SIP Transformation Workgroup          

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Tranforming the SIP Process:  Finding a Better Approach to Cleaner Air


Reasons for Transforming the SIP Process

  • SIP-related emissions across the country are now dominated by federally preempted sources such as cars and trucks.

  • Pollutant transport from other states and countries is playing a more significant role in the ozone problem and such transport is outside of individual state control.

  • SIP planning focuses myopically on one pollutant at a time and only on criteria pollutants in nonattainment areas.

  • SIPs emphasize paperwork over results 

            

Suggested Solution to the SIP Problem--SIP Transformation 

For meaningful SIP transformation to occur, the Clean Air Act must be revised.  Below are the two suggested components of this revision.

1.  Align Responsibility with Authority.  The Act must be revised to properly align responsibility for achieving the National Ambient Air Quality Standards (NAAQS) with the authority to achieve the standards.  States are responsible for achieving the NAAQS through the SIP process, yet the authority to achieve the NAAQS rests largely with the federal government (i.e. the ability to regulate federally preempted sources and interstate/international pollutant transport).  Realigning  authority with responsibility would allow states to spend their time and resources on issues they can more efficiently and properly control rather than on justifying what they cannot effectively do.  Hundreds of millions of dollars could be liberated to focus on localized public health concerns, compliance, enforcement, monitoring, and developing innovative emission reduction strategies. 

2.  Transform SIP Process into a Comprehensive Air Quality Planning Process.  EPA, states, and local governments currently are not required to do any air quality planning—they are required to do SIP planning.  SIP planning looks narrowly at only one pollutant over a limited period of time.  Many citizens have concerns with other pollutants such as particulate matter, toxics, and CO2.  Comprehensive air quality planning is necessary to ensure that control efforts will be coordinated to produce the greatest public health benefit at the least amount of cost to taxpayers and businesses.  

SIP Transformation Workgroup

The SIP Transformation Workgroup is an informal workgroup dedicated to the purposes of transforming the SIP process for the betterment of citizens, businesses, and the environment.  The workgroup is non-partisan, non-affiliated, and comprised only of volunteers.  Individuals representing the interests of industry, government, and the environment have all participated in this effort. We welcome anyone to participate in this workgroup who is dedicated to the purpose of reforming the SIP process.

For additional information please contact:

The SIP Transformation Workgroup
c/o Jed Anderson, Chair
Phone:  (281) 852-8064
Email:  jedanderson@jedlaw.net  

 

 

 

 

 

 

 

 

 

 

 

Purpose

The State Implementation Plan (SIP) process has become a complicated, costly, and largely ineffective way to further improve air quality.  A paradigm shift is needed—a shift away from a process that favors paperwork and procrastination toward a process that favors pollution reduction and public health.  

Two things must happen to effectuate this change:

1.       Responsibility for achieving the National Ambient Air Quality Standards (NAAQS) must be properly aligned with the authority to achieve the NAAQs.   

2.       The SIP process must be transformed into a comprehensive multi-pollutant planning process.

                   
 

What is the SIP Process?

 A SIP is a state’s plan on how it will achieve the National Ambient Air Quality Standards (NAAQS) for any area designated in the state as “nonattainment”.  The U.S. Environmental Protection Agency (EPA) sets the NAAQS for criteria pollutants such as ozone.  Once a NAAQS is established, EPA reviews data from monitors across the country to determine what areas are not in attainment for that standard.  Once designations are made, states must develop SIPs demonstrating to EPA how the areas will achieve attainment by a given date using federal controls and any additional state/local controls. 

      

    

WHO SHOULD BE CONCERNED ABOUT THE EFFECTIVENESS OF THE SIP PROCESS?

Below are maps indicating areas subject or potentially subject to the current SIP process for ozone, particulate matter and CO2.

Ozone


Particulate Matter 2.5




CO2