&EPA
Guidance and Policy for
Implementation of Tribal Air
Monitoring Programs
Final
April 2008
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Abstract
This document, Guidance and Policy for Implementation of Tribal Monitoring Program, was
developed to improve the ability of tribes and EPA Regional Offices to prioritize monitoring
needs, choose an appropriate level of funding for ambient air monitoring on tribal lands relative
to other air management work, and ensure that monitoring funds are used effectively on chosen
projects. This document is also intended to provide a level of consistency between OAR and the
EPA Regions in our expectations of tribal monitoring programs. The intended audience for this
document is EPA Regional Office and Headquarters staff involved in resource allocations, tribal
air grant award and management, program evaluation, strategic planning of monitoring networks,
technical support to monitoring programs, and using ambient air data collected from tribal
monitoring programs.
This document has been developed in a question/answer format as a way of distinguishing
discrete topics related to ambient air monitoring activities. This guidance and policy document
is an internal EPA document and will be revised as needed.
Background:
In August 2005, a Tribal Monitoring Workgroup made up of staff from the Office of Air and
Radiation (OAR), EPA Regional Office tribal air coordinators, and tribal air professionals
gathered to develop guidance on tribal ambient monitoring. An early draft version of the
guidance was shared with a wider group at the National Tribal Air Association (NTAA) meeting
in October 2005, and at other Tribal meetings. As a result of tribal input, the Workgroup agreed
that, due to the scope of the topics covered, the guidance should evolve into two separate
documents, of which this document is the second. The first of these two documents was the
Technical Guidance for the Development of Tribal Air Monitoring Programs. This guidance
document provided specifics on how to plan and implement ambient air monitoring programs
and was developed specifically for tribes as the primary audience. The document was completed
in August 2007, and posted on the OAR Tribal Website
(http://www.epa.gov/air/tribal/airprogs.html).
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Table of Contents
Page
Abstract iii
List Of Abbreviations v
BACKGROUND 1
OVERVIEW
1. Who are the intended readers and users of this document? 4
2. What are the purposes of this document? 4
3. What are the guiding principles for working with the tribes on air monitoring? 6
4. Does this guidance supersede or change any previous guidance or procedures? 8
IMPORTANCE OF AIR MONITORING PROGRAMS AND EPA-TRIBE RELATIONSHIPS
5. Why is having an ambient monitoring program important? 8
6. What facilities, staff capabilities, and other resources (apart from funding) does a tribe 9
have to possess to make ambient air monitoring a realistic possibility?
7. Does EPA support the full cost of a tribe's monitoring program? How does the degree of 10
funding for tribes compare to that for state/local agencies?
8. What are the differences between EPA's relationships with states regarding monitoring 11
and EPA's relationships to tribes regarding monitoring?
9. Can tribes join the NATTS, local scale air toxics, IMPROVE, CASTNET, NADP, and/or 12
NCore monitoring programs?
10. Does EPA set overall goals for its support to ambient air monitoring by tribes? How 13
does EPA evaluate success in meeting those goals?
11. How does EPA ensure that funds given to a specific tribe for ambient monitoring are 14
used efficiently?
12. How much time does EPA allow a tribe with a new grant for ambient monitoring 16
to be operating its new monitors, have a QAPP in place, and reporting data to
AQS?
13. Why is it important for tribes to report their ambient air data to AQS? Are there other 17
alternatives that are acceptable to EPA, if preferred by a tribe?
MONITORING REQUIREMENTS AND DATA REPORTING
14. Why is it important that tribes adopt and follow a quality assurance project plan and
quality management plan (QAPP/QMP) ? 18
15. How does EPA help tribal monitoring programs satisfy the 40 CFR Part 58 Appendix A 19
requirement to have adequate and independent performance evaluation audits?
STATUS OF MONITORING NETWORKS
16. How many tribes are monitoring their air quality using funds from EPA? Are the data 20
from this monitoring available to others?
17. How does EPA help a tribe understand its air quality in the absence of a 21
monitoring program?
ADDITIONAL INFORMATION
18. Where can a tribe get more information on ambient monitoring and on other air quality
topics that relate to monitoring? 22
APPENDIX A: Grant Related Information 23
APPENDIX B: Background for Planning Tribal Air Monitoring 30
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List of Abbreviations
AQI Air Quality Index
AQS Air Quality System
CAA Clean Air Act
CASTNET Clean Air Status and Trends Network
CFR Code of Federal Regulations
EPA Environmental Protection Agency
GAP General Assistance Program
HAP hazardous air pollutants
IMPROVE Interagency Monitoring of Protected Visual Environments
IT information technology
ITEP Institute for Tribal Environmental Professionals
MDN Mercury Deposition Network
NAAMS National Ambient Air Monitoring Strategy
NAAQS National Ambient Air Quality Standard(s)
NADP National Atmospheric Deposition Network
NATTS National Air Toxics Trend Stations
NCore National Core Network
NPAP National Performance Audit Program
OAQPS Office of Air Quality Planning and Standards
OAR Office of Air and Radiation
OMB Office of Management and Budget
PEP Performance Evaluation Program
PM particulate matter
PM2.5 particulate matter < 2.5 microns
PSD prevention of significant deterioration
QA quality assurance
QAPP quality assurance project plan
QMP quality management plan
RPOs Regional Planning Organizations
SIP State Implementation Plan
SLAMS state and local monitoring stations
STAG State and Tribal Assistance Grants
SOP standard operating procedure
TAR Tribal Authority Rule
TAMS Tribal Air Monitoring Support Center
TIP Tribal Implementation Plan
|ig/m3 micrograms per cubic meter
WRAP Western Regional Air Partnership
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BACKGROUND
The U.S. Environmental Protection Agency's (EPA) Indian Policy, originally signed in 1984 by
Administrator William Ruckelshaus, sets forth the principles that guide EPA in working with
tribal1 governments. In Principle 3 of that Policy, EPA states that "The Agency will take
affirmative steps to encourage and assist tribes in assuming regulatory and program management
responsibilities for reservation lands." The statement under this principle identifies grants as a
mechanism that EPA will use "... .within the constraints of EPA's authority and resources..."
Section 301 (d) of the 1990 Clean Air Act Amendments provides federally recognized tribal
governments the authority to implement Clean Air Act programs for their reservations and other
land for which they can demonstrate jurisdiction. The Tribal Authority Rule (TAR) promulgated
on February 12, 1998, further delineates the authority of tribes to implement air quality programs
under the Act.
The EPA Office of Air and Radiation (OAR) supports tribes in ambient air monitoring activities.
The funds that support the OAR Tribal Program are appropriated by Congress to assist tribes in
developing and implementing air quality management programs. Funds under the State and
Tribal Assistance Grants (STAG) appropriation are allocated among the Regional Offices, which
are responsible for awarding grants to tribes and tribal consortia, where appropriate. With goals
to protect public health, welfare and cultural values, the grants are used by tribes for activities
such as: identifying specific air quality issues; deploying and operating monitoring stations for
various pollutants; participating in the work of regional planning organizations; providing
education and outreach to tribal leaders and community members; developing and adopting air
quality regulations; and ensuring tribes are represented in regional and national policy
developments and initiatives.
Since 1999, funding of tribal grants has remained relatively constant while EPA's outreach to
tribes and the growing awareness of air quality issues among tribes has led to steadily increasing
numbers of applications and grants being awarded. In FY 1995, the EPA Regional Offices
awarded nine grants to tribes to conduct air quality work; by FY 2003, grants were awarded to
115 tribes.
EPA anticipates that requests by tribes for air grants will continue to increase, while the amount
of funds available may not. Air quality is becoming more of a priority for many tribes as they
become more aware of the potential impacts of airborne pollutants from local and distant
sources, as air pollution transport issues become more evident, and as tribes participate on
regional and national air quality initiatives. Tribes generally have a much better understanding
of the need for and importance of air programs than they did only a few years ago.
1 For the purposes of this document, the terms "tribe," "tribal", and "tribal government" refer to federally
recognized Indian tribes that are acknowledged by the Secretary of the Interior to exist pursuant to the Federally
Recognized Indian Tribe List Act of 1994, 25 U.S.C. Section 479a. See 67 Fed. Reg. 46328 (July 12, 2002). These
terms also refer to tribal consortia, as appropriate, where tribal governments have authorized consortia to act on their
behalf.
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Tribes are diverse in their air quality problems, challenges, and capabilities. Because EPA
Regional Offices understand individual tribal situations, effective decisions about funding and
in-kind assistance are best made at the Regional Office level. EPA has taken the approach of
delegating to the Regional Office level the roles of assisting tribes in identifying their goals and
managing the available resources to help meet those goals. To date, Regional Offices and
individual tribes have entered into many grants that have dedicated a significant portion of the
available tribal air management resources to plan, establish, and operate ambient air monitoring
stations in Indian country.
It is important that management policies ensure grant funds are used effectively and that there is
sufficient regional flexibility to consider and weigh the unique circumstances of individual
tribes. Since federal funds are not likely to increase in the near future, it will be important to
ensure that the funds are distributed appropriately and are based on strategic goals. These goals
must be articulated in clear and consistent grant criteria. The draft document titled: Protecting
Public Health and Air Quality Resources in Indian Country: A Plan for EPA/Tribal Partnerships
2008-2013 articulates these goals and should be used by the EPA Regions as a basis for
formulating the grant criteria. This document will be referred to as the "2008-13 Plan" for the
remainder of this document and will be finalized in 2008.
Concerns Expressed by the Tribes
Although this document addresses EPA goals, EPA has met with interested tribal professionals
to prepare this strategic guidance on tribal air monitoring. These tribal air quality professionals
have helped shape this document through their communication with EPA and the concerns they
have expressed about the approaches EPA has taken.
One point of concern expressed by tribal professionals is the budget allocation for tribal air
programs. As tribes become more aware of their air quality issues, and more tribes attempt to
secure funds for monitoring activities, they also become aware of the limited funds available to
support these activities. The tribes realize that they will be in competition with other tribes for
these federal funds and have expressed negative feelings with this competitive approach. Many
tribes do not have the time or the expertise to write "winning" proposals. Smaller tribes that may
have legitimate monitoring needs tend to be at a disadvantage to larger tribes or tribes that have
had past success. In addition, the tribes are aware that the EPA Regions use different approaches
in their grant allocations, leading to concerns about consistency.
EPA believes that tribes would like to follow as many of the monitoring requirements as
possible. Because they are often small organizations and resource limited, they cannot always
afford to implement certain requirements or secure and keep the technical expertise they need.
