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 i ------- 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 2 ------- 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 3 ------- 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: 4 ------- 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. 5 ------- 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 6 ------- 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. 7 ------- 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) 8 ------- 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 9 ------- 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 ------- 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 ------- |