MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

JAN 2 3 2013 OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

SUBJECT: Memorandum dated May 26, 20 II titled "Input from Agriculture Community on 

Review of Particulate Matter National Ambient Air Quality Standards" 

FROM: William T. Harnett, Associate Director Is/ 

Program Integration and International Air Pollution 

Office of Air Quality Planning and Standards 

TO: Docket No. EPA-HQ-OAR-2007-0492 

The attached memo was prepared before the closing date for the above referenced docket. It has 

not been altered since the date of signature on the memorandum but it was inadvertently not 

physically lodged in the docket at the time of signature. 

Internet Address (URL) • http://www.epa.gov 

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UNITE D STATES ENVIRONMENTAL PROTECTIO N AGENCY

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 of the 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 of the country. At each meeting, agriculture

community representatives expressed appreciation for the opportunity to learn more about what

the current status of the review of the 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 of the 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 of the 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[

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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 of the 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 in this 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 about whether there are risks

associated with this fraction or if health risks actually are from PM2.5.

The third issue raised was the lack of a risk assessment for coarse particles. Participants

pointed to this 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 in this 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 to the 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 on the 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 to the 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 on the 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

how the standards should be implemented. I would 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 of the 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 discretion to 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 evaluate the 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 the way they are used to

char acteize health effects.

- Follow up question (Kurt Blase, Coarse PM Coalition) - what is the 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

evaluate whether the standard needs to be revised. The quality and

uncertainty of the studies that Scott described are highly germane to this

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 is the 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 is triggered by monitoring high values, but they can

be excused by "exceptional events," which are things like wildfìres 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 is the

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 is that 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 the way 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, as opposed 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 the West 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 the West 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 (Tamara Thies, 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 County to 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 long term 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 5 year mark

from the 2006 revision so 2011 is our goal, but it is ambitious. There is no concrete schedule

currently planned.
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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 and the status of the current PM review.

Question and Answers and Comments

Q. What is CASAC?

A. The Clean Air Scientific Advisory Committee (CASAC) provides independent advice to the EPA

Administrator on the.technical bases for EPA's national ambient air quality standards. CASAC addresses

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

the CASAC also 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 Office forms ad hoc committees and panels on

environmental science topics, as needed. Chartered SAB members chair SAB committees and panels.

Draft advisory reports prepared by committees 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 Policy Assessment, they recommended that the NAAQS be

revised to the lower part of the range presented by staff in the draft Policy Assessment.

Q. Locations of Monitors in MO and KS?

A. Maps were prepared by EPA and provided as a vísual.

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 is an additional monitor in Cedar Bluffs, comprehensive monitoring site for background air quality

in KS.

PM monitors are located in Topeka, Chanute, Linn County, Wichita, and Dodge City
The KS Monitoring Strategy is reviewed/revised every 5-yrs and submitted to EPA for approval. At this

point it does not look like they 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 counties throughout 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 - "are the 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 KS at 75 ptg/m3 and did not see any violations.

Q. Can you be more specific for MO?

A. Jim K. - MO did a quick review and found 3 counties would be in non attainment: Buchanan, Jasper,

St. Louis.

Q. Allie Divine - NationalCattlemen's Beef Association (NCBA) conducted a study/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 with their 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 how they 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 in the 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 in very 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 I study)

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 have the greatest

impact (i.e. PM fine)

C. Last week 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 of the farming community.

Q. lf l'm a farmer and I have neighbors complain about the dust when l'm tilling my fields, will the state

put a monitor along my property?

A. The state has a process to deal with complaints. There is a difference between nuisance dust and a

NAAQS violation.

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 any weight 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 information to 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 8 Administrator Jim Martin.

lntroductions were made by attendees 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 is working on the policy

assessment. EPA intends to make a proposal early this year for PM10, and finalize 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 has approximately 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 a dozen 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 a dozen 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 a quarter of the monitoring sites are operated by the state,

and the rest are operated by industry. We are seeing more monitors in the southwest portion of the

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, and whether or not

new monitors need to be installed. They will take into account population size, as well as whether or

not they will see a high concentration in the area. EPA and the State will jointly 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 in the final

monitoring rule. The last time the rule was revised, the number stayed the same (at 100,000).

. Gary Teague, Teague Diversified, lnc.: Can you tell us by state where to go to get current air

quality data that is collected?

