SIP Transformation Workgroup          

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What are Other Experts Saying About the SIP Process?

Comments from National Air Quality Experts on the SIP Process

“The SIP process now mandates extensive amounts of local, state, and federal agency time and resources in a legalistic, and often frustrating, proposal and review process, which focuses primarily on compliance with intermediate process steps. This process probably discourages innovation and experimentation at the state and local levels; overtaxes the limited financial and human resources available to the nation’s AQM system at the state, local, and federal levels; and draws attention and resources away from the more germane issue of ensuring progress toward the goal of meeting the NAAQS.” .  

- National Research Council, “Air Quality Management in the United States”, 2004.

 “The CAA and its associated amendments specify a number of deadlines that proved to be unrealistic. A prime example is the specification of attainment deadlines that proved to be infeasible for O3 in the CAA Amendments of 1970 and 1977. (It remains to be seen if the more liberal attainment deadlines specified in the CAA Amendments of 1990, which extend to 2010, are feasible).  Setting unrealistic deadlines can lead to frustration for local and federal agencies that do not see any reasonable way to achieve the requirements of the act.  It can also introduce an aura of fiction to the entire SIP process as agencies endeavor to meet the letter of the law by promulgating attainment demonstrations that have little likelihood of accurately forecasting future air quality trends.”

- National Research Council, “Air Quality Management in the United States”, 2004.

 “The best estimates are that we could have achieved the present level of environmental quality at a quarter of the direct cost.” 

-  David Schoenbrod (Law Professor and former Natural Resources Defense Council Litigator) discussing the SIP process, “Protecting the Environment in the Spirit of the Common Law”, The Common Law and the Environment:  Rethinking the Statutory Basis for Modern environmental Law, 2000.

“The committee makes five interrelated recommendations to be implemented through specific actions [. . .] Transform the SIP process into a more dynamic and collaborative performance-oriented, multipollutant air quality management plan.”


- Committee on Air Quality Management in the United States, National Academy of Sciences, “Air Quality Management in the United States”, 2004.


“When federal regulations are delayed or modified, states are forced to make important policy decisions in a reduced timeframe.  [. . .]  Consequently, states are often forced to employ less cost-effective measures.” 


- National Governor’s Association, NR-7, The Clean Air Act