FY 2020 Section 105 Air Planning Agreement
U.S. EPA Region 4
Draft
05/15/2019

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Organization of the Air Planning Agreement (APA)
FYs 2018-2020 OAR National Program Manager Guidance
Page 3
FY 2018-2022 EPA Strategic Plan Goals, Objectives and Strategic Measures
Supporting the APA:
1.	Goal 1 - Core Mission: Deliver real results to provide Americans with clean air, land, and
water, and ensure chemical safety.
Obiective 1.1 - Improve Air Oualitv: Work with states to accurately measure air duality and
ensure that more Americans are living and working in areas that meet high air quality standards
Strategic Measure: Reduce the Number of Non-Attainment Areas.
Strategies for Achieving the Obiective: Inwove Air Oualitv
Section 105 Commitments:
¦	Implement the PM2 5 NAAQS
¦	Implement the 8-hour Ozone NAAQS
¦	Implement the Lead NAAQS
¦	Implement the Regional Haze Program
¦	Attain and Maintain the Other NAAQS
¦	NAAQS Cross Cutting
¦	State Implementation Plans
¦	Implement Mobile Source Programs
¦	Implement New Source Review Programs
¦	Ambient Air Monitoring
¦	Address Air Toxics Problems in Communities
2.	Goal 2 - Cooperative Federalism: Rebalance the power between Washington and the states
to create tangible environmental results for the American people.
Obiective 2.1- Enhance Shared Accountability: Inwove environmental protection through ioint
governance and compliance assistance among state, tribal, local, and federal partners.
Strategic Measures: 1) Increase the number of grant commitments achieved bv states,
tribes, and local communities; 2) Increase the use of alternate joint governance
approaches to address state, tribal, and local community reviews.
Section 105 Commitments
3.	Goal 3 - Rule of Law and Process: Administer the law, as Congress intended, to refocus the
Agency on its statutory obligations under the law.
Obiective 3.1 - Compliance with the Law: Enforce environmental laws to correct noncompliance
and promote cleanup of contaminated sites.
Strategic Measures: 1) Reduce the time between the identification of an environmental
law violation and its correction; 2) Increase environmental law compliance rate
Strategies for Achieving the Obiective: Monitoring and Enforcement
Section 105 Commitments
4.	Cross Cutting Issues (Supports Goals 1-3 Above)
Emissions Inventory for Hazardous Air Pollutants
Emissions Inventory for Criteria Air Pollutants
Planning Commitments
Agency Expectations
Pages 4-21
Environmental Outputs and Outcomes of the APA
Page 3
Reporting Requirements for the FY 2020 APA (Separate Companion Document)

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FY 2020 OAR National Program
Manager (NPM) Guidance
The FY 2020 Office of Air and Radiation's (OAR) National Program Manager (NPM) Guidance
describes the key activities expected to be undertaken by EPA Headquarters (HQ) and regional
offices and implementing air agencies (i.e., state, tribal or local air pollution control agencies),
and should serve as the basis for negotiations between HQ and regions and air agencies as to
resource allocation and expected performance. Specific expectations and deliverables will be
established through negotiations in grant agreements between regions and air agencies. For more
information on the FY 2020 Office of Air and Radiation's NPM Guidance, see
http://www2.epa.gov/planandbudget/national-program-manager-guidances.
Environmental Outputs:
In addition to the outputs described in the commitments in the Air Planning Agreement, the
companion document, FY 2020 Section 105 Air Planning Agreement Reporting Requirements, is
incorporated into the Air Planning Agreement by reference, and identifies additional outputs,
such as reports and data entry, and their reporting schedules.
Environmental Outcomes:
The Air Planning Agreement directly supports EPA's strategic goals of Core Mission: Deliver
real results to provide Americans with clean air, land, and water, and ensure chemical safety;
Cooperative Federalism: Rebalance the power between Washington and the states to create
tangible environmental results for the American people; and Rule of Law and Process:
Administer the law, as Congress intended, to refocus the Agency on its statutory obligations
under the law. By implementing the activities and commitments in this agreement, the recipient
supports the achievement of strategic numerical targets identified for each objective. The
recipient's role is to continue to review, validate, report and certify timely quality-assured data
into the Air Quality System (AQS) since this information serves as the foundation for the
environmental measure.
Reporting Requirements:
The reporting requirements associated with this agreement are identified in the FY 2020 Section
105 Air Planning Agreement Reporting Requirements.

