## MEMORANDUMUNITEDSTATES ENVIRONMENTAL PROTECTIONAGENCY RESEARCHTRIANGLE PARK, NC 27711



## JAN232013 OFFICEOF AIRQUALITYPLANNING ANDSTANDARDS



### SUBJECT: MemorandumdatedMay26, 20II titled "InputfromAgricultureCommunityon ReviewofParticulateMatterNationalAmbientAirQualityStandards" 

## FROM: WilliamT. Harnett,AssociateDirector 

### Is/ ProgramIntegrationandInternationalAirPollution OfficeofAirQualityPlanningand Standards TO: DocketNo.EPA-HQ-OAR-2007

-0492
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### has notbeenalteredsincethe dateofsignatureonthememorandumbut

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### inthedocketatthetimeofsignature.

InternetAddress (URL) • http://www.epa

.gov RecycledfRecyclable•PrintedwhhVegetableOilBased Inkson RecycledPaper(Minimum25%Postconsumer)UNITE D STATES ENVIRONMENTAL PROTECTIO NAGENCY RESEARCH TRIANGLE PARK, 

### NC 27711



### THRU:
TO: Gina 

### McCarthy, Assistant 

### Administrator

Office of

### Air and 

### Radiation

This memo 

### provides a general 

### sunmary of the feedback we received during the stakeholder 

### meetings

### we held 

### in February and 

### March to receive 

### information from the agriculture 

### community on the 

### potential impacts 

### ofthe current 

### review of the 

### National Ambient 

### Air Quality Standards 

### (NAAQS) for particulate matter. We held these 

### meetings as a

### follow up

### to Administrator Jackson's commitment 

### to ensure

### that the 

### agriculture community had the 

### opportunity to 

### provide us

### with information before the 

### EPA develops 

### proposed standards, 

### especially 

### for 

### PMl0, which is 

### of particular concern

### to agricultural stakeholder groups. 

### We held six meetings 

### in different parts 

### ofthe 

### country.

### At each 

### meeting, agriculture 

### community representatives expressed 

### appreciation 

### for the 

### opportunity to learn more about 

### what the current status

### of the 

### review ofthe 

### PM 

### NAAQS and 

### to 

### provide input to the 

### Agency before decisions are made. 

### While a

### detailed set 

### of attendees, 

### concerns and 

### comments is included in the attachments, 

### I have 

### summarized the 

### key concerns

### ofthe 

### agriculture community below. The concerns relate 

### to: 1)

### the basis 

### for confirming or 

### revising of the 

### PMl0 standards; 

### 2) decisions on the 

### PMl0 monitoring network; 3) issues

### with designation 

### of nonattainment areas; and

### 4) implementation 

### ofthe 

### PM10 

### NAAQS. 

# L The b'asß

## for confirming or revising of the 

### PMj0 standards 'We heard several concerns 

### related to the basis 

### for retaining or 

### revising the 

### PM10 standards. 

### The

### first, 

### which we heard 

### consistently at 

### all of the meetings, was concern 

### that 

### rural OFFICE OF AIR QUALITY PLANNING AND STANDARDS 

### MEMORANDUM 

## SUBJECT: Input from Agriculture Community on 

### Review of Particulate 

### Matter National

Ambient 

### Air Quality

# Standards ¡, I 

# F'RoM: v/iltiam T. Harnett, Associate 

## Director

# ilrilJd^^')th^^d[

rtepnen 

## D'

# Yase'"i";iiÞMïït^{rffi' *,AY 2

# 6 2011 

### Office of

### Air

# Qualit (J

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### PM has 

### not been demonstrated 

### to be as

### toxic as urban 

### particles. Participants attribute 

### this opinion

to the fact that 

### rural PM tends 

### to be composed 

### of more crustal 

### material as opposed 

### to sulfates, 

### nitrates and 

### carbon components. They believe the 

### health studies 

### which are 

### primarily based 

### on urban areas are 

### not representative 

### ofthe risks associated

### with exposure 

### to rural PM. They cited studies showing that 

### people 

### in rural areas 

### live longer and saw

### this as 

### supporting 

### their belief that rural 

### particles are 

### not

### toxic. They argued 

### strongly that,

### without much more 

### compelling evidence 

### of negative health effects, 

### it would be 

### appropriate 

### to retain the current 

### PM10 standard. 

### The second concern 

### they raised 

### inthis category was 

### the adequacy

### of the 

### monitoring network to 

### properly characterize 

### ambient concentrations 

### of 

### PM coarse 

### particles. 

### PM coarse 

### particles are 

### those generally greater than 

### PM2.5 

### in size and 

### generally less

### than 

### PMl0 in size. 

### Participants said 

### they believe the 

### relatively small number 

### of 

### monitoring sites 

### for coarse 

### particles, as

### well as 

### uncertainties associated 

### with approaches used 

### in health studies 

### to estimate 

### ambient concentrations 

### of coarse 

### particles, leads

### to greater 

### uncertainty aboutwhether there are 

### risks associated 

### with this 

### fraction or 

### if health risks actually are 

### from PM2.5. The 

### third issue raised 

### wasthe 

### lack of a 

### risk assessment 

### for coarse 

### particles. Participants pointed 

### tothis as a sign 

### of how 

### uncefain the data 

### is on 

### ambient concentrations and on

### the health effects associated 

### with coarse 

### particles. 

# 2. Decisions on the 

### PMI0 monitoring network Participants in the 

### meetings believe we are

### going 

### to create alarge 

### PMl0 network that 

### will reach 

### into 

### all of the 

### agriculture communities. They expressed 

### concem that such a

### network would 

### find violations of 

### potential alternative 

### PM10 standards discussed 

### in the 

### Policy Assessment and

### would cause

### farming practices to be affected 

### in the long 

### run. Combined 

### with the 

### points under 

### item one above 

### they 

### felt there

### would be 

### significant costs 

### incurred 

### for no health 

### benefit. 

# 3. Issues 

### with designation of nonattainment areas 

### Two issues came 

### up on 

### inthis category. The

### first came

### primarily from state 

### or 

### local air 

### pollution agency representatives, 

### who were concemed about 

### violations that are caused 

### by natural or exceptional events 

### like dust storms or fires. 

### If the 

### PM10 standard 

### is made 

### more stringent, then more data

### will have 

### to be 

### reviewed 

### to look at 

### whether they were caused 

### by such events. 

### The state and 

### local agencies 

### complained that the Çurrent process 

### for them 

### to make demonstrations on these events was 

### too burdensome and said 

### that unless the 

### EPA changes 

### the process there

### will be a 

### huge cost 

### impact on these agencies. One state

### director pointed out he has a 

### PMl0 nonattainment areathat has a desert 

### in 

### it. Every level of wind picks up dust and

### takes 

### it tothe PM10 monitors. He

### would 

### like a process 

### that 

### simplified the demonstration he

### would need 

### to submit 

### for such a 

### county.The other issue,

### which was raised 

### primarily by the

### agriculture industry, is a 

### concem that 

### all existing farms

### will have 

### to model 

### to show compliance 

### with the 

### PM10 

### NAAQS. They based 

### this concem onthe approach used 

### in the guidance on designating areas

### for the SO2 

### NAAQS, in which we are

### asking the states 

### to combine 

### modeling of large sources 

### with monitoring information to make 

### their recommendations 

### for attainmenlnonattainment designations. 

### They

### believe the above 

### two actions

### will lead

### to a 

### huge number 

### of new 

### PMl0 nonattiainment areas as



### evidenced 

### by a 

### report submiued 

### tothe 

### EPA by the 

### PM Coarse 

### Coalition. 

# 4. Implementation 

### of the 

### PMI0 NAAQS. The 

### first issue the 

### participants raised regarding 

### controlling agriculture sources

### for dust 

### emissions is

### that 

### implementation strategies 

### would change 

### the common, every day 

### practices

## of how they manage 

### their farms. They noted that 

### today, dust can be used as an 

### indicator of the 

### kinds

### of activities they should 

### or should 

### not undertake on a

### farm on a

### particular day, and said 

### that 

### if it is suppressed, a

### very cost-effective farm management 

### tool 

### will be 

### lost.They also raised the 

### point that even 

### working 

### with USDA on best management 

### practices 

### did not ensure practices 

### that made sense

### in all areas. 

### They were 

### especially concemed 

### that 

### control strategies 

### would involve using water 

### to suppress 

### dust on 

### roads and 

### fields 

### in areas 

### where water 

### is 

### in scarce 

### supply. They also 

### felt 

### it would lead 

### to 

### paving

### of roads 

### in rural areas

### with huge costs and 

### no health benefit. They believe the 

### implementation 

### of a 

### more stringent 

### PMl0 NAAQS 

## will add 

### significant costs 

### onthe operations 

### of farms 

### which cannot 

### afford them. 

### We encouraged 

### them 

### to continue 

### to participate throughout the process 

### of reviewing the 

### PM 

### NAAQS and

### to also

### file comments as

### we propose any actions on

### the 

### NAAQS, monitoring or howthe standards 

### should be 

### implemented. 

### Iwould appreciate 

### it 

### if you

### would send 

### this 

### information forward to the 

### Administrator. Attachments (11) 

# cc: Janet 

### McCabe 

### Lany Elworth

### Outreach on PM-10 

### NAAQS 

### with Agriculture Representatives 

### Washington DC 

### February 

# l7,20ll Attendees 

### EPA: Janet 

### McCabe, 

### Deputy Assistant 

### Administrator, 

### OAR Larry Elworth, 

### Agriculture Counselor 

### to the

### Administrator Dr. Scott Jenkins, 

### Health Scientist 

### for PM-10 

### NAAQS, OAQPS 

### Dr. Robert 

### Vanderpool, Aerosol Research 

### Engineer, 

### ORD 

### Alison Davis, Senior

### Advisor for Public

### Affairs, OAQPS Joe 

### Dougherty, Environmental Protection Specialist, OAQP S 

### Bill Harnett, Associate 

### Director, OAQP Congressional 

### Staff: Mary Neumayer, House Energy and 

### Commerce 

### Committee 

### Staff Amanda 

### Taylor, Senator 

### Grassley's 

### Staff 

### Industry: Tamara Theis, 

### National Cattlemen's Beef 

### Association Ashley Lyon, National Cattlemen's Beef 

### Association 

### Kurt Blase, 

### Holland and 

### Ifuight (Coarse 

### PM Coalition) Rick Krause, 

### American Farm Bureau 

### Tom Hebert, 

### United Egg Producers Steve 

### Hensle¡ USA Rice Federation 

### Keith Menchley, National Cotton 

### Council David Hickley, National 

### Milk Producers 

### Federation Jeremey Peters, 

### National Farmers 

### Union Beverly Paul,

### American Soybean 

### Association

### 2/17 Outreach 

### Meeting Summary

Intro (Larrl¿ 

### Elworth. Janet 

### McCabe. and 

### Bill Harnett. 

### EPA)

## - importance 

### of organizing these 

### listening sessions and 

### understanding the 

### regulatory process 

### from the perspective 

### ofthe affected parties 

### Overview of PM 

### proeram (Scott Jenkins. 

### EPA)



## . Upcoming meetings 

### (Bill Harnett, 

### EPA)- 2123,Kansas 

### City, 2125 Des 

### Moines, 3/2 

### Riverside, 3/9 Spokan e, 3 I

## l0 Denver



## . Question (Dr. 

### Keith Menchley, National Cotton Council) - opportunity for more meetings 

### in the southwest region 

### of the

### country? 

### Answer 

### (Bill Harnett): explanation 

## of how meetings were organized 

### regionally and

### that 

### Arizona and 

### Nevada are 

### included in the Riverside 

### CA meeting

. 

### Discussion 

### of primary (health based standard) 

### for PM, definitions for "requisite" standard, 

### role of CASAC



# - Question (Dr. Keith Menchey, 

### National Cotton Council): what science 

### is 

### CASAC looking 

### at? Answer (Scott Jenkins, 

### EPA): CASAC reviews the integrated science assessment 

### in a

### public review process, 

### during 

### which both the 

### public and 

### CASAC can 

### introduce outside studies.

. 

### Scientifìc review 

### of CASAC


# - Question (Tom Hebert, 

### United Egg Producers): what is the 

### level of guidance that govems 

### what science 

### is introduced 

### during the 

### scientific advisory process?



# . Answer (Scott Jenkins, 

### EPA): CASAC is composed 

### of scientific experts, and 

### they have 

### the

### discretionto introduce 

### all of the 

### relevant science 

### that they deem necessary 

# - Follow up question (Tom Hebert, 

### United Egg Producers)- 

### how does 

### EPA define the 

### term "adequate 

### margin 

### of safety"? Answer (Scott Jenkins, 

### EPA): Administrator's judgment, in weighing evidence and 

### uncertainties, as 

### determined 

### by the 

### CAA directive to evaluatethe best 

### available science

. 

### Health effects 

### linked to coarse 

### PM

Question (Tamara Thies, 

### National Cattlemen's Beef Association) 

### -Are the health effects 

### linked to both coarse and

### fine 

### PM? Answer (Scott Jenkins): General description 

### of co-pollutant models and

### theway they are used

### to char

### acteize health effects. 

# - Follow up question 

### (Kurt Blase, Coarse 

### PM Coalition) 

## - what isthe 

### level

## of uncertainty in the data?

### Answer #1 (Scott Jenkins, EPA) 

## - general 

### overview of the

### findings in the 

### primary studies and a 

### description 

### of the 

### uncertainties 

### identified 

### in the

### draft 

### policy assessment.

### Answer #2 (Janet 

### McCabe, 

### EPA):

### noted that the 

### Administrator is not required to 

### lower the standard,

### just evaluatewhether the standard needs 

### to be 

### revised. The 

### quality and 

### uncertainty of the studies 

### that Scott described are 

### highly germane 

### tothis discussion and

### will impact whether the

### Administrator determines

### to lower the standard. 

# - Follow up Question #2 

### (Dr. 

### Keith Menchey, 

### National Cotton Council)

# - what

### tlpes of controls are used 

### in these studies? 

### Answer (Scott Jenkins, 

### EPA) :

### overview 

### of controlled exposure 

### studies

### with human volunteers, 

### particularly lung inflammation and 

### heart rate 

### variability data. Also discussed 

### installation studies 

### involving animals and 

### how they are used. 

# - Follow up Question #3 

### (Tom Hebert, 

### United Egg Producers) 

## - has there been 

### any

### thinking regarding 

### how

### to orgarize the disparate studies? 

### Answer (Scott Jenkins): yes, 

### the integrated science assessment has a

### "weight of evidence" 

### framework that is developed 

### in conjunction 

### with 

### CASAC. It helps 

### EPA make
a

### judgment regarding causality, considering the available evidence.

. 

### PM 

### NAAQS Review Process

### to Date: Integrated Science Assessment, 

### Risk/Exposure Assessment, 

### Policy Assessment, 

### policy options, 

### staff conclusions, 

### CASAC review


# - Question (Rick Krause, 

### American Farm 

### BureaÐ -

### Will CASAC review the 

### final policy assessment? 

### Answer (Scott Jenkins and

### Bill Harnett, 

### EPA): On a case 

### specific basis 

### they can, and these 

### reviews can be requested 

### by EPA.

.

### CASAC's recommendation 

## - revise the standard

.

### Staff Conclusion 

## - evidence 

### could support either 

### retaining or 

### revising the current 

### standard.Argument for retaining the standard centers 

### on uncertainties 

### in evidence and 

### the argument 

### for revising the standard centers 

### on 

### positive associations 

### between coarse 

### particles and 

### health effects.


# - Question (Tom Hebert, 

### United Egg Producers)

## - what isthe

### definition

## of "form" in the phrase 

### "revising the

### form" on page 6 

### of the 

### briefing?Answer #1 (Scott Jenkins, 

### EPA): we use an 

### indicator (PM10), averaging time 

### (24hr), and 

### form (1 expected exceedance). 

### Form refers to

### which value you need 

### to compare to the standard 

### level. 

### It can also be 

### thought 

### of 

### in terms 

### of the number 

### of exceedances 

### of the standard 

### level you 

### get. Answer #2 (Janet 

### McCabe and 

## Bill Harnett, 

### EPA): form istriggered by 

### monitoring high values, but 

### they can 

### be excused 

### by "exceptional events," 

### which are 

### things 

### likewildfìres or

### wind events. 

# - Follow up Question #1 

### (Rick Krause, 

### American Farm Bureau)

## - would you consider 

### modifying the exceptional event 

### policy? 

### Answer (Janet 

### McCabe, 

### EPA): the exceptional event 

### policy is currently being reviewed, though 

### this process 

### is 

### occurring independent 

### of the 

### NAAQS process.

# - Follow up Question #2 

### (Tom Hebert, 

### United Egg Producers) 

## - what isthe 

### role of location and exposure 

### in the data?

### Answer (Scott Jenkins, 

### EPA): the 

### primary evidence 

### is epidemiological data,

### which measures 

### fluctuations 

### in health effects

### with fluctuations in 

### monitoring data, 

### indicating exposure. 

### Answer #2 (Janet 

### McCabe, 

### EPA)

## - monitors are 

### primarily located 

### in population centers 

### to address

### this issue. 

# - Follow up Question #3 (Beverly Paul,

### American Soybean 

### Association) 

# - how many monitors? 

### Answer 

### (Bill Hamett, EPA): roughly 800 

### nationally 

# - Follow up Question #4 

### (Tom Hebert, 

### United Egg Producers) 

## - how is 

### uncerlainty in monitoring exceedances addressed?

### And how good 

### isthat data 

### in rural areas? 

### Answer (Scott Jenkins, EPA)

## - general description 

### of how exposure 

### error 

### is considered

### with monitoring data and 

### epidemiological studies. In 

### rural areas, 

### the issue 

### is complicated given where 

### epidemiological studies are 

### usually done. 

# - Follow up Question #5 

### (Tom Hebert, 

### United Egg Producers) 

## - do 

### rural areas need a

### different standard due

### to theway 

### they are 

### impacted 

### by coarse 

### PM? 

### Answer (Scott Jenkins): the issue 

### is

### still being evaluated, and has been 

### raised 

### by CASAC in response 

### to

### variability in urban and 

### rural data.


### Introduction 

### of Study/General Issues 

### (Tamara Thies, 

### National Cattlemen's Beef Association) 

# -

. 

### Intro

# - coarse 

### PM in rural, agricultural areas 

### is 

### "fugitive," mainly caused 

### by 

### truck dust and 

### other sources. Rural producers 

### arc already 

### struggling to meet 

### the 150 standard, and 

### believe that the available evidence supports 

### retaining the current standard.

.

