Final,
April
19,
2005
Page
1
of
2
Pages
White
Paper
#
2:
How
Should
States
Document
A
Natural
Event?

Date/
Status:
April
19,
2005
Final
Background:
When
a
State
believes
that
a
natural
event
has
caused
a
measured
exceedance
of
the
NAAQS,
the
Natural
Events
Policy
(
NEP)
requires
the
State
to
establish
a
clear
causal
relationship
between
the
measured
exceedance
and
the
natural
event
through
the
use
of
filter
analysis,
meteorological
data,
modeling/
receptor
analysis,
video/
photographs
or
news
accounts
of
the
event.
The
type
and
amount
of
documentation
required
for
the
event
should
be
sufficient
to
show
that
(
1)
the
natural
event
occurred,
(
2)
it
impacted
a
monitoring
site
in
such
a
way
as
to
cause
the
measured
PM10
concentration,
and
(
3)
absent
the
event,
PM10
concentrations
would
not
have
exceeded
the
NAAQS.

Documentation
of
a
natural
event
is
to
be
made
available
to
the
public
for
review
and
comment
to
allow
for
discussions
about
the
event,
its
causes,
actions
taken
and
the
issue
of
attainment/
non­
attainment.
The
NEP
requires
the
State
to
submit
the
data
to
the
EPA
Air
Quality
System
(
AQS)
within
180
days
from
the
time
of
the
event
with
a
request
to
flag
the
data.
The
NEP
requires
EPA
staff
to
acknowledge
receipt
of
the
documentation
and
confirm
that
the
request
to
flag
the
data
as
a
natural
event
has
taken
place
within
60
days
of
receipt
of
the
request.

Discussion:
The
NEP
was
written
with
the
understanding
that
each
State
is
the
"
expert"
on
the
causes
of
air
pollution
episodes
within
their
jurisdiction.
The
NEP
is
not
clear
about
what
data
is
necessary
to
constitute
a
"
clear
causal
relationship."
In
the
absence
of
national
guidance
on
necessary
data,
the
regions
have
not
been
consistent
in
how
they
have
treated
documentation
submitted
by
the
states.
Furthermore,
if
the
Region
and
State
disagree
on
the
adequacy
of
the
documentation,
there
is
no
mechanism
identified
other
than
the
courts
to
resolve
the
dispute,
which
may
result
in
a
very
protracted
resolution
process.

Recommendations:

The
Workgroup
recommends
that
soon
after
the
policy
is
revised:

a.
EPA
collaborate
with
the
States
to
issue
guidance
on
the
documentation
requirements
that
is
implemented
consistently
from
region
to
region
and
State
to
State.
The
goal
is
documentation
that
is
simple,
technically
sound
and,
to
the
extent
possible,
based
on
readily
available
information.

b.
As
part
of
the
national
guidance,
EPA
and
the
States
work
together
to
establish
a
mutually
acceptable
dispute
resolution
mechanism
that
relies
on
a
technical
evaluation
of
the
documentation
versus
an
administrative
evaluation
by
an
independent
third
party,
and
will
result
in
a
timely
resolution
of
issues
as
they
arise.
Final,
April
19,
2005
Page
2
of
2
Pages
c.
EPA
regional
offices
work
with
the
States
within
their
region
to
develop
criteria
for
appropriate
documentation
based
on
the
national
guidance.

Task
Group
Members:
Gerry
Guay,
Alaska 
author
Dave
McNeill,
Utah 
reviewer,
editor
Doug
Schneider,
Washington 
reviewer,
editor