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Improving Air Quality
Goal 1- Core Mission: Deliver real results to provide Americans with
clean air, land, and water, and ensure chemical safety.
Objective 1.1 - Improve Air Quality: Work with states and tribes to accurately measure
air quality and ensure that more Americans are living and working in
areas that meet high air quality standards.
Strategic Measure: By September 30, 2022, reduce the number of nonattainment areas
to 101.
FY 2020 Section 105 Commitments:
Implement the PM2.5 NAAQS
>	As appropriate, address any area violating the PM2.5 NAAQS that is not designated
nonattainment and provide quarterly reports on activities and accomplishments to the
Regional Office.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
EPA Sections to Review - Air Regulatory Management Section
- Air Data and Analysis Section
Implement the 2015 8-hour Ozone NAAQS
>	As appropriate, address any area violating the ozone NAAQS that is not designated
nonattainment and provide quarterly reports on activities and accomplishments to the
Regional Office.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet

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Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
EPA Sections to Review - Air Regulatory Management Section
-	Air Data and Analysis Section
>	Begin development of SIP revisions to address nonattainment requirements (i.e., emissions
statement, emissions inventory and nonattainment new source review) for the 2015 Ozone
NAAQS for areas designated nonattainment on April 30, 2018. Submissions are due August
3, 2020.
Agencies with Access -
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
EPA Section to Review - Air Regulatory Management Section
Implement the Lead NAAQS
>	As appropriate, address any area violating the 2008 Lead NAAQS that is not designated
nonattainment and provide quarterly reports on activities and accomplishments to the
Regional Office.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Knox County Department of Air Pollution Management
EPA Sections to Review - Air Regulatory Management Section
-	Air Data and Analysis Section

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Implement the Regional Haze Program
>	Submit a SIP revision to address the best available retrofit technology requirements for the
initial implementation period for regional haze.
Agencies with Access -
Mississippi Department of Environmental Quality
EPA Section to Review - Air Regulatory Management Section
Attain and Maintain the Other NAAQS
>	As appropriate, address any area violating the other NAAQS that is not designated
nonattainment and provide quarterly reports on activities and accomplishments to the
Regional Office.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
EPA Sections to Review - Air Regulatory Management Section
- Air Data and Analysis Section
>	In accordance with a recent SO2 consent decree, EPA completed the second round of SO2
designations prior to July 2, 2015, and the third round of designations prior to December 31,
2017. There is one remaining round of SO2 designations (i.e., by 2020 for the round based on
monitoring). States are invited to submit additional recommendations and technical support
to help inform these designations. If your Agency intends to submit additional
recommendations and technical support information, EPA requests that you do so by the
timeframes specified for each round of designations.
Agencies with Access -
Alabama Department of Environmental Management
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
North Carolina Department of Environment and Natural Resources
EPA Section to Review - Air Regulatory Management Section

