Guidance & Policy for Implementation of Tribal Air Monitoring Program August, 2007
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&EPA
Guidance and Policy for
Implementation of Tribal Air
Monitoring Programs
DRAFT
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Guidance & Policy for Implementation of Tribal Air Monitoring Program August, 2007
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Abstract
In August of 2005, a Tribal Monitoring Workgroup made up of staff from the Office of Air and
Radiation, EPA Regional Office tribal air coordinators, and tribal air professionals was convened
with the objective of developing 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:
1. Technical Guidance for the Development of Tribal Air Monitoring Programs- The
intended purpose of this guidance document is to provide specifics on how to plan and
implement ambient air monitoring programs and is developed specifically for the tribes.
The document was completed in August, 2007 and will be posted on the OAR Tribal
Website (http://www.epa.gov/air/tribal/airprogs.html ) in September, 2007.
2. Guidance and Policy for Implementation of Tribal Monitoring Program- The intended
purpose of this guidance document is to improve the ability of tribes and 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 to best effect on chosen projects. This document is also
intended to provide a level of consistency between OAR and the Regions in our
expectations of tribal monitoring programs. 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.
It has been developed in a question/answer format as a way of distinguishing discreet topics
related to ambient air monitoring activities. This guidance and policy document will remain an
internal EPA document and will be revised as needed.
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Table of Contents
LIST OF ABBREVIATIONS
BACKGROUND
OVERVIEW
1. Who are the intended readers and users of this document?
2. What is the purpose of this document?
3. What are the guiding principles for working with the tribes on air monitoring?
4. What input has EPA received from tribal environmental professionals and tribal leaders
regarding EPA's support for ambient air monitoring by tribes?
5. Does this guidance supersede or change any previous guidance or procedures?
IMPORTANCE OF AIR MONITORING PROGRAMS AND EPA-TRIBE RELATIONSHIPS
6. How can having an ambient monitoring program be important to a tribe?
7. 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
-Facilities
8. 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?
-Demonstrated eligibility to be treated as a state
-Not demonstrated eligibility to be treated as a state
9. What are the differences between EPA's relationships with states regarding monitoring
and EPA's relationships to tribes regarding monitoring?
GRANTS FOR TRIBAL AIR MONITORING
10. What is EPA trying to accomplish by giving Congressionally appropriated funds to tribes
for air quality management, including ambient monitoring?
11. What is the process by which EPA gets Congressionally appropriated funds to individual
tribes for air quality management, including ambient monitoring?
12. What principles do OAR and the EPA Regional Offices try to apply as they make
decisions to award grants for air quality management projects proposed by tribes and then
as they administer those grants?
-Regional Office responsibilities in the grant process for monitoring
-Criteria for grant funding from Regional Offices
13. Can tribes join the NATTS, local scale air toxics, IMPROVE, CASTNET, NADP, and/or
NCore monitoring programs?
14. Does EPA attempt to set overall goals for its support to ambient air monitoring by tribes?
How does EPA evaluate success in meeting those goals?
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15. How does EPA ensure that funds given to a specific tribe for ambient monitoring are
used efficiently?
16. How much time does EPA allow a tribe with a new grant for ambient monitoring to
"come up to speed" in correctly operating its new monitors before the tribe should be
expected to have a QAPP in place, be running the monitors routinely, and be reporting
data to AQS?
MONITORING REQUIREMENTS AND DATA REPORTING
17. Why is it important to both EPA and tribes for tribes to report their ambient air data to
AQS? Are there other alternatives that are acceptable to EPA if preferred by a tribe?
18. Why is it important that tribes adopt and follow a quality assurance project plan (QAPP)?
19. How does EPA help tribal monitoring programs satisfy the 40 CFR 58 Appendix A
requirement to have adequate and independent performance evaluation audits?
STATUS OF MONITORING NETWORKS
20. How many tribes are monitoring their air quality using funds from EPA? Are the data
from this monitoring available to others?
21. How does EPA help a tribe understand its air quality as well as possible if the tribe
cannot get EPA funding to run a monitoring program, or not enough funding?
ADDITIONAL INFORMATION
22. Where can a tribe get more information on ambient monitoring and on other air quality
topics that relate to monitoring?