### There 

### is general consensus 

### that 

### rural dust, asopposed 

### to urban and 

### industrial, causes less

### of a 

### health 

### risk

.

### Historically, EPA proposed

### to eliminate the coarse 

### PM standard due 

### to 

### limited health effects, but retained 

### it as a 

### cautionary 

### measure. Coarse 

### PM itself was 

### not the concern,the 

### main issue 

### was hne 

### PM attaching 

### itself to coarse 

### PM.

. 

### Dust storm events 

### distort the data

.

### By setting an

### ambient standard, 

### EPA indicates 

### to the 

### public they are unsafe every 

### time the standard is 

### higher than the standard, despite 

### the

### fact 

### thatwallagriculture dust does 

### not 

### indicate clearly detrimental impacts on 

### public health.

. 

### In eastern 

### United States

### it's 80% fine,20o/o coarse, 

### but 

### this is reversed 

### in the 

### western 

### agricultural areas 

### (80% coarse, 20o/o

### fine). 

### A coarse 

### PM standard 

### would adversely affect the arid west, and

### would potentially lead 

### to a

### shutdown 

### of agriculture operations.

. 

### úrvoluntary

### job loss 

### also causes adverse 

### health effects. 

### Exceptional Events rule has been 

### ineffective 

### in addressing 

### the issue, and has 

### recently rejected 

### monitoring spikes 

### in Califomia New Research 

### (Kurt Blase, Coarse 

### PM Coalition)

# -

. Research 

### was sponsored 

### by coalition of

### Agriculture and 

### Mining groups

. 

### If EPA lowers standard (to 65-85)

## - impacts 

### would potentially be

### twice as

### stringent, unattainable 

### in large areas 

### of theWest and 

### Midwest

. 

### Monitors 

## - what happens 

### in unmonitored areas? Coarse 

### PM Coalition has 

### collected some 

### preliminary data.

. 

### Impact on background concentrations, state 

### by state

. 

### Reviewed 

### PM concentrations 

### in all 50 states, 

### looked at 

### over 1100 

### yearly data sets

. Results 

## - numerous areas 

### would shift from attainment 

### to nonattainment

. East and South 

### would benefit by 

### having less 

### nonattainment areas 

### from a 

### revised standard, 

### while theWest 

### will have 

### more nonattainment areas

.

### Conclusion - 98Yo change raises a series 

### of concerns, 

### the exact 

### indicator raises 

### certain concerns, and

### there are 

### uncertainties 

### in health data

.

### Will be

### providing the study

### to EPA shortly and 

### happy to meet

### with them on 

### it.

Question (Tamara Thies, 

### National Cattleman's Beef 

### Association)

## - what 

### is EPA's general 

### thinking regarding 

### implementation? Specifically, how are 

### we addressing 

### Pinal County? 

### Answer 

### (Bill Hamett, EPA)

## - in the 

### way the standards are set 

### up, we 

### work 

### with the 

### individual sources 

### to bring down values, 

### work 

### with USDA on 

### effective strategies, and

### try to 

### bring the 

### air quality to a

### level appropriate to protect 

### public health.



### Follow up#2 (TamaraThies, 

### National Cattleman's Beef Association) 

## - Pinal 

### County can't meet 

### the standard 

### now, even 

### while spending 

### roughly $1000 a day 

### to achieve

## it. If EPA goes

### to the 

### new standard, 

### it would be 

### completely impossible 

### for certain areas 

### like Pinal Countyto ever come 

### into attainment. 

### Answer (Scott Jenkins and

### Bill Harnett, 

### EPA)

# - distributed breakdown 

## of counties that 

### would be effected 

### by a 

### proposed 65-85 

### standard. Overview 

## of how the existing 

### monitoring network is evaluated. Believe 

### it is 

### possible to develop strategies 

### to attain the standards



### Question (Dr. 

### Keith Menchey, 

### National Cotton 

### Council) 

## - what is our latest evidence 

### of acute versus 

### longterm 

### effects. Answer (Scott Jenkins, 

### EPA)

## - overview 

### of epidemiological data and 

### how those 

### metrics are 

### weighed and evaluated.

### Question (Kurt Blasé, Coarse 

### PM Coalition) 

# - schedule 

### moving forward? Answer (8i11 

### Harnett,



### EPA)

# - a

### briefing for the

### Administrator on 

### all issues 

### is currently 

### planned. 2011 

### is a 5year 

### mark from the2006 

### revision so

### 2011 is our goal, but 

### it is ambitious. There 

### is no concrete schedule 

### currently planned.Sign-in for Region 8Agriculture Particulate Matter Meeting Denver, CO March 10,ZOLL,8:30 am

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)Listening Session: Agricultural lndustry's Concerns Related to 

### the Potential Revision of 

### the PM10 NAAQS American Royal, Kansas City February 

### 23,2OIL Welcome 

### lntroduction: Karl Brooks 

## - EPA Regional 

### Administrator Presenters: Bill Harnett - OAQPS Scott Jenkins 

## - OAQPS Rick 

### Brunetti- KDHE

PowerPoint slide presentation 

## - Scott Jenkins The steps of a NAAQS review andthe status ofthe 

### current PM review. Question and Answers and Comments Q.What is CASAC? 

### A. The Clean Air Scientific Advisory Committee (CASAC) provides independent advice 

### tothe EPA Administrator onthe.technical bases

### for EPA's national ambient air quality standards. CASACaddresses research related

### to health/environmental impacts, air quality, and sources of air pollution. The Chair 

### of the CASACalso serves as a member of 

### the chartered Science Advisory Board. Congress established 

### the EPA Science Advisory Board (SAB) in 1978 and gave it a broad mandate 

### to advise the Agency on technical matters. The SAB Staff Officeforms ad hoccommittees and panels on environmental science topics, as needed. Chartered SAB members chair SAB committees and panels. Draft advisory reports prepared bycommittees and panels are

### transmitted to the chartered SAB

### for discussion and deliberation. C. NAAQS pollutants are review/evaluated individually, each by a

### different panel of experts in

### that field 

### of health/risks.
C.When CASAC reviewed

### the 2nd PM 

### draft PolicyAssessment, 

### they recommended that 

### the NAAQS be revised to 

### the lower part of 

### the range presented bystaff in

### the draft Policy Assessment. Q. Locations 

### of Monitors in MO and KS? A. Maps were prepared by EPA and provided as avísual. Rick Brunetti (KDHE): KS Monitoring Strategy 

### Most monitors are placed in an urban setting. Two large 

### monitor clusters in KS: 1) KC MSA, agreements

### with Wyandotte County Health Department and Johnson County Health Department, 

### 2)Wichita There isan additional 

### monitor in Cedar Bluffs, comprehensive monitoring site 

### for background air quality in KS. PM monitors are located inTopeka, Chanute, Linn County, Wichita, and Dodge CityThe KS 

### Monitoring Strategy is reviewed/revised every 5-yrs and submitted 

### to EPA

### for approval.At this



### point it does 

### not look likethey 

### will be adding additional PM monitors, just ozone monitors. At 

### monitor locations where values are low,

### they may remove or move monitors. Q. How many monitors are 

### currently in non attainment and how many monitor values 

### will be affected by

### the new standards? A. 41 countiesthroughout 

### the US

### will violate the 

### current PM10 standard

### with the current air quality 

### information. C.What 

### the States 

### will also need

### to look at and

## tak into consideration - "arethe adjacent counties s 

### contributing?" Scott Jenkins provided a chart

### with the breakdown of proposed values

## / population

### / number 

### of counties, etc. C. The 

### Midwest has

### the biggest potential 

### for impacts. Q. Can you be more specific 

### for KS? A. Rick- KDHE did some preliminary assessments 

### for KSat 75 ptg/m3 and did not see any violations. Q. Can you be more specific 

### for MO? A. Jim K.

## - MO did aquick review and 

### found 3counties

### would be in non 

### attainment: Buchanan, Jasper, St. Louis. Q. Allie Divine - NationalCattlemen's Beef Association (NCBA) conducted astudy/analysis. Has OAQPS had a chance

### to review? A. Bill

### - they have seen 

### the map and set up a meeting

### with NCBA 

### to discuss 

### what methodology they used

### to come up

### withtheir results. The map provided 

### to them from 

### the NCBA had almost every county in

### the Midwest listed as non 

### attainment

## - this is 

### not possible. There have never been

### that many counties in nonattainment 

### for any 

### pollutant. A meeting has been scheduled 

### for March 

### to meet

### with them and 

### find out howthey arrived at

### their analysis. Out of 3,000 counties possible in US,there are only around 350 currently monitoring 

### for PM and some monitors are inthe same county.
C. The lack 

### of monitoring stations is 

### not a reassurance. Networks can be expanded. Q.

### With SO2, modeling was use

### to determine 

### the standard. Would 

### that be an option 

### for PM? A. Bill

## - SO2 and PM are structured very 

### differently and SO2 is based on a

## t hr 

### standard. We have never required modeling 

### to determine nonattainment areas 

### for PM10 Q. 

### lf monitors are primarily in urban areas, why is

### there one in Linn City, KS, in a low populated area? Bill

## - Monitors are also placed invery rural areas 

### for background air quality measurements. These monitors are useful 

### for determining intrastate and international transport. Q. Have 

### there been any studies 

### to look 

### at natural background VS.

### anthropogenic and 

### what science has been reviewed for 

### the health effects? A. Yes. Mainly 

### for PM coarse (sand storm dust) associated 

### with cardiovascular isease. There 

### are not specific studies for 

### windblown dust 

### at lower particle concentrations. New 

### multi-city studies have been published

### that correlated course particles and health effects (i.e., hospital adm issions and/or 

### mortality) A USDA Task Force is also working on an agriculture air quality issues.Scott J.- Studies have been published looking at fluctuations 

### of PM concentrations in relationship 

### to

hospital admissions over 24-hr. period. He could provide copies

### to anyone wanting this 

### information (i.e. epidemiologica Istudy)
C.The dilemma is how

### to set a standard 

### to address both urban and rural.
C. Given

### the budget restraints EPA should focus on urban 

### efforts where they 

### will havethe greatest impact (i.e. PM fine) C. Lastweek 31 Senators sent letters of concern 

### to Administrator Jackson. C. 300 million children go

### to bed hungry every night. One acre of

### farm land provides enough grain 

### for 155 people. Please consider 

### the positive impacts ofthe farming community. Q. 

### lf l'm afarmer and I have neighbors complain about 

### the dust when l'm 

### tilling myfields, will the state put a 

### monitor along my property? A. The state has a process

### to deal 

### with complaints. There is adifference between nuisance dust and a NAAQSviolation. Q. Has

### the Presidents Executive Order 

### for reducing burdensome regulations been taken into consideration? Scott -. Yes, under 

### the Regulatory lmpact Analysis. Bill - But, it would be helpful 

### to submit 

### information during 

### the Federal Register public comment period. All submittals 

### will be reviewed 

### for consideration. Q. ls

### there anyweight in submitting comments during 

### the public comment period? 

### A. Yes, in

### the last review, 

### the PM10 standard was retained due 

### to the large amount 

### of public response supporting such a position. Bill H.- There are a lot 

### of unknowns creating levels 

### of uncertainty. This 

### will ultimately impact the decision of the Administrator. There is also a chance 

### that we could decide

### wait until 

### the next review, when science has advanced and we have more 

### informationto address 

### the uncertainties and make a decision on. The task given the 

### Administrator is

### to set a level

### that is protective 

### of human health, 

### not budgets, cost, etc. Karl

## - Closing remarks.Notes 

### for Region 

## I Particulate 

### Matter 10 

### Meeting

Denver, CO March 

## tO,20tl

Documents provided during 

### the meeting for 

### the Docket: North Dakota Grain Growers provided a

### letterfrom the 

### GovernortotheAdministratoron the PM standard. Colorado Livestock Association provided a 

### letter that was sent to the Administrator. Nebraska Wheat Growers provided a list of cattlemen who are willing 

### to discuss 

### the PM NAAQS and its impact on agriculture. Notes

### from EPA Presentation: Welcome remarks were provided by Region 8Administrator Jim Martin. lntroductions were made byattendees in

### the room and attendees participating by phone. Bill Harnett, OAQPS, provided welcoming remarks, and noted 

### that any 

### information received during the meeting 

### will be 

### put ¡nto 

### Docket. lt 

### will also be provided 

### to the Administrator 

### for her

### to take 

### into account in making any decisions regarding 

### the PM10 standard. Bill Harnett reviewed

### the presentation: Primary National Ambient Air Quality Standards (NAAQS) 

### for PM10: Outreach Meeting 

### with the Agriculture Community, March 

### I0,zOlL Bill Harnett noted 

### that no decisions have been made yet, and 

### that EPA isworking on

### the policy 

### assessment. EPA intends

### to make a proposal early this year 

### for PM10, andfinalize later this year. Adam Eisele reviewed 

### the Region 8 

### monitoring 

### network. He noted

### that although R8 sent 

### out an earlier version

### of maps

### that included all PM monitors, today's version just includes PM10 monitors. The monitors collect samples 24 hours, 

### from midnight 

### to midnight. Most are in urban, 

### not rural areas. Colorado hasapproximately 30 sites; although these numbers change

### from tíme

### to time, and they are 

### pretty distributed 

### throughout 

### state. Colorado's 

### monitors are both urban and rural, Montana has about adozen PM 10 sites. There are new monitors being installed near 

### the Powder River Basin, and existing monitors around Missoula The North Dakota network consists of seven 

### sites. The major cities 

### of Fargo and Bismarck have monitors. South Dakota has monitors around Rapid City and Sioux Falls. There are about adozen PM10 monitoring sites in

### the state. ln Utah, all

### the monitors are around the Salt Lake City 

### area. There are about ten sites in Utah.Notes

### for Region 8 Particulate 

### Matter 10 Meeting

Denver, CO 

### March 

### tO,2OtL
Wyoming has the greatest number 

### of PML0 monitoring sites

### with about eighty-five 

### sites. Most are near coal mines in northeast 

### Wyoming. About aquarter of 

### the monitoring sites are operated bythe state, and 

### the rest are operated by 

### industry. We are seeing more monitors inthe southwest portion ofthe state by

### the oil and gas industry.



## o Brent Boydston , Colorado Farm Bureau: How is EPA defining populated areas? For those areas in Colorado 

### with a large population and agriculture, 

### what happens 

### if it is

### out of attainment? We are expecting 

### that the State 

### will evaluate areas 

### to determine nonattainment, andwhether or not new 

### monitors need

### to be 

### installed. They

### will take into account population size, aswell aswhether 

### or notthey 

### will see a high concentration inthe 

### area. EPA and the State 

### willjointly determine the 

### monitoring network. 

## ¡ Brent Boydston, Colorado Farm Bureau: Clarifying 

### question. How is EPA determining population size 

### for monitoring purposes? From 

### the Census 

### Department. EPA

### will specify 

### the population number 

### that will be used inthe final 

### monitoring rule. The last

### timethe rule was revised, 

### the number stayed the same (at 100,000).



## . Gary Teague, Teague Diversified, 

### lnc.: Can you 

### tell us bystatewhere 

### to go 

### to get current air quality data 

### that iscollected?
EPA

### will send a link out. 

## o Dan Wogsland, North Dakota Grain Growers: North Dakota Grain Growers recommends 

### that EPA retain the current standard. There are ramifications 

### for regulations for agriculture 

### that would affect farming, tillage practices, and cattle 

### operations. There is no science 

### that shows 

### that ag dust is a

### concern. North Dakota Grain Growers is adamant 

### that EPA keepthe current standards asthey 

### are. Mr. Wogsland shared a 

### letterwith the group 

### that the ND Governor sent 

### to the 

### Administrator. The NDGovernor istaking

### the lead intalking 

### with the Administrator and DC. The ramifications far exceed

### the health benefits we 

### will see

### with a revision of 

### the standard. There are recommendations 

### that will be made 

### for coarse particles. There is a discussion

### of rural coarse 

### particles. There is uncertainty inthe 

### toxicity indifferences between rural and urban particles. There are studies 

### that have been done where scientists are looking at

### the impacts where wind 

### will pick up dust 

### from non-urban 

### to urban 

### areas. EPA isacknowledging uncertainties, and is including 

### it indocuments we are producing. 

## o Dan Wogsland, North Dakota Grain Growers: As EPA promulgates these Rules and looks atthe issue, we need

### to look at 

### the intent of Congress. Our decision needs

### to be science-based. 

### lf there is no evidence 

### of health effects,then we do 

### not need

### to regulate.Notes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO March 

## L0,20tl

There are 

### important uncertainties. These 

### will be presented

### totheAdministrator asshe makes her 

### decision. lnthe Statute, the 

### Administrator is charged by Congress 

### to make a decision 

### that in her judgment the standards 

### will protect health. She must weigh all the evidence, including 

### the uncertainties.



## . Ryan McCormick, Montana Grain Growers 

### Associat¡on: Montana Grain Growers Association backs the statements made by North Dakota Grain Growers. We do notwant to

### throw urban farmers under 

### the bus. lf 

### the standards were changed, 

### then no onefarming in Montana 

### will be able

### to meet

### the standard

### for PM 2.5. 

## ¡ Tom McDonald, JBS Five Rivers Cattle Feeding Company: 

### With respect 

### to the coarse PM uncertainty, did 

### the risk exposure assessment focus on fine, and not coarse? Yes, 

### there is uncertainty and EPA was unable 

### to perform 

### a rísk assessment for coarse 

### particles. We do 

### not have a national monitoring 

### networkfor coarse particles

### from 2.5 

### to 10 microns in size, sowetake an estimate 

### from co-located PMl-0 and PM2.5 monitors, which produces 

### uncertainty. The 

### report simulates 

### different air quality concentrations 

### for different standards. With the uncertainty, 

### there is not acredible risk assessment based on the data

### available. lt would 

### not be useful 

### for informing the 

### Administrator's decision. 

## o Tom McDonald, JBS Five Rivers Cattle Feeding Company: lfwe cannot do acredible risk assessment of coarse particles, how canwe contemplate tightening the standards as much as double 