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>	For any area where modeling of actual SO2 emissions serve as the basis for designating such
area as attainment for the 2010 SO2NAAQS, the air agency shall submit an annual report to
the EPA Regional Administrator by July 1 of each year, either as a stand-alone document
made available for public inspection, or as an appendix to its Annual Monitoring Network
Plan (also due on July 1 each year under 40 CFR 58.10), that documents the annual SO2
emissions of each applicable source in each such area and provides an assessment of the
cause of any emissions increase from the previous year.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
EPA Sections to Review - Air Regulatory Management Section
NAAQS Cross Cutting
>	Continue to develop and implement standards, plans, strategies, and actions to preserve air
quality in attainment areas and prevent further degradation in areas with the potential to be
designated nonattainment in the future. Continue screening of monitoring data for early
indication of nonattainment. For areas that violate after the designation, work with Region 4
to develop a plan to expeditiously bring each area back into attainment.
Agencies with Access - All Agencies
EPA Sections to Review - Air Regulatory Management Section
-	Communities Support Section
-	Air Data and Analysis Section
>	Consistent with the national allocation of section 105 grant resources and the states' and
locals' voluntary withholding of 105 grant resources for special projects, continue developing
regional planning capabilities for National Ambient Air Quality Standards (NAAQS) and
regional haze, including emission inventory development, building air quality modeling
capacity, other technical analyses and collaboration with other agencies. The state and local
contact or section chief in the Air Regulatory Management Section should be notified, at the
mid-year point and a month prior to the end of the grant period, via e-mail of how the state or
local agency is meeting this grant condition, specifying applicable specific grants or
programs.
Agencies with Access - All Agencies

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EPA Sections to Review - Air Regulatory Management Section
Implement Mobile Source Programs
> Actively participate in the transportation conformity process, which includes the following
activities: consult with appropriate transportation and air quality partners on development of
motor vehicle emissions budgets; participate in the interagency consultation process; and
develop relationships with transportation partners.
Agencies with Access -
Alabama Department of Environmental Management
Jefferson County Department of Health Air Pollution Control Program
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Knox County Department of Air Pollution Management
Shelby County Health Department Pollution Control
EPA Sections to Review - Communities Support Section
- Air Regulatory Management Section
Implement NSR Programs
> Issue major NSR/Prevention of Significant Deterioration (PSD) permits and minor source
permits that comply with CAA requirements and enter Best Available Control Technology
(BACT)/Lowest Achievable Emissions Rate (LAER) determinations for major sources in the
Reasonably Available Control Technology (RACT)/BACT/LAER Clearinghouse (RBLC).
Agencies with Access -
Alabama Department of Environmental Management
Jefferson County Department of Health Air Pollution Control Program
City of Huntsville Division of Natural Resources
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
Forsyth County Office of Environmental Assistance and Protection

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Western North Carolina Regional Air Quality Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Metro Public Health Department - Nashville-Davidson County
Knox County Department of Air Pollution Management
Chattanooga-Hamilton County Air Pollution Control Bureau
Shelby County Health Department Pollution Control
EPA Sections to Review - Air Permits Section
> Upon receipt of an NSR/PSD permit application for a major source, submit a copy to EPA. If
your agency has a completeness determination process, notify EPA when each NSR/PSD
permit application is deemed complete. Upon public notice of a draft NSR/PSD permit for a
major new source of modification, submit a copy to EPA of any documents relevant to the
preliminary determination and draft NSR/PSD permit. Upon issuance of a final major source
permit, submit a copy to EPA of any documents relevant to the final determination and final
permit.
Agencies with Access - All Agencies
EPA Sections to Review - Air Permits Section
Ambient Air Monitoring
>	Operate all criteria pollutant monitors and perform requisite data review and quality
assurance/quality control elements in compliance with the requirements of the CFR and other
applicable federal policy and guidance. This commitment includes all reporting and data
certification requirements (e.g., annual State and Local Air Monitoring Station (SLAMS)
reports and data certifications due by May 1 each year).
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	The agency will collect strip chart data or its electronic equivalent for quality assurance
purposes. Electronic strip chart data must be collected on a 1-minute timeframe or less. This
data must be retained for a minimum of three (3) complete monitoring years.
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
> The State will develop and submit for approval a statewide ambient monitoring network plan.
The network plan should be consistent with requirements outlined in 40 CFR Parts 50, 53,
and 58. State agencies, as applicable, will coordinate with their Local agencies in the

