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Why did EPA promulgate CAIR Federal Implementation Plans (FIPs) on March 15, 2006, before the CAIR SIP submission deadline of September 11, 2006?

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Why did EPA promulgate CAIR Federal Implementation Plans (FIPs) on March 15, 2006, before the CAIR SIP submission deadline of September 11, 2006?

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In a final rule published April 25, 2005 (70 FR 21147), EPA made national findings that States failed to submit SIPs required under Clean Air Act (CAA) section 110(a)(2)(D) to address interstate transport with respect to the 8-hour ozone and PM2.5 National Ambient Air Quality Standards (NAAQS). The April 25, 2005 findings started a 2-year clock for EPA to promulgate a FIP to address the requirements of section 110(a)(2)(D). Under CAA section 110(c)(1), EPA may issue a FIP any time after such findings are made and must do so unless a SIP revision correcting the deficiency is approved by EPA before the FIP is promulgated. For States covered by CAIR, an approved SIP revision meeting the CAIR requirements satisfies the section 110(a)(2)(D) requirement.

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