### to address a health risk we cannot quantify?
EPAcan look at 

### the health evidence in

### different ways, both quant¡tatively and

### qualitatively. Health studies have been conducted 

### that link ambient coarse particle emissions to things like hospital visits and premature 

### mortality. There are some studies 

### that would indicate 

### that the current standard does 

### not adequately 

### protect human 

### health. There are 

### still health effects at the current standard, which gives us reason 

### to evaluate 

## it. lnthe end, 

### the administrator makes

### the decision. 

## ¡ Ryan, Montana Grain Growers Association - Some 

### of studies do indicate that 

### the current standard is protective and some do not?
EPA looks at 

### the population and

### whether the associations between coarse particles and human health effects were positive, aswell as if

### the relationships were statistically 

### significant. For coarse particles, most studies show positive relationships 

### though many are not statistically significant; however,

### the evidence is not asstrong assome 

### other pollutants we set standards 

### for. All ofthis 

### information is laid 

### out inthe 

### draft policy assessement. There is more uncertainty 

### for coarse particles, than 

### for fine 

### particles. All of this is considered and weighed in making decisions.Notes 

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO March LO,201,l


## o lvan Steinke, Colorado Livestock Association: lsthere adifference between 

### the correlation between combustion based PM10 and crustal PM10 identified in

### the risk assessment or health assessment? 

### lt is 

### important

### to identify the origin 

### of PM10. This issue hascome up

### aswe have looked 

### atdifferentstudies, 

### whetherthe particle is urbanversus rural. ORD

### just put 

### out a call

### to have scientists come up 

### with away

### to get atthis issue in a study 

### that estimates and analyzes differences in health effects 

### for rural versus urban particulate 

### matter. EPA has recognized 

### the uncertainty 

### with these issues. EPA 

### will continue 

### to study andfund these ongoing issues. lnthe integrated science assessment 

### there have been links between coarse particles of avariety 

### of compositions and health effects, including crustal materials. The policy assessment addresses links between ambient concentrations and health effects and how health effects are affected by the composition of

### the particles. lf

### the uncertainty is so great inthe 

### Administrator's mind it could be a reason

### for retaining 

### the current standard and allowing research 

### to continue. 

## ¡ Dayton Christensen, Nebraska Wheat 

### Growers: lf PM 2.5 isgoing 

### into urban areas, it also is in rural areas. The rural life expectancy is higher than 

### the national 

### average. NE Wheat Growers passed around a list of cattlemen who support this (lnformation 

### forthe Docket). ln urban areas these particles fall out 

### from Texas

### to North Dakota. Look at 

### the life expectancy, andfarmers have been inthese areas. You cannot harvest aquality crop

### without 

## dust. There is no evidence 

### that it isn't coming 

### from around the 

### globe. What do we

### want inthis 

### country? Right now Washington DC is proposing an apple orchard barrier around 

### water, based upon computer composites 

### from annual 

### rainfall. The 

### water is under the threshold and EPAstill wants these orchards as 

### buffers. Where do youwant your food 

### to come 

### from? Dowewant 

### to import from 

### othercountrieswheretheydonothaveasstrictastandard? Particulatesdon'tjustgointothe urban areas, look at

### the life expectancy. Just as ND Wheat Growers 

### invited EPA

### to come 

### totheir state, he

### would like

### to invite EPA 

### to come fly out over Nebraska. The country has progressed 

### to low and no

### till farming, and 

### there is not the dust that 

### there used 

### to 

### be. Farming is now a no

### till practice. The Phoenix study

### would be interesting 

### to h¡m, 

### to see

### what air stations are actually 

### putting 

### out. He agrees 

### with the regulatory system 

### with EPA, but does not want 

### to hurt agriculture. 

### With respect 

### to the water side,we can't accept or reject those statements at this

### time, asthe folks 

### that are present are not 

### with the 

### water program. They

### will get us

### information. EPA is addressing health affects in

### the policy assessment. Through

### the review process, point out ways you would characterize 

### it differently. 

## o lvan Steinke, Colorado Livestock Association: 

### After reviewing

### the integrated science assessment, 

### it isonly suggestive 

### of health correlations 

### from increased PM. lt did say inthe document 

### that the data is 

### not reliably 

### quantitative. As States develop monitoring systems,they are 

### currently highly 

### urban. ls

### there any chance

### that EPA 

### will do a modeling approach 

### forNotes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March

## tO,20tl
enforcing 

### the non-attainment areas? The only way EPA can enforce is

### at property lines 

### for agriculture. The integrated science assessment is suggestive, which is addressed in

### theWeight 

### of Evidence Framework 

### for causality. Thejudgment in

### the integrated science assessment is

### that fine particles are causally related

### to health 

### effects. The ranking goes 

### from causal 

### to not likely causal. EPA

### will identify the uncertainties in

### the integrated science assessment on health effects. 

### With respect 

### to the comment on 

### no-till and minimum 

### till practices and life-expectancy, you mentioned high dust 

### areas. EPA does 

### not have evidence 

### that numbers come 

### to levels beyond the standards. You are describing 

### that it iscoming 

### from a rural 

### area. We are finding 

### that when dust comes

### from a rural area, 

### it is awind storm coming in over 

### the desert bringing in high concentrations of crustal material over acity in a level much higher than 

### the current PM10 

### standard. Dust is not

### the same across 

### from urban 

### to rural areas. There are components of crust in urban areas 

### that might be

### toxic. Coarse particles in urban areas might be moretoxic than rural areas. 

### With respect 

### to life expectancy data, submit it as part of

### the comment process. 

### With respect 

### to monitoring and modeling, EPA has always relied on monitoring 

### for NationalAmbient Air Quality Standards. EPA is relying on modeling 

### to determine where 

### future monitors may be 

### placed. 

### lf folks have concerns aswe move forward, 

### theywill have a chance

### to comment on

### the rule. Comments From

### the Phone

# - o Director Ron deYong, Montana Department ofAgriculture: Montana does 

### not have the population centers; 

### it is mostly all small 

### cities. What are

### the chances of getting non-attainment areas in rural areas like Montana? We 

### would have

### to look at 

### the data

### to determine 

### the likelihood of getting a nonattainment area in 

### Montana. What we arefinding at this 

### time in states like Nebraska and lowa is

### that the nonattainment areas are associated 

### with cement plants and quarries atthe current 

### standard. The State agency could 

### tellyou if

### there are currently areas like quarries resulting in non-attainment areas. Scott looked up 

### the informationfor Montana 

### - Based on the 

### current monitoring 

### network from 2OO7- 

### 2009,if the standard were reduced 

### to 95 or 85 ug/m3, 

### there are 

### currently no areas in Montana 

### that would 

### violate. There might be one county if wewent 

### to 75 ug/m3. 

# o Dave Klemp, Montana Department 

### of Environmental Quality: MT DEQ doesn't expect 

### that 

### it wouldn't have

### different non-attainment areas, 

### but it does 

### not have 

### the data 

### to bring specificity 

### to the question. 

# o Leonard Stone, Montana Farmers 

### Union: Montana Farmer's Union opposes any EPA regulation 

### of dust 

### from farms and ranches. Nofarmer goes out 

### to make 

### dust. When 

### Mt. Saint HelensNotes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March

### lO,2OlI
erupted 

### it made dust and Missoula was huge into

### that. That was the only 

### time he remembered seeing

### that particulates were 

### incredible. lt wasthe only 

### time in 31-years 

### that he has seen changes. 

### Mt. Saint Helens 

### would qualify as a natural 

### event. When an event happens, we

### will see concentrations rise inthe short 

### term; however, 

### it doesn't last long

### time periods. What is

### difficult istrying 

### to build statistical correlation. We 

### would need health information 

### for everyone 

### that was 

### timed with all 

### concentrations. We would see

### the urban monitoring system affected by the 

### event. With 

### the health effects studies we 

### currently have,we do 

### not have the curve of 

### the line

### to saywhere 

### the points are

### for crustal 

### particulates. lt is hard

### to separate 

### out one impact. 

## o Dr. Brock Faulkner, Colorado Livestock Association: 

### With respect to 

### the equivalency ofthe standard, Figure 3-7 of

### the policy assessment document shows 

### the PM10 Coarse regression line. The conclusion is drawn 

### that 85 

### ug/Lfor 98%is equivalent 

### to the current 

### standard. There is no discussion of the variability around 

### the regression line; however,

### the range of data is

### from 20 ug/L

### to 135 ug/L, which is asubstantial range. lf we take all data in

### the U.S. and parse 

### out data east of

### the Mississippi River versus west ofthe Mississippi River, we havefound that 

### the particles are distributed similarly no matter 

### the location, and less of 

### the PM 10 is PM 2.5. 

## o Dr. Brock Faulkner, Colorado Livestock Association: 

### lt is

### still not an equivalent standard when you address variability. The Coarse Particulate Coalition submitted a report onthis 

### subject. ln

### the second 

### draft policy assessment EPA 

### will do more characterization of regional 

### variability. Whenwe do the final we

### will address

### the regression line, and it 

### will be broken 

### out by region inthe equivalent concentration section. 

### It is really not

### that different around the 

### country. lfyou look at

### the county counts and

### the number 

### of people living in counties, 75

## - 85 ug/L could be equivalent, depending on

### what metric is used. This is shown in

### the slide in

### the Powerpoint. With the current standard, 4l- counties

### with 33 

### million people are pulled 

### in. Some counties 

### that are currently violating the current standard 

### of 150 ug/L and are coming 

### into attainmentwould notviolate the 85 ug/L standard, and visa versa. 

## o Director 

### of Environmental Programs, Martha Rudolph, Colorado Department 

### of Public Health and Environment: My comment is more related

### to supporting states if

### the standard is changed. ls EPA going 

### to issue guidance 

### for states? ln

### the implementation rule, EPA is addressing reasonably attainable control technology and best achievable control 

### technology. We are addressing general control technologies in

### the rule, then clarifying case specific control technologies 

### for certain industries

### with additional 

### memos. We 

### will work 

### with the Department ofAgriculture in developing best management practices (BMPs)for reducingNotes 

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO March 

### tO,zOtL

emissions. This process is usually coordinated 

### with state involvement aswell as USDA, 

### with industry at the table. 

## ¡ Dr. Brock Faulkner, Colorado Livestock Association: You mentioned 

### that atthe current standard 

### that there are 4'J.counties affected, 

### but if

### the standard was changed, some 

### will be going off the list and some coming

### on. How 

### from a policy standpoint can this bejustified? The Clean Air Scientific Advisory Committee (CASAC) and 

### the EPA policy assessment evaluate ifthe 

### retention of current standard reasonable. 

### lt is an 

### option, and isone 

### that will be presented

### to the Administrator 

### with the others, aswell asthe 

### data. EPA

### will be changing the 

### form ofthe standard if 

### it is determined bythe Administrator 

### to be 

### appropriate. We look at a single evidence base when considering the current and potential alternative standards. Compared 

### tothe evidence for 

### fine particles, the evidence relevant

### tothe PM10 standard is less certain. 

## o Dan Wogsland, North Dakota Grain 

### Growers: How does EPA propose 

### to enforce more stringent regulations? Who ischarge, is it

### the state 

### or EPA? Are 

### other industries engaged

### with EPA inthis discussion? Other industries affected by

### the PM standard were engaging in

### the beginning inthis 

### review. All have participated in

### the review. Asfar as

### the roles between us and 

### the state in enforcing

### the standard, the state determines which areas are violating 

### the standard and are non-attainment 

### areas. EPA has

### to review and concur on 

### that list. They 

### willthen adopt rules 

### that apply to 

### that area, and sharethem 

### with EPA. The air plan at 

### the local level comes 

### into account 

### with the planning process as

### well. Enforcement is done by

### the state and locals inalmost all cases. As provided inthe State lmplementation Plan, if a state doesn't come in

### with a plan, or doesn't enforce its plan, EPA has its own authorities 

### to implement or enforce. 

## ¡ Dan Wogsland, North Dakota Grain 

### Growers: What do enforcement actions 

### include? Fines? Cease and Desist Orders? The enforcement process generallyfollows 

### thefollowing process. First a Notice of Violation is issued by the state or federal agency. The NOV provides 

### the parties involved 

### to figure 

### out 'did 

### that really 

### happen'? The agency

### will get 

### information back 

### fromthe source. lf it 

### still believes 

### it is a problem, it 

### will begin a more

### formal process and

### will sit down 

### with the source. At this point one of

### two things can happen. The preferred process is

### to negotiate and sign a legal Consent Decree. We 

### would rather not go 

### to court 

### to minimize costs on both 

### sides. ln

### that process

### there can be fines or penalties as part 

### of it. The

### facility might have had afinancial benefit, so

### that would be factored into the 

### consideration. 

### lf everyone is in disagreement, we go

### to 

### court. The 

### court hears both sides and makes a

### decision. There are enforcement policies out 

### there on our website and possibly onthe states' websites.Notes

### for Regiør 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March LO,20tl
## o Brad Thykeson, North Dakota Grain Growers Association: You alluded

### to models and current monitoring, 

### the physical locations of

### the monitors, but does EPA have monitors 

### for inthe car and in

### the home? Does EPA have data inthose areas 

### for both coarse and

### fine particles? All of

### the monitors are 

### ambient. The measurement provides an overall picture of 

### the air quality inthe city, which can include the air in cars or in a 

### home. When siting

### the monitors, we 

### try

### to avoid being next 

### to a high emitting source; 

### that would be inappropriate as we are trying 

### to measure the general air 

### quality. Sometimes we construct a monitor and someone starts aconstruction project 

### that cause higher values when construction isgoing 

### on. This isaccounted

### for in

### the designation process,where we have 

### to answer isthere a problem 

### that is causing 

### the high concentrations. 

## o Brad Thykeson, North Dakota Grain Growers Association: lf EPA isworried about ambient air quality being an issue, and we are only breathing 

### the air IO-I5% of

### time, how is it a health issue? We do

### try to teasethis 

### information out across 

### multiple city studies, using measures at hospitals, and take 

### into account 

### other 

### pollutants. ln a car,

### the ambient aír is coming into the car 

### cabin. We are 

### worried about

### that as well as

### the air in a 

### home. Studies have looked at health affects linked 

### to ambient air quality; you can get exposures 

### from other thanjust standing outside. 

## o Joe Petrocco, Petrocco Farms: ln looking at the slide 

### that shows the standards 

### with the number of counties and people affected, it seems possible 

### that alternative standards are more

### tolerant of urban areas 

### with higher concentrations. 

### Youcannottellbythislistingwhichoftheseareasareurban,andwhicharerural. EPAwill providea listing of 

### the counties when 

### the rule is proposed. 

## o Kim Baker, Montana Cattlemen's Association: Where she comes

### from dust is a good thing inthe arid and dry 

### northwest portion of Montana. Montana Cattlemen's Association 

### would like

### to see a revocation of

### the current PM 10standard, or ma¡ntaining of

### the current PM10 standard. Exposures seen can be due 

### to stress. Looking at urban versus rural areas is like comparing apples 

### to oranges. What she really wants

### to know is how

### willthis affect Montana's farmers and ra nchers? We 

### will take this comment 

### into consideration aswe move 

### forward. 

## o Dayton Christensen, Nebraska Wheat Growers Association: lf a comprehensive study is done 

### of metropolitan areas, how

### willwe regulate 

### the contributions coming 

### from Canada? Concentrations are measured at monitors and compared 

### tothe health effects 

### to inform where the standard should be

### set. When ¡t is set, if evidence shows 

### that impacts are coming across 

### the border, we have a

### joint program 

### that works on common air quality 

### rules. We look at what's coming 

### into a city from 

### the U.S. versus Canada, sowe are not asking 

### the local area

### to addressthis 

### contribution. We areworkingNotes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Derruer, CO 

### March

### tO,zOtL

with Canadaon Eastern U.S.which isall highly populated 

### to address ozone concerns. We do not show a 

### lot of internationaltransport of PM10 but we have been working on Sulfur and Nitrogen reductions

### for acid rain purposes That 

### will reduce PML0 levels aswell.



## . Dayton Christensen, Nebraska Wheat Growers Association: Will 

### there be a comprehensive review available? PM 2.5 or 10 can get suspended in

### the

### air. Smog and dust are notthe same thing and shouldn't be considered same

### thing. Dust particles in

### the air stream can pick up 

### tox¡ns. ls anyone looking 

### at Mercury contributions 

### from China? Studies have been 

### completed. A study has been done onthe toxins in

### the Northern Hemisphere 

### that we can

### forward along. 

## o Jeff Missling, North Dakota Farm Bureau 

### -The Powerpoint references CASAC;who is onthis committee, and are 

### the elected or appointed? CASAC is an independent science

### organization. The membership includes representatives 

### from state environmental agencies or organizations and scientists working inthe field 

### of health and environmental effects of air pollution. 

## ¡ ln looking at Page 5of

### the Powerpoint, you are looking at low socioeconomic 

### factors. How is 

### that taken into account in

### the PM evaluation? The low socioeconomic 

### factor is asurrogate, as it can result in less exercise, poor diet, and living in areas 

### that might be more 

### polluted. All these are caught by

### that single factor, can result in higher incidents 

### of health effects, and higher suscept¡bility 

### to certain kinds 

### of pollutants. 

## o Ryan McCormick, Montana Grain Growers: ln 2OOI-2OO2 there was a massive drought in Montana, and

### the dust cloud was

### visible. Would this affect farmers? 

## ¡ No, by lawthere are rules

### for natural and exceptional events 

### that exclude air quality data. Natural events include wild 

### fire and instances like 

### Mount Saint Helens. For prescribed burns, we like having asmoke management program in 

### place. For those

### that we have in place we are more flexible about 

### them. Brent Boydston, Colorado Farm 

### Bureau: ln

### the southeast Colorado area in Lamar ifwe use 

### different standards or

### the standards are revised down, what are

### the chances ofthis 

### monitor becoming a 

### nonattainment area? Since most of 

### the monitoring is urban, do we need

### to change our 

### monitoring rules as

### to where we 

### monitor inthe country? No decisions have been made on

### that. We 

### will be giving guidance 

### to states on numbers and quantities 

### of monitors and what 

### to look

### for. EPA has not changed 

### the PM10 

### monitoring network since we established requirements 

### for it. 

## o LelandSwenson,RockyMountainFarmersUnion: 

### lfEPAislookingatthestandardsbecauseofa public health reason, dowe have reports

### from L97Lto today, 

### of health effects specifically tied 

### to PM10 exposure versus

### thefactors listed, and are

### the statistics included in

### the report?Notes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March

## tO,z0tl

We do have a number of susceptibility factors including obesity and low socioeconomic status specifically identified when looking at