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 keep the current

standards as they are. Mr. Wogsland shared a letter with the group that the ND Governor sent

to the Administrator. The ND Governor is taking the lead in talking 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 in the toxicity in differences 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 is acknowledging uncertainties, and is including it in documents we

are producing.

o Dan Wogsland, North Dakota Grain Growers: As EPA promulgates these Rules and looks at the

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 to the Administrator as she makes her

decision. ln the 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 not want to throw urban

farmers under the bus. lf the standards were changed, then no one farming 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 network for coarse particles from 2.5 to 10 microns in size, so we take 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 a credible

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: lf we cannot do a credible risk

assessment of coarse particles, how can we contemplate tightening the standards as much as

double to address a health risk we cannot quantify?

EPA can 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. ln the 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, as well 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 as strong as some other pollutants we set standards for. All of this information is laid

out in the draft policy assessement. There is more uncertainty for coarse particles, than for fine

particles. All of this is considered and weighed in making decisions.
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Denver, CO

March LO,201,l

o lvan Steinke, Colorado Livestock Association: ls there a difference 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 a way to get at this 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 and fund these ongoing issues. ln the

integrated science assessment there have been links between coarse particles of a variety 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 in the 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 is going 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 for the Docket). ln urban areas

these particles fall out from Texas to North Dakota. Look at the life expectancy, and farmers

have been in these areas. You cannot harvest a quality crop without dust. There is no

evidence that it isn't coming from around the globe. What do we want in this 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 EPA still wants these

orchards as buffers. Where do you want your food to come from? Do we want to import from

othercountrieswheretheydonothaveasstrictastandard? Particulatesdon'tjustgointothe

urban areas, look at the life expectancy. Just as ND Wheat Growers invited EPA to come to their

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, as the 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 is only suggestive of health correlations from increased PM. lt did say in the

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 for
Notes 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 the Weight of Evidence

Framework for causality. The judgment 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 is coming from a rural area. We are finding that when dust comes from a rural

area, it is a wind storm coming in over the desert bringing in high concentrations of crustal material over

a city 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 more toxic 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 National Ambient Air

Quality Standards. EPA is relying on modeling to determine where future monitors may be placed. lf

folks have concerns as we move forward, they will have a chance to comment on the rule.

Comments From the Phone -

o Director Ron deYong, Montana Department of Agriculture: 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 are finding at this time in states like Nebraska and lowa is that the nonattainment

areas are associated with cement plants and quarries at the current standard. The State agency could

tellyou if there are currently areas like quarries resulting in non-attainment areas.

Scott looked up the information for 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 we went 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. No farmer goes out to make dust. When Mt. Saint Helens
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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 was the 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 in the short term; however, it doesn't last long time periods. What is difficult is trying 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 say where 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 of the

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 a substantial range.

lf we take all data in the U.S. and parse out data east of the Mississippi River versus west of the

Mississippi River, we have found 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 on this subject. ln the second draft policy

assessment EPA will do more characterization of regional variability. When we do the final we will

address the regression line, and it will be broken out by region in the equivalent concentration section.

It is really not that different around the country. lf you 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 attainment would not violate 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 of Agriculture in developing best management practices (BMPs)for reducing
Notes for Region 8 Particulate Matter 10 Meeting

Denver, CO

March tO,zOtL

emissions. This process is usually coordinated with state involvement as well as USDA, with industry at

the table.

¡ Dr. Brock Faulkner, Colorado Livestock Association: You mentioned that at the 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 be justified?

The Clean Air Scientific Advisory Committee (CASAC) and the EPA policy assessment evaluate if the

retention of current standard reasonable. lt is an option, and is one that will be presented to the

Administrator with the others, as well as the data. EPA will be changing the form of the standard if it is

determined by the Administrator to be appropriate. We look at a single evidence base when

considering the current and potential alternative standards. Compared to the evidence for fine particles,

the evidence relevant to the PM10 standard is less certain.

o Dan Wogsland, North Dakota Grain Growers: How does EPA propose to enforce more stringent

regulations? Who is charge, is it the state or EPA? Are other industries engaged with EPA in this

discussion?

Other industries affected by the PM standard were engaging in the beginning in this review. All have

participated in the review. As far 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 will then adopt rules that apply to that area, and share them 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 in almost all cases. As provided in the 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 generally follows the following 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 from the 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 a financial 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 on the states' websites.
Notes for Regiør 8 Particulate Matter 10 Meeting

Denver, CO

March LO,20tlo 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 in the car

and in the home? Does EPA have data in those areas for both coarse and fine particles?

