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Particulate Matter (PM)

Fact Sheet: Finding of Failure to Submit State Implementation Plans Required for the 1997 PM 2.5 NAAQS


  • On November 19, 2009, the U.S. Environmental Protection Agency (EPA) issued findings that three states missed Clean Air Act deadlines for submitting plans, or elements of plans, to implement EPA’s 1997 national ambient air quality standards (NAAQS) for particulate matter 2.5 micrometers in diameter and smaller (PM2.5).   The deadlines are for submitting complete plans; they are not deadlines for meeting the national 1997 PM2.5 standards.
  • The states are: Georgia, Illinois, and Pennsylvania.
  • The 1997 PM2.5 nonattainment areas are: Atlanta, Georgia, St. Louis, Illinois portion only, Liberty-Clairton, Pennsylvania, and Philadelphia-Wilmington, Pennsylvania portion only.
  • The plans due are known as state implementation plans, or SIPs, and are developed by States with PM2.5 nonattainment areas.  These SIPs are required to show how those areas will meet the 1997 PM2.5 NAAQS by their attainment dates.  The SIP must include the attainment demonstration, Reasonably Available Control Measures or Reasonably Available Control Technology (RACM/RACT), Reasonable Further Progress (RFP), and contingency measure requirements.  These requirements are described in more detail below.
  • For the states subject to today’s finding, the Clean Air Act requires EPA to start three timetables, known as “clocks” once these findings are published in the Federal Register. The three clocks include two sanctions clocks, and a deadline for EPA to issue federal implementation plans (FIPs). These clocks range from 18 months to 2 years.
  • Sanctions will not apply to states that submit complete SIPs before these clocks run out and EPA will not issue FIPs for states with plans approved before the FIP deadline. EPA is working with these states to ensure they submit revised, approvable plans as soon as possible.

The Clocks

  • Emission offset sanctions (18 months): Under emission offset sanctions, a state must ensure that each ton of emissions created by a new stationary source of pollution is offset by a two ton reduction in existing stationary sources.  These offset requirements would apply in areas designated as “nonattainment” for the 1997 PM2.5 standard.  Emission offset sanctions will not apply to states that submit complete SIPs within 18 months after these findings are published in the Federal Register.
  • Highway fund sanctions (2 years): Under highway fund sanctions, a state can lose funding for transportation projects if the funds have not been obligated by the Federal Highway Administration by the date the highway sanctions are imposed.  (Projects that have already received approval to proceed and had funds obligated may proceed.)  Highway sanctions will not apply to states that submit complete SIPs within 24 months of publication of these findings.
  • Federal Implementation Plans (2 years): Under a FIP, EPA, not the state, determines what steps must be taken to meet the standard.  For the FIP clock to be turned off, EPA must approve the required SIPs within 24 months of publication of these findings.


  • Five main types of pollutants contribute to fine particle concentrations: direct PM2.5 emissions; sulfur dioxide; nitrogen oxides; ammonia; and volatile organic compounds. The effect of reducing emissions of each of these pollutants varies by area, depending on the fine particle composition, emissions levels, and other area-specific factors.
  • The applicable statutory and regulatory requirements for nonattainment SIPs for the 1997 PM2.5 NAAQS are provided in the PM2.5 Implementation Rule available at http://www.epa.gov/pm/actions.html and 40 CFR 51.1000 to 51.1012

Attainment demonstration

  • States with nonattainment areas are required to analyze the potential of those areas to meet the 1997 PM2.5 standard.  The state uses air quality models and other relevant technical information to demonstrate its ability to achieve the air quality standard by a certain date. (In the findings issued November 19, 2009, states with PM2.5 nonattainment areas are required to show they can meet the standard “as expeditiously as practicable,” but no later than the statutory attainment date of April 5, 2010.)
  • (Note: for an area with a more severe or complex nonattainment problem, the state could propose in its plan to extend the attainment date an additional 1 to 5 years beyond the initial five year period if it meets the statutory and regulatory requirements.) 
  • This SIP element was due to EPA in April 2008.

Reasonably Available Control Measures/Reasonably Available Control Technology

  • Each nonattainment SIP must include RACM and RACT as necessary for the area to attain the 1997 PM2.5 NAAQS.  The Clean Air Act requires the state to demonstrate that it has adopted all reasonably available control measures, considering economic and technical feasibility and other factors that are needed to show the area will attain the fine particle standards as expeditiously as practicable. 
  • The attainment demonstration takes into account projected emission reductions from existing federal and state measures, plus any additional RACM/RACT that can be adopted by the state to attain “as expeditiously as practicable.”  Air quality modeling of these projected emissions reductions in future years is an important element of the attainment demonstration.
  • This SIP element was due to EPA in April 2008.

Reasonable Further Progress

  • SIPs must also provide for steady progress, also known as RFP, toward attainment of the 1997 PM2.5 standard.  This provides a way to ensure states make continual progress toward meeting the standard by their attainment date.
  • The PM2.5 Implementation Rule provides that for areas with an attainment date within 5 years of designation, the attainment demonstration is considered to satisfy the RFP requirement.  Areas with attainment dates beyond 2010 are required to submit an RFP plan according to the requirements in the implementation rule. 
  • This SIP element was due to EPA in April 2008.

Contingency Measures

  • SIPs must also include contingency measures, which are emission reduction measures to be undertaken if the area fails to satisfy the RFP requirement or fails to attain the standards by the attainment date.  These measures are to take effect without significant further action by the state or EPA.
  • This SIP element was due to EPA in April 2008

For More Information

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