Tribes have hired and trained monitoring personnel only to see them hired at higher salaries by
private, state, or local agencies. This turnover means that training is required at higher
frequencies, but also that monitoring and or data reporting may be interrupted until replacements
can be found. In addition, some requirements, like QA programs, require a level of independence
that may be very difficult to meet by some tribal monitoring agencies. Tribes believe EPA needs
to be sensitive to these issues and help to find workable solutions.
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The data submission requirement to Air Quality System (AQS) has become an issue with some
tribes. The tribes feel the current level of AQS support has not been sufficient to meet their
needs and because data submission to AQS occurs so infrequently (every quarter at most); the
tribal information technology (IT) person has a hard time maintaining his/her skills. Some tribes
wanting to continue monitoring (using federal funds) may not want to submit data to AQS for
various political or cultural reasons and now feel they are being forced to comply. These tribes
may decide to discontinue monitoring or monitor using other funds to avoid submission
requirements.
Tribal members participated in the development of the National Ambient Air Monitoring
Strategy (NAAMS) and as of 2006, have had a representative on the National Ambient Air
Steering Committee. Some tribal professionals feel the motivation to study human health issues
(a tribal concern) is not addressed in the National Ambient Air Monitoring Strategy (NAAMS)2.
The document does have many useful details that address tribal air monitoring.
The NAAMS highlights that the NCore strategy could benefit from including tribes. Tribes can
provide additional monitoring sites, fill data gaps, and identify background conditions. These are
the reasons why tribal air monitoring can help the entire NAAMS. Tribes feel an
institution/organization with a nationally recognized leadership role in working with tribes on
environmental issues, such as the Institute for Tribal Environmental Professionals (ITEP), should
be identified to do the "representativeness" analysis for all tribes in certain regions of the U.S.
Identifying those tribes that are not currently represented by the NCore network will help in
providing the tribes with access to regional air monitoring data, so that they can determine the
status of their air quality. This project also should be aimed at locating opportunities for filling
tribal data gaps, as well as where air is pristine enough to provide data on background conditions.
An example of how this could be performed is the data gathering work ITEP performed for the
Western Regional Air Partnership (WRAP) in 2001. In this case, ITEP was able to gather data
for 156 of the 237 federally recognized tribes in the WRAP region. This project identified
several challenges and opportunities for tribal air quality programs in the Western U.S., and can
be used as a template all over the U.S.
2 http://www.epa.gov/ttn/amtic/monstratdoc.html
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OVERVIEW
1. Who are the intended readers and users of this document?
The intended audiences for this document are EPA Regional Office and Headquarters staff
involved in resource allocations, tribal air grant award and management, program evaluation,
strategic planning of monitoring networks, technical support to monitoring programs, or using
ambient air data collected from tribal monitoring programs. Higher-level EPA managers and
staff with experience and responsibility in these topics have reviewed the document to ensure
that it reflects EPA intentions and policies. Other EPA staff, especially new staff, should use this
document as guidance in their own work related to tribal monitoring programs and in explaining
those programs to others. State monitoring officials will find the document useful in improving
their understanding of tribal goals and how EPA strives to help tribes meet their goals so they
can collaborate more efficiently with tribes whenever collaboration serves state and tribal
objectives.
In addition, tribal environmental professionals may also benefit from this document. It should be
useful to those tribal professionals who want to apply for EPA funding support for ambient air
monitoring, or whose tribes are already receiving funding, by helping them understand EPA
practices and the reasons for them.
2. What are the purposes of this document?
The intended purpose of this guidance document is to help tribes and EPA Regions prioritize
monitoring needs, determine an appropriate level of funding for ambient air monitoring3 on tribal
lands relative to other air management work, and ensure that the funds are used effectively on
chosen projects. With support from OAR, the EPA Regions should:
1. provide a unified strategy for applying resources in support of tribes which allows them
to form the vision for their program themselves;
2. serve as information resources for tribes as they determine their need for monitoring,
prepare work plans and grant applications, as well as a one-stop resource for locating
technical information4;
3. ensure that tribal goals and measures of success for air monitoring are clearly stated and
documented in grant agreements (or other suitable forms) before resources under EPA
management are applied;
4. ensure that milestones and/or timetables are articulated within the grant;
5. track progress in meeting those goals and make adjustments when appropriate; and
6. recognize the need for flexibility to address the unique needs of individual tribes.
3 For ease of use, ambient air monitoring will refer, in general, to any type of air monitoring and will include for
example, criteria pollutant monitoring, IMPROVE, CASTNET, PAMS or toxics monitoring (NATTS or local scale)
4 In July 2007, a Technical Guidance Document for the Development of Tribal Monitoring Programs was developed
to provide the "one-stop" resource http://www.epa.gov/ttn/oarpg/tlpgm.html.
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Consistency-
Another goal of this document is to provide a level of consistency between OAR and the EPA
Regions in our expectations of tribal monitoring programs. Some of these expectations include:
Monitoring - There is an expectation that ambient air monitoring will be implemented
following the requirements developed for the specific data collection activity (i.e.,
monitoring for NAAQS or IMPROVE). There is an expectation that upon grant
approval, monitoring and data reporting commences within an appropriate and agreed
upon time period.
Efficiency - There is an expectation that the most efficient methods for meeting a
particular monitoring objective will be implemented. There have been circumstances
where tribes and states have worked together to achieve objectives of mutual benefit and
resource savings. The potential for teaming and cooperation should be encouraged in the
planning process.
Quality Assurance- Regardless of the type of monitoring, appropriate quality systems
will be developed for any monitoring program prior to commencement of routine
monitoring. In particular, any monitoring for NAAQS comparison must meet 40 CFR
Part 58 Appendix A requirements. OAQPS has developed a graded approach5 and
software to help tribes develop these documents. This approach provides the EPA
Regions flexibility during review and approval of the required quality assurance
documentation.
Data - There is an expectation that monitoring results will be reported to the Air Quality
System (AQS) or the appropriate national data base with very few exceptions. Data
should be reported, at a minimum, within nine months of the start of routine monitoring
implementation and then at agreed upon timeframes (i.e., quarterly).
Monitoring Completion - There must be some expectation agreed upon by the tribes and
EPA Region as to the length of the monitoring program. This length needs to be based on
the objective of the monitoring activity and subsequent data evaluation, but should be
articulated in the grant workplan or program documentation so false expectations on
commitments to long-term monitoring are eliminated. Any tribal monitoring should be
assessed at least every five years and a written determination made either to continue or
discontinue funding the activity.
Technical Support- Some tribes will need more technical help than others in developing
monitoring programs. In addition, some EPA Regions have different technical
capabilities. Good communication must be established to understand what technical
needs a tribe has, prior to approving a monitoring program, and to determine ways to
meets these needs in order to ensure monitoring program success.
This guidance document is rather general in nature, reflecting the need to accommodate the
diversity of tribal situations. Even though EPA should not and does not have a national strategy
for what types of monitoring should be conducted by specific tribes, EPA can and does have a
national strategy (or approach) for administering resources that it directs to supporting tribal
monitoring. EPA's budget for supporting tribal air quality management work of all types is not
large enough to allow approval of all requests from tribes for funds for monitoring programs. As
1 Graded Approach to Quality Assurance http://www.epa.gov/ttn/amtic/geninfo.html
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a result, EPA makes decisions about what tribal work to fund. While these decisions are made at
the Regional Office level and are not guided by a specific national strategy, there are general
guiding principles that the Regional Offices follow.
3. What are the guiding principles for working with the tribes on air monitoring?
The purpose of listing these guiding principles is to promote understanding and observance of
the principles by EPA staff and to help tribes anticipate and understand the basis for future EPA
actions. Most of these principles flow from the Clean Air Act, the EPA Indian Policy, the Tribal
Authority Rule, and other existing EPA rules and policies such as budget, quality assurance and
ambient monitoring. EPA Regional Offices may have their own guidelines or grant criteria. In
the course of developing this guidance document, Regional Offices have ensured their guidelines
and criteria do not conflict with the principles stated here. EPA's guiding principles include the
following:
(1) EPA has a responsibility to relate to each tribe on a government-to-government basis
and has a trust responsibility to act in the tribe's best interest. The federal Indian trust
responsibility is a legally enforceable fiduciary obligation, on the part of the United
States, to protect tribal lands, assets, resources, and treaty rights, as well as a duty to
carry out the mandates of federal law with respect to American Indian and Alaska
Native Tribes. To the extent possible, EPA should also take into account the tribe's
preferences. EPA is obligated to consult with tribes at an appropriate level. Input
from tribal environmental professionals was obtained starting at an early point in the
development of this guidance/strategy. However, EPA's consultation responsibilities
may require continued discussions between tribal leaders and appropriate EPA staff
or management.
(2) Tribes set their own air quality goals. As sovereign nations, tribes can set air quality
standards below the level of the NAAQS. EPA strives to assist tribes in setting air
quality goals and in determining how monitoring can help clarify and/or accomplish
those goals.
(3) Monitoring supported by EPA grant funds should always be for the identified purpose
of characterizing and/or managing specific known or suspected short-term and/or
long-term risks to environmental values that depend on maintaining or restoring good
air quality, including:
a. Human health risks
b. Ecological risks
c. Cultural resources and values, including those related to visibility.
(4) EPA and each tribe receiving funding to conduct monitoring should reach a clear
understanding, before operations commence, of the duration of the funding or the
timing and process for future decisions regarding continuation of the funding. There
needs to be periodic re-evaluation of the need for and value of ongoing monitoring,
for example on a three-to-five year cycle.
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(5) EPA supports tribal capacity building. Contractor support may be necessary and
appropriate in some situations, but generally is not the preferred approach to carrying
out monitoring. In the area of ambient monitoring, capability includes development
of monitoring objectives, development/execution of quality assurance plans,
installation and operation of the monitors, information management and reporting to
AQS, and understanding the implications and uses of the observed ambient
concentrations for appropriate air quality management purposes. EPA should seek to
provide tribes sufficient support and opportunity to progress through these stages.
(6) EPA has limited resources in its enacted budget to help pay for tribal air quality
management in general. EPA is, therefore, unable to support all monitoring in Indian
country that may have value to the affected tribes.
(7) There needs to be consistency, equitability and flexibility to address unusual or
unexpected tribe-specific situations.
(8) Decisions affecting specific tribes should be made at a level where individual
situations can be appreciated.
(9) Where technically relevant, EPA should encourage all parties to take advantage of all
available data on ambient air quality. Non-tribal monitors may provide useful
information on air quality in and around tribal lands.
