1. Proposed PM NAAQS and Regional Haze
WESTAR Business Meeting
Las Vegas, Nevada
March 28, 2006
WRAP will probably not have consensus on PM NAAQS in time for formal comments.
We will be putting these comments into a letter, with accompanying attachment with more detail, and ask states, tribes, other WRAP participants to sign if they can.
So: These are not WRAP comments, but are the major points covered by the WRAP Air Managers committee.
The issues discussed here relate mainly to visibility, regional haze

2. Regional Haze : PM NAAQS
Level and Form of Primary NAAQS
Not much discussion
Short-Term/Secondary NAAQS
Proposed Primary NAAQS not very Protective of Urban Visibility
More Restrictive = Enhanced Visibility Protection
Tough to Meet in Urban Areas
Whether a separate secondary standard for PM2.5 is warranted (71 FR 2681)
Pros:
Yes, A uniformly applicable secondary PM2.5 standard to reduce soiling, nuisance and visibility impairment in urban areas would also enhance visibility protection programs in rural areas.
Cons:
Not needed for visibility protection. The Regional Haze rule is designed to protect and enhance visibility in Class I areas. This should be sufficient without the need for another overlapping requirement.
A sub-daily (4- to 8-hour averaging time) PM2.5 standard to address visibility impairment, within the range of μg/m3 and with a form within the range of the 92nd to 98th percentile (71 FR 2681; 71FR 2685; 71 FR 2686)
NOTE: EPA should provide clear guidance on how the PM NAAQS relates to regional haze in general, especially establishing Reasonable Progress Goals.
A uniformly applicable secondary NAAQS more restrictive than the primary NAAQS would provide more assurance of emission reductions to achieve health and visibility benefits.   
In several (??) western cities, measured PM2,5 ambient concentrations near the proposed primary NAAQS (35ug/m3) coincident with observed visibility impairment suggests that the proposed primary standard will not protect visibility.
It is likely however that a PM2.5 NAAQS stringent enough to protect visibility would be difficult to impossible to achieve in some areas in the west, even with application of extreme control measures-thus would be meaningless.
The Regional Haze Rule provides states and tribes ample authority to require control measures for these source categories to the extent needed in their long-term strategies for regional haze.
A PM10-25 NAAQS may not be needed for haze protection as long as the regional haze rule alone provides sufficient regulatory authority. This is not clear for some states with ‘no more restrictive…’ requirements.

3. Regional Haze : PM NAAQS
PM10/PM10-2.5
Revoke PM10, Except in Some Urban NAA’s
Replace with Redefined PM10-2.5
Primary=Secondary PM10-2,5 NAAQS
Major Issue Areas…:
(PM NAAQS : Regional Haze)
These elements of the EPA proposal have been covered…
There are several major issue areas concerning the proposal to transition from PM10 to PM10-2.5…

4. Regional Haze : PM NAAQS
Major Issue Areas:
Define PM to Exclude PM Mixes “Dominated by…” (Rural Dusts)
Health Protection for Rural Populations?
How to distinguish on filter?
No Secondary PM in Rural Areas
Welfare (visibility) Protection in Rural Areas?
overarching objection to the idea of revoking PM10, except for large Non Attainment Areas, defining the replacement PM so narrowly as to exclude mixes “dominated” by urban-type sources, together with the exceptions for agricultural and mining operations.
The rationale for this urban-rural split in applicability of PM coarse is unfounded.
Primary NAAQS….
Rural citizens deserve the same degree of health protection that is provided to our urban citizens, especially in light of the sensitive populations present throughout our States and Region, including but not limited to segments of tribal populations.
Secondary NAAQS….
There is no rationale for removing the PM10 secondary standard with respect to the visibility effects of coarse particles, particularly in rural areas. There is no difference in visibility impairment effects between “PM that is dominated by resuspended dust from high-density traffic on paved roads and PM generated by industrial sources and construction sources” and “PM that is dominated by rural windblown dust and soils and PM generated by agricultural and mining sources.”
Not having a national backstop to the coarse particulate matter impacts in
large portions of the country and the resulting lack of ongoing monitoring
in these areas would make it very difficult for States to make reasonable
progress towards natural visibility conditions at national parks covered by
EPA’s regional haze program.
In order for States to achieve NAAQS for PM for all citizens, and to achieve co-benefits of reduced regional haze at Class I areas, NAAQS should apply nationwide rather than only in some urbanized areas.