### the ambient concentrations of coarse PM linked

### with hospital visits, 

### mortality, cardiovascular response, 

### etc. We also have seen health effects 

### of human 

### volunteer studieswhere people have been exposed in chambers. 

## ¡ Leland Swenson, Rocky Mountain Farmers 

### Union: Since EPA put 

### the PM standard ínto effect in 

### t97t, dowe have data 

### that looks at changes in health effects? The 

### monitoring network was created in

### the late 80's, and 

### there has been more of afocus of studies on 

### PM10. Anything biggerthan 

### that is not efficiently getting into 

### the respiratory system. The science and research hasfocused on urban areas, and looks at 

### what happens 

### to health effects in hospitals 

### the day 

### that the concentrations change and

### the days immediately 

### following. We do have those kinds of analysis for 2.5, but cannot do

### for coarse particles. A regulatory impact analysis 

### will be done for the standard, where we

### will look at

### the potential public health benefits as

### well as potential costs 

### for the decision, which 

### will be out for 

### the public 

### to look at and comment on.



## . Gary Teague, Teague Diversified: At the 

### current standard, are there counties

### that have been in non-attainment 

### that have

### gotten into 

### attainment? How havethey done that? For most ofthose areas 

### that were in non-attainment, agriculturewasn't a large 

### contributor to the vast 

### majority. The impacts were largely 

### for industrial sources, andthey were able

### to implement control practices. The vast majority 

### of non-attainment areas have come 

### into compliance. The States have all adopted 

### contol measures. 

## o Source unknown: Going

### to back to the slide showing 

### the level 

### of how many counties and people are affected if we setthe standard so

### that 41 counties and 33 million people were affected, will we focus on installing new monitors, and would 

### the number then go up? ln

### the past we have notfound 

### the need

### to change 

### the 

### network. lt hasn't been decided as

### to whether changes are needed. 

## o Paul Mathiason, Red River Valley Sugar Beet 

### Growers: Could we look at a specific example? 

### lf someone was driving down a road seven to 

### ten days ayear 

### would it exceed the standard? lfwe are measuring every day ofthe year, you would 

### first discount 

### the highest value, and would look at 

### thevalue below 

### the highest 

### value. You would evaluate three years 

### of data looking for 

### the second highest 

### to see if it v¡olated 

### the current standard

### of 150ug/1. lfyou measured every day, youwould go down 

### to about 

### thefirst seven, look at the average across three 

### years. Most states have data 

### for one out of six 

### days. Look at 

### the highest value overthree years 

### with the current standard;

### with the 98th percentile you

### would look atthe second highest for each ofthree years, andwould average them 

### together. lf

### the second higheswas45 

### ug/l, that might pull down 

### the other values- For PM10, unlike

10Notes 

### for Region 8 Particulate 

### Matter 

### lOMeeting

Denver, CO 

### March

### tO,2OtL

some 

### other pollutants, 

### the measurements are not done daily; most are done every six 

### days. ln

### that case you might only get 

### two measurements 

### out of seven days. 

## ¡ Tom McDonald, Colorado Livestock Association: Onthe slide looking at the existing monitoring. Dr. John Richards 

### with the coarse particulate matter coalition predicts much larger numbers

### of counties going 

### into non-attainment. What are

### the chances 

### of EPA going 

### from monitors 

### to modeling? This is highly 

### unlikely. Although 

### the process isn't done yet, folks 

### will be able to track progress. EPA has met 

### with the Coarse Particulate 

### Matter Coalition after they submitted 

### their study, as EPA has problems 

### with the study. We sent 

### them a 

### letter in reply to 

### their study, and we can send it

### out. The Coalition

### will be coming back 

### with comments on our comments. 

## o We understand 

### the difficulty in setting 

### the PM standard, but when we set aone size

### fits all standardwe run 

### into 

### difficulties. PM Coarse 

### with toxicity varies; we strongly encourage EPA

### to keep

### the current standard by looking at the standard in

### the next five year go-round 

### with a new health effect study. A lot of studies have been completed both in

### the east and

### west. We see populations in both areas reacting

### to the PM Coarse. These are primarily urban based studies. 

## o Dr. Brock Faulkner, Colorado Livestock Association: lf 85 ug/L at the 98th percentile is projected 

### to be equivalent, we

### would implore EPA

### to keepthe same standard; as states 

### implement differently, expecting 

### the property line standard not

### to be exceeded. Often times he is required 

### to do modeling and present 

### information to the state

### that the property line does 

### not exceed the 

### standard. 

### lt is not appropriate when applied

### that way, especially 

### for crustal 

### material. Bill Hammerich 

### with Colorado Livestock Association submitted these 

### comments. There should be changes 

### tothe implementation guidance 

### that the NAAQS should 

### not be applied this 

### way. We were 

### told during 

### the last review 

### that this was not going

### to be applied

### that was in

### the guidance; however, when the guidance 

### wentfinal, it was included. Property-line standards are only considered

### for PSDpermitting, when a new source is moving in or an existing source is making major 

### modification, and 

### it isonly for 

### the emissions coming

### out of

### the stacks; not 

### for fugitive 

### emissions. Agrîculture is not one of 

### the source categories 

### that is listed

### for PSD 

### permitting requirements which include 

### the counting of fugitive emissions. There are statistical approaches 

### that scientists have used 

### for coarse part¡cles 

### to separate impacts from 

### otherfactors (i.e. existence 

### of disease, smoking). These can be done by population assessments for your 

### studies. They are statistically trying 

### to separate these in

### the study. We do 

### not have a

### quantitative risk assessment 

### for coarse particles;

TLNotes 

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO March 

### LO,2OLl



## . Dayton Christensen, Nebraska Wheat Growers Association: Nebraska would also like

### to stay 

### with the same standards in 

### place. lf most violations come 

### from industrial sources and not

### from agriculture, why aren't we targeting them?

We have been targeting inour monitoring 

### strategy. We have found 

### that farming is right up

### to urban areas. We 

### will look at

### the monitor and at 

### what is causing the 

### violations. The State 

### will look atwhat the right sources

### to address 

### are. Generally speaking, it's the direct 

### emitting stationary sources. They can 

### put on 

### controls. We have not always seenwhere astrategy

### for control of agriculture is needed; however, this has come 

### into play in AZ and CA. 

## o lvan Steinke, Colorado Livestock Association: Some of 

### the BMPs NRCS havedeveloped

### to reduce dust include spraying water, and may go against

### the CWA. Other BMPs

### that have been developed 

### for spraying on roads may go against 

### the Pesticide

### Act. Becareful of 

### the unintended consequences of anyair BMPs

### that are developed. 

### With respect 

### to the discussion 

### of monitoring stations, you 

### referto urban areasand 

### populations. The one state in 

### R8that hasthe most 

### monitoring locations is WY

### with 85; however, 

### it is

### the least 

### populated. lncreasing monitoring 

### for certain populations results could result in increased monitoring, and ag isvery concerned. Colorado Livestock Association isverythankful for the stakeholder meet¡ng 

### with an ag based 

### theme; are there 

### other industry meetings going on? Yes, 

### there are 

### other meetings 

### with other industries; however, none have raised 

### the issues

### that have come up

### with agriculture. With respect 

### tothe BMPs, USDA isworking 

### with us intaking a look at 

### other regulations, and looking regionally at 

### different approaches. Trying 

### to account 

### for the sametechnique 

### for very 

### dry/desert areas might not 

### work in

### the northern 

### tier. The BMPs may not havethe same effectiveness or 

### contribution. The sameth¡ng goesfor 

### tillage. Aworkable approach has been agreed to. lnWyoming, 

### there is avery particular reason 

### they have so many monitors; specifically, coal mines

### that provide a great amount of coalfor 

### the country. The monitors were not driven by concerns, but they were installed 

### for avery specific reason,

### to hold industry accountable. You do not see nearthe amount 

### of emissions 

### from agriculture asyou do 

### from coal 

### mining. Adam -We are only looking at

### the PML0 

### monitoring maps, 

### there isalso a lot of 

### other monitoring 

### that is going on 

### with other pollutants. 

## o Leonard Stone, Montana Farmer's 

### Union: For any number offarmers and farm groups in Region 8,

### the big 

### thing is

### to meet a

### standard. There is no way 

### that we can asfarmers have

### the right 

### informationcomingdowntheroadyearsinadvanceofthingswecandowiththeEPA. As farmers we want 

### to work 

### with your organization, not against 

### it. There's 10 Regions and here is no group or committee 

### that works

### with EPA

### that would report back 

### to us

### to give us away 

### to change 

### what we are doing, or work 

### with urban partners

### to make changes

### that would benefit all 

### of us.

L2Notes

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March LO,zOtL 

### ThereistheUSDAAirQualityTaskForce. ltwasjustreformedandwecanshareinformationthrough 

### them. Their group does interact on these kind 

### of issues and highlight where we should be working closer 

### together. We met in 2010 and discussed everything we are going over 

### here. EPA is

### currently using

### that body, we can have

### further discussions on how

### to get the 

### word out through a representative 

### group. Work 

### with your Agriculture Advisor

### to see how this can best be done. 

## o Tom McDonald, Colorado Livestock Association: As

### the Rule progresses,

### willthere be an impact as

### to howthis

### will impact state agencies?

### Will EPA do an economic impact analysis? Yes, 

### therewlll be an impact assessment at proposal 

### for comment, ifwe propose 

### to revise the standard. It

### will include both

### the benefits and

### the cost 

### of implementing 

### the standard, which we

### will take comment 

### on. However,we cannot consider 

### the cost in setting 

### of standards. We do an impact assessment every 

### time we set a NAAQS. When we are developing a 

### monitoring rule, we

### will look atthose issues, 

### from states implementing 

### the monitoring network 

### to how we are looking at making this 

### fit within the states' 

### andourresources. lfwehaveaparticularincrease,wewillmakeaproposalforit.Everybudgetcycle we are looking at what 

### would be

### the cost of a new

### standard. One thing we look at is

### the number 

### of nonattainment areas. An area

### willget more money if

### they need

### to do more planning. 

## o Dayton Christensen, Nebraska Wheat Growers Association: China is putting up one coal mine a 

### months. Where are you detecting mercury at air stations, and are you testing for this? We typically only monitor 

### for criteria pollutants. There is some mercury monitoring in Region 8; however, 

### it is not geared towards Asian 

### dust. EPAdoes notfund a network in mercury monitors 

## o Dayton Christensen, Nebraska Wheat Growers Association: Because if mercury is here, we are 

### getting particulates

### from china, 

### too. There are studies on China's emissions, we can

### forward and you look at it. 

## o lvan Steinke, Colorado Livestock Association: Colorado Livestock Association submitted comments for 

### the Docket. How long 

### will the Docket stay open ifwe haveadditional comments? You cansubmit comments

### from now 

### until about 90 days 

### until after 

### the proposal 

### to Scott

### Jenkins. EPA has a legal obligation 

### to respond 

### to all comments. 

## o Tom McDonald, Colorado Livestock 

### Association: Iwant 

### to re-emphasize the comments made earlier about BMPs. Sometimes intrying 

### to solve issues, we create another 

### one. We are in a 

### water deficit part ofthe 

### world. There needs

### to be a lot of

### thought ofthe gallons of

### water that are sprayed on

### the ground

### to alleviate PM emissions. ln afeedyard, one way

### to control dust is by

### frequent manure collection, but this increases GHG

### emissions. Allthings need

### to be weighed, and

### the benefit is 

### not documented and 

### pretty small 

### for all

### the hoops ag

### will have

### to jump through, 

### for recordkeeping alone.

13Notes 

### for Region 8 Particulate 

### Matter 10 

### Meeting

Denver, CO 

### March

### tO,2OtL

Let's see

### what happens 

### with the standards and monitors 

### first, but we

### will keep in mind the concerns you have mentioned regarding implementation down 

### the road. The USDA representative heard the comments 

### on BMPs. 

## o Robert Sakata, Sakata Farms: We need

### to look at 

### the difference between PM 10 versus general dust on

### farms. There is a study 

### that shows

### that asthma rates are lower 

### for children on farms. That study has not

### yet been 

### submitted inthis process, 

### but EPA 

### will probably get

## it. lf substantial new science comes up 

### that would cause us

### tothink differently, then we have a method 

### to reopen 

### the review ofthe science.



## . Dayton Christensen, Nebraska Wheat Growers Association: lfyou are spraying water on feedlots and on any area at 90 degrees, then you create even a

