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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