(10) Tribes should have equal opportunity to participate in programs that are not
inherently tied to state/tribe distinctions. They also should benefit from resources
used to support those programs, where such access is consistent with program goals.6
(11) Grant procedures and grant performance must comply with applicable laws and
regulations.
(12) EPA will work with tribes to ensure that there is timely EPA and public access to data
collected with federal funds. EPA will need to explain the significance and need for
this access to tribes generally and to each grant recipient. EPA should help tribes
understand the significance of their data so they are aware of the data and its
implications.
(13) This EPA guidance does not limit any tribe's right to monitor for whatever air
pollutants it chooses in its own portion of Indian country, but rather addresses how
EPA will make decisions on what to fund and support within its available resources.
6 For example, EPA's CASTNET monitoring program is intended to monitor acid deposition across broad areas for
the purposes of national objectives. CASTNET is funded separately from the state and tribal air grant (STAG)
funds. Some CASTNET sites are currently located in Indian country. As strategically appropriate new sites are
contemplated, tribal lands should be considered equally with state and federal lands.
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4. Does this guidance supersede or change any previous guidance or procedures?
This guidance document is not intended to modify any existing EPA policies on tribal air quality
management, nor is it intended to set goals or timetables for the tribes. General tribal grant
requirements are published at 40 CFR Parts 31 and 35. Nothing in this document is intended to
supersede any part of the applicable regulations. This guidance document provides information
on applying resources in support of tribes as it relates to the 2008-13 Plan, but it allows
individual tribes to form their own vision for their ambient monitoring programs.
IMPORTANCE OF AIR MONITORING PROGRAMS AND EPA-TRIBE
RELATIONSHIPS
5. Why is having an ambient monitoring program important?
Tribes are concerned about the health and welfare of their tribal members and the environment
and on those activities of cultural significance. For these reasons, they may need to conduct
ambient air monitoring for a variety of reasons: (1) attainment with health and welfare-based
National Ambient Air Quality Standards (NAAQS); (2) impairment of visibility and biological
diversity for vistas within or near reservations; (3) supporting designations as a Federal Class I
area; (4) measurement of toxic air pollutants for health and ecological effects; (5) collection of
near-real time data for reporting Air Quality Index (AQI), to the tribal community, and to EPA's
AIRNOW real-time mapping program; (6) monitoring air quality relative to tribal environmental
and cultural resource concerns; (7) participation in a regional/state monitoring network; and (8)
determining air quality background levels and establishing air quality baselines. Appropriate
regulatory decisions or voluntary measures can be pursued from these monitoring activities to
restore air quality as needed. In addition, tribal participation in ambient air monitoring may also
serve to increase the tribal community's awareness of the health risks of indoor air and its
association with asthma and respiratory disease.
This spectrum of air quality issues is frequently shared with states, since pollutant transport and
meteorological systems ignore political boundaries. Tribes have a need to understand the short-
and long-term effects of long distance transport on tribal lands and the effects of atmospheric
deposition on the ecology of their lands. Tribes also need air monitoring data to identify the role
of off-reservation sources and to build support for controlling those sources. Examples of
programs for tribal participation include IMPROVE, CASTNET, NADP, MDN, ozone, PM2.5,
precursor gas (CO, NOx and 802) and toxic air quality monitoring. Any measurement
contribution from tribal monitoring efforts may be viewed as an asset to a larger integrated
national need for air quality measurements. Similarly, tribes should perceive some level of
ownership of air quality data collected on non-tribal lands that has relevance to tribal air quality
issues.
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6. What facilities, staff capabilities, and other resources (apart from funding) does a tribe
have to possess to make ambient air monitoring a realistic possibility?
Staffing-
A recent document titled: Technical Guidance for the Development of Tribal Air Monitoring
Programs1 has been developed to provide the tribes with information necessary to plan and
implement an air monitoring program. One section of the document provides a discussion on the
technical staffing necessary to implement an air monitoring program. There are a number of
important functions, depending on the type of monitoring accomplished, that tribes must be able
to accomplish or have funds to accomplish. Table 1 identifies these functions and provides some
of the key activities within the functional category. Not all functions are needed for long periods
of time. The tribe may feel that it can contract some of the functions that are needed. For
example, the tribe may wish to contract the information technology (IT) function to have the
monitoring instruments connected to a data logging system that would transfer data to a local
data base and eventually to an external data base like AQS. This part of the process might be
considered a "one-time" event needing a particular expertise and may not require a full time
person. However, someone within the tribe must have the ability to understand this IT function
to ensure data collection is operating properly on a day-to-day basis. Regardless of whether the
tribe possesses the expertise in-house, or will contract for these functions, resources are needed
and should be identified in grant documentation to cover the activities in Table 1.
Table 1 Monitoring Functions that Need Some Level of Staffing or Expertise
Function
Procurement
Technical
Data Analysis (Statistical)
Quality Assurance
Information Technology
Activities
- Purchasing capital equipment and consumables
- Developing contracts and maintenance agreements
- Applying for EPA grants
- Setting up a monitoring site, electricity, communications
- Developing standard operating procedures
- Selecting and installing monitoring equipment
- Calibrating equipment, performing quality control
- Shelter and equipment maintenance
- Understanding population and measurement uncertainty
- Developing sampling designs
- Developing networks to achieve objectives
- Assessing/interpreting data (data quality assessments)
- Developing quality systems, QMPs/QAPPs
- Developing data quality objectives
- Implementing technical systems audits, performance evaluations
- Validating data
- QA reporting
- Selecting information technology (data loggers and local data base)
- Developing analyzer outputs to data loggers and data transfer to local data base
- Transfering data from local data base to external data repositories (AQS, etc.)
http://www.epa.gov/air/tribal/airprogs.html
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Facilities-
Depending on the particular pollutants being measured and the type of instruments used to make
these measurements or collect a sample, a facility should be available that is capable of
calibrating instruments, performing repairs, storing spare parts/equipment, shipping and
archiving samples (e.g., cold storage). The facility should be capable of housing the information
management system including backing-up and archiving electronic data securely. A question
that may be posed is "does the tribe have a facility which can provide instrument repairs such
that a minimum amount of data loss (1 month) would be expected if an instrument
(analyzer/sampler) went down?" A tribe may not have the facilities or capabilities to perform
calibrations, maintenance, or repairs. If this is the case, then the grant documentation should
describe how these activities will be accomplished with a minimum loss of data and the
resources that will be allocated to this activity.
7. Does EPA support the full cost of a tribe's monitoring program? How does the
degree of funding for tribes compare to that for state/local agencies?
During the development stages of a tribe's monitoring program, EPA may support the full cost of
monitoring through the use of CAA ง103 state and tribal assistance grant (STAG) funds. Section
103 grants are for air program planning and short-term projects and have the advantage of not
requiring the tribe to match any of the federal funds. Since many tribal monitoring programs
may be using data to compare to National Ambient Air Quality Standards (NAAQS) which
may take 1 year to plan, 1-3 years for data collection, and a year for information management,
data reduction and assessment use of ง103 funds may be 3-5 years for any specific monitoring
project.
If the tribe wants to continue monitoring after the initial monitoring period, they may seek CAA
ง105 funds for the monitoring program 8or continue to apply for ง103 funds. There is no
guarantee the ง103 funds will be available for a particular tribe to continue monitoring past the
initial funding period.
Although there can never be a guarantee of ง105 funding, ง105 fund recipients have a greater
chance of receiving ongoing funding and cannot have their grant reduced without an opportunity
for a hearing. The disadvantage is that the tribes must provide some matching funds for
monitoring. The match cannot be made up from other federal government funds. Information on
tribal match requirements can be found in 40CFR ง 35.575 or 40CFR ง 49.4{q}
http://www.gpoaccess.gov/cfr/index.html. In addition, the tribes should know that they are
eligible only for the specific tribal ง105 funds, and may not compete for the ง105 funds allocated
for state and local monitoring organizations.
Degree of Funding
40 CFR Part 49.4 makes it clear that the ง105 grant federal maximum contribution of three-fifths
(60%) for state and local monitoring agencies does not apply to all tribes. There are differences
! Ambient air monitoring is just one of many ง105 activities.
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in the maximum federal financial assistance that can be provided depending on whether the tribe
has demonstrated eligibility to be treated as a state under 40 CFR Part 49.6.
Demonstrated Eligibility to be Treated as a State -
As described in 40CFR Part 35.575, for tribes that receive funds under ง105 and that have
demonstrated eligibility to be treated as a state under 40 CFR Part 49.6 "the Regional
Administrator may provide financial assistance up to 95% of the approved costs of planning,
developing, establishing or improving an air pollution control program, and up to 95% of the
approved costs of maintaining the program." After two years, the Regional Administrator can
reduce the maximum federal share to 90% if it is felt, based on objective assessment, that the
tribe has the ability to increase its share.
Not Demonstrated Eligibility to be Treated as a State -
If the tribe has not demonstrated eligibility under 40 CFR Part 49.6, the Regional Administrator
may provide financial assistance under ง105 in an amount up to 60% for planning and
maintaining a monitoring program.
In general, since many tribes are small, run small monitoring programs, and may be operating
with limited resources, the federal contribution tends to be larger than those for state and local
monitoring agencies that have been operating for a significant period of time. However, the
amount of federal financial assistance granted to each tribe will reduce the overall amount of
tribal assistance within the Region. Decisions will need to be made to either fund fewer
programs with a higher percentage of federal funds or fund more projects but allocate fewer
federal funds to each.
8. What are the differences between EPA's relationships with states regarding monitoring
and EPA's relationships to tribes regarding monitoring?
In most cases, EPA's relationship to tribes and states are similar with regard to air monitoring.
When tribes are implementing ambient air monitoring for specific objectives, such as
comparison to the NAAQS, then 40 CFR 58 requirements for network and siting criteria, method
use (federal reference or equivalent methods), and QA requirements must be followed. When
tribes are cooperating or participating in national programs such as IMPROVE, there is an
expectation that the implementation requirements of these programs will be met. Therefore,
when tribes participate in national monitoring programs their relationship with EPA is similar to
the state relationship. EPA does provide some allowances and flexibility in regards to timelines,
data submission and the techniques to achieve the monitoring requirements. As an example,
EPA is working with the tribes on a strategy to submit data to AQS. This strategy may allow for
more time to submit data to AQS than is required by state and local monitoring organizations.
Tribes implementing special purpose monitoring for other objectives not national in scope will
not need to meet CFR requirements. However, if the monitoring is funded by EPA, the tribe will
need to develop an appropriate quality assurance project plan (QAPP) and quality management
plan (QMP) which will describe the appropriate siting, methods and quality assurance activities
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needed to achieve the objective. EPA Regions can work with the tribes to ensure the usability of
this information and may suggest that it conform to as many of the ambient air monitoring
requirements as applicable without being cost-prohibitive. This will allow the data to be used for
multiple purposes.
