NAAQS and Other CAAImplementation UpdatesOffice of Air Quality Planning and StandardsAnna Marie WoodDirector, Air Quality Policy DivisionWESTAR Spring MeetingMay 2014Exceptional Events Next StepsRevisions to the 2007 Exceptional Events Rule (EER)We anticipate proposing the EER revisions in mid-2015 andpromulgating EER revisions in mid-2016Schedule provides EER changes in advance of implementationactivities for any potential new or revised ozone NAAQSGuidance to Support Data Exclusion Requests forWildfire-Related Events that May Affect OzoneConcentrationsSchedule anticipated to parallel EER revision effortFocus on demonstration components and the technical toolsavailable to support EER criteria19Exceptional Events Rule RevisionsPossible Areas of Focus for Rule RevisionsTake a deep breath and refocus on statutory language,streamlining, and protection of public health“Not reasonably controllable or preventable”“But for”Clarification of fire-related terms and conceptsMitigationEPA recognizes that there are few readilyavailable, cost-effective tools that air agencies canuse to support ozone-related exceptional eventdemonstrations under the existing EER.We intend to address this gap20Stakeholder Feedback on EERRevision ProcessFeedback:Statutory language could have been implemented by codifying the NaturalEvents Policy (NEP)Response:We incorporated many of the NEPand Natural Events Action Plan (NEAP)concepts in the High Winds Interim Guidance.We expect to propose applying some ofthese same concepts more broadly than PM.Feedback:Current implementation complications are due, in part, to regulatory-onlycriteria: “but for” and “historical fluctuations”Response:“But for” is possible focus area for rule revisionsComments received prior to release of InterimGuidance indicated agreement/support of EPA’sposition that historical fluctuations consists ofa showing of how themeasured concentrationcompares to historical levels. We expectto propose codifying this interpretation.Feedback:Air agencies need ozone-related exceptional event implementation guidancenowResponse:Much of the Interim Guidance applies to all pollutantsIf we developed ozone guidance now, it wouldneed to reflect the current rule elements ratherthan our anticipated rule revisionsWe intend to develop ozone guidancein concert with rule revisions21Exceptional Events in DesignationsEffortsKey Dates for the 2012 PM2.5NAAQS DesignationsDecember 14, 2012 – EPA promulgated 2012 PM2.5NAAQSBy December 13, 2013 – States/tribes submit area and boundaryrecommendations based on 2010-2012 dataBy August 14, 2014 - EPA notifies states/tribes re: any intendedmodifications to their recommendations (120-day letters) based on 2011-2013 dataDecember 2014 - EPA promulgates final PM2.5area designationsPromulgated Exceptional Event Schedule5 states cited reliance on exceptional event claims (for multiplecounties/events in each state) in their December 2013 recommendations22Air Quality Data Collectedfor Calendar YearEvent Flagging & Initial DescriptionDeadlineDetailed Documentation SubmissionDeadline2010 and 2011 July 1, 2013 December 12, 20132012 July 1, 2013 December 12, 20132013 July 1, 2014 August 1, 2014Exceptional Events in DesignationsEffortsExample Dates for a potential 2015 Ozone NAAQS (under a 2-yeardesignations schedule)By December 1, 2014 – EPA proposes 2015 Ozone NAAQSMid-2015 - EPA proposes Exceptional Event Rule revisions/guidanceBy October 1, 2015 – EPA promulgates 2015 Ozone NAAQSMid-2016 - EPA promulgates Exceptional Event Rule revisions/guidanceOctober 2016 - States/tribes submit area and boundary recommendationsbased on 2013-2015 dataJune 2017 - EPA notifies states/tribes re: any intended modifications to theirrecommendations (120-day letters) based on 2014-2016 dataOctober 2017 - EPA promulgates final ozone area designationsPotential exceptional event schedule23Air Quality Data Collectedfor Calendar YearEvent Flagging & Initial DescriptionDeadlineDetailed Documentation SubmissionDeadline2013 and 2014 May 2016 October 20162015 May 2016 October 20162016 May 2017 June 2017Exceptional Events in DesignationsEffortsExceptional events implementation for a potential 2015 OzoneNAAQSAnthropogenic sources within the U.S. are largely responsible for4th highest 8-hour daily maximum ozone concentrationsExceptional events affecting the 4thhigh values are relatively infrequentEPA expects a limited number of exceptional events to have regulatorysignificance and will focus our review on these packagesThe reality of flagging in AQS and preparing ozonedemonstrations:Can air agencies flag 75 ppb (orlower) concentrations now?YesHow much effort should air agencies invest into compiling exceptional eventsevidence?Air agencies can begin compiling information using current InterimGuidance. We don’t expect many changesto affects air quality (includinghistorical fluctuations), natural event/human event unlikely to recur, or clearcausal relationship. Save work on“but for” until after the NAAQS arepromulgated and the EER revisions proposedWhat is acceptable evidence?See Interim Guidance24QUESTIONS OR COMMENTS25