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Untangle paperwork provisions.
Believe it or not, a common violation under the CAA is not sending paperwork to the correct regulatory authorities. So, who should the paperwork go to? The state, the EPA region, or both? Yep. It depends.
Most states have an authorized CAA program, called a state implementation plan or SIP. Under the SIP, a state administers the new source review (NSR) program [Parts 51 and 52] and other authorities necessary to achieve compliance with the national ambient air quality standards (NAAQS) [Part 50]. A SIP operates in lieu of the federal regs and may be more stringent and broader in scope.
Authority for some CAA programs may only be delegated to states, which means the state acts on behalf of EPA, as opposed to operating their own authorized program. The three source category standard programs under Part 60, Part 61, and Part 63 fall into this area. Thus, states may administer these programs and may even request more stringent standards for particular source categories, but EPA is still the ultimate authority.
Paperwork for authorized programs under a state SIP goes to the state. If EPA has delegated authority to the state for the source category standards, paperwork should be sent to both the state and the EPA region for these programs. If EPA has not delegated authority, paperwork should be sent to the EPA region. If you are ever unsure, ask your regulators or send it to both. Visit our website and find more compliance morsels.
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