APPENDIX A: The Tribal Air Grant Application Process
APPENDIX B: Background for Planning Tribal Air Monitoring
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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
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.s 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 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) support tribes in ambient air monitoring activities,
as needed, to assess and manage air quality. The funds that support the OAR Tribal Program are
appropriated by Congress to assist tribes in developing and implementing air quality
management programs with no specification of specific amounts for specific types of activities,
such as air monitoring. 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. These 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 FY1995, the EPA Regional Offices
awarded nine grants to tribes to conduct air quality work; by FY2003, grants were awarded to
115 tribes.
The EPA anticipates that requests by tribes for air grants will continue to increase. 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 with states on shared air concerns through Regional
Planning Organizations and other regional and national 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 refers 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. In addition, tribes
face non-air risks to the health of their members, as well as other challenges and disadvantages,
that are different from those facing non-tribal communities. Because of the diversity in
situations and goals from tribe to tribe, EPA has taken the approach of delegating to the Regional
Office level the task of assisting tribes in identifying their goals and the task of managing the
available resources to help meet those goals. Because Regions understand individual tribal
situations, effective decisions about funding and in-kind assistance are best made at the Regional
Office level. Regional Offices have taken the initiative on helping tribes set air quality goals
and design ambient monitoring to support them. Each Region has prioritized requests from
tribes when they collectively exceed the tribal air management grant funds available to the
Regional Office. Regional Offices also negotiate, award, and manage grants to individual tribes.
Regional Offices provide in-person, telephone, and written guidance and assistance to the tribal
governments at all these stages. 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.
This guidance is rather general in nature, reflecting the need to accommodate the diversity of
tribal situations.2 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. EPA therefore
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 principles that
the Regional Offices follow.
As the number and size of tribal air programs continue to expand, while total funding remains
constant, EPA Regions will be required to make more constrained decisions on which grant
proposal to award. 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 be based on
Headquarters and Regional strategic goals. These goals must be articulated in clear and
consistent grant criteria. The draft document titled: Protecting Public Health and Air Quality
The available strategic guidance (excluding technical guidance on monitor operations and maintenance) includes
the following documents, and perhaps others at the individual Regional Office level:
1. 4-page section titled "Tribal Air Quality Management" in the Final National Program and Grant Guidance
for Fiscal Years 2006-2008, April 27, 2005.
2. Memo from Jeffrey R. Holmstead, "Criteria for Providing Funds to Tribes from the State and Tribal Grant
Assistance Appropriation for 103 and 105 Grants," January 27, 2005.
3. "MENU ITEM: Air Quality Monitoring Activities," in The Tribal Air Grant Framework - A Menu of
Options For Developing Tribal Air Grant Work Plans and Managing Grants for Environmental Results,
September 2004. -
http://vosemite.epa.gov/R10/AIRP AGE.NSF/webpage/Tribal+Air+Program+Main+Page
4. Guidance for Conducting: TRIBAL AIR QUALITY ASSESSMENTS, U.S. EPA Region 10, April 15
2005.
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Resources on Indian Country: A Plan for EPA/Tribal Partnerships 2008-2013 provides these
goals and should be used by the EPA Regions as basis for formulating the grant criteria. This
document will be referred to as the "2008-13 Plan" for the remainder of this document and is
currently being reviewed as a draft.
Although this document addresses EPA goals, Headquarters and Regional Offices have met with
interested tribal professionals to prepare this strategic guidance on tribal air monitoring, and to
recommend how EPA will prioritize requests for funding assistance.
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.
Finally, it should be noted that unlike most EPA programs, the goals of the tribal air monitoring
program have been set by the tribes with general guidance from Regional Offices and OAR. A
result of this decentralized approach is that individuals inside and outside of EPA who are not
personally involved in working with tribes on monitoring projects need the benefit of reporting
systems to be able to be aware of and assess what is being accomplished towards the tribal goals
with available resources. The preparation of this document included one cycle of such
assessment and reporting of current and recent tribal air monitoring programs (see Question 20).
This document will provide useful documentation for possible future independent reviews of the
tribal air monitoring program. Such reviews might be conducted by EPA's own Inspector
General, the Government Accountability Office, or the Office of Management and Budget.