9. Can tribes participate in NATTS, local scale air toxics, IMPROVE, CASTNET, NADP,
and/or NCore monitoring programs?
Yes, tribes have the opportunity to participate in any national monitoring program provided that
the tribes are providing the funds for that activity. EPA will not obligate or even strongly
encourage a tribe to conduct any particular monitoring that would be mostly helpful in meeting
national objectives unless EPA is providing extra resources beyond those originally designated in
its budget for support of tribal air quality management. The following is a summary of what the
NAAMS provides with regard to monitoring:
Tribal nations generally are seeking to expand ambient air monitoring efforts, and it is
generally recognized that there is a substantial need for tribal air monitoring support.
Nothing in the NAAMS imposes requirements regarding tribal monitoring or mandates
linkages of tribal air monitoring with national networks.
Tribal participation in national monitoring networks can benefit all parties as
opportunities exist for tribes to operate NCore multi-pollutant sites, particularly in rural
areas where there remain significant spatial gaps in monitoring. There are many rural
tribal airsheds that could be considered pristine and, therefore, excellent candidates for
background monitoring sites, potentially filling in important gaps in the nation's network.
Tribes will be given fair consideration for hosting sites of national interest, and for
receiving associated funding. In making determinations on sites for rural monitors, EPA
is committed to considering Indian country on an equal basis, such as for CASTNET or a
possible new mercury deposition network. It is also possible that some NCore multi-
pollutant rural stations might best be sited in Indian country.
These comments are not intended to suggest that the tribal monitoring priority is, or should be, to
foster a connection to national networks. Most of the tribal monitoring priorities involve
developing a better characterization of local exposure to air pollutants, and utilize funding
separate from funds that would be used to host national network sites. The linkage to national
programs should be perceived as leveraging opportunities that simultaneously benefit tribes and
the state/national networks. As an example, tribes in Maine have worked with the Maine
Department of Environmental Protection and EPA Region 1 to develop a cooperative air
monitoring network that shares important resources (shared QA and data management support)
and serves the needs of these monitoring agencies.
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10. Does EPA set overall goals for its support to ambient air monitoring by tribes? How
does EPA evaluate success in meeting those goals?
Yes, as described in the 2008-13 Plan, OAR has developed a broad set of 5 goals:
1. Provide financial and technical support to tribes, with assistance from the EPA Regions,
to assess air quality (and potential health concerns) within its jurisdiction.
2. Build tribal capacity to implement air quality programs.
3. Support a wide variety of training activities, outreach and detailed technical support.
4. Ensure that the appropriate mechanisms and tools exist to address regulatory and non-
regulatory program needs in Indian country.
5. Develop and implement the use of voluntary programs to address the specific needs of
tribes in areas such as indoor air quality outreach, mobile source emissions and exposure
to ultraviolet (UV) radiation.
Goal two and four provide support for ambient air monitoring, but within the context of the
goals, the tribes decide what ambient air monitoring is needed. As mentioned earlier, resources
may not be adequate to cover all requests from the tribes for air monitoring. In order to ensure
that EPA is targeting its funding to ensure the greatest possible health and environmental
benefits, funding decisions should address one or both of the following overriding factors:
1. Significant Air Quality-Related Health Concerns: A tribe has, or is believed to have,
a significant air pollution problem that has an adverse impact on human health. An air
pollution problem would include, but not be limited to: a reservation or a portion of a
reservation being designated nonattainment; air toxics issues; atmospheric
deposition/bioaccumulation issues; and indoor air quality concerns (except radon). On-
reservation population size (tribal and non-tribal) may be considered as part of this factor.
2. Significant Air Quality - Related Environmental and Cultural Resource Concerns:
A tribe has reasonable concerns that air pollution is having an adverse impact on cultural
resources or the environment within its jurisdiction. Issues such as visibility concerns
and modeled or monitored Class I increment violations under the Prevention of
Significant Deterioration regulation would be addressed here. On-reservation population
size (tribal and non-tribal) may be considered as part of this factor.
Evaluating Success
EPA is very aware of the importance of being able to document that the success of the tribal
assistance portion of the Air Program. EPA can evaluate the success of ambient air monitoring
efforts by:
allowing the tribes to set their own ambient air monitoring goals;
ensuring that the individual grants have goals that are well articulated, and provide
measurable outcomes and environmental results; and
selecting the most appropriate grants to fund (these then become EPA goals).
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One of the keys to measuring success is being able to supply management and interested parties
with information about tribal monitoring programs, how the monitoring program's information is
being used, and the key assessments that demonstrate success. OAR is collaborating with the
EPA Regions to develop a tribal database that will accommodate these important pieces of
information. This database is expected to be operating and collecting data in 2008. Some of the
information in this database will be derived from "pulling" information from other databases and
some will be input directly from the EPA Regions. Tribes will not be required to maintain or
physically input data directly to this system.
11. How does EPA ensure that funds given to a specific tribe for ambient monitoring are
used efficiently?
As described in the document: The Tribal Air Grants Framework- A Menu of Options, 9one way
to ensure that funds provided to the tribes are used efficiently is to ensure that proposals
submitted for federal funds have:
1. One or more objective(s);
2. activities that support the achievement of the objective(s);
3. outcomes or deliverables that will produce environmental results within the
objective(s); and
4. performance measures and milestones that help to measure progress in achieving the
environmental results.
Federal funds should be allocated to those projects that clearly address the highlighted items
above. In November 2007, EPA produced a document titled: Technical Guidance for the
Development of Tribal Air Monitoring Programs10. This document provides materials for the
tribes to determine the need for monitoring and the basic technical requirements to consider for
planning and implementing a monitoring activity. In addition, the document provides guidance
on how to write workplans/proposals that articulate the items highlighted above.
With regards to whether funds are being used efficiently, the EPA Regions will need to balance
their response between achieving the monitoring objectives and the goal of capacity building.
With these aspects in mind, EPA Regions should review the workplan with an eye to whether the
objectives are being accomplished efficiently from the standpoint of:
Technology - Will the objectives best be met with the chosen technology or can the objective be
met just as well with something less costly or over shorter periods of time?
Collaboration/Cooperation - Could the tribe partner with other entities that can help meet the
objectives?
Infrastructure- Is the tribe requesting funds for infrastructure that may not be the most efficient
use of funds for this particular project?
Available on OAR website http://www.epa.gov/air/tribal/grants.html
10 http://www.epa.gov/air/tribal/airprogs.html
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As an example, a tribe may propose a short term PM2.5 monitoring program (initial objective to
assess if the tribe has PM2 5 problems it should be aware of) for which the tribe requests funds
that includes development of a PM2.5 filter weighing laboratory. It may be more efficient from
the initial assessment aspect of the project to procure laboratory services rather than purchase
laboratory equipment, develop a lab with adequate filter weighing conditions, and hire/train
personnel to weigh filters. However if the tribe's initial assessment found that PM2 5 is an issue
and there was a commitment to long-term monitoring, then a laboratory may be considered
feasible and an efficient use of funds.
During the communication process with the tribes on funding ambient air monitoring projects,
there should be a discussion of project completion. The proposal should relate completion to the
achievement of stated objectives or environmental results. If a tribal ambient air monitoring
project meets the objective for which it was funded, EPA should declare success in order to
enable the funding of other priority projects within the tribal community. Discussing the issue of
project start and completion with tribes up front will acknowledge the importance of meeting the
objectives and provide the tribes lead time to either find other sources of funds or apply for
additional funds that may further the objective or improve the environmental results.
It is important that tribes identify the performance measure/milestones that will allow the
tracking of progress and that these are described in the grant agreements so that both the tribes
and EPA know what they are, are in agreement, and can work cooperatively towards a successful
project or product. These measures and milestones should be set such that they can be reviewed
at some appropriate frequency (e.g., quarterly) so that if problems are occurring, they can be
discovered and resolved quickly. Documenting the goals that are achieved will communicate the
success of these monitoring programs and help garner support for more resources in the future.
By establishing a good communication process with the tribes and having well documented goals
and performance measures, EPA can avoid situations where projects falter or do not meet
performance measure and milestones. If a project is not meeting expectations, it should not
come as a late surprise to the tribes or EPA. Depending on the outcome of discussions, it may be
necessary to discontinue funding a project until the best method to get the project back on track
can be determined.
Encouraging Collaboration/Cooperation
Because resources to fund important environmental projects are becoming increasingly scarce,
collaboration among tribal and non-tribal organizations can provide solutions to the benefit of
all. EPA Regions can help foster this collaboration. Examples of successful collaborations
include:
The Nez Perce Tribe, Region 10, and Idaho Department of Environmental Protection
have successfully collaborated on the development of a smoke management plan.
The Salt River Pima-Maricopa and Gila River Indian Communities, Fort McDowell
Yavapi Nation, Maricopa County, Institute for Tribal Environmental Professionals,
Arizona Department of Environmental Quality, Arizona Department of Transportation,
and the EPA (Region 10 and OAQPS) have collaborated on the Joint Air Toxics
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Assessment Project. The parties have partnered to develop a monitoring site for a
Differential Optical Absorption Spectroscopy (DOAS) instrument that is currently
collecting and reporting "real-time" toxics data.
Several tribes in the Northeast operate ozone and PM2.5 air monitoring sites in areas that
the states are less able to monitor. The Wampanoag Tribe of Gay Head at Aquinnah, MA
(Martha's Vineyard) operates an air monitoring program consisting of an ozone monitor,
an IMPROVE sampler and a meteorological station in partnership with the Massachusetts
Department of Environmental Protection. The state provides quality assurance audits,
data entry into AQS, and technical support for the ozone monitoring and the Tribe
operates and maintains the site. EPA provided the air monitoring equipment and data
logger through the Tribal Air Grant Program.
The Nez Perce, Yakama Nation, Umatilla and Warm Springs Tribes are involved in a
cooperative effort to look at air impacts in the Columbia River Gorge Scenic Area where
all four tribes have treaty fishing rights.
These are but a few examples of the cooperative/collaborative efforts occurring throughout the
EPA Regions. The EPA Regions should document these successes and use them as examples as
ways of extending limited monitoring resources and working in an efficient manner.
12. How much time does EPA allow a tribe with a new grant for ambient monitoring to be
operating its new monitors, have a QAPP in place, and reporting data to AQS?
