Good morning. For the record my name is Eric Massey. I am the Director of the Air Quality Division for 

the Arizona Department of Environmental Quality and I appreciate this opportunity to provide oral 

comments on EPA's proposed revisions to the Exceptional Events Rule. 

ADEQ commends EPA for the level of effort it has gone to listen and adapt to the concerns of States that 

have experienced hardships implementing the existing Exceptional Events Rule. Western States in 

particular have been heavily involved throughout the history of this rule, submitting comments, working 

on potential improvements and working collaboratively with EPA and other States to improve the 

· process necessary to develop the documentation that's been provided. 

ADEQ's specific experience throughout this entire process has been laborious, but always positive. To 

our understanding no other State has gained as much experience with implementing this rule, in large 

part due to the specific conditions of Arizona's unique environment. Our efforts have always been 

focused on making certain that the most defensible exceptional event documents are developed with 

the most efficient and productive processes that can be developed. 

ADEQ aspires to lead Arizona and the nation in protecting and enhancing the environment at the same 

time improving the quality of life for the people in our State. It is our belief that the most sustainable 

solutions are achieved when we properly balance the needs of our unique environment, our economy 

and the communities. Through this balance we believe that we achieve better outcomes and generate 

more support for our solutions leading to lasting improvements in all three areas. It is through this 

balance that we believe we can help make Arizona the number one state in which to live, work, 

recreate, start a business, get an education and recreate. 

The proposed changes to the Exceptional Events Rule fit well into ADEQ's vision and mission. The 

changes have been made in response to partnerships developed between EPA and the States. It 

benefits from lessons that States have learned through implementation and uses that experience to 

encourage more efficient processes. At the same time it continues to ensure environmental protection, 

but ensures that States, t!ieir communities and their economies are not held responsible for natural 

events or those that cannot otherwise be reasonably prevented or controlled. 

Overall ADEQ supports all of the changes that EPA has made to this rule, but recognizes that there is still 

work to be done reviewing the entire package. We believe that there are still some areas where 

additional changes could be made that preserve the balance of the rule but still provide procedural 

benefit for Arizona. As a result we intend to submit written comments in addition to the oral comments 

provided today. 

Finally, we want to recognize Senator Flake's leadership in this matter and also support his request for 

an extension of the public comment period. There are many important programs that are currently in 

public comment or in the beginning stages of implementation (specifically the Clean Power Plan and 

Ozone). States already have stretched their limited resources in an effort to begin developing responses 

and programs that will implement these programs into the future. Additional time will provide States 

with the ability to provide more thoughtful and thorough comments on all of these programs that 

compete for State time. 

Thank you for this opportunity to comment, and I would be happy to clarify any of my remarks if there 

are any questions.