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2. What is the purpose of this document?
The intended purpose of this guidance document is to improve the ability of tribes and Regional
Offices to prioritize monitoring needs, determine an appropriate level of funding for ambient air
monitoring on tribal lands relative to other air management work, and ensure that the funds are
used to best effect on chosen projects. With support from headquarters offices, the Regional
Offices should:
1. provide a strategy for applying resources in support of tribes which leaves the formation
of a vision to the individual tribes themselves,
2. provide information resources for tribes as they determine their need for monitoring and
prepare work plans and grant applications, as well as a one-stop resource for locating
technical information3,
3. ensure that tribal goals for air monitoring projects and what accomplishments will be
considered "success", 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.
Another intent of this document is to provide a level of consistency between OAR and the
Regions in our expectations of tribal monitoring programs. Some of these expectations include:
• Monitoring expectation - There should be an expectation that ambient air monitoring will
be implemented following requirements similar to the state and local monitoring
organizations or to the specific program (i.e., IMPROVE) for which they are
participating. There is an expectation that upon grant approval, monitoring and data
reporting would commence within an appropriate and agreed upon time period.
• Efficiency expectation- There is be an expectation that the most efficient methods for
meeting a particular monitoring objective be implemented. There have been
circumstances where tribes and/or states and tribes have worked together to achieve
objectives of mutual benefit and at resource savings. The potential for teaming and
cooperation should be encouraged in the planning process.
• QA expectation- 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 approach4 to help tribes
develop these documents. This approach provides the Regions flexibility during review
and approval of the required quality assurance documentation (see question 18).
• Data expectation- There is an expectation that monitoring results will be reported to AQS
or the appropriate national data base with very few exceptions. Data should be reported,
at a minimum, within 9 months of the start of routine monitoring implementation and
then at agreed upon timeframes (i.e., quarterly).
3 In July, 2007 a Technical Guidance Document for the Development of Tribal Monitoring Programs was developed
to provide the "one-stop" resource.
4 http://www.epa.gov/ttn/amtic/geninfo.html Graded Approach toe Quality Assurance
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• Monitoring completion expectation- There must be some expectation agreed upon by the
tribes and 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 expectation- Some tribes will need more technical help developing
monitoring programs than others. In addition, some 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.
The following questions and answers address these expectations in more detail in an attempt to
provide an appropriate level of communication and consistency in the implementation of air
monitoring programs among EPA Regions and Headquarters which in turn will provide tribes
with a set of consistent expectations.
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 on budget, quality assurance, ambient
monitoring, etc. Individual 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 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 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
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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.
(5) EPA should support tribal capacity building, for example, by helping to develop the
capabilities of tribal staff. 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 of and using 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. Question 11 also provides some
guiding principles for the allocation of federal funds for monitoring projects.
(7) There needs to be consistency/fairness across tribes, but also 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) EPA should encourage all parties to take advantage of all available data on ambient
air quality where technically relevant. Operating monitors may provide useful
information on air quality some distance from their location and on transport into and
out of state and tribal lands.
(10) Tribes should have equal opportunity to participate in programs that are not
inherently tied to state/tribe distinctions, and to benefit from resources used to support
those programs, where such access is consistent with program goals.5
5 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 new sites are contemplated, tribal lands in
the right areas of the country should be considered equally with state and federal lands.
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(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 quickly so tribes are never less aware than
others of the data and the data's 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.
4. What input has EPA received from tribal environmental professionals and tribal leaders
regarding EPA's support for ambient air monitoring by tribes?
In a general sense, tribes are happy that EPA is trying to provide support for ambient air
monitoring activities. Through EPA outreach, training and communication efforts, the tribes feel
more a part of the monitoring community and are appreciative of EPA providing opportunities to
be an integral part of the monitoring planning process.
Although EPA is making progress to include tribes in these planning processes, the tribes have
identified issues and concerns in current ambient air monitoring support.
One point of concern 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 more often 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, so 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 may not be aware of all the different grants and/or resources available to
them.
Tribes would like to follow as many of the monitoring requirements as possible but because they
are often small organizations and resource limited, they can not 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 try to find workable solutions to the issues.
