR 63029)
•	Fee Programs for Severe and Extreme Nonattainment Areas That Fail to Attain
(83 FR 63009)
•	General Nonattainment NSR Requirements (83 FR 63008)
•	International Transport (83 FR 63009)
•	Managing Emissions from Wildfire and Wildland Prescribed Fire (83 FR 63023)
•	Modeling and Attainment Demonstration Requirements (83 FR 63003)
•	Nonattainment NSR Offset Requirement: Interprecursor Trading for Ozone
Offsets (83 FR 63016)
•	Redesignation to Nonattainment Following Initial Designations (83 FR 63002)
•	Requirements for an OTR (83 FR 63008)
•	Requirements for Contingency Measures in the Event of Failure to Meet a
Milestone or To Attain (83 FR 63026)
•	Requirements for RACM: Consideration of Sources of Intrastate Transport of
Pollution (83 FR 63015)
•	Requirements for RACT and RACM G. CAA Section 182(f) NOX Exemption
Provisions (83 FR 63008)
•	Requirements for RACT: Deadlines for Submittal and Implementation of RACT SIP
Revisions (83 FR 63012)
•	Requirements for RFP (83 FR 63004)
•	Requirements for RFP: Milestone Compliance Demonstrations (83 FR 63011)
•	Submission Deadlines and Form for Nonattainment Area and OTR SIP Elements
Due Under CAA Sections 182 and 184 (83 FR 63000)
•	Transportation Conformity and General Conformity (83 FR 63024)
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Final 2.26.2019
EPA LEAN Thinking and Methods- Kaizen:
•	https://www.epa.gov/lean/lean-thinking-and-methods-kaizen
Implementation Training and Assistance for State and Local Air Agencies:
•	https://www.epa.gov/ground-level-ozone-pollution/implementation-training-and-
assistance-state-and-local-air-agencies
SIP Checklist Guide:
•	https://www.epa.gov/ground-level-ozone-pollution/state-implementation-plan-sip-
checklist-guide
State Plan Electronic Collaboration System or SPeCS:
•	https://www.epa.gov/air-quality-implementation-plans/submit-sips-online
Additional References:
Emissions inventory
•	40 CFR 51.30(b)(3) and 40 CFR 51.1315
•	https://www.epa.gov/air-emissions-inventories/air-emissions-inventory-
guidance-documents
Emissions statements
•	https://www.epa.gov/air-emissions-inventories/implementation-emission-
statement-program
RACT
•	40 CFR 51.1312
•	http://www.epa.gov/ttn/caaa/tl/memoranda/ractqanda.pdf
•	https://www.epa.gov/ozone-pollution/control-techniques-guidelines-and-
alternative-control-techniques-documents-reducing
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Final 2.26.2019
SIP Revisions and Due Dates for 2015 Ozone NAAQS Nonattainment
Areas (Designations Effective August 3, 2018)1
SIP Revisions Due August 3, 2020
SIP
Marginal
Moderate
Serious
Severe
Extreme
OTR
Emissions Inventory
X
X
X
X
X

Emission Statements
X
X
X
X
X

VOC/NOx RACTfor

X
X
X
X
X
Major/CTG Sources






VMT Growth Demonstration



X
X

(and TCMs if needed)






SIP Revisions Due August 3, 2021
SIP
Marginal
Moderate
Serious
Severe
Extreme
OTR
Nonattainment NSR
X
X
X
X
X

Attainment Demonstration,

X




RACM and Contingency






Measures






15 percent ROP and

X




Contingency Measures






Basic l/M

X




Clean Fuel for Boilers




X

SIP Revision Due February 3, 2022 (If Applicable)
SIP
Marginal
Moderate
Serious
Severe
Extreme
OTR
Clean-Fuel Vehicles Program


X
X
X

(or Substitute Provisions)






SIP Revisions Due August 3, 2022
SIP
Marginal
Moderate
Serious
Severe
Extreme
OTR
Attainment Demonstration,


X
X
X

RACM and Contingency






Measures






RFP and Contingency


X
X
X

Measures






Enhanced l/M


X
X
X

SIP Revision Due August 3, 2028
SIP
Marginal
Moderate
Serious
Severe
Extreme
OTR
Section 185 Penalty Fee



X
X

Program






1 San Antonio, Texas designation effective September 24, 2018. Emissions Inventory and Emission Statements SIP
revisions due September 24, 2020. Nonattainment NSR SIP revision due September 24, 2021.
10

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Final 2.26.2019
Ozone Quick Start Guide - Major Milestones
< 5
s I
NOV 2018 OEC 2018 IAN 2019 FEB 2019 MAR 2019 APR 2019 MAY 2019 JUN 2019 JUL 2019 AUG 2019 SEP 2019 OCT 2019 NOV 2019 OEC 2019
2020
i August 3,2020 Submittal Deadline
JAN 2020 FEB 2020 MAR 2020 APR 2020 MAY 2020 JUN 2020 JUL 2020 i AUG 2020 SEP 2020 OCT 2020 NOV 2020 OEC 2020
2021
August 3,2021 Submittal Deadline
JAN 2021 FEB 2021 MAR 2021 APR 2021 MAY 2021 JUN 2021 JUL 2021 AUG 2021 SEP 2021 OCT 2021 NOV 2021 DEC 2021
August 3,2022 Submittal Deadline
JAN 2022 FEB 2022 MAR 2022 APR 2022 MAY 2022 JUN 2022 JUL 2022 j AUG 2022
« ?i
i Mi
i -s > ¦§>
St
Assign SIP Lead & OAQPS POCs
Initial Discussions between HQ and Regions
& Assign SIP Team
Ongoing Discussions between Air Agency
and EPA
Early Engagement Draft Submitted
EPA Review & Feedback to Air Agencies
Air Agency Public Comment Period
Assign SIP Lead
Initial Discussions between HQ and Regions
& Assign SIP Team
Ongoing Discussions between Air Agency
and EPA
Early Engagement Draft Submitted
EPA Review & Feedback to Air Agencies
Air Agency Public Comment Period
Assign SIP Lead
Initial Discussions between HQ and Regions
& Assign SIP Team
Ongoing Discussions between Air Agency
and EPA
Early Engagement Draft Submitted
EPA Review & Feedback to Air Agencies
ir Agency Public Comment Period

11

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