1. Department of Air Quality Exceptional Event Streamlining, Standardization & Coordination CDAWG November, 2015 Clark County

2. Overview General agreement on need to streamline exceptional event documentation Standardization would facilitate development and review of documents Coordinated effort through an inter-agency working group would expeditiously facilitate development of appropriate formats and templates in collaboration with EPA Effort could assist EPA in finalizing exceptional events rulemaking and guidance documents

3. Overview (continued) Both state/local agencies and EPA are frustrated with the current exceptional event concurrence process EPA is inundated with request for review of exceptional event documentation Concern that EPA is not reviewing exceptional events affecting the states for regulatory purposes Region 9 is now administratively requiring states to submit prescreening documents Concern from all parties on level of detail needed

4. Detail of Documentation Level of detail in exceptional event documentation varies greatly by agency and by region Recent Clark County PM10 high-wind document 1 249 pages and 155 figures Some other agencies also developing very detailed documents Clark County Ozone documents running 75 to 80 pages 1 Arizona high wind event documents running 56 to 89 pages 1 1 Number of pages provides a rough but imperfect metrics of level of detail

5. Detail of Documentation (continued) EPA Region 1 has approved even shorter exceptional event documents EPA Region 9 management requested Clark County to produce PM10 documents more like Arizona’s The irony is not lost on Clark County Take home point: we can all learn from each other

6. Draft Exceptional Events Rule Will provide for approval of exceptional events meeting one of five criteria An action to designate or redesignate an area as attainment, unclassifiable/attainment, nonattainment or unclassifiable for a particular NAAQS The assignment or re-assignment of a classification category (marginal, moderate, serious, etc.) to a nonattainment area to the extent this is based on a comparison of its “design value” to the established framework for such classifications

7. Draft Exceptional Events Rule (continued) A determination regarding whether a nonattainment area has actually attained a NAAQS by its CAA deadline A determination that an area has had only one exceedance in the year prior to its deadline and thus qualifies for a 1-year attainment date extension, if applicable A finding of SIP inadequacy leading to a SIP call to the extent the finding hinges on a determination that the area is violating a NAAQS

8. Draft Exceptional Events Rule (continued) Provides for an “alternative path” for exceptional events Simplified submittal requirements for flagged data Flagged data would not be used for historical analysis, monitoring site assessment, and other similar uses Target date for final rulemaking and guidance publication is August 2016

9. Exceptional Events Working Group Clark County is proposing a collaborative exceptional events working group The focus of the working group could include Streamlining exceptional event documentation Developing “best practices” standardized formats for different types of events, bearing in mind that one size does not fit all Narrow focus would not duplicate efforts of WESTAR, WRAP, and NACAA on broader exceptional rule issues, but work product might supplement those efforts

10. Exceptional Events Working Group (continued) Participants would include agencies from California, Nevada, EPA and perhaps Arizona We envision an informal working group organized along the lines of the BACM WG circa 1997-2008 Working group would facilitate expeditious development of work products and allow for efficient use of EPA staff resources

11. Contact Information Rodney Langston, Principal Planner Clark County Department of Air Quality Desk Phone: (702) 455-1661 Email: LANGSTON@ClarkCountyNV.govLANGSTON@ClarkCountyNV.gov

12. Discussion