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Data submission to 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. Although, we cannot require anyone to input data to AQS
more frequently, the Tribes should be aware that they can input their data on a more frequent
basis (e.g., monthly). EPA Regions have received feedback from state and local AQS users, who
upload data to AQS monthly, that inputting the data more frequently makes the process easier
each time they do it (they need to remember what they did 30 days ago instead of 3 months ago).
Those who continue to upload data quarterly tend to have the most problems with AQS.
Both the Institute for Tribal Environmental Professionals (ITEP) and the OAQPS National Air
Data Group are working with the EPA Regions to create some additional options to either
provide more capacity building opportunities for the tribes or provide mechanisms (contractors,
circuit riders) to get the monitoring data into AQS. However, 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. One of the motivations for tribes to want to monitor the air quality is
human health issues- it is not a scientific interest in this subject. Some tribal professionals feel
this motivation is not addressed in the National Ambient Air Monitoring Strategy (NAAMS)6,
but the document has many useful details that address tribal air monitoring.
The NAAMS highlights the fact that the NCore strategy could benefit from including tribes
because the tribes can provide additional monitoring sites, fill data gaps, and identify background
conditions. These are the reasons why tribal air monitoring could help the entire NAAMS.
Tribes feel an institution/organization with a nationally recognized leadership role in working
with tribes on environmental issues, such as ITEP, should be identified to do the
"representativeness" analysis for all tribes, in certain regions of the US. Identifying those tribes
that are not currently represented by the NCore network should be made. These tribes should
have access to the regional air monitoring data to determine the status of their air quality. This
project should also be aimed at locating tribes that would serve to fill data gaps, and those that
have air pristine enough to provide 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 about 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 could be used as a template
all over the U.S.
5. 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
6 http://www.epa.gov/ttn/amtic/monstratdoc.html
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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 leaves the
formation of a vision concerning ambient monitoring programs to the individual tribes.
IMPORTANCE OF AIR MONITORING PROGRAMS AND EPA-TRIBE
RELATIONSHIPS
6. How can having an ambient monitoring program be important to a tribe?
Tribes may need to conduct ambient air monitoring for a variety of reasons which include the
following: (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 related 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. From these monitoring
activities appropriate regulatory decisions or voluntary measures can be pursued 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/or to build a case or partnership for controlling those sources.
Examples of programs for tribal participation include IMPROVE, CASTNET, NADP, MDN,
ozone, PM2.5, precursor gas (CO, NOy 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.
7. 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. This document can also help EPA Regional personnel
who may not be familiar with the implementation of ambient air monitoring. One section of that
7 http://www.epa.gov/air/tribal/airprogs.html
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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 so the tribe may feel that it can
contract out some of the functions that are needed. For example, the tribe may wish to contract
out 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 whose function might 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 will be 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.)
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), and is capable of housing the information management
system including backing-up and archiving electronic data securely. A question that might 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 but if this is the case, then the grant documentation should describe how
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these activities will be accomplished with a minimum loss of data, and the resources that will be
allocated to this activity.
8. 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 costs
of monitoring through the use of CAA §103 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 1 year for information
management, data reduction and assessment, a rule of thumb for use of 103 funds might be 3-5
years for any specific monitoring project.
After the initial monitoring period, if the tribe wants to continue monitoring, they may seek CAA
§105 funds for the monitoring program 8or continue to apply for §103 funds. There is no
guarantee the §103 funds will available for a particular tribe to continue monitoring past the
initial funding period.
§105 funds have the potential advantage that recipients are guaranteed some level of funding and
can not 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 can not be made up from
other federal government funds. Information on tribal match requirements can be found in
40CFR § 35.575 or 40CFR § 49.4{q} http://www.gpoaccess.gov/cfr/index.html. In addition, the
tribes should be made aware that becoming eligible to receive §105 funds does not mean that
tribes can compete for the §105 allocated for state and local monitoring organizations.
40 CFR part 49.4 makes it clear that the 105 grant federal maximum contribution of three-fifths
(60%) for State and local monitoring agencies does not apply to all tribes. There are differences
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 §105 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.
! Ambient air monitoring is just one of many §105 activities.
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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 Section 105 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, so 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.