All of the monitors are ambient. The measurement provides an overall picture of the air quality in the

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 a construction project that cause higher

values when construction is going on. This is accounted for in the designation process, where we have

to answer is there a problem that is causing the high concentrations.

o Brad Thykeson, North Dakota Grain Growers Association: lf EPA is worried 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 tease this 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 than just 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 in the

arid and dry northwest portion of Montana. Montana Cattlemen's Association would like to see

a revocation of the current PM 10 standard, 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 will this affect Montana's farmers and

ra nchers?

We will take this comment into consideration as we move forward.

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

metropolitan areas, how will we regulate the contributions coming from Canada?

Concentrations are measured at monitors and compared to the 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, so we are not asking the local area to address this contribution. We are working
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Derruer, CO

March tO,zOtL

with Canada on Eastern U.S. which is all 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 as well.

. 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 not the 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 on the toxins in the Northern Hemisphere that we

can forward along.

o Jeff Missling, North Dakota Farm Bureau -The Powerpoint references CASAC; who is on this

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 in the field of health and environmental

effects of air pollution.

¡ ln looking at Page 5 of the Powerpoint, you are looking at low socioeconomic factors. How is

that taken into account in the PM evaluation?

The low socioeconomic factor is a surrogate, 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 law there 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 a smoke 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 if we use different standards or the standards are revised down, what are the

chances of this 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 in the 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, do we have reports from L97Lto today, of health effects specifically tied

to PM10 exposure versus the factors 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

studies where people have been exposed in chambers.

¡ Leland Swenson, Rocky Mountain Farmers Union: Since EPA put the PM standard ínto effect in

t97t, do we 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 a focus of studies on

PM10. Anything bigger than that is not efficiently getting into the respiratory system. The science and

research has focused 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 have they done that?

For most of those areas that were in non-attainment, agriculturewasn't a large contributor to the vast

majority. The impacts were largely for industrial sources, and they 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 set the 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 not found 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 a year would it exceed the standard?

lf we are measuring every day of the year, you would first discount the highest value, and would look at

the value 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. lf you measured every day, you would go

down to about the first seven, look at the average across three years. Most states have data for one out

of six days. Look at the highest value over three years with the current standard; with the 98th

percentile you would look at the second highest for each of three years, and would average them

together. lf the second highes was 45 ug/l, that might pull down the other values- For PM10, unlike

10
Notes 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: On the 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 a one size fits all

standard we 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 keep the 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 to the 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 went final, it was included.

Property-line standards are only considered for PSD permitting, when a new source is moving in or an

existing source is making major modification, and it is only 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

other factors (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;

TL
Notes 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 in our 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 at what the

right sources to address are. Generally speaking, it's the direct emitting stationary sources. They can

put on controls. We have not always seen where a strategy 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 have developed 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. Be careful of the unintended

consequences of any air 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 is very concerned.

Colorado Livestock Association is very thankful 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 to the BMPs, USDA is working with us in taking a look at other

regulations, and looking regionally at different approaches. Trying to account for the same technique

for very dry/desert areas might not work in the northern tier. The BMPs may not have the same

effectiveness or contribution. The same th¡ng goes for tillage. A workable approach has been agreed to.

ln Wyoming, there is a very particular reason they have so many monitors; specifically, coal mines that

provide a great amount of coal for the country. The monitors were not driven by concerns, but they

were installed for a very specific reason, to hold industry accountable. You do not see near the amount

of emissions from agriculture as you do from coal mining. Adam - We are only looking at the PML0

monitoring maps, there is also a lot of other monitoring that is going on with other pollutants.

o Leonard Stone, Montana Farmer's Union: For any number of farmers and farm groups in Region

8, the big thing is to meet a standard. There is no way that we can as farmers 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 a way to

change what we are doing, or work with urban partners to make changes that would benefit all

of us.

L2
Notes 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, will there be an impact

as to how this will impact state agencies? Will EPA do an economic impact analysis?

Yes, there wlll be an impact assessment at proposal for comment, if we 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 at those 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. EPA does not fund 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 if we have additional comments?

You can submit 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: I want to re-emphasize the comments made

earlier about BMPs. Sometimes in trying to solve issues, we create another one. We are in a

water deficit part of the world. There needs to be a lot of thought of the gallons of water that

are sprayed on the ground to alleviate PM emissions. ln a feedyard, one way to control dust is

by frequent manure collection, but this increases GHG emissions. All things 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.