### finer material and it

### will blow even more. We need

### to be in

### thefeedlots 

### to look at this avenue more; wasting a natural resource like

### water seems ridiculous.
As we get 

### to proposalwe

### will keep everyone apprised, through a mailing list.

T+

### Outreach

## with Agricultural Industry on the 

### Potential Revision of the PM10 

### NAAQS Des 

### Moinesr 

## IA February 25,2011 During opening remarks, and 

### during the presentation, the process 

### by which EPA is bound (the 

### CAA requirements) to 

### review a

### NAAQ was discussed. As part 

### of this discussion representatives 

### from OAQPS 

### (Bill Harnett and 

### Scott Jenkins) discussed 

### the current version 

## of the PMro standard 

### (150 pg/m3 

### not to be exceeded 

### more than once 

### per year) and the 

### preliminary conclusions 

### of the 

### draft Policy Assessment that had been 

### provided for 

### public comment 

### (retain the standard 

### in its current 

### form or 

### revise the standard 

### within arunge 

### of 65-85 Wúmt based 

### on a 

### threeyear average, 98th 

### percentile 

### form). The 

### Administrator 

### will make her decision based 

### on 

### weight given 

### to available 

### scientific information and 

### its associated 

### uncertainties. The differences between a 

### "not more than one exceedence 

### per year" standard and a 

### "three year average, 98th 

### percentile" standard 

### were discussed. 

### Basically, a 

### "no more than one exceedence 

### per

### year" standard 

### could 

### allow the state 

### to "discount" thethree 

### highest exceedences 

### that occurred 

### over three

### years. 

### A "three year average, 98th 

### percentile" standard 

### could 

### allow the state 

### to discount up 

### to eight 

### of the 

### highest exceedences, based 

### on 

### monitoring frequency. The conversation wasthen opened 

### up 

### for discussion. 

### IA specific 

### information: IDNR circulated a 

### document 

### (Appendix 

### A) that 

### included a 

### map 

### of PMro 

### monitors in the 

### State. The document also 

### listed 

### potential design 

### values 

### (dv) calculated considering 2008-2010 data based 

### on a

### three year average, 98th

### percentile. The dvs

### for the 

### monitors located 

### in Mason 

### City and 

### Buffalo, 

### IA may exceed the PMro standard 

### if the standard 

### is revised 

### to a 

### level 

### in the 65-85 ¡rglm3range based 

### on a

### three year average, 98th 

### percentile 

### dv. It was explained that these

### two areas 

### have a

### history of compliance issues

### with the PMro standard 

### (in its current 

### form) and 

### that the State had 

### previously worked 

### with local aggregate 

### operations to 

### bring the areas 

### into attainment. Nebraska 

### specific 

### information: NDEQ explained that, based 

### on a

### three year average, 98th 

### percentile 

### dv, monitors located 

### in Omaha and 

### Weeping Water, 

### NE may exceed 

### the standard 

## (if revised) 

### considering 2007-2009. 

### It was explained that Omaha 

### is populous and 

### industrial area and 

### that there 

### is some 

### influence from a

### mining operation near 

### Weeping Water. General 

## Q. Is 

### the

### Agency looking to revise 

### boththe PMro and 

### the PMz.s standard? 

## A. The

### Agency 

### isn't necessary 

### looking to revise either standard, 

### but yes 

### both standards are 

### currently under 

### review to determine 

## if either should be 

### revised. Q. 

### What isthe difference between 65 pglm3and 85 ¡rg/m3? 

### What 

### will the 

### Agency base 

### its decision on?

## A. The 

### Agency

### will base 

### its decision on 

### how much 

### weight the

### Administrator puts on 

### the



### scientific evidence on 

### the health effects and 

### its associated 

### uncertainties. 

### It could 

### look something 

### like this: Very 

### uncertain: retain the current 

### standard; Science 

### is good, 

### but 

### still 

### uncertaintp revise 

### to 85 ¡rglm3based 

### on a

### 3 year average, 98th 

### percentile; Science 

### is 

### really good and 

### little uncertaint5 revise

## to a 

### level lower than 85 pglm3based 

### on a

### 3 year average, 98th 

### percentile. 

## Q. Has 

### the

### Agency considered economic issues 

### from health effects? 

## A. The 

### Agency can 

### not consider cost 

### when 

### reviewing a

### standard. The 

### Agency

### will establish the standard based on 

### the available science and 

### health benefits. The state

### will be able

### to consider cost 

### when developing 

### its attainment State 

### Implementation Plan (SIP). 

## Q. Hasthe agency 

### considered what 

### it

### will do about exceedences 

### that occur 

### in a 

### drought year? 

## A. If a 

### monitored exceedence 

### wasthe direct result 

### of an

### event that 

### is considered a 

### "natural event" (i.e. dust storms, volcanoes), the state can 

### submit a request 

### that 

### EPA excluded the data 

### from consideration 

### of compliance 

### with the standard. 

## Q. Secondary 

### formation of PMz.5 

### is a

### big concern; 

### is 

### it the same

### for PM16? 

### If so, 

### how isthat 

### being looked at 

### in this 

### review process? 

### If there 

### is secondarily 

### formed PM10, does 

### is disperse the same as

### secondarily formed PM2.5? 

## A. PM16-2.s does 

### not have a

### secondary 

### component. PMro-z.s 

### is 

### mostly formed through abrasion processes and, because

### of its size, 

### is 

### usually settled 

### out 

### of the atmosphere 

### relatively quickly. Sand 

### storms can 

### transport Pmro 

### long distances 

### but that is due

### to areally high entrainment 

### of the 

### particulate in the atmosphere. 

### For this reason, 

### when we 

### look at 

### the 

### history of nonattainment 

### for PMlgthere 

### usually are 

### only single counties or 

### partial counties designated as 

### nonattainment. PM16 

### could cross 

### very local state 

### or country bordersthough. 

## Q. Is 

### the

### Agency compelled 

### to consider the 

### "practical" impact of revising the standard? 

## A. The

### Agency

### will provide a 

### Regulatory 

### Impact Statement 

### with the promulgated standard. 

### When developing and 

### Implementation Rule we

## will consider the correct 

### level of control necessary; so

### far we 

### haven't seen 

### the 

### agricultural industry as a 

### large 

### contributor to

### violations 

## of the current standard. 

### Also, at 

### this 

### time, we are 

### not proposing to revise the 

### monitoring requirements 

### to deploy more 

### monitors in rural areas. 

## Q. The

### Agency seems 

### to be 

### giving conflicting messages 

### when 

### it uses 

### the

### word "equivalency''. For instance, the 

### Agency is saying that 

### it may revise the standard 

### to a 

### lower value, but that 

## it would also change 

### the

### form of the standard so

### itwould essentially be 

### "equivalent" tothe current 

### standard. 

### If it is equivalent, 

### why revise it? 

## A. The standard and

### form, 

### if revised, 

### would not be 

### equivalent. The counties 

### monitoring nonattainment could change 

### but the 

### number 

### of nonattainment areas 

### may stay about 

### the same.

### What the 

### Agency is saying is that 

### if the standard and

### form was revised 

### to 85 

### ¡rglm' 

### llAtn

percentile), the 

### number 

### of nonattainment areas 

### could be equivalent 

### to or less

### than the current number 

### of nonattainment areas 

### on a

### national scale. The 

### "equivalency''numbers changes as

### the potential value 

### of the standard 

### lowers. 

### Current Standard: 4 1 

### nonattainment areas 

### nationally Revise standard and 

### form to 85 

### ¡rglm', 98* percentile:predict 39 

### nonattainment areas 

### Revise standard and 

### form to 75 

### ¡tglm', 98* percentile:predict 55 

### nonattainment areas 

### Revise standard and 

### form to 

### 65 ¡tglm', 98* 

### percentile: predict 87 

### nonattainment areas 

### Health 

### Risk Assessment 

### Q. Can 

### you explain 

### more aboutthe Health 

### Risk Assessment? 

### Why wasn't one 

### completed 

### for PMro? 

## A. There were 

### limitations onthe

### availability of data and

### therewere 

### limitations in linking the available data

### to health 

### risks. Scientists have 

### tried to estimatethe number 

### of hospital visits and/or deaths 

### related to the current ambient air 

### monitoring data 

### for PMls-PMz,s 

### but there 

### is a sparse data 

### set. So, 

### scientists 

### looked at PMro 

### monitors collocated 

### with PM2.5 

### monitors but that method introduced 

### too much 

### uncertainty to

### justify a

### quantitative assessment 

### of 

### PMl0-2.5 health risks. 

### Q. What is the sample 

### population from hospitals? 

## A. Scientists

## will solicit information from one 

### or more hospitals 

### in an

### area. The 

### hospital

## will release 

### admissions statistics 

### (by admission 

### codes). The scientists then comparethe statistics to 

### monitored air 

### quality 

### in the same

### area.This occurs at 

### multiple locations 

### throughout the country. 

### Q. How can

### the

### Agency be certain that 

### hospitalization statistics are 

### directly related 

### to PM¡6? 

## A. Researchers have used 

### co-pollutant models 

### to compare 

### fluctuations 

### in different pollutants occurring at

### the same

### time and 

### hospitalization statistics. This modeling shows 

### that health effects 

### (hospitalizations) remain even 

### after 

### co-pollutants are

### accounted

### for in the 

### model. The

### Agency also 

### relies on 

### human 

### health studies 

### werevolunteers are exposed 

### directly to the 

### pollutant. 

## Q. So,

### there are 

### no 

### monitors that measure 

### the range 

### of PMro 

### to PMz.s? 

## A. There are 

### monitors that can 

### directly measure 

### PMl0-2.5. However, currently most 

### of our 

### PM10-2.5 air quality data comes 

### from comparing the PM1¡ and PMz.s 

### concentrations at 

### colocated 

### monitors. 

## Q. So, a 

### Health 

### Risk Assessment is not required as 

### part 

### of the 

### review process?

## A. No. The

### Agency is 

### required to 

### look at 

### the available 

### science.

### A Health Risk Assessment is



### very 

### helpful but is 

### not available 

### for all pollutants and 

### is 

### not a 

### requirement, Causal Relationships 

## Q. Can

### you speak 

### more about 

### the Causal 

### Relationships? 

## A. This is discussed 

### in the Integrated Science Assessment and 

### is based 

### on a

### Weight of Evidence 

### (WOE)framework considering 

### epidemiological evidence, 

### controlled 

### human exposure studies and 

### animaltoxicology studies. In

### the'WOE, we 

### look at each

### of those 

### lines of evidence together. 

### Q. 

### What do those 

### lines 

### of evidence 

### tell us?

### What arethe 

### uncertainties? 

## A. Each 

### line 

### of evidence 

### tells us 

### something about 

### the

### link between 

### PMl0-2.5 and adverse 

### health effects. There are 

### important uncertainties associated 

### with each 

### type 

### of study. These 

### uncertainties are discussed 

### in the

### draft Policy Assessment. 

### Q. 

### How are

### we (as a

### potentially regulated 

### community) supposed 

### to get our heads around 

### uncertainty in the data? Such as: does 

### PMlo 

### differ from urban to 

### rural? ; can 

### monitored PMro 

### values be compared

### to collocated 

### PM2.5 values 

### to determine the PM¡6-PMz.s 

### value? 

# ; are exposures 

### to PM1¡-PM2.5 a 

### health 

### risk to humans? 

## A. There 

### is a 

### lot of 

### uncertainty. So, 

### we are 

### looking for more 

### scientific data 

### to

## fill in these gaps. 

### The

### Agency did recently 

### put out a request 

### for research 

### but this is 

### mostly through university/collegiate programs and

### will mostly focus onthe urbanvs. 

### rural uncertainties. This 

### will take some

### time. There 

### is also a

### study that the 

### Agency recently received 

### from the 

### National Cattlemen's 

### Association that we are 

### reviewing. Already seems 

### to be some 

### signifìcant discrepancies 

### in the numbers 

### provided by the

### Association. So,

### the question is 

### how

### will the 

### Administrator 

### utilize the science 

### available to 

### inform her decision now? 

### Q. There seems 

### to be a 

### "suggestion" 

### of a causal 

### relationship, but the

### Agency may cut 

### the standard 

### in half based 

### on a 

### "suggestion". 

### It sounds 

### like the

### Agency needs 

### more 

### data. Is 

### the 

### Agency 

### really contemplating 

### cutting the standard 

### in 

### halfl 

## A. The 

### Agency is 

### not considering 

### cutting the standard 

### in 

### half. If the standard 

### is revised, the 

### method

### for computing compliance 

### with the standard 

### would also change 

### (described above). 

### Monitoring Network 

# a. If the standard is 

### revised, based 

### onthe current 

### monitoring network, two monitors 

### in 

### IA may have design valuess 

### that are 

### not compliant 

### with the

### standard.

### Will there 

### be changes

### to the 

### monitoring requirements 

### if the standard 

### is revised? 

## A. At this 

### point the 

### Agency has 

### not considered revisions 

### to the 

### monitoring requirernents

### for PMro. 

### We do need 

### to 

### monitor where 

### we expect there 

### will be exceedences 

### of the standard.

### IA inserted: The 

### IA monitoring network is currently set 

### up to help 

### with PSD 

### permitting. There

are 

### monitors that show background levels 

### of PM so

### that construction permits may be 

### issued faster. 

### Q. What 

### if the 

### Agency promulgates changes 

### to the 

### monitoring requirements? 

## A. The state

### will develop 

### its network to meet those 

### requirements. 

### If a 

### new 

### monitoring site is needed 

### the state

### will deploy the 

### monitor and 

### collect threeyears 

### of complete data 

### before a 

### designation recommendation could be made. 

### Nonattainment 

### Q. What happens 

### when there is nonattainment? 

## A. Oneyear

### from the 

### NAAQ revision, 

### if there 

### is 

### monitoring data 

### showing a

### violation for an area, 

### the Governor 

### will identiff what sources are 

### contributing to a

### violating monitor and 

### recommend a 

### nonattainment boundary based 

### onthat 

### information. 

### If there is no 

### monitoring data 

### the Governor may recommend that an area 

### is designated 

### unclassifiable. 

### If there 

### is 

### monitoring data

### that shows compliance 

### with the standard, 

### the Governor may recommend that an area 

### is classified 

### attainment. The Governor must recommend a 

### designations status

### for all areas 

### of the state 

### tothe

### Administrator one 

### year 

### from the 

### promulgation of the 

### NAAQ revision. The

### Agency has one year 

### to evaluatethe 

### information provided by the Governor and 

### promulgate the designations (a

### total of 

### two years 

### after 

### promulgation 

### of a 

### revised 

### NAAQ). The State has

### three years 

### from the date 

### of designation 

### to develop an 

### attainment SIP 

### to bring any area desi gnated 

### nonattainment 

### into attainment. 

### Q. What existing nonattainment areas 

### do

### we already see 

### that have an 

### agricultural component? 

### A. Phoenix, 

### AZ area and 

### the San

### Joaquin 

### River 

### Valley, CA are

### current PM1¡ 

### nonattainment areas. The 

### CA nonattainment area 

### is 

### heavily populated 

### but 

### it does 

### have an

### agriculture component; there 

### is a 

### heavy 

### influence 

### from diesel 

### engines. The

### AZ nonattainment area 

### is heavy populated, has 

### large 

### impact from 

### windblown dust and also 

### agriculture. 

### Q. What happens 

### in areas 

### with an 

### agricultural component? 

## A. Areas, such as

### the San 

### Joaquin 

### River 

### Valley in CA, have

### worked

### with USDA to develop Best Management Practices 

### (BMP) to be adopted 

### in tothe 

### SIP. There was consultation 

### with the 

### agricultural industry. 

### Q. What are some 

### of the BMPs? 

## A. Assistance was

### givento farmers to replace or 

### retrofit diesel engines 

### (CA) through the 

### Environmental Quality Incentives Program (a 

### Natural Resource Conservation Service 

### program);

### Conservation 

### No-Tilling; work 

### with large 

### livestock producers

### to install shelter belts (trees)



### which usually help to 

### limit PMro

### from being entrained 

### in to the air; 

### paving of roads. 

## Q. So 

### how is

### the 

### control efficiency determined 

### for paving things? 

## A. We 

### really 

### don't. We do 

### look at 

### diesel engine manufactures' 

### information regarding engines and 

### the 

### USDA and/or 

### local community works

### with the

### community to reduce speeds 

### on gravel 

### roads. There 

### is some 

### consideration 

### for 

### oiling or watering roads 

### but this may lead

### to other resource concems. 

### Comments 

## 1) Disappointed 

### with the 

### Agency's slide (# 

### of presentation) 

### listing premature death 

### fìrst on the 

### list of health 

### risk associated 

### with exposures 

### to PMro. 

### If the

### Agency is uncertain 

### of the science 

### behind the 

### PMro 

### NAAQ revision; the commenter suggested 

### that 

### this list be 

### reorganized. 

# a. The

### Agency does 

### have 

### scientific data 

### indicating the 

### premature death 

### is a

### health 

### risk of exposure 

### to PMro-z.s as a 

### pollutant and 

### it is the 

### most serious 

### effect so

### that is 

### why 

### it is listed

### first onthe slide. 

## 2) Request 

### that the 

### Agency's management 

### visit a 

### ranch

### to see a

### farm 

### first hand. Dust is 

### naturally occurring and can 

### be a 

### good

### thing: indicate when not 

### to seed 

### or harvest. 

## 3) The 

### USDA spoke 

### of paving roads as a 

### management strategy toward 

### reducing PMle emissions 

### from gravel roads, 

### butwho is going to pay 

### for the 

### paving and

### the maintenance? 

# a. The State

### would have 

### to consider 

### all of the 

### pros and cons 

### to 

### paving 

## if it wanted to 

### utilize paving as a

### strategy 

### in its attainment SIP. 

### EPA is not 

### requiring paving.

6

### PrimaryNational Ambient 

### Air Quality Standards 

### (NAAQS) for PM10

Outreach 

### Meeting 

### with the

### Agricultural Community Inland Empire Public 

### Utilities Agency March 

## 2,201I
See 

### signup sheet. 

### Kerry Drake 

## - Welcome Thanks 

### to 

### all for coming. 

### I sought 

### location between San 

### Joaquin

### Valley (SJV) and 

### Phoenix, and close 

### to Imperial 

### Valley. Thanks 

### to those 

### who

### traveled. Introductions. 

### Bill Harnett The 

### EPAAdministrator, at a 

### meeting 

### of the Senate 

### Agricultural Committee, made a 

### commitment 

### to consult 

### with the 

### agriculture community regarding the 

### review of the 

### PM 

### NAAQS before decisions are 

### made. 

### Dr. Scott Jenkins

### will be

### walking us 

### through 

### what is 

### going on. 

### Scott Jenkins presentation

## - lead

### for review of primary PM10 

### NAAQS. Notes and 

### signup

### will be 

### in the docket. Slide

### with statutory/legal framework. Primary standards are

### for protection of public health. Requirement to 

### review the 

### NAAQS every 5years. 

### As part 

### of that process 

### we are 

### required to engage

### with an 

### independent 

### scientific advisory board (the Clean

### Air Scientif,rc 

### Advisory Commttee, 

### CASAC). We cannot consider costs 

### in the standard 

### setting process, 

### though we can 

### in the 

### implementation phase. 

### PM standards 

### have changed 

### over 

### time. 

## l97I 

## - fìrst total suspended 

### particulates (TSP) standard. 

## ln 1987 

### we revised that standard as

### 24 

### hr and 

### annual 

### PMl0 standards. 

### EPA reviewed standards 

### in 1997 

### and2006.Today's 24-hr 

### PMl0 standard has 

### not changed 

### since 1987. 

### Slide 5:

### We do 

### have an expanded database 

### of health studies 

### for this 

### review comparedto previous 

### reviews. Studies 

### link exposure 

### to coarse 

### particles 

### tovarious adverse 

### health effects, and

### various factors make people 

### more susceptible 

### to PM health effects. Slide 

### 6: Started 

### current 

### review in2007 for bothfine and coarse 

### particles. The process consists 

## of various steps,

### with each step 

### having opportunities for public comment and science 

### advisory review. See 

### slide 

### for details 

### of the process so

### far. Policy assessment 

# - second 

### draft released June 

### 2010; 

### final draft

### still to be issued.

### Slide 

### 7: Staff conclusions 

### in2"d draft 

### policy assessment note 

### that 

### scientific evidence 

### could

support either 

### retaining or 

### revising (to 85-65 

### micrograms/m3) current 

### PMl0 standard 

### (150 

### micrograms/m3). CASAC recommended that the current 

### 24hour PM10 standard be 

### revised to increase 

### public health protection. 

### Slide 8: 

### Next steps

## - no 

### specific date

### forfinalizing staff 

### policy assessment Propose 

### rule, 90 day comment period. 

### Final rule 

### Bill Harnett: Slide 9: 

### PM10 monitoring requirements 

### Existing network consists 

### of about 800 

### monitors 

### in 373 counties. 

### Number of monitors 

### EPA requires depends on 

### population size and 

### PMl0 concentrations. 

### Slide 10: State 

### requirements 

### for implementing a 

### PM10 standard. 

### Slide 12: 

### Map of R9 

### PM10 monitors Slide 13: 

### Map of R9 PM2.5 monitors. End 

### of presentation. Question: Regarding health studies 

### tied 

### to coarse 

### particulate: Where were those studies 

### held, and

### what were the 

### PM2.5 levels? Were they also 

### high? 

### A: Lots 

### of studies 

### in this 

### review have 

### looked at

### specifically at 

### PM10-2.5 

### ("PMl0 minus 

### 2.5"), and 

### have 

### linked health effects 

### to 

### PMl0-2.5 fraction. They have used 

### statistical techniques

### to tease 

### out 

### PM10-2.5 effects 

### specifically. Q: Have those 

### actually measured 

### PM10 levels? Some studies have used 

### specific dichotomous samplers. Others have used 

### collocated 10 and 2.,5 samplers. 

### Speciation: 

### Most study areas have been 

### urban, 

### but do occur 

### in areas 

### where 

### you can 

### get a 

### large 

### fraction 

### of coarse 

### particles due

### to crustal sources. Some studies 

### in Coachella and 

### other less 

### populated areas. One 

### question is whether 

### rural coarse 

### particles are less

### toxic than urban 

### particles


## - possibly yes, 

### but there 

### is 

### uncertainty regarding 

### this issue. 

### Concern that 

### rural areas are 

### being drawn 

### into nonattainment areas 

### when exceedances are due to 

### urban areas.

### EPA: We 

### really do defer 

### tothe states

### on 

### implementation of the standards. 

### They decide

### what

sources 