In general, a tribe will need about one year from the award of a grant to prepare for a new
monitoring activity. It is important to recognize the work involved in developing a new
monitoring capability. The tribe will typically be required to:
identify and purchase the appropriate equipment and consumables;
select and build/procure site(s) including outfitting electrical and communications
services;
develop information management systems including local systems and communication to
national data bases;
seek the necessary expertise and/or the necessary training to implement monitoring; and
develop QA documentation (QMPs/QAPPs/SOPs).
The document Technical Guidance for the Development of Tribal Air Monitoring Programs
provides more detail on activities and personnel necessary to develop and implement a
monitoring site or network and should be used to assist the tribes in making good monitoring
decisions. EPA Regions should encourage collaboration with successful monitoring
organizations to help in the selection of equipment and information technology. Tribes should
also be aware of the training opportunities offered by EPA Headquarters, the EPA Regions,
ITEP, TAMS, RPOs, state monitoring organizations and various national organizations.
It is an EPA requirement to have a QAPP in place and approved before an environmental data
operation begins (see Question 14).
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MONITORING REQUIREMENTS AND DATA REPORTING
13. Why is it important for tribal data to be reported to AQS? Are there other
alternatives that are acceptable to EPA, if preferred by a tribe?
While recognizing the sensitivity of tribes to the use of their data, OAR expects tribal grants to
include a grant condition for quality-assured monitoring data to be submitted on a timely basis to
the Air Quality System (AQS) or other relevant databases (e.g., AQS is not able to receive the
data directly from the CASTNET or IMPROVE networks at this time). EPA also encourages
tribal participation in AirNow, but this does not need to be a condition required in the grant
unless this is one of the primary reasons for monitoring. The following are some advantages to
submitting data to AQS:
Builds tribal capacity and familiarity with EPA staff and systems.
Demonstrates that tribes are active in environmental issues.
Brings tribal participation to national awareness when tribal data is used in NAAQS
decisions, trends evaluations or the Air Quality Index.
Makes data available to EPA tribal staff that must assess grant performance and plan
future directions.
Provides automated range checking, data quality assessments and ensures all calculations
are accomplished as required in EPA regulations; reducing the programming burden on
the tribal offices.
Ensures data meet an acceptable level of quality and comparability which helps in data
sharing and building partnerships.
Can become the final data repository and data archive.
- AQS data are secure and can be recovered
- Can be retrieved in different formats
AQS system is available at no cost
AQS provides:
- Data base and reporting enhancements. Recent enhancements to AQS eliminated
tribal concerns regarding use of state codes to enter tribal data;
- training; and
- support team for assistance through help desks and conference calls.
Takes advantage of other sophisticated Web tools like AirNow and Air Explorer and the
numerous reports available.
Although AQS reporting is a "front-end" investment in time for the tribes, the pay-off is the
wealth of statistical data evaluation and mapping tools that become available to the user once
their data are in the AQS system.
Some tribes performing air monitoring have not submitted data to AQS. OAR has worked with
ITEP to develop a strategy to increase the number of tribes reporting data to AQS. EPA Regions
will need to communicate to the tribes on the approaches in this strategy. However, the first
approach will be to ensure that grant conditions require the submission of data to AQS for
relevant tribal air monitoring programs.
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There does not appear to be any acceptable alternative to tribal submissions to AQS that would
not increase the burden on EPA Regions or OAR staff to support such an alternative system.
Prior to AQS re-engineering, when the system was mainframe based, a monitor type "9" was
used to secure certain monitoring data from access to the general public. During the re-
engineering process, OAR determined that this process should be discontinued. Tribal concerns
related to data submission frequently stem from other entities having access to the raw data and
making assessments that could be detrimental to tribal issues. Any alternative system that would
provide data to EPA (e.g., to the EPA Regions) would still be accessible by the public through
the Freedom of Information Act and so would not ameliorate this concern. EPA "regional" tribal
databases would make it difficult to perform national assessments particularly when and if
NAAQS attainment decisions need to be made, in addition to the fact that one cannot take
advantage of many of the new web applications available to information supplied to AQS.
14. Why is it important that tribes adopt and follow a quality assurance project plan and
quality management plan (QAPP/QMP)?
EPA QA Policy 5360.114 requires that all organizations funded by EPA for environmental
data collection develop QMPs and QAPPs before collecting data. In addition, monitors in
Indian country must be properly sited, use adequate technology, and follow prescribed QA
procedures in 40 CFR Part 58 Appendix A (including reporting quality data to AQS) if a
tribe wants to use data from the monitor to compare to the NAAQS. Independent of the
requirement, these QA documents are important because they:
identify the reasons for collecting data and for collecting it in a specific way;
document how the data are collected and how quality is maintained;
ensure data will be collected in the same way
- from day to day; and
- from one person to the next.
Tribes should approach the development of QAPPs and standard operating procedures (SOPs) as
an investment. Tribal monitoring programs are known to have high personnel turnover rates
which can cause monitoring program delays and downtime until new personnel are hired and
trained. The QAPPs and SOPs, if written properly, serve to preserve the institutional technical
knowledge of the tribes monitoring approach and can be used as a training tool. This alone is
reason to ensure these documents are in place. In the past, EPA has been able to use QAPPs and
SOPs to defend an agency's data; without them, data may be considered suspect.
Guidance for the development of these QA documents can be found on the EPA Quality Staffs
website11. In addition, EPA has provided flexibility to EPA organizations on how they
implement this policy, allowing for use of a graded approach. Because EPA funds the collection
and use of data for a number of monitoring objectives and for organizations with a broad range
of capabilities, flexibility in the QMP and QAPP requirements is necessary. For example, data
collection for the purpose of comparison to the NAAQS is associated with more stringent
requirements, while monitoring programs for special purposes may not require the same level of
http://www.epa.gov/qualityl/
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quality assurance. The level of detail of QMPs and QAPPs, as explained in the EPA Quality
Manual, "should be based on a common sense, graded approach that establishes the QA and QC
requirements commensurate with the importance of the work, available resources, and the unique
needs of the organization." The ambient air program has developed a graded approach that will
help the tribes develop both QMPs and QAPPs. In April 2007, the ambient air monitoring
graded approach12 was distributed to the Regional Tribal Air Coordinators and the Regional
Ambient Air Contacts.
QA requirements and/or guidance have been developed for most of the major national
monitoring programs. Many programs such as the PM2 5 Chemical Speciation Network and the
National Toxics Trends Network (NATTS) have developed program QAPPs that should be
adopted by the monitoring organization by providing written confirmation to the EPA Regions.
There is also an opportunity for tribes and states to consolidate monitoring sites into one primary
quality assurance organization (PQAO). Region 1 has adopted this approach where tribes and
the state monitoring organizations have consolidated to one PQAO13. This will allow tribes to
adopt one QAPP and set of SOPs. There must be written confirmation of this activity on file in
the EPA Regional Office identifying all monitoring sites and organizations for which the
QAPP/SOPs apply, and each tribe should have these documents available at its offices.
OAR has worked with ITEP to develop a generic ambient air monitoring QAPP software product
called Turbo-QAPP. Turbo-QAPP mimics the functions of "tax software" to lead tribal
monitoring personnel through the development of their project specific ambient air monitoring
QAPPs. Turbo-QAPP should help tribes by providing most ambient air monitoring guidance for
the criteria pollutants within a click of a mouse. For information on Turbo-QAPP, contact ITEP
http: //www4. nau. edu/itep/index. asp.
Once the tribe has finished writing the QAPP, it is submitted to the Regional Office for approval.
QAPPs should be written and approved before any "official" data is collected. The QAPP
provides EPA some assurance that the monitoring organization has performed adequate planning
to control and assess the quality of its data before funds are spent on data of questionable quality.
In many cases, EPA provides funding for the tribal monitoring organization to purchase the
necessary equipment and consumables to start a monitoring project, as well as time to become
familiar with the instruments in order to develop an adequate QAPP.
15. How does EPA help tribal monitoring programs satisfy the 40 CFR Part 58 Appendix
A requirement to have adequate and independent performance evaluation audits (NPAP
and PEP)?
Most of the QA requirements in 40 CFR Part 58 Appendix A are performed by the monitoring
organization. These checks are very important and should be submitted to AQS along with
routine data. Requirements like the National Performance Audit Program (NPAP) and the PM2.5
Performance Evaluation Program (PEP), although they are the responsibility of the monitoring
12 http://www.epa.gov/ttn/amtic/geninfo.html
13 See OAR Tribal Newsletter November, 2007 edition http://www.epa.gov/air/tribal/tribalnws.html
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organizations, are being performed, in most cases, through federally implemented programs
using STAG funds.
The Appendix A requirements are specific to data that are collected for comparison to the
NAAQS. Tribes monitoring for NAAQS comparison purposes must follow these requirements
including participation in the NPAP and PEP programs. This should be acknowledged during
grant negotiations. Tribes monitoring for other purposes are encouraged to participate in these
two programs, as well as the other QA requirements in Appendix A, but it is not a requirement.
The tribes, similar to all state and local monitoring organizations, have the option of
implementing the program themselves (through a number of options including contracting) or
utilizing the federally implemented program with an appropriate redirection of STAG funds to
EPA to support the audits. Tribes will need to meet specific criteria for adequacy and
independence before being able to self-implement the audit programs. In addition, there are
some cases where a Regional Office or a state may be able to perform these audits for the cost of
consumable supplies. EPA Regions 1 and 7 provide all or some portion of the audits for
monitoring organizations in its region.
Tribes requiring the audits or wishing to participate in them need to make this decision each
year. In April 2007, OAR developed a whitepaper14 that explained the options available to the
tribes. This document should be a used as a "communication" starting point to provide an
understanding of the programs and the specific options available for implementation. A form,
included in the whitepaper, can be used during the grant application process to collect the
information needed to address implementation decisions each year.
STATUS OF MONITORING NETWORKS
16. How many tribes are monitoring their air quality using funds from EPA? Are the data
from this monitoring available to others?
The OAR Tribal Program has accomplished significant gains in the short number of years since
its inception in 1996. As of 2007, 120 tribes received grant support and some of these tribes are
operating the 150 air quality monitors in Indian country. Tribes have continued to progress from
assessments to program development and 26 tribes have received eligibility determinations of
CAA authority under the Tribal Authority Rule. These more experienced tribes are beginning to
complete Tribal Implementation Plans for submission and approval- two have been submitted to
date and several more are in development. Tribes have also expressed interest in PSD
redesignations to reclassify their airsheds for optimum protection against deterioration, and to
date, nine tribes have redesignated their airsheds to Class 1 under PSD. Over 100 tribes
participate in Regional Haze planning organizations, and the Western Regional Air Partnership is
currently co-chaired by Councilman Lloyd Irvine, of the Confederated Salish and Kootenai
Tribes. We expect this trend to continue, and the Tribal Operations Committee is reflecting this
increasing interest in air programs in Indian country. EPA continues to strive to support the
ongoing needs in this growing program.