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development of this plan. The network plan is to be submitted on or before July 1 of each
year incorporating any changes, real or proposed. Include in the network plan a certified
evaluation of the agency's ambient monitors and auxiliary support equipment and categorize
the condition of the equipment as "Good," "Fair," or "Poor." Please indicate which
equipment pieces are not in everyday use (e.g., spare/back-up equipment stored in a lab or
warehouse). Auxiliary equipment includes items such as calibrators, data loggers,
meteorological equipment, modems, etc. The agency is requested to replace equipment
categorized as "Poor."
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	Maintain an approved quality management plan (QMP) for the criteria pollutant network.
QMPs expire every five (5) years. The QMP will be submitted at least 180 days prior to the
expiration of the current QMP electronically to R4QMP@epa. gov or in hard copy to: EPA
Region 4, Laboratory Services and Applied Science Division, 980 College Station Road,
Athens, GA 30605, Attn: Regional Quality Assurance Manager. QMPs must address EPA
Requirements for Quality Management Plans (EPA QA/R-2, http://www.epa.gov/quality/qs-
docs/r2-final.pdf). For additional information and guidance see
http://www.epa.gov/qualitv/qmps.html.
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
>	For all new pollutants to be monitored and methods to be used, a quality assurance project
plan (QAPP) must be submitted for approval 180 days prior to collection of environmental
data. Electronic copies may be submitted to r4sesdairqa@epa.gov and hard copies to: EPA
Region 4, Laboratory Services and Applied Science Division, 980 College Station Road,
Athens, GA 30605, Attn: Quality Assurance Section Chief. QAPPs must address EPA
Requirements for Quality Assurance Project Plans (EPA QA/R5,
https://www.epa.gov/sites/production/files/2016-06/documents/r5-final O.pdf).
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
>	Maintain an approved quality assurance project plan (QAPP) for the criteria pollutant
network. EPA will review the QAPPs submitted by the State and/or local agencies for
approval in accordance with the following:
1. The State and/or local agencies will review their QAPPS annually. The review
will be documented in an email to R4sesdairqa@epa.gov. The email should state
the date of the review and whether the QAPP is adequate as written or requires

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changes. If revised, the QAPP will be submitted to EPA for approval within 180
days following the date of the email.
2.	The State and/or local agency QAPPs expire every five (5) years and thus will be
reviewed, revised and submitted to EPA for approval 180 days prior to expiration
of the current QAPP.
3.	The State and/or local agency will submit standard operating procedures (SOPs)
associated with the QAPPs. SOPs will be submitted with revised QAPPs and are
referenced during the QAPP review; however, SOPs will not be reviewed or
approved.
Electronic copies may be submitted to r4sesdairqa@epa.gov and hard copies to: EPA Region
4, Laboratory Services and Applied Science Division, 980 College Station Road, Athens, GA
30605, Attn: Quality Assurance Section Chief. QAPPs must address EPA Requirements for
Quality Assurance Project Plans (EPA QA/R5,
https://www.epa.gov/sites/production/files/2016-06/documents/r5-final O.pdf.
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
>	Maintain up-to-date standard operating procedures (SOPs) for instrumentation and quality
system processes (e.g., data handling and validation, document control, etc.) in support of
criteria pollutant monitoring activities, and as appropriate, any air toxics monitoring activities
conducted by your agency. SOPs for newly acquired instrumentation should be developed
within 180 days from the start-up of the equipment. Please submit courtesy copies of all
SOPs either electronically at R4sesdairqa@epa. gov or by mail to EPA Region 4, Laboratory
Services and Applied Science Division, 980 College Station Road, Athens, GA 30605, Attn:
Quality Assurance Section Chief.
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
>	For all SLAMS and special purpose monitors (SPMs) meeting the requirements of 40 CFR
58, notify EPA as soon as possible, but no later than 30 days, after the determination of
exceedances/violations of the NAAQS for all criteria pollutants, including PM2.5. For the
8-hour ozone NAAQS, report all 4th maximum concentrations that are at or above the level
of the standard (agencies meet this commitment for monitors that have data reported to
AirNow).
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section