9. What are the differences between EPA's relationships with States regarding monitoring
and EPA's relationships to tribes regarding monitoring?
Congress has delegated authority to EPA to ensure that environmental programs designed to
protect human health and the environment are carried out throughout the United States, including
Indian country. However, there is a different relationship between the EPA and state and local
agencies and the EPA and tribes. All the CAA regulations and related CFR requirements related
to ambient air monitoring have been developed primarily for state and local monitoring agencies.
Although state and local agencies are consulted on the development of the ambient air
monitoring regulations and can provide comment on these regulations, once the regulations are
promulgated and approved, the state and local monitoring agencies are expected to follow these
requirements.
In contrast, the tribes are responsible for setting the vision of their ambient air monitoring
networks and many of the ambient air monitoring requirements do not necessarily apply to the
tribes. As described in the 2008-13 Plan, the OAR tribal program strategy is designed to define,
create, and enhance partnerships that protect human health and air quality in Indian country by
ensuring the full implementation of both regulatory aspects of the Clean Air Act (CAA) and
accompanying voluntary programs while recognizing the special relationships, policies and legal
context of the government-to-government relationship. The goal, as it is related to ambient air
monitoring, may be approached:
• through direct federal implementation of federal regulations and voluntary programs
designed to protect air quality. EPA is responsible for nationwide implementation of the
CAA and will develop federal plans and regulations as appropriate.
• by helping tribes acquire the tools and expertise necessary to implement delegated CAA
regulatory and/or voluntary programs that address their needs.
• by helping tribes acquire the tools and expertise necessary to implement their own tribal
regulatory or voluntary programs under their sovereign authority.
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No matter the method, the ultimate intent is to ensure that Indian country is afforded the same air
quality protections and participation as are provided to other parts of the United States, with an
emphasis on tribal implementation where possible, in accordance with existing federal and EPA
policies. EPA works with the tribes to determine what part of the C AA regulations they plan to
implement, through their tribal authority, and implements programs that tribes may not currently
have the capacity to implement.
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. In
addition, 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.
Tribes implementing monitoring for other objectives not national in scope will not need to meet
all the CFR requirements. However, if EPA funded, the tribe will need to develop an appropriate
QA project plan which will describe the appropriate siting, methods and quality assurance
activities 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.
GRANTS FOR TRIBAL AIR MONITORING
10. What is EPA trying to accomplish by giving Congressionally appropriated funds to
tribes for air quality management, including ambient monitoring?
OAR and the EPA Regions are 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 §103 and CAA §105 grants all allow
EPA to provide support to tribes for this purpose.
GAP: The Indian General Assistance Program (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." (See
"Guidelines on the Award and Management of General Assistance Agreements for Indian
Tribes" at http://www.epa.gov/indian/tgrant.htm, March 2000, page 11). 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 would be warranted. In such a
case, a tribe could incorporate into its GAP work plan activities to set up an ambient air
quality monitoring network to characterize the air quality of the reservation as part of
building their capacity to operate and manage an environmental program. In addition,
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GAP funds can be used to develop QA documentation such as quality management plans
or quality assurance project plans as well to fund travel to QA training activities.
CAA §103: are 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 §103 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 and affecting lands within their jurisdiction.
CAA §105: are used for implementing ongoing programs for the prevention and control
of air pollution. Tribes that have established eligibility to receive CAA §105 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 §105 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.
11. What is the process by which EPA gets Congressionally appropriated funds to
individual tribes for air quality management, including ambient monitoring?
EPA request
to OMB/President
OMB/President
request to Congress
Congress allocates
to EPA
EPA allocates
to HQ/Regions
HQ allocates
to Tribal Consortia
Ambient air monitoring is one of many activities that are 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.9 An increasing number of tribes have become interested in
establishing monitoring stations, and not all interested tribes will be able to obtain EPA financial
support for ambient air monitoring if 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
9 In FY2005, 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 FY2005 budget. EPA has proposed
the same separation for FY2007, and EPA has issued grant and technical guidance for FY2007 based on this
separation. The proposed 2007 budget provides ~ $ 11 million, see http://www.epa.gov/ocfo/budget/.
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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 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 recommendations10.
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.