14
Options Available for Tribes to Meet Independent Performance Evaluation Requirements for the Ambient Air Monitoring
Programs Collecting Data for Comparison to the NAAQS http://www.epa.gov/air/tribal/announce.html
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Over the past several years, 96 tribes have implemented air monitoring programs using tribal air
grants provided by EPA (84 tribes were collecting ambient air data as of July 2007). As
expected, most of the data collection activity is located in the Indian country west of the
Mississippi River where about 80 percent of the monitoring sites are located, primarily in EPA
Regions 6, 8, 9 and 10. To date, approximately 80 percent of the tribes with monitoring
programs have reported their data to AQS or other national data bases (IMPROVE, CASTNET)
and about half of those tribes submitted their data themselves while the other half relied on some
type of assistance from another tribe, an EPA Regional Office, a state agency or a contractor. Of
the six criteria pollutants, data are being collected primarily for ozone, PMio, and PM2.5.
17. How does EPA help a tribe understand its air quality in the absence of a monitoring
program?
In the absence of monitoring on tribal lands, EPA assists the tribes by providing access to
important data evaluation tools and data sources. OAR has recently completed revision on a
document titled: Technical Guidance for the Development of Tribal Air Monitoring Programs15,
which was developed to help tribes gain a better understanding of the ambient air monitoring
process and to provide information on resources and tools to build and sustain air environmental
monitoring programs. A section of the document provides information on various web-based
tools for air quality assessments, the types of models available and how they are used. In
addition, the document provides web links to many ambient air data sources and tools, most of
which are available on the OAR website.
EPA has been successful at building various data assessment tools, but tribes also need to
understand the basis for using these tools and should be trained on various aspects of air quality
monitoring and assessment. EPA works with the ITEP to sponsor training courses at the Tribal
Air Monitoring Support Center16 (TAMS). TAMS was created through a partnership between
tribes, the ITEP and EPA. It is the first technical training center designed specifically to meet
the needs of tribes involved in air quality management and offers an array of training and support
services to tribal air professionals. EPA participates in many of the training activities and this
assistance should continue to be encouraged. EPA Regions should get involved in this training
because it helps to build relationships with the tribes.
Many EPA Regions offer training on various aspects of air monitoring and may offer to share
this expertise with other EPA Regions. For example, if a few EPA Regions have expertise in
AQS reporting they may be able to provide this training to tribes in regions that are not as
familiar with AQS, or that do not have the same capacity to help tribes in this area.
ADDITIONAL INFORMATION
15 http://www.epa.gov/air/tribal/airprogs.html
16 http://www4.nau.edu/tams/
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18. Where can a tribe get more information on ambient monitoring and on other air
quality topics that relate to monitoring?
The Ambient Monitoring Technology Information Center (AMTIC)17 is the foremost website for
the ambient air criteria pollutant network. The site is operated by EPA's Ambient Air
Monitoring Group (AAMG). AMTIC contains information and files on ambient air quality
monitoring programs, details on monitoring methods, quality assurance guidance and reports,
relevant documents and articles, information on air quality trends and nonattainment areas, and
federal regulations related to ambient air quality monitoring. AAMG is in the process of revising
this website and looks for the EPA Regions to help provide review/critique to make this website
more useful.
The guidance document mentioned in Question 17, Technical Guidance for the Development of
Tribal Air Monitoring Programs, was developed to help the tribe plan and implement a
monitoring program and assess the data collected from their program. This document discusses:
steps for identifying goals and objectives for conducting air monitoring;
information for planning and selecting the appropriate type of monitoring network
including discussions of staffing, network design, monitor selection, quality system
development and training;
costs for operating a monitoring network, funding sources and tips and resources for
writing a grant proposal and work plan;
implementation of monitoring networks;
data acquisition, management and reporting; and
data analysis and interpretation including information on modeling techniques.
The document might be considered the "yellow pages" of information on ambient air monitoring.
It is not intended to provide the details of each specific monitoring program, but it can provide
the key attributes and web addresses that would lead one to those details. Although it is
somewhat skewed toward traditional "NAAQS" monitoring, it attempts to be generic and
contains fact sheets (Appendix A) describing many of the major national air monitoring
programs like IMPROVE, CASTNET, PAMS etc. These fact sheets contain the pertinent web
addresses where more information on the programs objectives, methods, guidance, or data
attributes can be found. The document is posted on the OAR Tribal Website18. Appendix B of
this document also provides some general background on ambient air monitoring and may be
very useful as a guide to the tribes.
17 http://www.epa.gov/ttn/amtic/
18 http://www.epa.gov/air/tribal/airprogs.html
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APPENDIX A
GRANT RELATED MATERIAL
The Funding Process
EPA request
to OMB/President
OMB/President
request to Congress
Congress
appropriates to EPA
EPA allocates
to HQ/Regions
Ambient air monitoring is one of many activities that is supported by federal funds for air quality
management. The following information provides a brief synopsis of how funds are provided in
support of air quality management in Indian country. Although this section goes beyond ambient
air monitoring, it provides a beneficial understanding of the current allocation techniques and
how ambient air monitoring fits into the overall allocation scheme.
Each year, EPA requests a certain amount of funding for use in providing grants to tribes to
support air quality management. For the last several years, Congress has appropriated about $11
million for this purpose.19 An increasing number of tribes are interested in establishing
monitoring stations, and not all interested tribes will be able to obtain EPA financial support for
ambient air monitoringif resources for tribal air quality management remain steady. Many
Regional Offices report that they are not able to meet all requests to provide grant funds for tribal
air monitoring. The experience of working across Headquarters and Regional Offices and with
tribal professionals has better informed EPA staff and EPA budget decision-makers about the
tension between resources and needs. Based on this growing tension, in April of 2005, a
workgroup representing each of the EPA Regions participating in the Tribal Program (as
appointed by their respective Division Directors) and OAR convened to discuss revising the
principles by which the tribal STAG allocation to the Regional Offices was determined.
Meetings were held roughly every two weeks, and the Workgroup arrived at a set of draft
recommendations20. Additional input was received from EPA's Air Program Managers followed
by discussions with EPA's Air Division Directors and extensive outreach and discussions with
tribal government representatives nationwide.
In FY 2005, EPA proposed to Congress that there be separate amounts of air grant funding for states and tribes.
EPA observes these two separate ceilings in its operating plan under the enacted FY 2005 budget. EPA has
proposed the same separation for FY 2008, and EPA has issued grant and technical guidance for FY 2008 based on
this separation. The proposed 2008 budget provides ~ $ 11 million, see http://www.epa.gov/ocfo/budget/.
20 April 24, 2007 Memo from Barrel Harmon to Beth Craig and Regional Air Directors on STAG Allocation
Revisions
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General Principles for STAG Distribution
The principles generally fall into three categories: 1) to target funds based on priority
considerations as surrogates for risk; 2) to target funds based on stability considerations, and; 3)
to balance support for new and ongoing programs (such as ง103 and ง105). The Workgroup's
approach was to reach consensus while recognizing that a balance was required between
considerations for priority and stability. These principles were developed by the entire group:
discussed, refined and restated as the following:
1. EPA supports the development of tribal air monitoring programs to assess, understand
and address problems affecting the health and environment of federally recognized Indian
tribes. While all tribes are eligible for support, our priorities are to address areas with the
highest risks and those where the greatest results are being realized when funds are
unavailable to meet every request.
2. As stated in the January 27, 2005, Assistant Administrator memo on awarding STAG
funding to tribes: AWe should recognize that some tribal governments made long-term
commitments to develop and implement air quality programs (programmatic
commitment) and, AWe should also recognize tribes that have emerged or are expected to
emerge as leaders or key participants in providing tribal input into external factors that
affect air quality management nationwideฎ (leadership and involvement).
3. Funding levels to each Region should remain relatively stable over time.
4. All federally-recognized tribes and tribal consortia are eligible for funding regardless of
their air quality status, but are not assured of receiving a grant due to limited funds.
5. Every Region with federally recognized tribes should receive some portion of the
available funding each year.
6. Grant resources are limited so EPA Regions must prioritize on what basis tribes receive
funds.
7. In allocating tribal resources at the national level (Region by Region), relative need,
capability, and past accomplishments also need to be considered.
8. The allocation should support the ongoing operations of CAA 105 tribal air quality
programs.
9. EPA will seek the input of the tribes in devising a strategic and equitable funding
allocation.
10. Adequate funding coverage of large, complex tribal air quality programs should receive
priority consideration.
The full document can be found at the Tribal Grants and Funding Website21. Headquarters will
continue to secure funds to support national priorities, specifically the national tribal training
program through the Institute for Tribal Environmental Professionals (ITEP) and the Tribal Air
Monitoring Support (TAMS) Center.
Memo summarizing the process of revising the tribal STAG allocation http://www.epa.gov/oar/tribal/grants.html
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Major Tribal Funding Sources
EPA is committed to working with tribes to develop and implement CAA programs in Indian
country. One of OAR's primary tools in this effort is to award CAA grants in order to help build
tribal knowledge and increase the tribes' capacity to manage air quality issues. General
Assistance Program (GAP), CAA ง103 and CAA ง105 grants all allow EPA to provide support
to tribes for this purpose.
GAP: The Indian General Assistance Program 22 (GAP) provides resources to tribes to
"build the basic infrastructure of a tribal environmental program, which may include
planning, developing, and establishing the administrative, technical, legal, enforcement,
communications, and environmental education and outreach infrastructure." The
planning and development elements of a GAP program can include specific activities
related to assessing environmental degradation and acquiring the tools to complete the
assessment. For instance, a tribe may want to know the extent of degradation in its air
quality to determine whether or not a dedicated tribal air program is warranted. In such a
case, a tribe can incorporate activities into its GAP work plan to establish an ambient air
quality monitoring network. This network can characterize the air quality of the
reservation as part of building their capacity to operate and manage an environmental
program. In addition, GAP funds can be used to develop QA documentation such as
quality management plans or quality assurance project plans, as well as fund travel to QA
training activities.
CAA ง103: used for special projects, generally for limited terms, to study the causes and
prevention of air pollution, including demonstrations, experiments, surveys, and research,
such as that will demonstrate uniquely effective or efficient means for preventing air
pollution or its adverse effects. A federally-recognized reservation is not a prerequisite to
a recognized tribe receiving such a grant. Through CAA ง103 grants, tribal air pollution
control agencies, among others, may conduct and promote research, investigations,
experiments, demonstrations, surveys, studies and training related to air pollution. Tribes
typically use this funding source to research and investigate the air quality within their
jurisdiction.
