1. ANPR: Transition to New or Revised PM NAAQS WESTAR Business Meeting March 2006

2. What issues are discussed in the ANPR? Proposed options for transitioning from 1997 PM 2.5 NAAQS to any new 2006 PM 2.5 NAAQS Timelines for implementation of any new 2006 PM 2.5 NAAQS Timelines for implementation of any new PM 10- 2.5 NAAQS Transition from the PM 10 standards to any new PM 10-2.5 NAAQS What emission inventory requirements should apply to PM 2.5 and PM 10-2.5 NAAQS Next steps

3. Transition from 1997 to 2006 PM 2.5 NAAQS Option 1: –Proposed change to annual PM 2.5 standard is minimal Not significant enough to require new designations –Propose to not revoke the annual PM 2.5 standard –Propose to revoke the 1997 24-hr PM 2.5 standard one year after designations under any new 24-hr PM 2.5 standard –SIPs for annual PM 2.5 standard would stay in place until areas redesignated attainment

4. Transition from 1997 to 2006 PM 2.5 NAAQS Option 2: –Revoke annual and 24-hr PM 2.5 standard 1 year after designations under any new PM 2.5 standards –Develop and implement “anti-backsliding” rule Which planning control requirements remain? NSR program Conformity programs

5. Timeline Comparison for PM standards including proposed 2006 PM 2.5 standards Milestone1997 PM 2.5 Primary NAAQS CAIR2006 PM 2.5 Primary NAAQS Effective date of Standard July 1997March 2005December 2006 Monitoring Data Used for State Recommendations 2001-20032004-2006 State Recommendations to EPA Feb. 2004December 2007 Final Designations Signature Dec. 2004December 2009 Effective Date of Designations April 2005April 2010 SIPs DueApril 2008Sept. 2006April 2013 Attainment DateApril 2010 (based on 2007-2009 data) Jan. 2009 (Phase I NOx) Jan. 2010 (Phase I SOx) Jan. 2015 (Phase 2 - NOx and SOx) April 2015 (based on 2012-2104 data) Attainment Date with Extension Up to April 2015April 2020

6. Timeline for New PM 10-2.5 Standard* Milestone2006 PM 10-2.5 NAAQS Effective date of StandardDecember 2006 Monitoring Data Used for State Recommendations 2009-2011 State Recommendations to EPAJuly 2012 Final Designations SignatureMay 2013 Effective Date of DesignationsJuly 2013 SIPs DueJuly 2016 Attainment DateUp to July 2018 (based on 2015-2017 data) Attainment Date with ExtensionUp to July 2023 *Schedule based on monitor deployment in 2009

7. Transition from the PM 10 standards to any new PM 10-2.5 NAAQS – Proposed in PM NAAQS Proposal for revoking PM 10 Standards upon promulgation of 2006 PM 10-2.5 NAAQS: –Revoke annual PM 10 standard everywhere –Revoke 24-hr PM 10 standard everywhere except Where violating monitor and urbanized area with population greater than 100K Taking comment on retaining 24-hr PM 10 standard in non-urbanized areas with ambient mix of PM from traffic, industrial and construction sources and one violating monitor

8. Transition from the PM 10 standards to any new PM 10-2.5 NAAQS – Proposed in ANPR Revoking 24-hr PM 10 standard one year after designations under PM 10-2.5 standards Anti-backsliding rule would be needed: –Control Measures – to be retained based on PM 10 classification – moderate or serious –Maintenance for areas that come into attainment w/ PM 10 prior to revocation? –Transportation conformity – to be addressed in separate rulemaking –General conformity – to be addressed in separate rulemaking –New Source Review – following slides

9. Transition from the PM 10 standards to any new PM 10-2.5 NAAQS: NSR Issues Does PM 10 continue to be a regulated NSR pollutant for PSD where 24-hr PM 10 is revoked? –Option 1: PM 10 continues to be regulated NSR pollutant since retained in some areas; PSD continues to apply – but only BACT since non-criteria pollutant –Option 2: interpret definition to be area-specific, so PM 10 no longer regulated NSR pollutant and none of the PSD requirements would apply Does the CAA require continued obligation for some form of PM increment? –Option 1: Conclude § 166(f) and § 163 requirements no longer applicable and develop new increments for PM 2.5 and PM 10-2.5 establishing new baseline and trigger dates –Option 2: Substitute PM 10 increments with two new increments PM 2.5 and PM 10-2.5 – retain existing baseline and dates

10. Transition from the PM 10 standards to any new PM 10-2.5 NAAQS: NSR Issues cont’d How should permitting authorities implement the PM 2.5 program upon revocation of PM 10 ? –Option 1: Continue to use PM 10 as surrogate – but compare PM 10 emissions concentrations with the PM 2.5 NAAQS - conservative –Option 2: Continue to apply existing surrogate policy for implementing the PM 2.5 program – compare PM 10 emissions with former PM 10 NAAQS How to implement PSD program for PM 10-2.5 upon the effective date of promulgation for PM 10-2.5 ? –Option 1: Use PM 10 as a surrogate – compare PM 10 emissions concentrations with the PM 10-2.5 NAAQS - conservative –Option 2: Compare PM 10 analysis to former PM 10 NAAQS and use compliance with this as surrogate for compliance with new PM 10-2.5 NAAQS for a temporary period –Option 3: Use compliance with BACT for PM 10-2.5 as a surrogate for the PM 10-2.5 compliance demonstration

11. PM 10-2.5 NAAQS : NSR Issue How should ambient PM 10-2.5 dominated by rural windblown dust and soils, and generated by agricultural and mining sources be treated in the NSR program for the proposed PM 10-2.5 standard? –Definition of proposed PM 10-2.5 standard suggests that NSR applicability test would exclude these sources from consideration. How do we implement the NSR program if a NAAQS with these characteristics is promulgated?

12. Applicable emission inventory requirements for PM 2.5 and PM 10-2.5 NAAQS EPA’s emission inventory program is specified in the Consolidated Emissions Reporting Rule, the Air Emissions Reporting Requirements, and guidance –Are the data elements specified in the CERR and AERR sufficient to develop adequate SIPS for PM2.5 and PM 10-2.5 ? –Fugitive emissions are significant contributors to PM 10-2.5 Should EPA require/develop more precise methods for estimating these emissions –Should EPA require any additional emission inventory data elements or temporal allocation techniques to estimate more accurately daily emissions and their variability? –Other inventory issues which need to be defined?

13. Next Steps ANPR published in FR on Feb 9 (71 FR 6718) w/ 60 day comment period ending April 10, 2006 Evaluate comments and develop proposal sometime after NAAQS are finalized in September 2006