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 §103 and §105). 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: "We should recognize that some tribal governments made long-term
commitments to develop and implement air quality programs (programmatic
commitment), and; "We 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 nationwide" (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 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.
10 April 24, 2007 Memo from Barrel Harmon to Beth Craig and Regional Air Directors on STAG Allocation
Revisions
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Headquarters will continue to hold back 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..
12. What principles do OAR and the EPA Regional Offices try to apply as they make
decisions to award grants for air quality management projects proposed by tribes and then
as they administer those grants?
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 following criteria 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
overriding factors11:
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 the decision making process, the following five criteria should be used 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: We should recognize that some tribal governments
made long-term commitments to develop and implement air quality programs.
(b) Leadership and Involvement: We should recognize tribes that have emerged or
11 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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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: We should recognize tribes that have the staffing and facilities to
plan, implement, assess and report air quality monitoring programs.
2. Prior Demonstration of Grant Performance: A tribe has either successfully completed
the work plan activities and objectives for a prior grant or grants, including 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 Grant Process
As mentioned in the background, because of the diversity in situations and goals from tribe to
tribe, EPA has taken the approach of delegating to the Regional Office level the tasks of assisting
tribes in identifying their goals and the task of managing the available resources to help meet
those goals. Because Regions understand individual tribal situations, effective decisions about
funding and in-kind assistance are best made at the Regional Office 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 as they are 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 that
will be required in 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
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adequate/appropriate work plan but should not assist in the actual technical development or
writing of tribal grants since this assistance could provide an unfair advantage to a tribe.
Criteria for 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
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 to 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 grants, OAR developed a document entitled: Tribal Air Grants
Framework: A Menu of Options12. In addition, the EPA Office of Grants and Debarment has a
website that provides tips on writing a grant proposal13. This information can help the tribes
develop comprehensive/acceptable proposals and workplans.
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 funding 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 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.
12 http://www.epa.gov/air/tribal/grants.html
13 http://www.epa.gov/ogd/recipient/tips.htm
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• 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
managing air quality on the reservation or tribal land, including the anticipated need for
future monitoring of the same or different types. EPA has a requirement that states assess
their networks every 5 years. This interval may also be appropriate for tribes.
While funding limitations and other considerations of the grant process, as well as rules
applicable to competition in Regions where this process is used, prevent any guarantee that a
particular grant proposal will be selected for funding, it is hoped that work plans will help tribes
develop proposals that can effectively address air quality issues in Indian country. This guidance
is intended to serve as a reference for both tribal and EPA staff during CAA grant and program
development.
Applicants are encouraged to contact their EPA Region for information on applicable
procedures prior to developing a work plan and supporting budget. The EPA Region can provide
information on any competition or particular criteria applicable to grant applications they
process.
13. Can tribes participate in NATTS, local scale air toxics, IMPROVE, CASTNET, NADP,
and/or NCore monitoring programs?
EPA guidance does not limit any tribe's right to monitor for whatever air pollutants it chooses in
its portion of Indian country with their own funds. Therefore, tribes have the opportunity to
participate in any national monitoring program provided 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. Consequently, the December 2005 draft of the NAAMS says very little of a
strategic nature regarding tribal monitoring. We do not presently see any reason why the next
version (to be completed in 2008) should do so either, although we are open to input on this.
The following is a condensation of what the National Strategy does say about tribal monitoring:
Tribal nations generally are seeking to expand ambient air monitoring efforts, and it is
generally recognized that there exists substantial need for tribal air monitoring support.
Nothing in the national Strategy imposes requirements on tribal monitoring or mandates
linkages of tribal air monitoring with national networks.
Tribal participation 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
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pristine and therefore excellent candidates for background monitoring sites, potentially
filling in important gaps in the nation's network. Under the 2005 NAAMS, tribes will be
given fair consideration for hosting sites of national interest, and the 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 should not be perceived as suggesting that the tribal monitoring priority is or
should be to foster a connection to national networks. Monitoring priorities must be based on
tribal decisions, which in many cases involve developing a better characterization of local
exposure to air pollutants, and involve 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 State of 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 both monitoring
agencies.
14. Does EPA attempt to set overall goals for its support to ambient air monitoring by
tribes? How does EPA evaluate success in meeting those goals?