CAA ง105: used for implementing ongoing programs for the prevention and control of
air pollution. Tribes that have established eligibility to receive CAA ง105 grants under
the Tribal Authority Rule and have assessed their air quality and demonstrated a need and
commitment to manage air pollution on their reservation will receive first consideration
for funding. Through CAA ง105 grants, tribes may develop and implement programs for
the prevention and control of air pollution or for the implementation of national primary
and secondary ambient air quality standards.
: http://www.epa.gov/indian/gap.htm
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Principles to Awarding Grants for Tribal Air Quality Management Projects
Tribal air grants are critical to the development and continued operation of tribal air
programs. To ensure the successful development and implementation of tribal air programs to
address the most serious risks and concerns, the Agency will use the criteria that follows to
evaluate tribal air grant requests. This will ensure that available funding is expended to meet the
greatest environmental needs, while also meeting the goals of the Clean Air Act and the EPA
Indian Policy. Regional Offices may develop more specific criteria based on this policy.
In order to ensure that EPA is targeting its funding to ensure the greatest possible
health and environmental benefits, funding decisions should address one or both of these
01
overriding factors:
1. Significant Air Quality Related Health Concerns: A tribe has, or is believed to have, a
significant air pollution problem that has an adverse impact on human health. An air
pollution problem would include, but not be limited to: a reservation or a portion of a
reservation being designated nonattainment; air toxics issues; atmospheric
deposition/bioaccumulation issues; and indoor air quality concerns (except radon). On-
reservation population size (tribal and non-tribal) may be used as part of this factor.
2. Significant Air Quality Related Environmental and Cultural Resource Concerns: A tribe
has reasonable concerns that air pollution is having an adverse impact on cultural
resources or the environment within its jurisdiction. Issues such as visibility concerns
and modeled or monitored Class I increment violations under the Prevention of
Significant Deterioration regulation would be addressed here. Again, on-reservation
population size (tribal and non-tribal) may be used as part of this factor.
To better clarify EPA's decision making process, the following five criteria should be considered
in addition to the overriding factors. Where tribes are addressing similar issues, these criteria
should be used to support decisions that increase the chance of successful implementation of
tribal air quality management programs.
1. (a) Programmatic Commitment: EPA should recognize that some tribal governments have
made long-term commitments to develop and implement air quality programs.
(b) Leadership and Involvement: EPA should recognize tribes that have emerged or
are expected to emerge as leaders or key participants in providing tribal input into
external factors that affect air quality management nationwide.
(c) Staffing and Facilities: EPA should recognize tribes that have the staffing and facilities to
plan, implement and assess air quality monitoring programs and report information generated
from the programs.
23 For regions awarding first time grants to tribes where these factors are unknown, the Region may award a grant
for an initial assessment or determination. Any additional grant would then be awarded based on whether there is a
significant air-quality health issue.
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2. Prior Demonstration of Grant Performance. A tribe has successfully completed
the work plan activities and objectives for a prior grant or grants. Successful completion
includes timely submission of reports, deliverables and required grant and financial management
activities with additional consideration for having established and sustained some air
quality project management capacity.
3. The tribe is located where essential data can be gathered. This factor may be important
in network monitoring, particularly where it is important to collect data that describe
background or attainment conditions, to quantify transport, and to assess attainment
status, as well as to assess conditions such as deposition and toxics.
4. The tribe has demonstrated a commitment to working on air quality issues or
participated actively in collaborative air quality management planning with federal, state,
local or tribal air quality agencies, such as through a Tribal/EPA Agreement that contains an air
component, or an air-related Memorandum of Understanding or Intergovernmental
Agreement.
5. The tribe has submitted a proposal for innovative ways to improve air quality that is
likely to be transferable to other areas.
Regional Office Responsibilities in the Tribal Air Grant Process
Because of the diversity in situations and goals from tribe-to-tribe, EPA has delegated to the
Regional Office level the tasks of assisting tribes in identifying their goals and managing
available resources to help meet those goals. Because the EPA Regions understand individual
tribal situations, effective decisions about funding and in-kind assistance are best made at that
level. In general the EPA Regions are responsible for:
articulating and distributing pertinent information to tribes through websites, list serves,
conference calls and meetings;
answering technical questions related to ambient air monitoring or the development of the
grant; and
processing and awarding grants.
A tribe will need to work with its EPA regional contact to begin development of a work plan
order to receive grant funds. This is especially important in the planning phase, as many of the
air monitoring development steps can be incorporated into the work plan objectives. EPA
Regional personnel can provide guidance on how to write an appropriate work plan but should
not assist in the actual technical development or writing of tribal grant applications because this
assistance could provide an unfair advantage to a tribe.
Criteria for Tribal Air Grant Funding from Regional Offices
The purpose here is to assist tribes that apply for CAA funding to draft more effective work
plans for projects that will develop tribal knowledge of air quality issues and build tribal
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expertise to manage air quality in Indian country. The CAA envisions an approach to air quality
management that includes:
Goals and standards to protect public health and the environment.
Assessing air quality through emissions inventories and monitoring.
Determining necessary reductions in pollution.
Federal, State or Tribal Implementation Plans.
Education or outreach programs and other voluntary measures.
Implementing and enforcing control measures.
The tribe should try to develop performance measures that help measure progress on achieving
the environmental results of their grants. Approvable work plans need to have (1) one or more
objectives; (2) activities that support the achievement of the objectives; and (3) outcomes or
deliverables that will produce environmental results within the objective. To assist tribes in
writing effective grant proposals, OAR developed a document entitled: Tribal Air Grants
Framework: A Menu of Options24. In addition, the EPA Office of Grants and Debarment has a
website that provides tips on writing a grant proposal.25 This information can help tribes develop
comprehensive/acceptable proposals.
Through the grant negotiation process, applicants produce work plans with supporting budgets to
address both the needs of the particular reservation or tribal community, as well as EPA
priorities. See Appendix A in this document for significant features of the tribal air application
process. This document should be reviewed to determine its current relevancy.
Once a determination is made that air quality monitoring may be appropriate on the reservation
or tribal land, the following elements should be addressed in a grant proposal:
$ Identify the pollutant(s) which should be monitored and the proposed monitoring method
(filter-based or continuous monitors) and the frequency of monitoring.
$ Identify potential monitoring location(s) and justify the purpose of each monitoring site.
$ Provide assurance that each monitoring site will comply with EPA's siting requirements
found in 40 CFR Part 58 Appendix E (if this is necessary for the type of monitoring being
conducted).
$ Commit to have EPA approve the Quality Assurance Project Plan (QAPP) before data
collection or monitoring begins.
$ Ensure that the tribal air monitoring specialist will be adequately trained in the operation
and maintenance of the monitor, data management, chain-of-custody procedures, and
quality assurance requirements.
$ Assure that the quality-assured data will be entered into EPA's national air quality
database system (AQS) or other appropriate national databases.
$ Plan for periodic analysis of the data and how it contributes to understanding and
24 http://www.epa.gov/air/tribal/grants.html
25 http://www.epa.gov/ogd/recipient/tips.htm
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managing air quality on the reservation or tribal land, including the anticipated need for
future monitoring of the same or different types. EPA requires states to assess their
networks every 5 years. This interval may also be appropriate for tribes.
Funding limitations and other considerations of the grant process, as well as rules applicable to
competition in EPA Regions where this process is used, prevent any guarantee that a particular
grant proposal will be selected for funding. Work plans should help tribes develop proposals that
can effectively address air quality issues in Indian country.
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APPENDIX B
BACKGROUND FOR PLANNING TRIBAL AIR MONITORING
Introduction
This appendix contains general background on ambient air monitoring, as well as other technical
information that is not specifically about tribal monitoring. It is intended to assist tribal
professionals so that they can participate more easily and effectively with EPA staff. In order to
be brief and understandable to tribal professionals unfamiliar with the history, complexity, and
technology of air monitoring and related topics, this appendix consists of thumbnail sketches and
pointers to other documents for fuller descriptions. The thumbnail sketches are simplified and
do not convey all provisions or nuances. They are intended to assist tribal staff in understanding
the more detailed references, and in discussing these topics with EPA specialists and more
experienced tribal professionals. Additional substantial amounts of information concerning (1)
technical issues related to monitoring, emissions inventories and air data; (2) health and
ecosystem-related topics; as well as (3) the Clean Air Act and associated EPA rules; and (4)
government policies, program planning, budgets and grants, can be found by tribal professionals
working through the following Internet addresses:
~ Clean Air Act - http://www.epa.gov/air/caa/
~ Chief Financial Officer (EPA) ~ http://www.epa.gov/ocfo/index.htm
~ American Indian Environmental Office (EPA) ~ http://www.epa. gov/indian/index.htm
- Tribal Air (EPA/OAR) - http://www.epa.gov/air/tribal/
~ Technology Transfer Network (EPA/OAR) ~ http://www.epa.gov/ttn/
~ Institute for Tribal Environmental Professionals ~ http://www4.nau.edu/itep/programs/
Ambient Monitoring Technology Information Center (AMTIC)
The AMTIC Internet website contains information and files on ambient air quality monitoring
programs, details on monitoring methods, relevant documents and articles, information on air
quality trends and nonattainment areas, federal regulations related to ambient air quality
monitoring, as well as information on training, contacts and related Internet sites. The AMTIC
Internet website is a valuable starting point for tribal members seeking information on a wide
range of air monitoring topics; its Internet address is:
http://www.epa.gov/ttn/amtic/
Existing State/Local/Tribal Monitoring Networks
Ambient air monitoring programs make it possible to evaluate the status of the atmosphere
compared to clean air standards and historical information. A review of
various air monitoring networks (e.g., SLAMS, NAMS, PAMS, SPMS, including
tribal monitoring) is provided as part of the National Ambient Air Monitoring Strategy.