13
Notes 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 in this process, but EPA will probably get it. lf substantial new

science comes up that would cause us to think differently, then we have a method to reopen the review

of the science.

. Dayton Christensen, Nebraska Wheat Growers Association: lf you 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 the feedlots to look at this avenue more; wasting a natural resource like water

seems ridiculous.

As we get to proposal we 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

three year 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" the three 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 was then

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 both the 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 is the 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. Has the agency considered what it will do about exceedences that occur in a drought year?

A. If a monitored exceedence was the 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 is that

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 borders though.

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 it would essentially be "equivalent" to the 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 about the Health Risk Assessment? Why wasn't one completed for

PMro?

A. There were limitations on the availability of data and there were limitations in linking the

available data to health risks. Scientists have tried to estimate the 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 compare the 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 were volunteers 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 animal toxicology studies. In the'WOE, we look at each of those lines of evidence together.

Q. What do those lines of evidence tell us? What are the 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 on the urban vs. 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 on the 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 three years of complete data before a

designation recommendation could be made.

Nonattainment

Q. What happens when there is nonattainment?

A. One year 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 on that 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 to the Administrator one year from the promulgation of the NAAQ revision.

The Agency has one year to evaluate the 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 to the SIP. There was consultation with the

agricultural industry.

Q. What are some of the BMPs?

A. Assistance was given to 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 on the 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, but who 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 EPA Administrator, 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 5 years. 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 compared to previous

reviews. Studies link exposure to coarse particles to various adverse health effects, and various

factors make people more susceptible to PM health effects.

Slide 6: Started current review in2007 for both fine 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 for finalizing 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 to the 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 is that 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: In the 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 evidence that there is a lack of effect from crustal materials, because we do

have studies that 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 shorter term 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 task force on these PMl0-2.5

standards?

EPA: We did have them over to RTP to 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 what to do with rural vs. urban areas. What you 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 do this. 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 to work with agriculture.

I want Elvis Graves of USDA to go back, and I want ananswer - how is USDA working with

EPA on this research? Because in rulemaking, it is over.

EPA: If you look at number of counties (slide I 8) 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 me that you 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: In the 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 in their 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. We wrote 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 on where contributions are coming from.

SJVAPCD - Our counties are in a unified air district. From an implementation point of view,

what would really happen is that 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 allowed to treat single monitors differently. We came to the table to work with you guys, and

you are continuing to ask for more. This is going to 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 long time. 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 1 8) 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 period where state allowed farmers to burn, which put them in

danger of a violation. It is different with wildlife 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,

as someone 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 show the

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 is true 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 long time. 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 going to 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: I would hope that 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 year to 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 to the 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

going to cork off that bull? Over next few fdays] we want you to 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

everything we 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 lead to

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 on the table.

Question: According to what was presented to the Task Force at RTP in September, the range of

standards recommended by CASAC was from 65 to 75. Based on that 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 per year. 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 per year, based on wind events that are area concentrated. If you don't ignore windblown

dust events, then you are going to have to tell people here that they need to significantly change

the way they do business. The CAA calls not just for a primary standard, but for a secondary

standard. One factor 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 is that 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 to thank you for 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 of Agriculture

hosted a call in line for stakeholders in lD who could not travel 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 fraction from urban soils is vastly 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 for the 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 a quantitave 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 area we show no new nonattainment areas in Washington, 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-cities would 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 to the level and form for PM10 but no

decisions have been made. The information presented on potential violating areas for different

levels and forms of the standard under consideration is based on State air quality

measurements. Will there still be natural event exclusions?

a. Yes
The natural event exclusion process is very burdensome to states.

a. EPA - we are working to improve the process prior to the designations of

nonattainment areas for the PM NAAQS.

There are few 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 is then 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 2 or 3 exceedances per year. EPA's analysis of fewer

counties out of compliance doesn't match their research.

a. EPA: We'll work together to 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 of the data, most of the 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 on the 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 process or how the

uncertainty will be presented to 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 and thus

will eventually show all of 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 is found and agriculture sources contribute to it, we had discussed of mitigation

strategies and how we work 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 in setting the standards not just in how you

achieve them. We explained how the Clean Air Act precludes the consideration of cost in the setting of

a NAAQS.

