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Western States / EPA Exceptional Events Meeting. February 25-26, 2009. Audience. EPA Headquarters Regional Offices Western State/Local Agencies Decision makers and managers with responsibility for implementing the Exceptional Events Rule. Primary Meeting Objective.

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EPA Headquarters

Regional Offices

Western State/Local Agencies

Decision makers and managers with responsibility for implementing the Exceptional Events Rule.

primary meeting objective
Primary Meeting Objective


meeting objectives
Meeting Objectives
  • Reach a common understanding of the definition of an exceptional event and identify examples of recurring natural events that may meet the definition.
  • Reach a common understanding of the role event parameters, such as statistical occurrence and magnitude, play in identifying qualifying exceptional events.
  • Reach a common understanding of the nature and extent of the documentation needed for a complete Exceptional Event demonstration, particularly for ozone.
meeting objectives cont d
Meeting Objectives (cont’d)
  • Discuss the elements of a “toolbox” states could use to document exceptional events, and the need for written guidance.
  • Discuss whether there would be utility in EPA developing a checklist of criteria for concurrence on event documentation, and its possible content.
  • Discuss consistency of review criteria between regions with similar exceptional events.
    • We want consistency – except when we don’t want it.
  • Discuss EPA concurrence/non-concurrence determination timeframes.
meeting outcome expectations
Meeting Outcome: Expectations
  • EPA’s expectations of what state and local agencies should do when an exceptional event occurs:
    • actions to take
    • content and scope of documentation
  • State/local expectations regarding the rigor and scope of analysis needed by EPA to approve an exceptional events flag.
classification system
Classification System
  • This is one possible solution to one of the issues – but nothing has been finalized.
  • Expedite the processing of exceptional events requests by screening them based on a variety of factors/criteria.
  • Classifying exceptional events into one of three “bins:”
    • Those requiring the simplest form of justification;
    • Those requiring a more rigorous analysis; and
    • Those requiring the most comprehensive justification package.
implementation of classification system
Implementation of Classification System
  • In order to implement this, we must answer these questions:
    • What factors/criteria will be used to classify events as “easy, medium, or hard?”
    • How will EPA apply the factors/criteria?
    • How will EPA’s expectations of state/local documentation of an event vary for each of the three classifications?
other issues identified
Other Issues Identified
  • On what basis will EPA determine that a state/local has met the requirement to take “appropriate and reasonable actions to protect public health?”
  • Will EPA approve exceptional event flags at levels below the NAAQS:
    • for limited maintenance plan areas; or
    • in the dataset used to calculate design values?


now what
Now What?
  • This topic was discussed on a call of the air directors.
  • The air directors authorized a project to develop recommendations on improving the implementation of the exceptional events rule.
  • WESTAR’s recommendations would benefit from consultation with representatives from local air agencies, EPA, and federal land management agencies.
  • No decisions about the outcome have been made.
exceptional events workgroup new and improved
Exceptional Events Workgroup“New and Improved”
  • Dan Johnson WESTAR
  • Karen Magliano California
  • Dave McNeill Utah
  • Tammy Egan Florida
  • Shawn Kendall Arizona
  • Diane Arnst Arizona
  • Doug Schneider Washington
  • Julie Oliver Washington
  • Scott Nester San Joaquin Valley APCD
  • Jean-Paul Huys Clark County APCD
  • Pete Lahm USFS
  • Sim Larkin USFS
  • Tara Strand USFS
  • Gary Cursio North Carolina State Forestry
  • EPA Headquarters TBD
  • EPA Regions TBD