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>	Comply with the requirements in 40 CFR § 50.14 regarding treatment of data influenced by
exceptional events. (Note: EPA Region 4 will neither review nor concur on either state or
local requests to exclude data unless the state is in compliance with the appropriate
requirements.)
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	In conjunction with the AQI, agencies are encouraged to submit an air quality forecast for
MSA^ greater than 350,000 people to the EPA AirNow Web site. The air quality forecast
should be submitted daily to the AirNow web site before 3:55 p.m. EDT. The air quality
forecast, like the AQI, will be based on the primary criteria pollutant. Unlike the AQI, an
index value is not required to be reported as a forecast; instead of the index value, the AQI
descriptor value of Good, Moderate, Unhealthy for Sensitive Groups, Unhealthy, or Very
Unhealthy should be used.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	Support staff participation at the following meetings:
A.	The annual Region 4 Ambient Air Monitoring Workshop; and
B.	The National Ambient Air Monitoring Conference.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	FRM/FEM data for each criteria pollutant monitor must be at a minimum 75% complete on a
quarterly and annual basis. Additionally, ozone data must be 90% or more complete on a
three-year average basis. Notify EPA immediately if a problem arises that will prevent the
agency from meeting a data completeness requirement for any pollutant. Provide reasons
why the data completeness requirement will not be met, a schedule for correcting the
problem, and corrective actions that will be taken to avert the problem from recurring. Notify
your EPA monitoring contact by email no more than 90 days after the end of the quarter of
any monitor not meeting the 75% data recovery requirement. Data recovery may become part
of a regional/national statistical report published by EPA.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section

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>	As part of the QA competency demonstration submittal (Reporting Requirement 19-14) that
your agency submits to EPA with its annual grant application package, provide a listing of all
QA documents (QMPs, QAPPs, and SOPs) for the criteria pollutants network maintained by
your agency, and the date that each document was most recently revised and approved (EPA
approval only required for QMPs and QAPPs).
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
Address Air Toxics Problems in Communities
>	Collect ambient air quality data for toxics from monitoring sites as appropriate for special
studies funded under this agreement. Include any planned air toxics monitoring in the
ambient monitoring network design plan that is submitted to EPA in July annually. If no
monitoring is planned, respond to this commitment by stating, "No air toxics monitoring will
be performed."
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	Maintain an approved quality assurance project plan (QAPP) for the air toxics network. EPA
will review the QAPPs submitted by the State and/or local agencies for approval in
accordance with the following:
1.	The State and/or local agencies should review their QAPPs annually. The review
will be documented in an email to R4sesdairqa@epa.gov. The email should state
the date of the review and whether the QAPP is adequate as written or requires
changes. If revised, the QAPP will be submitted to EPA for approval within 180
days following the date of the email.
2.	The State and/or local agencies QAPPs expire every five (5) years and thus will
be reviewed, revised and submitted to EPA for approval 180 days prior to
expiration of the current QAPP.
3.	The State and/or local agencies will submit standard operating procedures (SOPs)
associated with the QAPPs. SOPs will be submitted with revised QAPPs and are
referenced during the QAPP review; however, SOPs will not be reviewed or
approved.
4.	If no monitoring is planned, respond to this commitment by stating, "No air toxics
monitoring will be performed."
Electronic copies may be submitted to r4sesdairqa@epa.gov and hard copies to: EPA
Region 4, Laboratory Services and Applied Science Division, 980 College Station Road,
Athens, GA 30605, Attn: Quality Assurance Section Chief. QAPPs must address EPA
Requirements for Quality Assurance Project Plans (EPA QA/R5,

