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 –EPA Needs to Look at Those Questions as Natural Events Policy is Revised for PM 2.5 –What is the Time Frame for Developing a NEP for PM 2.5 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 PM 2.5 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 PM 2.5 is in Wind- Blown Dust How Can States Help EPA Establish Flags for Other Real World Exceptional Events (Fireworks, Car Shows, Etc)

PM 2.5 Implementation PM 2.5 NAAQS Under Review –Preliminary Review Indicates Most of Western US will be Nonattainment Under Current Time Frame, PM 2.5 Plans Will be Due Right When EPA Issues the Revised PM 2.5 NAAQS Will Industry or the Public Work With State Agencies to Develop a Plan to Attain an Inadequate NAAQS

PM 2.5 Implementation – PSD What is EPA’s expected approach to PSD for PM 2.5 –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 PM 2.5 emission factors for permitting purposes How will EPA address PSD for secondary PM 2.5 What is EPA expecting to include in its PM 2.5 implementation guidance related to these areas