Exceptional and natural events came up as well. They are very concerned about the resource burden on

states if they have a lot more events to get approved because the standard is lowered. EPA explained

there is ongoing work to address some of these issues. They were pleased with this approach but asked

s)

6)

7)
if any guidance would come out first in draft form for comment. We told them we were not sure of the

exact process we 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 will the change have regarding deaths? Will there be more than 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 will there be with the new standards, and where are the exceedances?

A - EPA: no areas violating based on current data in Washington, Pocatello and Boise are violating 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 for the 98th percentile ...

Q - for 365 days how would it work on average?

A- (from Scott on the phone) in the last review EPA proposed 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 are typically from "coarse" particles.

Q - Do natural events and high wind 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, is 2.5 microgram part of PM10?

Q - also what 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 as exceptional events. States have smoke management plans in place based on

daily conditions, if there is a good 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 a
quantitat¡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 to the 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

of the standards.

Q - ls there no correlation of PM10 to health effects?

A - concentrations of PM10 minus 2.5 - there's some uncertainty in the 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 2 or 3

exceedances. EPA's analysis of fewer countíes out of compliance doesn't match their research.

Q - Will the state be burdened with paperwork for each of 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 out why 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 of the time we're pretty good - their analysis shows

attainment.

Q - Rick Stott, ICA:

Comment: thanks for 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 - who justifies the validity, how can EPA justify?

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 less of them .

A - EPA solicits 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 5 year

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" ...

-EPA dismisses the 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 a significant cost component to lowering standards

Comment: only 2 counties in ldaho and none in Washington - adding monitors in rural areas -you'll

target farms and ranches as sources of dust - target painted on feed lots and farms - no comfort in EPA

assurances of 5 year horizons due to generational nature of farming and agriculture - Arizona and

California events in non-attainment due to exceptional events...

A - There are uncertainties and these 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 standard we will consider how best to address them and may take the

study to CASAC for 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 has concerns about changing to the 98th percentile -

currently there are about 7 days of exceedance, using the 1 in 6 days means using only 51 days a year 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 are working with western states to address this issue now, even before the draft document goes

out for comment.

Q - Jerry Snyder, farmer, rancher, fourth generation: There is way 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 is vastly 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 if there's no evidence of health effects?

Q - (Robert Blair, ldaho grain?) Comment: mandatory review every 5 years, uncertainties - why, ¡f there

is no intent to do something, are you proposing to make a change?

A - This meeting is for direct input from you, from stakeholders. No decision has been made on either

the standards or any changes to the monitoring network. All of your 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 L5 years

- they've done dust control for construction and feed 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 as they are now

BREAK

Bill: would like to explain how the 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 will work with emission sources on how to reduce their emissions (USDA and states work directly

with Agriculture sources if they are determined to be significantly contributing to nonattainment)
- after 3 years of clean air they can submit their plan of ho they will formally put the area in attainment

through different control strategies.

EPA summarized 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 al showed 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 EPA send those citations?

A - EPA will send the studies via Karma

Q - Karen Wood, Washington Dept. of Ecology:

- PM10 monitoring has been a low priority and has been reduced by about 50%

- exceedances due to fires 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 and the state

- he doesn't believe that EPA is showing 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 keep the current standard

A - the monitoring network is designed from evidence and to be sure it is complete 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 can take standards to an extreme and would eventually make everyone out of compliance
A - uncertainties in science will be taken 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 and justifies 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 has the option to go back to CASAC

for review and decision

Q - Thanks for 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 in this NAAQS review and all other NAAQS reviews will address whether 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 by showing 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 can we provide information to decision makers (zero funding)

- how do we value that?

- all grants, earmarks, have been zeroed out
Q - Best management practices

- everyone wants to keep the 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 a family farmer and has a family - notes that lack of food is creating unrest

around the world. His responsibility is to feed America and to feed the 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 his work.