### to regulate to reach 

### the standards. 

### Also note there are

### other health effects studies 

### beyond 

### epidemiological studies. 

### Question: : 

### Most available studies are 

### in urban aroas

## - it's not particles, but 

### what's coating the 

### particles. Out west, 

### particles 

### won't have as 

### much anthropogenic coatings. 

### You run a 

### risk

## of imposing a standard 

### that does 

### not achieve the health benefits you seek. 

### EPA: We do have 

### evidence 

### from big 

### windblown dust events 

### that those 

### particles are associated 

### with the same 

### effects as 

### urban particles. 

### Uncertainties arise 

### from the

### factthat overall 

### PMl0 concentrations are 

### much higher 

### in those events. 

### Question: 

### Many areas 

### in the 

### West have 

### major events 

### action plans. 

### EPA: We also have 

### controlled human exposure studies and 

### animal 

### toxicity data. One 

### thing worth pointing out: 

### if you have a 

### PMl0 standard 

### in an area that has a 

### really high fine particle concentration, the

### allowable concentration 

### of PM10-2.5 particles

### will be 

### relatively small, because 

### most 

### of 

### it

### will be

### taken 

### by PM2.5. One 

### implication of a 

### PM10 std 

### isthat you

### will in effect allow lower 

### PMl0-2.5 concentrations 

### in urban areas. 

### Comment: 

### But 

### I'm not sure 

### this

### follows in practice. 

### If you have 

### aPM2.5 standard, 

### there are 

### other measures 

### in place. 

### But in rural areas 

### with higher fractions 

### of coarse 

### particles, we 

### don't have those 

### kinds

### of synergies. 

### Comment: Inthe Coachella 

### Valley or Imperial County, dust events are

### almost always composed 

### of crustal material, 

### which is a

### different animal than urban 

### particles. 

### EPA: We don't have 

### evidencethat there 

### is a 

### lack 

### of effect 

### from crustal materials, because

### we do 

### have studiesthat show 

### similar health effects 

### from those 

### types

### of particles. Studies 

### going on 

### now may have an 

### effect on

### future reviews. 200ó annual 

### PM 10 standard 

### revoked. 

### EPA: We have 

### very few studies

### showing long-term exposure 

### effects 

### of PM10-2.5. But we do 

### have studies showing shorterterm 

### health effects

# - spikes 

### in hospital admissions, etc. 

### Comment: 

### But are those studies 

### masking the elevated levels 

### of 2.5 

### particles? 

### EPA: We are 

### not 

### looking at 

### PM10 studies, 

### but 

### PMl0-2.5 studies. 

### Comment: NRCS 

### under 1996 

### Farm 

## Bill said 

### that 

### USDA air quality task force

## will be 

### responsible 

### for communicating

### with EPA on 

### agriculture impacts. Today 

### I hear 

### that you have been 

### doing this 

### in the closet. 

### Did you consult 

### with the 

### USDA taskforce on these 

### PMl0-2.5 standards? 

### EPA: We did have 

### them over 

### to RTPto discuss 

### this 

### review. We do also 

### have an 

### interagency 

### coordination process 

### that occurs 

### during rulemaking.

### EPA: Part 

### of the reason we 

### have concentrated 

### our efforts on the 

### EPA Clean

### Air Scientific



### Advisory Committee 

### (CASAC) is because 

### it is

### difficult to say 

### where 

### we are

### going 

### until we receive 

### their advice. 

### Comment: Once 

### you are 

### in rulemaking, 

### it is over. 

### This administration could get 

### kicked out

## of office 

### in 2 years because 

### of the

### job devastation. $68 

### million in effect supported 

### intensivelyby Browner and 

### Nichols. 

### Looking atsize and 

### speciation. There is transport 

### from Iraq and 

### Iran coming 

### into California. I

## will not support you 

### leaving 

### it up 

### to state agencies and 

### AQMDs to decide

### whatto do

### with rural vs. 

### urban areas. 

### Whatyou are

### doing is

### allowing environmental wackos and 

### good enviros 

### to decide 

### how these 

### decisions are made. 

### EPA: Uncertainties are 

### all being made 

### very clear as

### we dothis. 

### They

### will be addressed 

### in the decision 

### making process. 

### Decisions have 

### not yet been 

### made.

### After we set a standard, 

### by law 

### it is the

### job of the states 

### to implement 

### it. If they 

### fail to do so, 

### then 

### EPA steps 

### in. We do have 

### policies in place 

### for fires and 

### other exceptional events. 

### Comment: 

### But you need 

### to

### work 

### with ARB's policy committee 

### to include agriculture. 

### You can 

### put a 

### monitor on the 

### back 

### of the disc. 

### You need

### towork 

### with agriculture. 

### I want 

### Elvis Graves 

### of 

### USDA to go 

### back, and 

### Iwant ananswer 

## - how is 

### USDA working 

### with EPA onthis research? Because 

### in rulemaking, 

### it is over. 

### EPA: 

### If you 

### look at 

### number 

### of counties 

### (slide I8) 

### not 

### likely to meet current and 

### potential alternative 

### PMl0 standards, 

### we are 

### not 

### looking at a 

### huge increase 

### in numbers 

### of counties. 

### Comment: The top 

### of this range 

### tells methatyou have gotten 

### rid of a

### few 

### highlypopulated counties. 

### Breaking things out 

### by specific counties and 

### regions 

### would be 

### more 

### informative. 

### I suspect 

### that less 

### populated counties

### will end 

### up 

### in violation. EPA: Inthe 

### final 

### policy document, we

### will not 

### only have county counts, 

### but also a 

### listing

## of specific counties. Comment: We have 

### different numbers at standards 

### of 85,

### 75, and 

### 65. (Based 

### on 

### National Cattlemen's study.) Even 

### CASAC admitted 

### intheir independent 

### individual reviews that the 

### causality 

### linking PM10-2.5 fis tenuous]? EPA has disagreed 

### with CASAC before, can do 

## it again. 

### Looking at 2 

### monitors in Pinal County, 

### AZ

## - at one 

### (Stanfield AZ), the summer 

### quarterly average exceeds 

### the 85 

### microg/m3 std

## - they were at

### -86. EPA: We did not ask

### for that 

### monitor for be 

### placed there. 

### We base 

### our data on 

### where states 

### have chosen 

### to put 

### monitors. We may push back, but 

### usually defer 

### to states 

### on 

### monitor locations. 

### We do 

### review whether 

### monitor number and 

### placements are

### sufficient to monitor compliance 

### with all of the 

### NAAQS. Once a 

### monitor shows an exceedance, 

### we can't remove 

### it. Comment: 

### If you 

### put a 

### boundary 

### line monitor on a

### farm, you

## will get an exceedance. 

### I'm talking about 150. 

### The second 

### you start 

### to 

### monitor in those areas, 

### you

### will have exceedances. 

### EPA: National Cattlemen's study chose

### their own method 

### for calculating what 

### would be a 

### violation that was

### different from our procedure. 

### Wewrote a

### detailed 

### letter commenting on 

### that study that 

### I am 

### happy 

### to share.

### Question: 

### Slide 18 

### is broken out 

### by county.



### EPA: Keep 

### in mind that 

### it matters 

### what emissions are

### driving the 

### violations at a 

### monitor. Neighboring counties, nearby urban areas. 

### When we do designations, we

### try to ensure 

### that they are based 

### onwhere 

### contributions are 

### coming from. SJVAPCD

# - Our counties are 

### in a

### unified air district. From an 

### implementation point of view, what 

### would really happen 

### isthat 

### in the southern 

### part 

### of the 

### valley, we

### will have a

### difficult time 

### with the entire range 

### of proposed standards. 

### We could 

### try to break out smaller areas, 

### but 

### I'm not sure

### the 

### California 

### Air Resources 

### Board 

### would go

### for that. 

### ARB: For 

### PM2.5, we 

### did

### try to make smaller nonattainment areas, 

### but EPA made 

### them larger. 

### EPA: 

### If that happened, 

### it was an

### Administrator's decision 

### in the designation process based 

### on the data. 

### Kerry: Original 

### PMl0 standard

### for SJV was 

### laid out 

### in the Clean

### Air Act. When we

### tried to make the eastern 

### part 

### of Kern County attainment, we found that those 

### boundaries were set 

### in the 

### law. Comment: There are

### just a 

### couple 

### of us 

### here 

### in attendance 

### that are 

### producers and 

### farmers. 

### In an area 

### like Artzona, our analysis shows 11 

### counties 

### in nonattainment. We have 

### worked

### with Maricopa County on 

### PMl0, but 

### it is impossible. 

### At some 

### point, we need

### to

## till the

### soil. 'We are 

### not allowedtotreat single 

### monitors 

### differently. We came

### tothetable to

### work 

### with you guys, and 

### you are 

### continuing to ask

### for more. 

### This is goingto be a 

### detriment 

### to agriculture. 

### Only altemative

### will be

### to sell and 

### build houses. 

### Where you have 

### high production agriculture, 

### this standard 

### will wreak havoc. Just as a

### political issue, 

### we 

### can't afford 

### it. We 

### haven't seen 

### the thousands 

### of people lined 

### up at 

### the 

### hospital 

### with problems. 

### Maybe people 

### shouldn't be

### allowed to 

### live in the desert. 

### There 

### is a

### frustration level for those 

### of us

### who have 

### attempted

### to

### work proactively 

### for a 

### longtime. 

### It is going to devastate 

### what we do. Our counties 

### don't have enough 

### money to pave 

### all the roads. 

### We can't afford to

### write the check. 

### Comment: 

### How much 

### of that 

### number 

### (slide 18) 

### is natural events? The process 

### of excluding natural events 

### is a

### difficult one. 

### There are 

### things that

### will not be covered 

### by "exceptional events," such as a 

### recent cold 

### periodwhere state 

### allowed farmers 

### to burn, 

### which put them 

### in danger 

### of a

### violation. It is

### different 

### withwildlife management fires. 

### Also, what happens 

### with tribal govemments? We had a

### tribe place a 

### monitor inappropriately next 

### to an 

### agricultural 

### field and a

### parking 

### lot, so 

### we were unable 

### to freach attainment] 

### until more data

### were gathered

### from an 

### additional monitor. Things could be 

### improved 

### with more 

### flexibility in the exceptional events 

### policy. Some 

### additional events 

### could be excluded, perhaps, 

### especially those 

### that are 

### precipitated by economic hardship.

### EPA: We have heard 

### complaints 

### from westem states 

### for several years on 

### this issue. 

### The EPA 

## Air

office is currently working though a process 

### to make 

### it easier

### to do exceptional events 

### demonstrations. 

### Comment: Shift has been

### toward continuous real time 

### monitoring, which may not be 

### appropriate 

### for either 

### PM10 or PM2.5. 

### SJVAPCD, You have 

### tried to take 

### into account 

### the uncertainty 

### in speciation. We have an issue, assomeone 

### who regularly goes

### to our board 

### with costly regulations, we want to make sure

### that 

### what you present 

### to decision makers 

### is clear 

### in its uncertainties. 

### As a

### public health agency, 

### we want 

### tô make sure 

### our resources are 

### allocated appropriately. We need

### to be able 

### to showthe 

### public, board, and 

### industry that they

### will be seeing 

### health effects. 

### For example, based 

### on conversation today, you have 

### introduced lots 

### of uncertainty regarding the effects 

### of 

### low 

### PMl0 concentrations 

### in rural areas. W'e 

### have adopted a

### policy position to adopt a 

### risk-based perspective, and 

### have advocated also 

### taking a species 

### approach. Our 

### preliminary data shows 

### that we

### will be 

### in pretty bad shape even 

### regarding attainment 

### with the 

### high end 

### of this range (85 

### micrograms). 

### EPA: 

### If you want 

### to see 

### how we 

### lay out the rationale 

### for different decisions, 

### you can

### find that 

### information in the 

### policy document. 

### It istrue that uncertainties are there, 

### but 

### Administrator could make 

### different decisions based 

### on those 

### uncertainties. Comment: We have had 

### nonattainment area 

### in Maricopa County

### for a

### longtime. Things have gotten better, 

### but county is

### still nonattainment. 

### You go

### to Pinal County 

## - last year 

### it exceeded 

### the 150 standard once, 

### but at a standard 

### of 85, 

### we 

### would have exceeded 55 

### times. Farmers are 

### never 

### goingto make the 85 standard. 

### You may as

### well sell 

### your farm and go home. 

### A: Comparison 

### of form of monitoring compliance under current standard and 98th 

### percentile 

### form of proposed standard. 

### Reply: Iwould hopethat given these 

### uncertainties, the 

### EPA

## will err on 

### the side 

### of farmers 

### producing food in the U.S.
Sacramento 

### APCD: Exceptional events 

### standard: 

### It is

### very

### difhcult for us

### to make 

### that 

### work. Policy is put 

### in the hands 

### of a 

### regional staff person, 

### working 

### with lawyers. These issues can 

### last 

### for months and years. 

### Need a

### simplified process 

### that can be 

### worked through 

### with a reasonable 

### amount 

### of effort. In one 

### of my other hats

### working for 

### NACAA, there is a need 

### for efforts to 

### reform the SIP process 

### to reduce the 

### burden 

### of developing plans 

### for all of the 

### NAAQS. Comment: 

### Air Director for Arizona: Lots of uncertainty reflected 

### in setting these standards, 

### but when 

### it comes 

### to implementation, no shade

### of uncertainty is allowed. We 

### in Arizona 

### will be 

### looking at a

### jump from 7

### violations 

### in a

### yearto 27. So 

### we end 

### up 

### in a 

### continuous state

## of

### nonattainment where 

### we are

### trying to make a 5Yo decrease 

### in an 

### inventory that 

### itself has



### uncertainties. Comment: 

### In 

### my former 

### life at

### the South Coast 

### Air Quality Management 

### District (SCAQMD), 

### Mike Laybourn and 

### I brought 

### forth the

### first PM 10 

### dustborne 

### rule

### for farming. As we were 

### going through 

### it, agriculture representatives 

### pointed out that we had 

### missed a

### lot of things. 

### We decided 

### to study 

### it some 

### more, 

### which kept us

### from 

### having avery prescriptive rule that 

### didn't have a great 

### impact a

### few years 

### down the 

### road. 

### If you 

### put controls disproportionate 

### tothe studies and data 

### that you have,you 

### won't get 

### improvements because 

### people

### will walk away 

### from the process. 

### Comment: 

### In 1989, 

### I received a 

### document 

### from EPA Region 9 

### stating that we needed 

### to prepare a

### fugitive dust 

### rule.They had 

### prepared

### this document 

### without science. 

### Document showed 

### that 

### we cultivated an 

### alfalfa 

### field 9

### times per year, and 

### that we 

### cultivated rice

### fields 13 

### times per year.

### They also 

### recommended that on 

### livestock side, 

### it showed 

### dairy cattle

### with a 

### pack harness, and said 

### that you had 

### to not allow a 

### cow to

### walk in more 

### than 1.5 

### in of manure at a

### time

## - you need 

### to cork them 

### off. They showed 

### adairy bull in document, and 

### Mr. Isom asked, 

### how are

### you goingto cork 

### off that 

### bull? Over 

### next

### few fdays] we want 

### youto communicate 

### with Dave 

### White of the

### Agriculture Task 

### Force,202-702-4525.I think that you need 

### to meet

### with the 

### USDA Task 

### Force. Our 

### industry has 

### over 500 

### rules 

### in the San 

### Joaquin 

### Valley. We are 

### going to be sued

### on 

### everythingwe submit. There have been 

### recoÍrmended 

### no-farm/no{i1l days, 

### not even 

### feeding 

### livestock, 

### in presentation 

### to SJV air board. I have no problern 

### with that 

### if we shut 

### the 

### goveÍrment and 

### everyone 

### down, and 

### no one gets 

### paid. Abandonment 

### of farms

## will leadto disease and 

### other problems 

### for farmers that remain. 

### If we 

### don't work this through 

### with the 

### USDA Task Force, things 

### will get 

### politically ugly in the 

### next few months. 

### Comment: One 

### of Manuel's points that 

### is good is the current nature and 

### approach

### of 

### litigating. As these 

### matters are delegated 

### to states. 

### I have a 

### lot of concern that you have a 

### huge gap

### with regard

### to coarse 

### particles. 

### Ultimately states

### will be saddled 

### with much 

### of the problems that are caused 

### by the 

### uncertainty 

### left onthetable. 

### Question: 

### According towhat was presented 

### totheTask Force at 

### RTP 

### in September, 

### the range 

## of standards 

### recommended 

### by CASAC was

### from 65 

### to 75. Based 

### onthat recommendation, 

### [X] additional counties

### will be designated 

### nonattainment. Can 

### you 

### tell me

### what those are? 

### EPA: We

### don't have 

### that 

### information here;

### it

### will be 

### in the

### final staff document. 

### Q: Slide 

### 9: Discussion 

### of number 

### of monitors required 

### by EPA. 

### In

## ** County, Central 

### Valley 

## of AZ,population -300,000, we have 

### over 10 

### monitors. Monitors in urban areas 

### generally show compliance, but 

### monitors in rural areas have 

### problems. 

### No-till days 

## I or 2 days 

### per year, 

### maybe. 

### But you can't farm 

### with 17

### no-till days 

### peryear. We 

### don't get the message 

### fshown on

### this slide] that 

### monitors are 

### placed based on 

### population size and 

### PM10 concentration, 

### from our regulators.

### We are 

### struggling 

### mightily with the

### current 150 

### microg/m3 standard. 

### The proposed standards



### will have a huge 

### impact on us. 

### EPA: V/e can't monitor 

### in 3,000 counties. 

### But 

### if monitors (for which EPA offers grants, and 

### which are 

### under the 

### responsibility of states) are 

### placed and 

### show nonattainment, they 

### can't be 

### removed. Comment: 

### In the 

### Antelope

## Valle¡ farming left there

### for economic reasons, and 

### left a 

### mini-dust bowl. Pinal County 

## - We have 4 

### monitors that were

### violating the 150 

### microgram/m3 standard 

### up

### to 50 

### times peryear, based 

### on

### wind events 

### that are area

### concentrated. 

### If you

### don't ignore 

### windblown dust events, 

### then

### you are

### going 

### to have 

### totell people here 

### that they need 

### tosignificantly change 

### theway they do business. 

### The 

### CAA calls not

### just for a

### primary standard, 

### but for a

### secondary standard. 

### Onefactor under 

### this secondary 

### effort is safety hazards. 

### V/e do have 

### people 

### getting 

### killed in Pinal County on the 

### highways during 

### windblown dust events. 

### Comment: 

### I have 

### adairy in the Santa 

### Ana corridor 

### fin Southem 

### California], and 

### I can 

### almost guarantee 

### you that we

### will be 

### in

### violation from May to November, because

### we are 

### in an area 

### where earth gets 

### moved 

### from one 

### real estate 

### location to another. 

### Being here 

### in the South Coast, 

### if these 

### new standards are 

### implemented, we

### will be out 

### of business. 

### It doesn't make sense

### to me 

### that 

### agriculture is the bad 

### guy and cars are 

### the good guy. 

### Comment: So 

### EPA, your recommendation to the

### Administrator isthat no,

### you can't do 

### it, right? EPA: I

### won't be answering that question on

### what advice we

## will give the

### Administrator. Comment: 

### We've talked about the 

### monitors quite a

### bit.

### At some 

### point, EPA needs 

### to address 

### this. 

### If we have a

### monitor next 

### to a

### dry 

### riverbed 

### in West Phoenix, there 

### ought to be a

### way 

### with sufficient evidence 

### to adjust 

## - move the 

### monitor a 

### quarter 

### mile, or whatever. There ought to be a process 

### that can 

### help 

### to move 

### monitors from inappropriate locations. Question: 

### How many 

### monitors have 

### co-located monitors? 

### A: We have 

### approximately 100 

### monitors that meet the co-located 

### monitoring FRM. Comment: 

### I'm hearing the 

### level of frustration of people 

### in Calfornia so 

### high that they 

### might even 

### vote Republican next 

### time around. 

### Comment: 

### Kerr¡,, 

### I want 

### tothank 

### youfor 

### pulling this together and 

### inviting industry, not

### just the 

### good enviros and the 

### bad enviros 

### who 

### don't eat 

### anything at 

### all except 

### pine cones..

### This is a

### very valuable 

### tool that you have done here. 

### Bill Hamett: Thanks 

### to 

### all for coming.

### Kerry Drake: Thanks 

### to the 

### Inland Empire Public 

### Utilities Agency for hosting. Thanks 

### to 

## Bill

and 

### Scott 

### for their presentations. Our 

### regional administrator, 

### who has

### visited farms 

### with the help 

### of some 

### of you, has 

### always remarked after those 

### visits that he

### wants 

### to

### find a

### win-win scenario.Spokane NAAQS PM 10 meeting March 

### 9,ãOLL
Thirty 

### two stakeholders attended 

### the meeting and 27 called 

### in. ldaho State Department ofAgriculture hosted acall in line

### for stakeholders in lDwho could nottravel 

### to Spokane. 

### Comments: 

# ¡ We have concerns due 

### to uncertainties 

### with science and 

### want EPA

### to keep

### the current standards. 

# o Urban and rural dusts are 

### different. Coarse 

### fractionfrom urban soils isvastly 

### different and should be considered before exceptional events. She prefers keeping 

### the present standard. 

# ¡ USDA-ARS data conflicts

### with EPA 

### estimates. We 

### would like 

### to clarify. 

# o Treatment of exceptional events is a

### concern. EPA needs

### to streamline 

### the process. 

# o There's insufficient evidence 

### for quantitative health assessment or scientific basis

### for lowering 

### the standard 

# o The scientific evidence is shaky 

# o We recommend keeping 

### the current standard 

# ¡ EPA has limited data and monitors, and should gather more evidence before moving ahead


### Follow up: Scott and Bill 

### will send citations 

### forthe studies 

### to Karma

### to send out 

### to stakeholders.


### Questions 

### from Agriculture Stakeholders 

## 1) What are

### the health impacts of a lowered standard? 

## a. EPA: EPA has done aquantitave risk assessment 

### for PM2.5 

### but not 

### for PMl-0-2.5 

## 2l How many new exceedances 

### willthere be

### with the new standards, and where are

### the exceedances? 

## a. EPA: ln

### the Region 10 areawe show no new nonattainment areas inWashington, we show violations of some levels 

### of potential PM10 standards in Pocatello and Boise in ldaho, and in one area of Oregon (Clamath Falls) 

## 3) Bill Schillinger - WSU: The

### tri-citieswould have 

### to be in exceedance. Tri-cities routinely exceed based on

### the last proposal 

### to change the standard

### to 70 ug. 

## 4l EPA: What is being considered is possible changes

### tothe level and 

### formfor PM10 

### but no decisions have been made. The 

### information presented on potential violating areas 

### for different levels andforms of 

### the standard under consideration is basedon State air quality measurements.Will 

### there still be natural event exclusions? 

## a. YesThe natural event exclusion process isvery burdensome 

### to states.



## a. EPA

## - we are working 

### to improve 

### the process prior to the designations 

### of nonattainment areas for 

### the PM NAAQS. There arefew monitors in rural areas. W¡ll EPA expand 

### the monitoring network? 

## a. EPA

### - We 

### will put out guidan'ce on 

### the appropriate places 

### to monitor. The guidance has not changed 

### for PM10 since 

### 1987. lt isthen up 

### to the states 

### to decide whether there is a need

### to make any changes in

### their monitoring networks based on 

### that guidance. USDA-ARS in Pullman has done extensive research on PM 10, and shows a large increase in exceedences if

