Air Pollution:

State Planning Requirements Will Continue to Challenge EPA and the States

RCED-93-113: Published: Jun 11, 1993. Publicly Released: Jul 20, 1993.

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Pursuant to a congressional request, GAO examined the: (1) responsiveness of the states to requirements in the Clean Air Act Amendments of 1990 that they submit revisions to their state implementation plans (SIP) for improving air quality; and (2) Environmental Protection Agency's (EPA) timeliness in reviewing and approving these plans.

GAO found that: (1) delays continue in the states' submissions of SIP despite the specific requirements of the 1990 amendments; (2) 35 states have failed to comply with the requirement to submit revisions to their SIP by November 15, 1992; (3) EPA is concerned that submitted SIP will not meet EPA requirements; (4) many SIP now require considerably less review than they did in the past; (5) there are significant delays in SIP processing and approval; (6) 50 percent of the SIP approvals took longer than the 12 months allowed; (7) initiatives to improve oversight of the SIP process include efforts to improve the information system for tracking actions taken on SIP and the introduction of regional program reviews of SIP processing; (8) the effectiveness of the management information system has been hampered by inaccurate and incomplete data; and (9) incorporating requirements for emission limits, control measures, and monitoring and reporting into a single permit for an individual pollution source can help improve accountability.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA has expanded its SIP reporting system beyond just ozone and PM-10. The expanded quarterly report identifies the status of SIP submissions, the length of time required to process SIP packages in EPA, and any indicators of delays. EPA's SIP tracking system (SIPTRAX), which provides information for the quarterly reports, has been updated to track additional information on SIPs from receipt by the regional offices through publication in the Federal Register.

    Recommendation: The Administrator, EPA, should expand EPA recent efforts to identify the causes for delays in the submission, review, and approval of SIP for ozone and PM-10 by undertaking similar efforts regarding delays in processing other SIP.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: As a result of a SIP workgroup established to examine the delegation of SIP review/approval authority, EPA has revised its criteria to allow many SIP actions that previously required Administrator approval to be approved by the Regional Administrators. EPA concluded that the experience gained by the regions over the last several years and the issuance of national guidance on SIP processing made it feasible to delegate additional approval authority for the regional offices.

    Recommendation: The Administrator, EPA, should explore other options, such as further delegation of SIP approval authority to regional administrators, to expedite SIP processing and minimize delays in the large number of actions required on SIP in the next several years.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA has taken several steps to improve the agency's management information system. In addition to requiring the regional offices to provide more specific data on the review and approval status of each SIP package, EPA has eliminated inappropriate and redundant data fields formerly required of the regional offices. The revised system requires a daily report that is to be quality assured on a regular basis.

    Recommendation: The Administrator, EPA, should direct EPA regional administrators to comply with the requirements for promptly and accurately entering, updating, and reporting in the agency's management information system all information on actions taken to process SIP.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: The Office of Air and Radiation has revised the criteria for its State Implementation Plan (SIP) Processing Program Reviews to include not only published actions but those SIP actions that are still in EPA's review process and are being significantly delayed. Although EPA states that a shortage of travel funds will prohibit annual program reviews in each region, an evaluation program using electronically generated data will, on an monthly basis, provide a status report on SIP processing.

    Recommendation: The Administrator, EPA, should revise EPA criteria to require annual program reviews of SIP processing at each regional office and to include SIP that are still in the EPA review process and experiencing significant delays, and also ensure that managers follow existing criteria requiring SIP reviews to target areas that are experiencing or have experienced significant processing delays.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Implemented

    Comments: EPA developed a draft SIP Flexibility Policy that was designed to allow review and approval of alternative requirements to those contained in the federally approved SIP without undertaking source-specific SIP revisions. In March 1996, EPA incorporated the draft SIP Flexibility Policy into the White Paper Number 2 for Improved Implementation of the Part 70 Operating Permits Program guidance document. According to EPA officials, implementation of this recommendation has made the SIP process work more efficiently and reduced the burden on sources, EPA and states.

    Recommendation: In view of the potential for the operating permits to strengthen and expedite the SIP process, the Administrator, EPA, should continue the agency's efforts to propose and finalize guidance to the states on how best to revise their SIP to take advantage of the flexibility offered by title V permits.

    Agency Affected: Environmental Protection Agency

  6. Status: Closed - Implemented

    Comments: EPA has revised its Part 70 regulations to provide for greater flexibility in how states implement their title V permit program. Additionally, EPA continues to work with the states to improve their SIPs to ensure that the permit program, which can only implement SIP requirements, will implement regulations designed to attain the national ambient air quality standards.

    Recommendation: In view of the potential for the operating permits to strengthen and expedite the SIP process, the Administrator, EPA, should ensure that EPA managers work closely with the states to develop and implement permit programs that will facilitate moving from the current regulatory system that relies on SIP as the primary means for ensuring compliance with Clean Air Act requirements to one in which title V permits assume much of that responsibility.

    Agency Affected: Environmental Protection Agency


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