That strategy and other relevant information (including types, purposes, history, funding)
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of monitoring networks, including tribal programs, are provided at the following
addresses:
http://www.epa.gov/oar/oaqps/qa/monprog.htmltfAmbient
http ://www. epa. gov/oar/oaqps/m ontring.html
http ://www. epa. gov/ttn/amtic/files/ambient/monitorstrat/naamstrat2005 .pdf
http://www.epa.gov/ttn/amtic/amlinks.html
http://www.epa.gov/castnet/
http://vista.cira.colostate.edu/improve/Default.htm
http: //nadp. sws .uiuc. edu/
http: //www4. nau. edu/tam s/servi ce s/index. html
http ://www. epa. gov/air/tribal/trib etotribe.html
Quality Assurance (QA) of Air Monitoring Programs
EPA uses its Quality System to manage the quality of environmental data collection, generation,
and use; the primary goal is to ensure that data are of sufficient quantity and quality to support
decisions for protecting health and the environment. The Ambient Air Monitoring Quality
Assurance program applies these principles to air quality data. This is accomplished through
effective communication and cooperation with monitoring organizations, which include EPA,
state, local, tribal agencies, the academic community and industry. To address QA requirements
and associated resource needs, the following tools are routinely provided: guidance documents.
The National Performance Evaluation Program, data quality assessments and reports, ambient air
quality assurance training, and example QA project plans (QAPPs). Information on QA tools,
QA requirements, and example applications should be given consideration in the development of
tribal monitoring programs; this information is available at the following Internet addresses:
http://www.epa.gov/quality/index.html
http://www.epa.gov/airprogm/oar/oaqps/qa/index.html
http://www.epa.gov/ttn/amtic/quality.html
http://www.epa.gov/ttnamtil/files/ambient/airtox/nattsqapp.pdf
National Ambient Air Monitoring Strategy
The overarching goal of the draft National Ambient Air Monitoring Strategy is to improve the
scientific and technical competency of the nation's air monitoring networks while increasing the
ability to protect health and environmental welfare. The Strategy seeks to accomplish this in
flexible ways that accommodate future needs in an optimized resource constrained environment.
Objectives in achieving this broad-based goal include: manage the nation's air monitoring
networks, establish a new air monitoring approach, provide a greater degree of timely public air
quality information, improve network efficiencies, foster the utilization of new measurement
method technologies, encourage multi-pollutant measurements, provide a base air monitoring
structure, develop and implement a major public information and outreach program, seek input
from the scientific community, provide air monitoring platforms and data bases, and assess
funding levels needed to maintain support for this monitoring strategy. The impact of this
strategy on tribal monitoring is also addressed, including operation of monitoring sites by tribes.
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Tribal monitoring programs should consider their activities in relation to implementation of this
strategy and should be poised to influence the strategy as it evolves. The draft monitoring
strategy document (December 2005) and supporting documents, which provide both a
description of the strategy and reflect ongoing components of the strategic plan development, are
available at the following Internet addresses:
http://www.epa.gov/ttn/amtic/monstratdoc.html
http://www.epa.gov/ttn/amtic/monitor.html
Air Quality System (AQS)
The AQS is EPA's widely used repository of ambient air quality data. AQS stores data from
over 10,000 monitors, 5000 of which are currently active. State, local and tribal governments
collect the data and submit it to AQS on a periodic basis. Tribes conducting air monitoring
programs should strongly consider submitting the resulting air data to AQS, if they are not
already doing so. A detailed description of AQS, supporting manuals and guides, web-based
access, information on training, and links to other sources of air quality information, including
State/Local/Tribal agencies, is provided at the following Internet address:
http://www.epa.gov/ttn/airs/airsaqs/
ITEP and TAMS Support
The Internet home page for the Institute for Tribal Environmental Professionals (ITEP) states
that "ITEP was established in 1992 to assist Indian tribes in the management of their
environmental resources through effective training and educational programs." The
subcomponent for the Tribal Air Monitoring Support Center states that "The Tribal Air
Monitoring (TAMS) Center was created through a partnership between tribes, the Institute for
Tribal Environmental Professionals and the United States Environmental Protection Agency." It
is the first technical training center designed specifically to meet the needs of tribes involved in
air quality management and offers an array of training and support services to tribal air
professionals. The TAMS Center's mission is to develop tribal capacity to assess, understand
and prevent environmental impacts that adversely affect health, cultural, and natural resources."
It provides technical support to tribes for all aspects of monitoring including workshops, a
resource library, and one-on-one technical assistance through the Professional Assistance
program. Listings of ITEP and TAMS Center training programs and services available to tribal
programs are provided at the following Internet addresses:
http: //www4. nau. edu/itep/
http://www4.nau.edu/tams/
National Emissions Inventory (NEI)
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The National Emissions Inventory is a national data base of air emissions information with input
from numerous state and local air agencies, from tribes, and from industry. This data base
contains information on stationary and mobile sources that emit criteria air pollutants and their
precursors, as well as hazardous air pollutants (HAPs). The data base includes estimates of
annual emissions, by source, of air pollutants in each area of the country, on an annual basis.
Emissions estimates for individual point or major sources (facilities), as well as county level
estimates for area, mobile and other sources, are available currently for 1990 and 1996 through
1999 for criteria pollutants, and for 1999 for HAPs; a final version of the 2002 NEI was made
available to the public in 2006. The NEI emissions data base is a key source of information
useful to tribal air programs. More information about the NEI data base and the compilation of
criteria pollutant and HAP emissions inventories, and links to the data base, are available at the
following Internet addresses:
http://www.epa.gov/ttn/chief/net/index.html
http ://www. epa. gov/ttn/chief/eiinformation.html
Air Quality Models
Air quality models, and how they can provide insight to ambient air quality in Indian country
when monitoring is not available, should be of particular interest to tribes. There are three types
of air quality models: dispersion, photochemical, and receptor models used in assessing control
strategies and source impacts. Source code and associated user's guides and documentation are
routinely provided for preferred/recommended models, screening models, and alternative
models. In addition, guidance is provided for applying air quality models in regulatory
applications for State Implementation Plans (SIP) and Tribal Implementation Plan (TIP)
demonstrations and revisions, as well as permit applications for new source reviews, including
Prevention of Significant Deterioration (PSD) regulations. These latter applications are
particularly relevant for estimating air quality impacts in Indian country. A Model
Clearinghouse is also available to help record the interpretation of modeling guidance for
specific regulatory applications. Modeling contacts within the EPA Regional Offices and state
environmental agencies can assist tribes in the regulatory application of air quality models.
Detailed information on models, codes and guidance in their use is available at the following
Internet addresses:
http ://www. epa. gov/ttn/scram/
http://www.epa.gov/scram001/guidanceindex.htm
http://www.epa.gov/scram001/guidance_clearinghouse.htm
The NSR/PSD Programs (relationship to monitoring needs)
The New Source Review (NSR) and the Prevention of Significant Deterioration (PSD) programs
apply to new major stationary sources and major modifications locating in areas designated as
attainment or unclassifiable for the NAAQS. These programs generally require the permit
applicant to conduct a source impact analysis using monitored data and air quality models. For
the NSR program, the impact analysis must demonstrate that the new or modified source will not
cause or contribute to a violation of state or national air quality standards or cause an adverse
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impact to visibility in any federal Class I area. The PSD program is generally designed to
provide a more comprehensive source impact analysis than the NSR program, including effect on
air quality related values, e.g., visibility, that have been identified for Class I areas. NSR and
PSD are major pollutant control programs that should be of concern to tribes. Coordination of
NSR/PSD and the use of air monitoring data in source impact analyses, to identify existing
(representative) conditions and potential future impacts, should be addressed by tribes; relevant
information is available at the following Internet addresses:
http://www.epa.gov/nsr/
http://www.epa.gov/ttn/amtic/files/ambient/criteria/reldocs/4-87-007.pdf
http://www.epa.gov/ttnamti l/files/ambient/visible/r-99-003 .pdf
Benchmarks for Health and Ecosystem Effects
General Air Benchmarks. Air Quality indicators, concentrations of criteria pollutants relative to
the NAAQS, effects on health due to toxic air pollutants, and other ambient measures such as
visibility and acid deposition, all provide benchmarks of the nation's air quality. These
benchmarks are directly relatable to the needs of tribal programs. The Report on the
Environment, and associated information on criteria and toxic air pollutants, is available at the
following Internet addresses:
http://www.epa.gov/indicators/index.htm
http://www.epa. gov/indicators/roe/html/roeTOC .htm
http://www.epa.gov/ttn/naaqs/
http://www.epa.gov/air/visibility/index.html
http ://www. epa. gov/airmarkets
Air Toxics and the Integrated Risk Information System (IRIS). IRIS was prepared and is
maintained by EPA as an electronic database containing information on human health effects
that may result from exposure to various chemicals in the environment. It was developed in
response to the need for consistent information on chemical substances for use in risk
assessments, decision-making and regulatory activities. The collection of computer files
covering individual chemicals contains descriptive and quantitative information concerning (1)
oral reference doses and inhalation reference concentrations (RfDs and RfCs, respectively) for
chronic noncarcinogenic health effects; and (2) hazard identification, oral slope factors, and oral
and inhalation unit risks for carcinogenic effects. Information on IRIS and other sources of air
toxics information that may prove useful to tribal programs are available at the following Internet
addresses:
http://www.epa.gov/iris/index.html
http://www.epa.gov/ttnatw01/hlthef/hapindex.html
http://www.epa.gov/air/toxicair/index.html
National Air Toxics Assessment (NATA)
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In February 2006, EPA released the results of its national-scale assessment of 1999 air toxics
emissions. The purpose of the national-scale assessment is to identify and prioritize air toxics,
emission source types and locations which are of greatest potential concern in terms of
contributing to population risk. EPA uses the results of these assessments in many ways,
including:
to work with communities in designing their own local-scale assessments,
to set priorities for improving data in emissions inventories, and
to help direct priorities for expanding and improving the network of air toxics
monitoring.
The national-scale assessment includes 177 air pollutants (a subset of the air toxics on the Clean
Air Act's list of 187 air toxics plus diesel particulate matter (diesel PM)). The assessment
includes four steps that focus on the year 1999:
1. Compiling a national emissions inventory of air toxics emissions from outdoor sources.
2. Estimating ambient concentrations of air toxics across the United States.
3. Estimating population exposures across the United States.
4. Characterizing potential public health risk due to inhalation of air toxics including both
cancer and noncancer effects.
Results are available at:
http://www.epa.gov/ttn/atw/nata 19997
Indoor Air Issues (radon and mold)
Radon and mold can both be problems in indoor environments. Radon is odorless and tasteless,
and may exist at concentrations that exceed action levels in homes. Indoor air containing radon
is the second leading cause of lung cancer in the United States. Molds can gradually damage
homes and furnishings and can cause potential health problems. Internet addresses with
additional information on radon and mold, associated effects, and mitigation strategies are
available at the following Internet addresses:
http://www.epa.gov/iaq/index.html
http://www.epa.gov/mold/index.html
http://www.epa.gov/radon/index.html
http://www.epa.gov/iaq/atozindex.html
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