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https://www.epa.gov/sites/production/files/2016-Q6/documents/r5-final O.pdf
Agencies with Access - All Agencies
EPA Sections to Review - Quality Assurance Section (LSASD)
>	If applicable, encourage laboratories conducting analyses for air toxics to participate in any
available national or regional inter-laboratory proficiency testing programs and audits and
conduct applicable corrective actions to enhance data quality.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
- Laboratory Services and Applied Science Division
>	If applicable, enter quality assured and associated QA/QC data into the AQS database system no
later than 180 days from the end of the quarter for all ambient air toxics monitoring data
collected.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	As part of the QA competency demonstration submittal (Reporting Requirement 20-14) that your
agency submits to EPA with its annual grant application package, provide a listing of all QA
documents (QMPs, QAPPs, and SOPs) for the air toxics pollutants network maintained by your
agency, and the date that each document was most recently revised and approved (EPA approval
only required for QMPs and QAPPs).
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
>	Assume delegation and implementation of all promulgated Clean Air Act Section 112, 111, and
129 rules and standards [National Emission Standard for Hazardous Air Pollutant (NESHAP),
and New Source Performance Standards (NSPS)] within 9 to 12 months of EPA's promulgation,
as appropriate, if a rulemaking is required to take delegation via the Agency's CAA Title V
approval process. Notify Region 4 by submitting rule adoption documentation within 60 days of
adoption.
Agencies with Access -
Alabama Department of Environmental Management
Jefferson County Department of Health Air Pollution Control Program
City of Huntsville Division of Natural Resources

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Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
Forsyth County Office of Environmental Assistance and Protection
Western North Carolina Regional Air Quality Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Metro Public Health Department, Nashville-Davidson County
Knox County Department of Air Pollution Management
Chattanooga-Hamilton County Air Pollution Control Bureau
Shelby County Health Department Pollution Control
EPA Sections to Review - Air Analysis and Support Branch, 10
>	Work towards establishing the programmatic expertise to address the risk-based components of
Clean Air Act sections 112, 111, and 129, by pursuing risk training when appropriate.
Agencies with Access - All Agencies
EPA Sections to Review - Air Analysis and Support Branch, 10
>	Maintain a record of all approved alternatives to monitoring, testing, recordkeeping, and
reporting requirements made for sources subject to MACT standards and provide copies of
approvals to the Region upon issuance (see 40 CFR Part 63.91 (g)( 1 )(ii)).
Agencies with Access -
Alabama Department of Environmental Management
Jefferson County Department of Health Air Pollution Control Program
City of Huntsville Division of Natural Resources
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
Forsyth County Office of Environmental Assistance and Protection
Western North Carolina Regional Air Quality Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Metro Public Health Department, Nashville-Davidson County
Knox County Department of Air Pollution Management
Chattanooga-Hamilton County Air Pollution Control Bureau

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Shelby County Health Department Pollution Control
EPA Sections to Review - Air Analysis and Support Branch, 10
> Prepare and submit CAA sections 111(d) and 129 state plans and letters of certification in
accordance with regulatory timeframes. In addition, collect and submit reports on progress of
sections 111(d) and 129 plans annually, pursuant to 40 CFR 60.25(e) and (f).
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Commonwealth of Kentucky Energy and Environment Cabinet
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
Forsyth County Office of Environmental Assistance and Protection
Western North Carolina Regional Air Quality Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
Metro Public Health Department, Nashville-Davidson County
Knox County Department of Air Pollution Management
Chattanooga-Hamilton County Air Pollution Control Bureau
Shelby County Health Department Pollution Control
EPA Sections to Review - Air Analysis and Support Branch
- Air Enforcement Branch (ECAD)

