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Congress Hears from States and Local Governments in Clean Air Act Forums—Fix the SIP Process!!!

November 29, 2012

Today at 10:00 am is the 3rd forum in the House Energy & Commerce Committee on the Clean Air Act (see link).

Seems like everyone is telling Congress to fix the SIP process:

State of Arkansas:  “The SIP process is badly in need of reform. The present process is overly cumbersome, slow and bureaucratic.”

State of Ohio:  “The State Implementation Plan process has become burdensome and overly complicated.”

State of Colorado:  “SIPs and other demonstration packages from states are only getting more voluminous and complex, often without concurrent air quality benefits.”

San Joaquin Valley Air Pollution Control District:  “The current regiment [the NAAQS/SIP Process] leads to a great deal of redundancy, overlap, and confusion.”

State of South Carolina:   “We are particularly concerned about the state implementation plan (SIP) process [. . .]” 

State of Texas:  “While states are responsible for achieving the NAAQS through the SIP process, the authority to achieve the ozone NAAQS arguably now lies with the federal government. The nonalignment between responsibility and authority is a primary issue that needs to be considered in reform of the Clean Air Act.”

South Coast Air Quality Management District:  “The current Clean Air Act places all the responsibility on the states, but then deprives them of the needed authority through preemption provisions. This is not a fair situation. If USEPA has the sole authority, it must also have the responsibility.”

City of Houston:  “[T]he SIP process has been problematic for local governments . . .”

State of Montana:  “[N]ot all aspects of the CAA have been implemented in a manner that allows us to keep pace with the changes in air quality management.  An example of this is the State Implementation Plan (SIP) process. [. . .]” 

State of Indiana:  “The SIP revision approval process is not predictable or timely.”  

State of New Hampshire:  “[O]ften states are working on SIPs for multiple pollutants for which EPA had established different compliance deadlines.”   

State of Arizona:  “Often times, action on SIPs deemed unimportant is delayed, for as much as 20 years.”

Dayton County Regional Air Pollution Control Agency:  “Addressing the SIP in the various forms of approval within permit conditions is difficult and confusing. Improvement is needed and can be accomplished only through simplification of the process within the CAA legislation.”

SIP Transformation Workgroup:  “The SIP process worked 40 years ago when the Clean Air Act was written, but circumstances have since changed. Our understanding has since changed. The world has since changed.  It’s time to develop a more efficient, effective, and less costly air quality management process to guide our nation’s future.”

(See links to full comments of States and others: 1st CAA forum, 2nd CAA forum, 3rd CAA forum)

The world is changing.  We must change with it.  Time to transform the SIP process.  We can make it happen.

For more information on the SIP transformation effort, see

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