- there's inherent distrust between regulated community and EPA

- will the common sense exhibited at this 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 to write 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. Thanks for 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 of Attendance

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

Dux

Claghorn Karey

lordan Nebraska 

lowa Deputy 

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Bureau

of Agriculture X

X

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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 of Natural Resources x

Graves Uvrs USDA - DC X EK

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last Name First Name Organizatlon Attending Signature of Attendance

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

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Licht Alice Nebraska Agri-Business

Linder Mike Nebraska Department of

Environmental Qualitv X

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I¿{cn Office of Senator Chuck Grassley X

ëú,f., t(cçn*,.r' e'if : - *- 'iMoreland lohn Office of Senator Tom Harkin X

Paap Kevin Minnesota Farm Bureau X

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Petersen Thom Minnesota Farmers Union

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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

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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

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Weinzierl Rodney lllinois Corn Growers Association

Whitaker John USDA Farm Service

Williarnson Dayle Office of Senator Ben Nelson X

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Wood Wayne Michigan Farm Bureau

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Zimmerman Paul Wisconsin Farm Bureau

lâst Nãme First Name Organization Attending Signature of Attendance

Boerner Ben Texas Grain and Feed Association

Bates Mike Arkansas Department of Environmental euality

X h,:l^kf,^

Bragg lay Texas Farm Bureau

Brundage Robert Missouri Pork Association (CNSL)

X

lrn",., Rick KDHE ay'ø^l"/

Carroll Jim Dairy Farmers of America

Government Relations X &* û*-M

Childers Marvin The Poultry Federatíon /

Devine Allie Ka nsas Livestock Association tÈ a//ø¿t¿

Dillon Corey Offìce of Claire McCaskiff 

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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

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Hampton Joe Oklahoma Grain and Feed Association

Harrell Ron Louisiana Farm Bureau

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last Name First Name

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, tl

Hildebrand SusanS fexas Commission on Environmental euality

Holdren Terry Kansas 

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Jackson Bill Agri-Servi 

X (additional) 4-rlK

ces of Bru nswick

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Johaness Kenlon Kansas Soybean Association t

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Kavanaugh Jim MDNR x!* éiL&,

Klippenstein Brian Office of Senator Roy Blunt

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Lyles lvory Arkansas Extension Service rts \)

Martin F. David New Mexico Environment Department

Masters lerry Arkansas Pork Producers

McFarland Mark Texas Agri-Life
last Name First Name Organization Attendine S¡gnaturê of Attendance

Minton Davis Ag Liaison MDNR

x

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Nikodim Don Missouri Pork Association

x

Nolan Cheryl Louisiana Department of Environmental eual ity

Peek Marla Oklahoma Farm Bureau

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Petersen Bob Peteæen€oaæl+in* h NZ"*l &w.c.t

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Popelka Aaron Office of Senator Jerry Moran

X (additional) fr nÆl

Reese 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 & Feed Association

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Staples Todd Iexas Department of Agriculture

Strain Mike Louisiana DAF

Stroda Tim Kansas Pork Association

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Swaffar Steve Kansas Farm Bureau

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Teague Evan Arkansas Farm Bureau
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Last Name First Name Organization Attendine Signature of Attendance

Terrill Eddie Oklahoma Department of Environmental euality Ç/1, '/J;

Thompson Steve Oklahoma Department of Environmental euality

Turley Darren ì-exas Association of Dairvman

uhl Mary New Mexico Environment Department

Vickery Mark Texas Commission on Environmental Quality ?r¿g-e-*#

Weinheimer Ben Texas Cattle Feeders Association

X

White Mark Missouri Corn Growers

X

White lere Kansas Corn Growers Association

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White Michael New Mexico Farm Bureau r

Windett Jeff Missouri Cattlemen's Association

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PM NAAqS Meeting

Name Title Agency City

Washington 3alled i Attended

Dan Newhouse Director WA State

Deparfment of Ag 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'A Association 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 Dept of

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 Â oen¡rr

Vancouver
PM 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.g ov

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

R cservqfinn

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.com
PM 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

A scnciafinn

Spokane

Iravis Gibson Agribeef Moses Lake ravis. eibson@ aeribeef. com

Barbara Quick 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 of Ae Boise I

Brian Oakev DeÞuty Dircctor ID Dept of Ae 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

Lapwai
PM 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 Perce Tribe

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

Â ssocietion

Boise

Ij ones@Idahograin-org
PM 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 Growers Association I

Oregon

Katy Coba Director ODA Salem

Ron Alvarado State Conservationist ORNRCS Portland

lennifer Zwicke OR NRCS Portland i ennifer.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 Corvalis
PM NAAQS Meeting

Name Iitle Agency City

tÂlashington Called i Attended

Elwood Patawa Chair, Board of Trustees

Confederated

Tribes of the

Umatilla Indian

R ccerrrqfinrr

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 of Air 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

27 32