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Monitoring and Enforcement
Goal 2- Cooperative Federalism: Rebalance the power between Washington
and the states to create tangible environmental results for the American
people.
Objective 2.1 — Enhance Shared Accountability: Improve environmental protection through
shared governance and enhanced collaboration with state, tribal, local, and federal
partners using the full range of compliance assurance tools.
Strategic Measures:
•	By September 30, 2022, increase the number of grant commitments achieved by states, tribes,
and local communities.
•	By September 30, 2022, increase the use of alternative shared governance approaches to address
state, tribal, and local community reviews.
Goal 3 - Rule of Law and Process: Administer the law, as Congress intended,
to refocus the Agency on its statutory obligations under the law.
Objective 3.1 — Compliance with the Law: Timely enforce environmental laws to
increase compliance rates and promote cleanup of contaminated sites through the use of
all of EPA's compliance assurance tools, especially enforcement actions to address
environmental violations.
Strategic Measures:
•	By September 30, 2022, reduce the average time from violation identification to correction.
•	By September 30, 2022, increase environmental law compliance rate.
FY 2020 Section 105 Commitments:
> Ensure enforcement and compliance monitoring is consistent with the Compliance Monitoring
Strategy Policy revised and reissued on July 14, 2014, The Timely and Appropriate Enforcement
Response to High Priority Violations Policy revised and reissued on August 25, 2014. Ensure
complete, accurate and timely data support of the Integrated Compliance Information System (ICIS-
Air).
Agencies with Access - All Agencies
EPA Sections to Review - Air Section 1 (ECAD)

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- Air Section 2 (ECAD)
>	Resolve violations of any rule for which EPA has delegated authority to the state or local agency.
Federally Reportable Violations should be reported to ICIS-Air in accordance with the Guidance on
Federally-Reportable Violations for Clean Air Act Stationary Sources revised and reissued on
September 23, 2014.
Agencies with Access - All Agencies
EPA Sections to Review - Air Section 1 (ECAD)
- Air Section 2 (ECAD)
>	Inspect 25% of all NESHAP asbestos demolition/renovation projects. These projects should be
selected so that all removal contractors are inspected at least once. Alternatively, lower inspection
rates can be negotiated if an effective contractor certification program is in place. Lower inspection
rates can also be negotiated if a non-notifier strategy is developed and implemented.
Agencies with Access - All Agencies
EPA Sections to Review - Air Sections 1 & 2 (ECAD)
>	Observe asbestos work practices in progress whenever possible to assess compliance. Special
priority will be given to entering a project of a contractor with a work practice violation within the
previous 12-month period.
Agencies with Access - All Agencies
EPA Sections to Review - Air Sections 1 & 2 (ECAD)
>	ACTS/NARS database is no longer available. Report the following asbestos NESHAP activities at
least forty-five (45) days after each fiscal six-month period 1) number of notifications received; 2)
number of inspections; 3) non-notifier activity if applicable; 4) number of non-penalty enforcement
actions; 5) number of enforcement actions with an assessed penalty; and 6) total penalty assessment.
Agencies with Access - All Agencies
EPA Sections to Review - Air Sections 1 & 2 (ECAD)
>	Maintain a State/Local health and safety plan for asbestos demolition/renovation inspectors. Plan to
include medical monitoring, protective equipment, and training as minimum requirements.
Alternatively, implement EPA's "Health and Safety Guidelines for EPA Asbestos Inspectors," dated
March 1991. These documents will be reviewed by EPA during state program visits.

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Agencies with Access - All Agencies
EPA Sections to Review - Air Sections 1 & 2 (ECAD)
>	Recommend (where appropriate) cases and provide support to the EPA Criminal Enforcement
Program.
Agencies with Access - All Agencies
EPA Sections to Review - Air Section 1 (ECAD)
- Air Section 2 (ECAD)
>	Implement the CAA section 112(r) program for affected sources. Develop a 112(r) work plan with
projected priorities including risk management program audits and facility inspections. Compile end-
of-year report of accomplishments.
Agencies with Access -
Alabama Department of Environmental Management
Florida Department of Environmental Protection
Georgia Department of Natural Resources
Louisville Metro Air Pollution Control District
Mississippi Department of Environmental Quality
North Carolina Department of Environment and Natural Resources
Mecklenburg County Land Use and Environmental Services Agency
Forsyth County Office of Environmental Assistance and Protection
Western North Carolina Regional Air Quality Agency
South Carolina Department of Health and Environmental Control
Tennessee Department of Environment and Conservation
EPA Sections to Review - Air Sections 1 & 2 (ECAD)

