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Natural Events Policy Questions. PM 2.5 Natural Events – States/Regions Need Written Statement Clarifying Position That It Is Allowed Under Current Law Who Has Final Say on Whether or Not Something is a “Natural Event” What Has Worked and What Has Not With PM 10 Policy
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Natural Events Policy Questions • PM2.5 Natural Events – States/Regions Need Written Statement Clarifying Position That It Is Allowed Under Current Law • Who Has Final Say on Whether or Not Something is a “Natural Event” • What Has Worked and What Has Not With PM10 Policy • EPA Needs to Look at Those Questions as Natural Events Policy is Revised for PM2.5 • What is the Time Frame for Developing a NEP for PM2.5 and PM Course
NEAP (contd) • What Is the Purpose of a NEAP? • Area Specific or Event-type Specific? • Specific Area or State-wide? • What Is the State Doing During a Natural Event • Does It Take Multiple 3-ring Binders • Are NEAPs Becoming a “SIP in Sheep’s Clothing” Because EPA Has Failed to Issue Guidance on What Makes up an approvable NEAP
NEAP / Data Flagging • Wind Events in the Drought-Stricken West Include High Concentrations of PM2.5 • Summer Wind Events May Result in Exceeding the Annual NAAQS But EPA is Focused on the 24-Hour NAAQS • What is the Hurdle States Must Clear to Get EPA to Acknowledge PM2.5 is in Wind-Blown Dust • How Can States Help EPA Establish Flags for Other Real World Exceptional Events (Fireworks, Car Shows, Etc)
PM2.5 Implementation • PM2.5 NAAQS Under Review • Preliminary Review Indicates Most of Western US will be Nonattainment • Under Current Time Frame, PM2.5 Plans Will be Due Right When EPA Issues the Revised PM2.5 NAAQS • Will Industry or the Public Work With State Agencies to Develop a Plan to Attain an Inadequate NAAQS
PM2.5 Implementation – PSD • What is EPA’s expected approach to PSD for PM2.5 • If attainment/nonattainment areas will be named by December 2004, states need to know how to establish increment levels for the pollutant. • What are EPA’s plans to develop valid PM2.5 emission factors for permitting purposes • How will EPA address PSD for secondary PM2.5 • What is EPA expecting to include in its PM2.5 implementation guidance related to these areas