AGENDA
WESTAR Planning Committee Conference Call
June 1, 2006 2:00 - 3:00 p.m. (Mountain Time)
Number: (800) 244-9194 Access Code: 107484
1. CALL TO ORDER:
(a)
Review May meeting notes
Alice Edwards/Cheryl Heying
Change “do” to “due.”
Present on the call, Alice Edwards, Bob Lebens, Doug Schneider, Ray Mohr, Deb Wolfe, Tina Suarez-Murias, Mike
Schnieder, Rachel Sakata, Don Arkell, Rita Trujillo, and Dan Johnson.
2. ACTION ISSUE ITEMS:
(a)
PM Transition ANPR –
Group Discussion
-discuss draft comments to be developed and schedule/needs from other committees
Quite a bit of discussion centered on drafting comments on the straw man proposal to submit to the Air Directors.
See attachment.
3. TRACKING ISSUE ITEMS:
(a)
Regional Haze Planning Update
Don Arkell
Don reported out on the WRAP Dust and Smoke Work Shop held in Sacramento California, information can be
found at www.wrapair.org, dust and haze web pages. The IWG meeting discussed the planning process and the
Class I areas that are impacted by more than one state. A series of phone calls is being planned to resolve as to how
states will coordinate. The Planners now have a SIP outline.
(b)
Exceptional Events Rule- final report from work group on comments
Doug Schneider/Dave McNeill
Doug Schneider reported out on the final version of the comment that went to the EPA under the Margie Perkins
signature. The comments are available on the WESTAR web page.
(c)
Share info on oil & gas initiatives
Anyone
Rita Trujillo reported that there is quite a bit of work going on in the 4 Corners area and anyone interested should
visit their website, www.nmenv.state.nm.us/aqb/4C/index.html. Ray Mohr reported that Colorado has now staff
directly dedicated to oil and gas issues. Colorado is also looking at cross media issues, including discussions on
impacts to solid and hazardous waste and water quality. Both Colorado and New Mexico are looking at possibly
developing minor source BACT permitting requirements.
(d)
Share info on mercury
Anyone
Colorado- Proposal in June, Final in September, they are participating in the trading program, however, allocations
will be based on actual mercury emissions.
Montana – Hearings now, no trading until 2018. Allocations will be based on actual mercury emissions.
New Mexico- Not opting in to the federal trading program. Allocations will be based on actual mercury emissions.
Oregon – Out for public comment now.
(e)
Any word on 110 SIP call
Anyone
Stay tuned, rumor has it EPA will actually get us some guidance by the time it is due. (No one had much to add
except that some states are getting nervous that the deadline is rapidly approaching, yet we still don’t have any idea
what EPA wants.
4. DISCUSSION ITEMS/OPEN MICROPHONE:
(a)
(b)
Open Microphone
Topics for Upcoming Meetings
Anyone
Get items to Cheryl or Alice.
5. Confirm Next Conference Call Date for July 6, 2006
Alice Edwards
MEETINGS/CALLS:
STAPPA/ALAPCO Air Toxics Committee Monthly Call, 11:30 am -12:30 pm Eastern Time, May 11, 2006; (800) 376-6136,
access code 832177
STAPPA/ALAPCO Criteria Pollutants Committee Monthly Call, 1:30 pm – 3:00 pm Eastern Time, May 24, 2006; (800) 321-7001,
access code 834059#
WRAP meetings and calls: See WRAP web site http://www.WRAPAir.org
ATTACHMENT
Dear Administrator Johnson:
The Western States Air Resources (WESTAR) Council, an association of state air quality managers from fifteen
western states, appreciates the opportunity to provide comments on the EPA’s Advance Notice of Public
Rulemaking for the Transition to New or Revised Particulate Matter (PM) National Ambient Air Quality
Standards (NAAQS), published on February 9, 2006. WESTAR states have followed EPA’s development of the
revised PM NAAQS closely. As a new or revised standard is implemented, we believe it is critical to carry
forward all of the gains achieved from the implementation of the existing PM standards.
EPA’s proposed revocation of the existing PM10 standard in most areas of the West is of particular concern. It
is important to preserve the improvements in air quality resulting from existing PM10 program control plans and
prevent backsliding. These control plans often address a combination of sources including residential wood
burning, transportation sources, industrial facilities, and crustal sources. During the transition to the revised
standards, EPA must proceed in a manner that does not undermine the legal underpinnings of the existing state
programs. Therefore, we urge EPA to maintain the current standards and implementation requirements in all
areas until EPA has the necessary tools and data in place to make a smooth transition to the revised standards.
Moving from the old standard to the new standard requires that technical and policy tools needed for
implementation be developed and put in place as guidance, or rules, so that programs can make a relatively
seamless transition. Despite the promulgation of a PM2.5 standard in 1997, there are still many technical tools
that are not yet available for states to use in implementing the standard. Much work is needed to develop these
technical and policy tools and this problem will be further enhanced by the adoption of a new PM10-2.5 standard.
Essential areas that need further work include relevant PM emission factors, monitoring methods,
implementation guidance relevant to daily PM2.5 violations, PSD increments, and permit program transition
issues. It is important that EPA work quickly to fund and develop the tools necessary for states to implement
the revised standards.
We urge EPA to work with the states and other interested parties in developing the necessary tools, guidance,
and rules for implementing the proposed particulate matter standards. If you have any questions, please do not
hesitate to contact Dan Johnson, WESTAR Executive Director, at 206-254-9145, djohnson@westar.org.
Sincerely,
<ROUGH DRAFT – UNDER DEVELOPMENT>
WESTAR Detailed Comments
NOTE: These comments would be considered for forwarding to EPA if they are not covered by the
STAPPA/ALAPCO comments.