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Cross Cutting Issues
Goals 1, 2 and 3:Deliver real results to provide Americans with clean air, land,
and water, and ensure chemical safety; Rebalance the power between
Washington and the states to create tangible environmental results for
the American people; and Administer the law, as Congress intended,
to refocus the Agency on its statutory obligations under the law.
Objectives: See all objectives listed in this agreement.
Strategic Targets:
¦ See all strategic targets listed in this agreement.
FY 2020 Section 105 Commitments:
Emissions Inventory - Hazardous Air Pollutants
> Review the National Air Toxic Assessment (NATA) results during the year the EPA Office of Air
Quality Planning and Standards (OAQPS) requests it and make revisions to your agency's inventory.
Report hazardous air pollutants to the National Emissions Inventory (NEI) through the Emission
Inventory System (EIS) when criteria air pollutants are reported. The EPA requests that state, local,
and tribal air agencies submit emissions information updates for major point sources to EIS database
annually or as requested by OAQPS. Information on the EIS Gateway can be found at:
https://www.epa.gov/air-emissions-inventories. The state and local NEI/NATA contact in the Air
Data and Analysis Section should be notified via e-mail when a submittal is made to the EIS.
Agencies with Access - All Agencies
EPA Sections to Review - Air Data and Analysis Section
Emissions Inventory - Criteria Air Pollutants
> Develop and submit to EPA, emissions inventory information for all applicable point sources,
criteria air pollutants (CAP) and time frames consistent with the Air Emissions Reporting
Requirements (AERR) Rule published in the December 17, 2008; 73 Federal Register 76539 and
any clarifying or updated policy. The CAPs point source emissions inventories should be submitted
to EPA Headquarters through the Emissions Inventory System (EIS) Gateway. Early submittals are
recommended. Information on the EIS Gateway can be found at: https://www.epa.gov/air-emissions-
inventories. Notify the state and local NEI/NATA contact in the Air Data and Analysis Section via
email when a submittal is made to the EIS.
Agencies with Access - All Agencies

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EPA Sections to Review - Air Data and Analysis Section
Planning
>	Submit a draft Air Planning Agreement for FY 2020 by August 1, 2019, respectively, by responding
to the commitments on the internet-based draft workplan at https://www3.epa.gov/cgi-bin/state.cgi.
Agencies with Access - All Agencies
EPA Sections to Review - Front Office and Grants Team
>	Participate with EPA in an end of year evaluation of performance to be completed by March 1, 2021.
This evaluation will be based on an annual summary report submitted by the agency by December
31, and on progress reports received throughout the year. In accordance with 40 CFR 35.115 and the
EPA Policy on Managing Unliquidated Obligations and Ensuring Progress under EPA Assistance
Agreements, the joint evaluation process will include:
A.	discussions of accomplishments as measured against work plan commitments;
B.	discussions of the cumulative effectiveness of the work performed under all work plan
components;
C.	discussions of existing and potential problem areas;
D.	suggestions for improvement, including, where feasible, schedules for making
improvements; and
E.	discussions of how effectively grant funds were managed and utilized, taking into account
any accumulation of unliquidated obligations.
Agencies with Access - All Agencies
EPA Sections to Review - Front Office
- Grants Team
-All Branches
>	Enter Agency's expectations of EPA (i.e., assistance needed from EPA to meet the commitments
under this Air Planning Agreement).
Agencies with Access - All Agencies
EPA Sections to Review - Front Office
Grants Team
All Branches

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