### the standard is 

### lowered. Brenton Sharrat - Eastern Washington

### / Columbia plateau blowing dust is

### from agricultural 

### sources. With lower standards Spokane

### will have 8 exceedances per year, now 

### there are 2or 3 exceedances peryear. EPA's analysis of

### fewer counties 

### out of compliance doesn't match 

### their research. 

## a. EPA:We'll work 

### togetherto figure out why EPA's numbers and

### their numbers

### don't match 

### but it could be we exclude measurements associated 

### with exceptional and natural events. 

## b. Bill Danworth of Spokane Clean Air 

### Network: The Spokane CAA removes exceptional events, and the 98th percentile takes 

### out a lot ofthe data, most ofthe 

### time we're 

### pretty good

## - Spokane CAA's analysis shows attainment.

Summary Generally, 

### the meeting's attendees were very concerned 

### with every aspect of

### what is even onthe table in

### the review. They were very concerned about 

### the uncertainty about the causal relationship between Coarse PM (PM10-PM2.5) and health effects and 

### felt we should not even consider changing the 

### standard. Their concerns were 

### not resolved by any of 

### the explanation of

### the processor how the uncertainty 

### will be presentedto the 

### Administrator offered by

### the EPA

### staff. We emphasized no decisions had been made but again

### they still were concerned. They also were very concerned 

### that: 1.They believe they would have many new areas as nonattainment under any new standard and 2. We 

### would require monitors everywhere agriculture operates andthus 

### will eventually show allof

### their normal activities show 

### violations. No amount of explanation of our past 

### monitoring rules and general approach 

### to located monitors was sufficient 

### to address

### their concerns.. Where 

### nonattainment isfound and agriculture sources contribute 

### to it, we had discussed

### of mitigation strategies and howwework 

### with USDA, the State and industry in coming up

### with Best Management Practices

### that would be implemented 

### through USDA's programs. They accepted this approach but 

### their concern was the cost impact of any such measures and 

### the effect of

### that on 

### the profitability of 

### their family 

### farms. They believe 

### that costs should be considered insetting 

### the standards not

### just in how you achieve 

### them. We explained how

### the Clean Air Act precludes 

### the consideration of cost inthe setting

### of a NAAQS. Exceptional and natural events came up as

### well. They arevery concerned about 

### the resource burden on states if

### they have a 

### lot more events 

### to get approved becausethe standard is lowered. EPA explained 

### there is ongoingwork 

### to address some ofthese 

### issues. Theywere pleased 

### with this approach but asked s)

6)

7)if any guidance would come out 

### first in 

### draft formfor comment. We 

### told them we were not sure ofthe

exact processwe would 

### follow and

### would check and get back to them.


### Detailed meeting notes: Questions and comments 

### from the room and phone: Q -Joe Anderson, ldaho wheat commission: What effect 

### willthe change have regarding deaths? Will 

### there be morethan one death per? That is, 

### if the standard is lowered would 

### there be more incidents per

### the lowered standard? 

### A-No,any loweredstandardswillbemoreprotective.Thechangeisintheformandstringencyofthe standa rds Q

## - How many new exceedances

### willthere be 

### with the new standards, and where arethe exceedances? A

## - EPA: no areas violating based on 

### current 

### data inWashington, Pocatello and Boise areviolating in ldaho, one area is

### violation in Oregon (Clamath Falls) Comment 

### from professor: the tri-cities 

### would have

### to be in exceedance. Tri-cities routinely exceeds

... Comment: previous ideas 

### for changing 

### the standards 

### to 70 micrograms are not on the table? A

## - EPA:70 micrograms is included in

### the range of consideration 

### forthe 98th percentile

... Q

## - for 365 days howwould it work on average? 

## A- (from Scott on

### the phone) in

### the last review EPAproposed

### to change 

### the level, 

### form *and* indicator. That's not 

### what's being proposed 

### now. Just

### the level and 

### form are being considered 

### to be changed. comment 

## - exceedances aretypically 

### from "coarse" particles.

Q

## - Do natural events and highwind exemptions still stand? Are they still excluded? A

## - Bill says yes (wind, 

### fire caused by lightning, etc.)


### Q- explain PM coarse and

### fine

...

### that is, is2.5 microgram part 

### of PM10? Q

## - alsowhat about wild fires 

### - are they exempt (in addition 

### to fires caused by lightning)? A

## - fine particles are2.5 micrograms and smaller, Particles 

### from 2.5

### to10 micrograms in size are referred 

### to as coarse particles. We are 

### not using a PM10 minus PM2.5 indicator. A

## - Wild fires do qualify asexceptional 

### events. States have smoke management plans in place based on daily conditions, if

### there is agood burn management plan in place then certain prescribed burn events can also be exempted.

Q

## - Cody Easterday

## - producer: some studies show lowered standards do 

### not improve health impacts. 

### Monitors are 

### not in rural counties now 

### but EPA

### will put more monitors in rural areas. A

## - EPA has concerns 

### that the study referred 

### to has problems and isn't credible. EPA 

### didn't do aquantitat¡ve risk assessment (extrapolation air quality 

### to health results) because we 

### don't have a

national 

### monitoring network. There are uncertainties in measuring PMl-0-2.5 

### that way. A

### - We haven't made recommendations 

### for any changes 

### tothe monitoring 

### network but we

### will speak 

### to that in

### the proposal. Comment 

## - if EPA isn't considering 

### putting monitors in rural counties those people are at risk. A

### -Where we have monitors in rural areas under the existing network we generally do not see violations ofthe standards.

Q

## - ls

### there no correlation 

### of PM10

### to health effects? A

## - concentrations 

### of PM10 minus 2.5

## - there's some uncertainty inthe assessment 

### of risk A

## - However, some of

### the health studies looked at coarse particles, they do show health effects 

## A- Most studies are based in urban areas: A questioned 

### to be considered in

### the review is: are rural particles 

### the same as urban particles, do 

### they have the same effects?


## Q- EPA understands Eastern Washington

### / Columbia plateau blowing dust 

### from agricultural sources is 

### the primary source? (Bill Shuttinger and Bret 

### from University of Washington attend a PM meeting every year) they say

### with lower standards Spokane 

### will have 8 exceedances per year, now

### there are 2or 3 exceedances. EPA's analysis offewer countíes 

### out of compliance doesn't match 

### their research. Q

### - Will 

### the state be burdened 

### with paperwork 

### for eachof

### the

### lL exceedances

### that are likely 

### to occur? Even 

### ifthe exceedances are due

### to natural sources? A

## - (Bill) says

### we'll work together 

### to figure 

### outwhy EPA's numbers and

### their numbers

### don't match. A

## - We're discussing demonstration requirements 

### for natural and exceptional events 

### with States Comment (Bill Danworth Spokane Clean 

### Air Network?) 

## - they remove exceptional events, and

### the 98th percentile takes 

### out a 

### lot of 

### the data, most ofthe time 

### we're pretty good

### - their analysis shows attainment.

Q

## - Rick Stott, ICA: Comment:thanksfor this meeting and 

### the opportunity to speak Comment:there's insufficient evidence 

### for quantitative health assessment or scientific basis

### for lowering 

### the standard Comment:

### the scientific evidence is shaky Comment: recommends keeping 

### the current standard Q

## - whojustifies 

### thevalidity, how can EPAjustify? Q

## - with limited monitors 

## - shouldn't EPA gather more evidence? Q

## - at who's discretion is 

### "natural events"? Comment:

### they have concerns due 

### to uncertainties 

### with science and 

### want EPA

### to keep

### the current sta ndards.A

## - there are more studies 

### for some pollutants (fine particles, ozone, etc.) and

### there are studies showing

health effects for coarse particles (PM10-PM2.5) but there are lessof

### them

. A

## - EPAsolicits studies and uses peer reviewed and credible 

### studies. They summarize them and they are reviewed by the Clean Air Scientific Advisory Committee, an independent outside body of scientists. A

## - State and local authorities document natural exceptional events 

### for exclusion when considering 

### whether an area meets 

### the standards. EPA is looking at ways

### to make 

### the process and documentation less burdensome 

### for the states.

Q

## - (Congressman's representative) Your promise not

### to expand 

### monitoring isn't credible. Standards should be set using current monitoring system. Agribusiness operates on 20-30 year plans

## - a 5year plan doesn't work well 

### with that system.

Q

## - Wyatt Prescott, lD Cattle Association: ldaho Cattle Association has grave concerns.
- Health effects are "associated 

### with"

... -EPAdismissesthe fact

### that there is

### *no* quantifiable evidence

- No studies providing evidence

- EPA health studies do not correlate hospital data directly 

### to PM

- European studies show rural kids have less asthma due 

### to dust and exposure 

### to animals

- EPA is proposing 

### to increase asthma and health impacts 

### with lowered standards

-

### there will be asignificant cost component 

### to lowering standards Comment: only 2counties in ldaho and none inWashington

## - adding monitors in rural areas 

### -you'll target farms and ranches as sources of dust 

### - target painted onfeed lots and farms 

## - no 

### comfort in EPA assurances of 5year horizons due to generational nature of farming and agriculture 

### - Arizona and California events in non-attainment due 

### to exceptional events... A

## - There are uncertainties andthese have been 

### identified in

### the draft EPA policy assessment, but we 

### *do* have evidence 

### of health effects due

### to PM10-2.5 (isolating PM10-2.5 

### from other pollutants). There's more evidence in urban areas but 

### there is some evidence 

### for PM derived

### from rural areas Q

## - (phone)

### will EPA consider 

### the New England Journal 

### of Medicine study? A

## - Research cut 

### off in 2009. Current studies are looking

### at PM 10 minus 2.5 for this standard. 

### lf important new studies are published, we could consider 

### them. lf new studies are submitted for the record when we propose 

### the standardwe

### will consider how best 

### to address 

### them and may take the study

### to CASACfor 

### their input A

## - No decisions have been made 

### to change 

### monitors. Comments 

### will be are hearing 

### will be considered in making

### that decision.


## Q- Ben Barstow, Washington Association of Wheat Growers: I had grave concerns walking in but then was more at ease after 

### the presentation, and now hasconcerns about changing 

### tothe 98th percentile 

## - currentlythere are about 7 days of exceedance, using

### the 1 in 6 days means usingonly 51 days ayear 

### of

### monitoring

...

Q

## - observation: 

### treatment of exceptional events is burdensome

### for state & local. Consider 

### putting out guidance 

### to streamline exceptionalevents 

### *before* the rule is posted. A

## - We areworking 

### with western states 

### to addressthis issue now, even beforethe 

### draft document goes 

### outfor comment. Q

### - Jerry Snyder,

### farmer, rancher, 

### fourth generation: There isway 

### too much confusion 

## - we 

### don't make decisions based on confusion. Dr.Anne Kennedy looks at dust and 

### dirt on the Columbia Plateau.

Dr Kennedy: Urban and rural dust are 

### different. Coarse fraction 

### from urban soils isvastly 

### different and should be considered before exceptional events. She prefers keeping 

### the present standard. Q

## - (phone

## - United Grain Producers?) 

### monitoring: is EPA looking 

### for funding 

### to add more monitors 

### to get more data? Why put 

### them in rural areas ifthere's no evidence 

### of health effects? Q

## - (Robert Blair, ldaho grain?) Comment: mandatory review every 5years, uncertainties

## - why, ¡fthere is no intent 

### to do something, are you proposing 

### to make achange? A

## - This meeting is

### for direct input 

### from you, 

### from stakeholders. No decision has been made on

### either the standards or any changesto 

### the monitoring network. All ofyour comments

### will be part of

### that decision. 

### Comment: The 

### intention

### to not put monitors 

### out is not credible. The uncertainties make EPA's decisions less credible. 

### A- EPA has made no decisions.

Q

## - (phone, 

### from Yakima?)

-

### they monitor 

### for PM10 and are in non-attainment despite no exceedance 

### for L5years

-they've done dust control 

### for construction andfeed lots which controlled 

### for PML0

-takes years

### to get 

### out of non-attainment

- agricultural area like theirs, PM 2.5 is a costly experience, 

### they're focusing on PM2.5 now


### - hoping standards 

### will remain asthey are now
BREAK Bill: would like

### to explain howthe system works today if

### you're in a non-attainment area:

- Governor proposes how

### to address

- all areas 

### with violating monitors must consider 

### what is contributing 

### to the exceedance

-

### the state must come up

### with a plan on how

### to reduce emissions



### - mobile emissions, weather conditions, etc. are considered

-The state

### will speciate 

### the PM

### to see

### what compounds are driving higher values.

-They 

### willwork 

### with emission sources on how

### to reduce 

### their emissions (USDA and states work directly 

### with Agriculture sources ifthey are determined 

### to be significantly contributing 

### to nonattainment)-

### after 3years of clean airthey can submit 

### their plan 

### of hothey will 

### formally put the area in 

### attainment

through different control strategies. EPAsummarized some key concerns they 

### thought they were hearing 

### to be sure it was correct:- there's a strong concern about uncerta¡nties about health impacts of coarse particles

- concern over urban vs rural sources and how they should be treated

-strong belief

### that there's no need 

### to change 

### the standard

Q

### -Bill Shillinger, WSU: We did a 

### literature review

### of health effects of coarse PM

## - plenty 

### of problems

### with studies and no strong evidence 

### for coarse particles A

## - there are several more recent larger 

### multi-city studies

- Peng et alshowed significant association 

### with hospital admissions 

### for cardio events and PM (and positive non-signifícant association 

### with respiratory admissions)

- another study showed significant association 

### with deaths

-smaller studies also now available Q

## - will EPAsendthose citations? A

## - EPA 

### will sendthe studies via Karma Q

## - KarenWood, Washington Dept. 

### of Ecology:

- PM10 

### monitoring has been a 

### low priority and has been reduced by about 50%

- exceedances due tofires do 

### not count

### for the standard

- State and EPA is a partnership but 

### the state pushes back and expects resources 

### to help 

### implement sta nda rds

- paperwork load 

### for exceedances is

### still burdensome

- high dust events are now easier 

### to detect

-Washington doesn't have much concern over dust Q

## - Cody Easterday, producer:

- kudos

### to Karen andthe state

- he 

### doesn't believe 

### that EPA isshowing

### the science

- rural America is under the

### jurisdiction of EPA
- how does 

### the science show 

### that there should be more monitors?

- he wants EPA

### to keepthe 

### current standard A

## - the monitoring network is designed 

### from evidence and

### to be sure 

### it iscomplete enough 

### to protect 

### the public 

### health. Please continue 

### to comment when 

### there is a public hearing. Q

## - Larry Bishop, Oregon Wheat Growers League:

-

### we'd all like

### the standards 

### to remain

### the same

-science is not conclusive

- science cantake standards 

### to an extreme and 

### would eventually make everyone 

### out of complianceA

## - uncertainties in science

### will betaken

### to the Administrator 

### for decisions

- independent scientists acknowledge uncertainties but still see cause 

### for concern. Q

## - researchers acknowledge uncertainties, 

### that reinforces 

### the need

### to keep

### the standard 

### the same A

## - Draft policy assessment takes uncertainty into account andjustifies keeping the standard 

## {Rmaking 

### it more stringent. Q

### - Jerry Snyder , producer and WA State Grange rep:

-thanks 

### to Scott

### for *not* giving yes

## - no answers

-thanks

### to Karma

-

### there are researchers in

### the room

### to help 

### with the uncertainties

-thanks

### to Bill

### for "taking 

### it" (looking like a porcupine)

- some things

### that were previously considered harmful are now considered helpful

## - for example phosphate in Canadian

### water is increasing Salmon population

- suggests reviews every 10 years in order 

### to do 

### better research

- 

### better for

### job security A

## - if

### there are 

### influential new studies they can be considered 

## - EPA hasthe option 

### to go back

### to CASAC 

### for review and decision

Q

### - Thanksfor 

### the opportun¡ty 

### to address

### the issue

-

### there are differences in sensitivities among 

### the population

- does lowering standards lower the effects on sensitive populations? A

## - there is a regulatory impact assessment

### for cost in lowering standards. Generally the standards under consideration inthis NAAQS review and all

### other NAAQS reviews 

### will addresswhether 

### there is a need 

### to have more protective standards 

### to reduce health effects and 

### will estimate what those benefits are 

### fr each alternative.


### Q-The abilityof Oregon and Washington 

### to be in compliance hinges on 

### naturalevents policy

-states are burdened byshowing best management practices

-funding 

### for research 

### to demonstrate BMP is less

- questions ability 

### to show 

### that this area

### will be able

### to show natural events 

### for exceedance

-

### will we be able

### to make comment on 

### that policy? A

## - B¡ll

### will check but thinks so

Q

## - íf real science isn't funded how canwe provide information 

### to decision makers (zerofunding)

- how dowevalue that?

