State Implementation Plans

A state implementation plan (SIP) refers to a collection of reports that details a specific program of forward-looking environmental initiatives, policies, and rules established by states, territories, and the District of Columbia. Local and state agencies are obliged to file the SIPs with the U.S. Environmental Protection Agency (EPA) to indicate their intention to implement specific measures to attain and maintain the National Ambient Air Quality Standards (NAAQS) for primary- and secondary-criteria pollutants. The measures pay particular attention to bringing predesignated polluted zones (nonattainment areas) under their jurisdiction into compliance with federal standards for clean air.

The SIP is a way to compel both local and state authorities to move decisively and pragmatically to respond to pollution alarms before the air quality has been too thoroughly compromised. SIPs, then, provide the mechanism for speedy and directed response to air pollution concerns. The SIP itself is an often massive document filed with the EPA and available for public inspection (indeed, most states maintain a Web site specifically to detail such compliance initiatives as a way to promote an environmentally friendly spirit and help attract both new residents and new businesses). The SIP is a broad, comprehensive document with four necessary parts: the narrative, which stakes out the dimensions of the problem and provides critical statistical data on air quality matched against federal standards; the rules, which outline the specific programs for addressing that pollution; the technical documentation, which provides the scientific backup for the proposed programs and verifies that the programs are not only doable but also practical, with specific and immediate benefits; and the legal agreements, which provide mandatory documentation signed by local and state officials as well as the state EPA representative.

It would be a misperception, however, to assume that despite such mandatory elements and tidy divisions the typical SIP is an actual report stored in some computer file or handed around in a three-ring binder in the EPA offices in Washington. In fact, seldom do the filed documents actually include specific plans for addressing the affected areas—rather, the SIP documentation demonstrates that the state understands the problem and its dimension and that it has every intention to pursue means to effect the maintenance, restoration, enhancement, or protection of its nonattainment zones.

A typical SIP can run to hundreds of pages in the state's efforts to provide a sufficient record of public and industry responses, measurements of pollutants, listings of federal regulations, environmental emission models, and data sets on noncompliant areas. Each initial SIP covers a five-year period in which the state identifies how it plans to achieve any pollution reductions to meet the federal clean air standards. Updates are required every three years thereafter to ensure continued compliance.

It is up to local and state authorities to develop specific programs or to implement new policy guidelines to achieve the designated numerical standards, with the EPA monitoring their progress. In this way, the SIP represents a bold initiative in federal and state cooperation, a partnership among local, state, and federal departments as well as the general public.

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