Anti-backsliding policy for PM10
EPA should promulgate a strong and clear rule requiring states to keep all emission reduction measures
adopted for PM10. These PM10 reduction measures adopted as part of an approved PM10 attainment or
maintenance plan should be kept in place until states demonstrate they are no longer needed to protect
compliance with the new PM2.5 or PM10-2.5 standards.
Specifics include:
State rules adopting emission reduction requirements for area, mobile, non-road, and industrial
sources
Local ordinances implementing PM10 attainment strategies
Growth management strategies (NSR, PSD)
Transportation – if conformity cannot be kept, EPA should encourage states to develop a state
process to recognize the importance of linking land use, transportation planning, and air quality

Prevention of Significant Deterioration
Increments regulate the amount of deterioration that can be allowed. Good increments must be
developed. They ought to be based on the original PM increment form 1977. Else there is a distinct
possibility that there will be further reduction in particulate air quality if new major and minor baseline
dates have to be set. With the changes EPA has made to the PSD program applicability requirements, it
is less and less likely that there will be a PSD project occurring that will trigger these dates.

Permitting (this will need some more organization)
Existing permit requirements for PM – BACT analyses, permit allowable emissions, use of secondary
emissions and how to track it in permitting, NSPS (no NSPS I know of regulates PM10 including those
written in the last few years.) - Should the current permit requirements remain even if PM10 is revoked?
Will EPA retain PM10 as a listed pollutant in 40 CFR 52.21(b)(23) just as it has retained TSP?) Until
EPA is ready to support a transition from PM10 to PM2.5, the existing PM10 requirements should
remain in place.
Industrial Permitting
EPA should provide a schedule and provide technical and monetary resources for States to
update their regulations and permits to reflect PM2.5 and PM10-2.5 and establish a priority for which
permits to update first.
EPA should initiate a program to update the NSPS and MACT requirements to reflect PM2.5 and
PM10-2.5 rather than perpetuate the regulation of TSP.
Permit Fees
States may need to adjust their industrial permit fee structure from one based on PM10 emissions
to one based PM2.5 and PM10-2.5 emissions. WESTAR requests that, prior to implementation of the
revised health standards, EPA analyze, in conjunction with the States, the impact of the transition on
States permit fee revenues.

Emission Factors
Currently emission factors for fine particulate are incomplete. EPA must fund the development of
appropriate emission factors for use in emission inventories. One option is for EPA to push industry and
trade associations to publically share their fine particulate matter emission factor data. Being able to
accurately estimate emissions is critical to permitting and planning for attainment with the standards.
Without accurate emission factors, air agencies are severely hampered in their ability to implement PM2.5
control programs.

Monitoring & Modeling
Measuring PM2.5 – backhalf measurement and what front-half test method to use?
Monitoring funding and network issues
Need for adequate models that can both address the physics of primary particulate and the transformation
of other pollutants into fine particulate in the atmosphere, but on a typical AERMOD type scale.

PM2.5 Implementation Guidance
The current PM2.5 implementation guidance is geared primarily toward the annual standard. The
proposed implementation rule seems to focus on industrial sources, precursors, and secondary PM2.5.
Under the proposed PM2.5 NAAQS, many states will now be faced with areas in violation of the 24-hour
standard, often from primary PM2.5 emissions from area sources, such as residential wood combustion.
This rule should be revised to better reflect the type of planning and implementation needed to address
episodic violations of the daily PM2.5 standard.

Transition from PM10 to PM10-2.5
WESTAR has already commented adversely to EPA’s approach to the revised PM standard that splits
the standard to address only urban, and not rural, impacts. If EPA moves ahead with the proposed
approach to the standard, the agency must consider the extended impacts on state and local programs in
place as well as the concerns of rural citizens who will lose protection from coarse particle pollution.