Snell & Wilmer ---- LLP. ----

LAW O FFICES 

0 1w Ariwna Ccn11·r 

400 E. Van Buren, Sui11· 1900 

Phoenix, Al 85004-2202 

602. 382.6000 

602.382.6070 (Fax) 

W.~wbw.con1 

Amanda A. Reeve 

(602) 382.Q L 77 

areeve@swlaw.com 

Environmental Protection Agency 

December 8, 2015 

Public Hearing re Proposed EER Modifications Rule and Draft Guidance 

Re: EPA Public Hearing Re EPA Docket Nos.: 

DENVER 

LAS VEGAS 

LOS ANGEi ES 

LOS CABOS 

OR ANGE COU NTY 

l'llOl!N IX 

Rl!NO 

SALT LAl:E CITY 

TUCSON 

EPA-HQ-OAR-2013-0572: Treatment of Data Influenced by Exceptional Events 

EPA-HQ-OAR-2015-0229: Draft Guidance on the Preparation of Exceptional 

Events Demonstrations for Wildfire Events that May Influence Ozone 

Concentrations 

My name is Amanda Reeve. I an1 an Environment and Regulatory Policy Advisor with 

Snell & Wilmer L.L.P. l am here speaking on my own behalf as well as a member of the 

Environment Committee with Arizona Rock Products Association ("ARP A"), per the request of 

the Association's President. ARP A represents 43 producers of aggregate, hot mixed asphalt, 

ready mixed concrete and cement. We have 584 operations statewide. Formerly, I served in the 

Arizona House of Representatives from February 2010 to January 2013. During my tenure in the 

legislature and as the Chair of the House Environment Committee, I was thoroughly engrossed in 

working with the EPA, Arizona Department of Environmental Quality and other state and local 

regulatory agencies on addressing Arizona's air quality issues, most especially the functionality 

and efficiency of the 2007 Exceptional Events Rule. 

My involvement in working on Arizona's air quality issues, including advocating for 

revisions to the Exceptional Events Rule, has been continuous since 2010. In fac t, ARP A and I 

would like to thank Senator Jeff Flake and his office for working with EPA Administrator Gina 

McCarthy in scheduling the November 20, 2013 listening session that provided Arizona 

stakeholders the opportunity to speak directly with EPA's Office of Air and Radiation's Acting 

Snoll & \l'Almor is a member of LEX MUNDI. Tho Loading Associalion of lndepondonl Law Firms. 
Snell & Wilmer ---- L.L. P. ----

Environmental Protection Agency 

December 8, 20 15 

Page 2 

Assistant Administrator Janet McCabe and technical staff regarding our concerns with, and 

suggestions for the modifying of, the Exceptional Events Rule. 

We would also like to express our appreciation to the EPA for: this opportunity to 

comment on its proposed rule revisions to the 2007 Exceptional Events Rule and its Draft 

Guidance on the Preparation of Exceptional Events Demonstrations for Wildfire Events that May 

Influence Ozone Concentrations; choosing to host this very important public hearing here in 

Ari zona at the headquarters for the Arizona Department of Environmental Quality; and for 

working to address some of the issues identified by the State of Arizona in developing this 

proposed rule and guidance. 

We greatly appreciate the EPA recognizing the importance of streamlining the 

Exceptional Events demonstrations process and addressing the substantive concerns in an effort 

to make the Exceptional Events Rule more functional and practicable. As such, we agree with 

the request put forth by Senator Flake in his November 19, 2015 letter to Administrator 

McCarthy. Therefore, we formally and respectfully request that a 30-day extension of the 

comment period be granted to permit a more extensive review and assessment of both the 

proposed rule and draft guidance. These proposed revisions and draft guidance are far too 

important to not be given the proper due diligence so that substantive feedback and, if necessary, 

additional suggestions may be provided to better inform the final revisions of both.