- all grants, earmarks, have been zeroed 

### outQ

## - Best management practices

- everyone wants

### to keepthe 

### dirt on 

### the land

-

### what's EPA doing on best management practices (B MP)

### for agriculture soils?

- are

### there dollar resources

### for BMP development? A

## - USDA does

### the research

## - EPA supports 

### their research but funding is not automatic 

### Q- is EPA helping producers 

### to implement BMP

### for non-attainment? A

## - EPA works

### with the USDA and states but 

### it does 

### not have

### the hands on experience or expertise on application of appropriate BMPs. Comment: Jeff Tee: he is afamily 

### farmer and has afamily

## - notes 

### that lack offood is creating unrest around the 

### world. His responsibility is

### to feed America and 

### to feedthe 

### world, and 

### to support his family while doing so, and

### to protect 

### the environment in order 

### to keep doing so. He's 

### frustrated about rules 

### that constrain hiswork.

-there's inherent distrust between regulated community and EPA

-

### willthe common sense exhibited atthis meeting be translated at headquarters?

-wants

### to do 

### it profitably and environmentally soundly

- urges EPA

### to leave

### the current standards in place A

## - Bill says 

### towrite 

### to him if 

### implementation is not showing common sense
- EPA needs these comments 

### to do good

### work

Q

## - Robert Blair, lD Grain Producers: There should be an economic component while considering the data A

## - it's

### written into law 

### that cost is 

### not considered in

### the setting of 

### the NAAQS..

Close Bill

### - Thanks

### to everyone for taking this time 

### to meet and

### to comment. Thanksfor 

### the concern and input. Karma

### will keep

### them informed. Karma 

### - Thanks also

### from Region 10 and continue 

### to send concerns 

### to her.

### last Name First Name 

### Organization Signature 

### ofAttendance

Anderson Robert Nebraska Cooperative Counci I Balvanz Carol lowa Soybean Association X 

### Bettin Tyler 

### lowa Pork Producers

### Æsociation X Bohuslausky 

### Victor Nebraska Soybean Board X Brunkhorst Kelly Nebraska Corn Board X Claghorn Karey 

### lowa Deputy Secretary 

### of Agriculture X 

# M

Dux 

### lordan Nebraska Farm Bureau X 

# luL/
Easterly l-homas 

### lndiana Dept 

### of Environmental lVlanagement Erdman Philip Office 

### of Senator Mike Johenns Fisher 

### lohn Ohio Farm Bureau Floss Craig lowa Corn Growers Association Formica Michael 

### National Pork Producers Gangwish Duane lowa Cattlem en's Association Gebhards 

### Mark lllinois Farm Bureau Gieselman Wayne lowa 

### Department 

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### - DC X 

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### Organizatlon Attending Signature 

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Gruenhagen Christina 

### lowa Farm Bureau Federation X 

# xuHolmstead Bob Office 

### of Senator Ben Nelson 

### Kliment Barbara Nebraska Sorghum Board Koch Kristen Nebraska Cattlemen Association X 

## ()

,

# #= 'È: Licht Alice Nebraska Agri-Business Linder 

### Mike Nebraska 

### Department 

### of Environmental Qualitv X 

# uffiX*'a t5o 

## Þ

I¿{cn Office 

### of Senator Chuck Grassley X 

## ëú,f., t(cçn*,.r' 

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# 'iMoreland lohn Office 

### of Senator Tom Harkin X Paap Kevin 

### Minnesota Farm Bureau X 

# l{';Y+
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### Minnesota Farmers Union I
Pielsticker Kathy Wísconsin Dept of 

### AgTrade & Consumer 

### Protection Preister Don Ratajczyk Craig lll inois Soybean Association Rempe Jay Nebraska Farm Bureau X Schaneman Royce Nebraska

### Wheat Board X 

# {,* JL^.-* Schneider Shelley NDËQ X 

# {,!',, 

# : O¡¡.¡å 

# L,þ*-@ qr1,,^ t-=.'if 

# tr

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## L*t*ye

Jeff Agribusiness Association 

### of lowa 

## Y 

# RSearles Lee 

### lowa Envirom ental Cou ncil X 

# þs;!., Villwock Don 

### lndiana Farm Bureau 

### Vinchattle Kevin 

### lowa Poultry Association X 

# f-qVJdþ* Weinzierl Rodney 

### lllinois Corn Growers Association 

### Whitaker John USDA Farm Service Williarnson Dayle Office 

### of Senator Ben Nelson X 

## "bo¿,

# /)tlito^,.-*,- Wood Wayne Michigan Farm Bureau 

## v
Zimmerman Paul Wisconsin Farm Bureau

### lâst Nãme First Name 

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### Attending Signature 

### ofAttendance

Boerner Ben Texas Grain and FeedAssociation Bates 

### Mike Arkansas 

### Department 

### of Environmental

### euality X 

# h,:l^kf,^ Bragg lay Texas Farm Bureau Brundage Robert 

### Missouri PorkAssociation (CNSL) X 

# lrn",., Rick KDHE 

# ay'ø^l"/ Carroll Jim Dairy Farmers of America 

### Government Relations X 

# &* û*-M
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### Marvin The 

### Poultry Federatíon 

## /
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# a//ø¿t¿ Dillon Corey Offìce 

### of Claire

## McCaskiff

# ^ dr/.y Dukes Cory Office 

### of Claire

## McCaskill '

# W Ferrell Shannon Oklahoma Cooperative Extension X Gabelmann 

### Margaret Office of Senator Jerry Moran X 

## /{/ Goldberg Natalie New 

### Mexico Extension Service Graves Elvis USDA 

### - DC X Hampton Joe Oklahoma Grain and Feed Association Harrell Ron Louisiana Farm Bureau 

# Jolt,rl W*oÂ-p,|,( 

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### TtOreanization 

### Attending SiEnature 

### of Attendance Harries Aaron Kansas Association of 

### Wheat Growers X 

# ûr, ¡1 

# /Tt""L,t Hatch Peggy Louisiana 

### Department of Environmental 

### euality Hawkins 

### Garrett Missouri Farm Bureau X 

### (additional) Hay 

### Iodd Missouri Farm Bureau X 

# Ø#.%¿Z Heinrich Craig Plains 

### Cotton Growers Henry Dalton Kansas Association 

### of Wheat Growers X 

# Yfr-$1,

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### SusanS fexas Commission 

### on Environmental

### euality X 

# ffiTLX
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### (additional) 

# 4-rlK

Jackson Bill Agri-Servi ces

### of Bru nswick X 

# \Ñì-N'{\ Johaness Kenlon Kansas Soybean Association 

# t

, Kavanaugh Jim MDNR 

# x!* 

# éiL&, Klippenstein Brian Office 

### of Senator Roy 

### Blunt X 

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# )
,

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### lvory Arkansas Extension Service 

# rts \)
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### Environment Department Masters 

### lerry Arkansas Pork Producers McFarland 

### Mark TexasAgri-Life

### last Name First Name 

### Organization 

### Attendine S¡gnaturê 

### of Attendance



### Minton Davis Ag Liaison MDNR 

### x 

## ,-- 

## =\ / Nikodim Don 

### Missouri Pork Association 

### x Nolan Cheryl Louisiana 

### Department 

### of Environmental eual 

### ity Peek Marla Oklahoma Farm Bureau 

### x 

# a/t-".de{
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### Peteæen€oaæl+in*

# h

# NZ"*l &w.c.t X 

# tllw

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### Moran X 

### (additional) 

# fr

# nÆl

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### lm Oklahoma 

### Department of 

### Agriculture 

### & Forestry 

## ./---"

Schulte Sue Kansas Corn Growers Association X 

### (additional) Sharp Kay Office 

### of Senator Pat Roberts X 

# ffr* Sporcic 

### Mike USDA-NRCS X Stankiewicz Mary Jane Grain 

### & FeedAssociation 'S Staples Todd Iexas 

### Department of Agriculture Strain 

### Mike Louisiana DAF Stroda Tim Kansas Pork Association X Swaffar Steve Kansas Farm Bureau X Teague Evan Arkansas Farm Bureau

# ,./-ó*ot.- 

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### Attendine Signature 

### of Attendance Terrill Eddie Oklahoma 

### Department 

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# Ç/1,

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### Department of Environmental 

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### uhl Mary New Mexico 

### Environment Department Vickery 

### Mark Texas Commission 

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# ?r¿g-e-*# Weinheimer Ben Texas Cattle Feeders Association X 

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### Meeting

Name 

### Title Agency City Washington 3alled i Attended
Dan Newhouse Director WA State Deparfment ofAg Olympia laclyn Ford Policy Assistant to the Director WSDA Olvrnpia JFord@aqr.wa.gov Brenton Shanat Research Unit Leader USDA-ARS Pullman Brenton. Sharratt@ARS.USDA.GOV I Ann Kennedv Resea¡ch Scientisl USDA-ARS Pullman akermedv@cahn¡s. wsu.edu 1 Bill Shiìlinger WSU Professor USDA-ARS Pullman schillw@wsu.edu I Brett Blankenship President Vy'AAssociation o Wheat Growers Washtuca 4brettb@email.com I Ryan K¡egqer WA V/heat Grower WAWG rkresser@oocketinet.com I Eric Maier State legislative Chair WAWG Ritzville maier@ritzcom.net 1 Mary Paìmer Sullivan WA Crains narvØwasrains.com I Ben Barstow WAV/G barstow@talouse.com 1 Jerry Snyder WA State Grange Wheat grower isnvder@ritzcom.net I Ron Jirava Wheat grower iiravalôwawe.ors I Roylene Rides-at- ;he-Door State Conservationist WA Natural Resources Conservation Serr¡ice Spokane
Rich Edlund Actine SRC WA NRCS Jpokane Richard. Edlund@wa.usda. eov Stu Clarh Air Quality Program Manager WA Deptof F.cnìnov )lympia Robin Priddy Executive Director Benton Clean Air Aç¡e.ncv Kennewick r¡ri@bcaa.net Ma¡k Asmundson Director Northwest Clean Air Asencv Mount

Vernon
Frank McNair Executive Director Clympic region Clean Air Agency Clympia

Mark Moore Puget Sound Clean Air Agency Seattle mark.moore@orcaa,org Roben Elliott Executive Director Southwest Clean A ir Âoen¡rr VancouverPM NAAqS 

### Meetine

Name 

### t¡tle Agency City Washington Called Attended William Dameworth Executive Director Spokane Regional Clean Ai¡ Agency Spokane WDarneworth@spokanecleanair. org I Gary Piruitt Executive Director Yakima Regional Clean Air Agency Yakima

Hasan Tahat, Ph.D. Yakima Regional Clean Air Agency Yakima Dr. Nichole Fmhertson Resource Coordinator rvVhatcom CD Lynden NEmbertson@whatcomcd. org George Boggs Director \ilhatcom CD GBoggslE whatcomcd.ors Dr. Pius Ndegwa Western Region Odor&Air Quality

Coordinator WSU Pulhnan ndegwa@wsu.edu Dr. Joe Harrison Nutient Management Specialist WSU Puvallup Ted Sturdevent Director WA Dept 

### of Ecologv Clympia Karen Wood Air Quality Manager V/A Dept ofECY Karen. wood@,ecv. w a.gov Michael O. Finley Business Council Chairman Confederated Iribes of the Colville Þ ecerrrqfinn Nespelem Harry Smiskin Chair Yakama Nation Toppenish
Kris Ray Ai¡ Resource Specialist Confederated Tribes of the Colviìle Rcservqfinn Nespelem

Noelle Saluskin Air Quality Specialist Yakama Nation Toppenish Ed Field Executive Vice Presidenl ìùy'A Cattlemen's Association Ellensburg -'d@wafeeders.ors Cody Eastrom Droducer ;ody@easterdayfarms.com lohn Stuhlmiller Director of Govemment Relations WA Farm Bureau Lacey Don Jacobs WA Farm Bureau Diacobslôwsfb.comPM NAAQS 

### Meetine

Name 

### Title Agencv City Washington Called i Attended Mike Sheìby Executive Director Western rrVA Agriculture Â.ssnniatinn Mount

Vernon Jay Gordon Executive Director WA Dairy Federation Elma
Mark Clark Executive Director WA Conservation Commission Olympia MClark(@scc.wa.gov I lim Fitzgerald Executive Director Far Vy'est Agribusiness Ascnciafinn Spokane
Iravis Gibson Agribeef Moses Lake ravis. eibson@ aeribeef. com BarbaraQuick Agribeef Moses Lake robbie ouickØ.aeribeef. com I Mike Poulson Staff -ongresswoman 3athy McMorris Rodgers walfØbossie.com I feff Schibel oroducer Odessa sfi@odess¿ofïìcc.cano I leff Tee I 

### Idaho Celia Gould Direclor lD Dept ofAe Boise I Brian Oakev DeÞuty Dircctor ID Dept ofAe Brian.Oakev@asri.idaho.gov I Jeff Burwell State Conservationist ID NRCS Boise leffery.B urwell@id.usda.gov I Charles Lyons President lD Cattle Association Boise I Rick D. Keller Executive Vice President, Chief Execrrtive Officer lD Farm Bureau Pocatello Kent Lauer & Dennis Canatooney I Chief J.Allen 3hair Coeur d'Alene Tribe Plummer Jennifer Porter Chair, Tribal Counci; Kootenai Tribe 

### of fdahn Bonners

Fe:ru McCoy Oatman Chairman Nez Perce Tribe of Idaho LapwaiPM NAAQS 

### Meetins

Name 

### Iitle Agency City Washington Called Attended Nathan Small Shair Shoshone-Bannok Iribes Fort Hall Martin Bauer, A,dministrator Air Quality Division ID Depafment Env. Oualitv Boise Lester Higgins Air Quality Manager Coeur d'Alene I'ribe Plummer Kevin Greenleaf Environmental Manager Kootenai Tribe 

### of Idaho Bonners

Ferrv Julie Simpson Air Quality Program Coodinator Nez PerceTribe rf Idaho Lapwai i_ulies@nezperce.ors I Lori Howell Acting Air Quality Manager Shoshone-Bannok l-ribes Fot Hall Ieff Tee Idaho Grain Producers Assoc. farmer ¡eeZIÙ2@aol.com Ioe Anderson D wheat Commission loeand@ootlatch.com Robert Blair lD Grain Producers farmer þleufarnas@aqri star.net Sid Smith ¡taff Sen. Jim Risch rrd srnithrisch.senator.qov {aron Calkins Regional Director, Cong. Raul Labrador aaron.calkins@email.house. gov I Keith Esplin Executive Director lD Potato Growers Association Blackfoot Rick Waitley Hay growers Roger Batt Idaho Eastem Oregon Seed Assoc, Amber Rand Actinq Air Quality Manaqer IDEQ Amber. Rand@deq. idaho.sov Don Dixon Special Assistant Mike Crapo's rffice Don Dixon@crapo.senate. qov Nate Rieeers Nez Perce Prairie srass srowers nateri ggers@ gmail. com Ron Parks- Idaho Cattle Assoc. I Rick Stott. Idaho Cattle Assoc. Wyatt Prescott Executive Vice President Idaho Cattlemen's Association Boise Robert Braun , Amalgamated Susar Iravis Jones Executive Director ID Crain Producers Âssocietion Boise Ij ones@Idahograin-orgPM NAAQS 

### Meeting

Name 

### Iitle Agency City Washington Called i Attended Bob Naerebout Executive Director Idaho Dairymen's Association Iwin Falls Roger Batt, Idaho Eastem Oregon Seed Assoc. I

Sarah Schmidt, Administrator ID Soil and Water Conservation Commission Boise Sara. Schmidt(@swc. idaho. gov I Benjamin Kelly. Nez Perce Prairie Grass Grower¡ I 'at Barclay, ldaho Commerce on lndusûy and Environment I Dennis Tanakuni, Idaho Farm Bureau I Brent Ohlmsted, Idaho Milk Producers Assoc. I Rick Vy'aitley. Idaho Food Producers Association I Dar Ohlberdins. Idaho Grain GrowersAssociation I Oregon Katy Coba Director ODA Salem Ron Alvarado StateConservationist ORNRCS Portland lennifer Zwicke OR NRCS Portland iennifer.zwicke@or. usda.gov I Andrew Ginsbure Air Quality Division Administrator OR DEQ Portland 0 Merlyn Hough Director Lane Regional Air Protection Agency Springheld Kay Teisì Executive Director OR Cattlemen's Association Salem Kathr¡,n Walker Program Director OR 

### Daþ Farmers Association Portland
Doug Krahmer 3hair OR Soil and Water Consewation Commission St. Paul

Mike Gamroth A.nimal Sciences Extension Specialist OSU CorvalisPM NAAQS 

### Meeting

Name 

### Iitle Agency City tÂlashington Called i Attended
Elwood Patawa Chair, Board of Trustees Confederated Tribes of the Umatilla Indian Rccerrrqfinrr Pendleton

Jack Butler Air Quality Specialist Confederated Tribes of the Umatilla Indian Þ ecerrrafinrr Pendlelon Larry Bishop Oregon Wheat Growers I-easue bishoollôwwics.com I Dave Dillon Executive Vice President Oregon Farm Bureau Salem Oraig Reeder CR Wheat growers [-eagr re :reeder@,hale-co.com Darren Padget President f,R Wheat growers [,eaqrre Padget@hughes.net Raymond Tyson 3R Wheat growers [,easlle ;ysonraymond@,yahoo. com Walter Powell SR Wheat growers f .eaq¡re lewisnlee@gmail.com Sally Ckistensen CR Wheat growers I paone sch¡ist@.owel.ors AK Alice Edwards Director ofAir Quality Department of Environmental Conçervrfion Iwreau 3indy Heil, Air Quality Program Manager Department of Environmental Conservation Anchorage, 

### Resional

Adam Chambers ' Air Quality and Atmospheric Change Team NRCS \ù/est National Technology Qervice ôenfpr Portland Adam.cha mbers@oor.usda.sov L
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