1.3.2 How is Measuring and Modeling Particulate Matter Different (and
Often More Complicated) than Ozone?
Before modeling the expected PM2.5 benefits from emissions controls, it is important to
understand the unique and complicated aspects of measuring and modeling particulate matter.
For many reasons, PM2.5 and regional haze modeling presents many more difficulties compared
to ozone modeling. In this section, we identify attributes of PM2.5 that are applicable to most
attainment or uniform rate of progress demonstrations. There are of course exceptions. As we
discuss in Section 11.0, States need to develop a conceptual description of the PM2.5 or regional
haze problem in each of their areas subject to a demonstration. If a substantially different picture
emerges from the general one presented in this section, modeling/analysis procedures which
differ from some of those we believe are generally applicable may be warranted.
Premise PM1. Particulate matter is a mixture. Unlike a compound (e.g., ozone) or an
element (e.g., lead), a mixture has components which (a) can behave independently of one
another (e.g., primary vs. secondary components) or (b) are related to one another in a complex
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