Region 10 SIP Process Improvement Project (SIP-PIP)
Why did we need to improve SIP processing?
State, local, and EPA air program directors in Region 10 have expressed a desire to improve the State Implementation Plan (SIP) development and approval process. Improvements include: enhanced working relationships, higher quality SIP revisions, shorter approval times and reduced re-work, research, and document preparation time. An effective process needs to be implemented so that EPA can complete its technical and legal review and approve each SIP revision within statutory deadlines.
What are the basic principles of the SIP-PIP?
1) State/local agencies should include in the SIP only those provisions required by the Clean Air Act. This will reduce unnecessary SIP revisions and workload.
2) State/local agencies should strive to keep SIP revisions simple so that they can be processed as minor revisions. This will reduce workload. State/local agencies will consult with EPA to determine if the revision is minor, provide adequate documentation to support determination as a minor SIP revision, including as appropriate, an analysis showing the SIP revision is not a relaxation, and a showing of the differences between the approved SIP and the revised SIP. Disagreement whether a SIP revision is minor may result in dispute resolution.
3) EPA and each State/Local agency working relationship will be summarized in an MOA or other working agreement. There will be improved communication of expectations for each SIP revision through an agreement on how the agencies will work together, and by developing guidance, templates, and checklists. These MOA and other agreements are NOT legal documents, but rather general discussions of ongoing working relationships.
4) SIP development and EPA approval will be managed. A SIP Development Plan should be prepared prior to SIP development. EPA participation “up-front” in the process, using project management principles will reduce “late hits”, second guessing, and unexpected delay. This planning effort will address technical, legal, and policy issues before work is initiated.
5) State/Local agencies should prepare and submit to EPA better documentation of the rationale and justification used to support the SIP revision. This will speed EPA’s work in preparing its supporting documentation and Federal Register notices.
Who developed these principles and who committed to implementing them?
The director of each air program, initiated a special project to address these concerns. A group of state and local agency and EPA representatives, (Core Design Team or CDT) was convened to develop recommendations on how to improve the SIP process. The group's charge also included development of mechanisms to assure long term implementation, process evaluation, and further refinements of the recommended processes over time.
What are the expected benefits from implementation?
1) Higher quality SIP revisions with improved documentation of the rationale for decisions.
2) Mutual expectations for completing SIP approval.
3) A “lean” federally-approved SIP, requiring fewer federal actions as agencies update their regulations.
4) Less EPA research time to justify approval decisions.
5) A “blue-print” for SIP development, review and approval, resulting in clearer roles and responsibilities for all parties involved in the process.
6) Realistic time frames for decision making and work completion.
7) Timely dispute resolution to keep the process “moving”, rather than agencies being burdened by endless re-work.
To download the SIP PIP Report: 