5. Regional Haze : PM NAAQS
Major Issue Areas:
Configure PM Monitoring to Exclude Rural Areas
Need more, not less information
Exempt AG and Mining from Controls
Reasonable Progress Goals?
The Strategy for air monitoring establishes 5 criteria for PM monitoring, which effectively removes PM monitors from less populated areas. This is not consistent with the logical direction of a monitoring strategy that responds to the clear need for additional monitoring to characterize PM in rural and urban areas.
A definition that excludes specified source categories without sufficient evidence they should be excluded is not a rational basis for setting NAAQS.
Exceptions for these major source categories in the definition of PM NAAQS removes a major tool used to control PM2.5 from these same sources.

6. Regional Haze : PM NAAQS
Major Issue Areas:
PMcoarse is Large Part of Dust Emissions and Ambient PM10 in Western States
PMcoarse Contains Significant % of Non-Crustal Material
Carbon, NOx, SOx
PMcoarse Significant in Class I Area Visibility Impairment
In general, Class I areas exhibit significant % pMcoarse on 20% worst-case days. (Call Marc Pitchford-Look on CoHa)
25% 50% PMcoarse is non-soils, example study by NPS at 9 Class I areas (5 were western Class I areas)
Average Coarse Mass Species Concentrations (ug/m3)
State Class I Area Smpl Period #Smp NH3So4NH3No4 EC OC Soil %Soil
AZ Grand Canyon 06/08/ /29/
CA San Gorgonio 08/07/ /29/
CA Sequioa 09/12/ /29/
WA Mt. Ranier 11/11/ /29/
WY Bridger 12/26/ /29/
AR Upper Buffalo 11/23/ /29/
IL Bondville 03/19/ /29/
NJ Brigantine 12/11/ /29/
TN Smoky Mtns. 05/15/ /29/
Notes:
* This spreadsheet was prepared by Lee Alter, Western Governors' Association.
* Data were provided by the Natioinal Park Service. Results are preliminary and may be revised based upon further quality assurance.
* All sulfate and nitrate is assumed to be ammonium-bound.
* Organic carbon mass is determined by multiplying organic carbon by 1.8, per the new IMPROVE equation.
* Sea salt is not included, although it should be minimal at all sites but perhaps Brigantine.
* Valid samples are typically collected every third day throughout the sampling period indicated.
* Eastern samples tend to show a little less % soils than Western

7. Regional Haze : PM NAAQS
IMPROVE Monitoring Network
Best Long-Term Speciation of Rural PM to date
Need for More Complete Speciation Work in Rural Areas
Tracking Reasonable Progress
Factor into overall National Monitoring Strategy
The IMPROVE air monitoring network provides the most complete speciated PM profile in rural areas. The speciated data from IMPROVE shows evidence of constituents that are believed to cause health effects. (e.g., ammonium sulfates and nitrates, carbon, etc. – cite data from stuff Lee sent)
Strong support of tailoring the nation’s air quality monitoring strategy, together with associated studies to address the current shortage of science-base cause-and-effect data that would better inform decisions.
There is a clear need, especially in Western states, to determine the coarse fraction of PM and the chemical constituents of PM.
This suggests expanding capacity of the PM monitoring networks to help characterize PM in urban and rural areas, not, as currently planned, to shrink monitoring to cover only urban areas.

8. Stay Tuned…
Good decisions are based on good data that should enable determination of an adequate margin of safety requisite to protect the public health to meet the requirements of Section 109 of the Clean Air Act. In the absence of good data, EPA should not assume that public health is protected with an adequate margin of safety without an applicable standard.
Commitment to work with EPA on a collaborative effort to locate, modify and operate additional monitoring sites, especially rural and tribal sites, taking into account existing siting opportunities such as the CASTNET and IMPROVE networks, as proposed.