The EPA is very aware of the importance of being able to document that the tribal assistance
portion of the Air Program has clear goals, guides participants to meet those goals, tracks
progress, and makes adjustments when needed.
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 Regions, to
assess their air quality (and potential health concerns) within their 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 1 has a measurable objective that states:
• By 2011, air quality assessments in Indian country, such as air quality and deposition
monitoring, emissions inventories, and toxics assessments, will be tribally-driven and
reflect tribal priorities and needs. At least three tribes will complete assessments each
year between 2007 and 2011, and at least two new tribes will undertake new assessments
each year between 2007 and 2011.
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A number of the goals support air monitoring activities but EPA tries to allow the tribes the
flexibility to determine their air monitoring needs within the context of the overriding factors
described in question 12.
Evaluating Success
Within the context of allowing the tribes to set their own ambient air monitoring goals (which
then in effect also become EPA goals), through the EPA Regions decision making process of
selecting the most appropriate grants to fund, and ensuring that the individual grants have
measurable outcomes and environmental results, we can determine whether our goals are being
met. Question 15 provides more information about developing the appropriate grant proposals
which would provide measurable outcomes for evaluating the success of an ambient air
monitoring program.
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 cooperating with the
Regions to develop a Tribal Database that will be able to accommodate these important pieces of
information so that we can more easily report this information to EPA management. 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.
15. How does EPA ensure that funds given to a specific tribe for ambient monitoring are
used efficiently?
One way to ensure that funds provided to the tribes are used efficiently is to ensure that
workplans/proposals submitted for federal funds have:
1. One or more objective,
2. activities that support the achievement of the objectives, and
3. outcomes or deliverables that will produce environmental results within the
objectives. The tribe should also develop performance measures and milestones that
help to measure progress in achieving the environmental results.
Since there will be a possibility that the Regions will have to make choices on which project to
fund, it will be important to communicate to the tribes that federal funds will be allocated to
those projects that clearly provide objectives, activities, outcomes/deliverables, performance
measures/milestones and environmental results and address the appropriate quality principles and
attributes described in Question 14.
In regards to whether funds are being used efficiently, the Regions will need to gage their
response based on whether the monitoring projects are long-term or short-term. Short-term
monitoring projects may be more driven to answer a specific question and therefore it may be
less efficient to develop infrastructure (capital equipment, staff and facilities) than a long-term
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project. However, there is also a capacity building goal to tribal monitoring projects so the
Regions need to weigh this goal while ensuring that programs are operating as efficiently as
possible. With these aspects in mind, 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 technology chosen or can the objective be
met just as well with something less costly or over shorter periods of time?
Cooperation - Could the tribe partner with other entities that might help meet the objectives?
Infrastructure- Is the tribe requesting funds for infrastructure that might not be the most
efficient use of funds for this particular project?
As an example, a tribe might 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 might be more efficient from
the initial assessment aspect of the project to utilize the TAMS laboratory, a state laboratory or a
contract lab rather then 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 was an issue and there was a commitment to long-term monitoring,
then a laboratory might be considered feasible and an efficient use of funds.
During the communication process with the tribes on funding ambient air projects, there should
be a discussion of project completion. The completion should be related to when objectives have
been met or when environmental results are achieved (declaring success) and therefore should be
articulated in the proposal/workplan. If a tribal ambient air monitoring project meets the
objective for which it was funded we should declare success in order to fund other priority
projects within the tribal community. Discussing the issue of project start and completion with
the 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 the 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 quickly, and EPA can assist the tribes to get the project(s) back on track. It is
important to document the goals that are achieved since it can 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, we 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 the project until it can be determined what the best method
might be to get the project back on track.
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16. How much time does EPA allow a tribe with a new grant for ambient monitoring to
"come up to speed" in correctly operating its new monitors before the tribe should be
expected to have a QAPP in place, be running the monitors routinely, and be reporting
data to AQS?
Each tribe will have different abilities to implement a monitoring program but in general, a good
rule of thumb would be to provide about one year from the award of a grant for a new type of
monitoring for tribes to prepare for that monitoring.
It is important to recognize the work involved in developing a new monitoring capability. The
tribe will have 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 make good monitoring
decisions. EPA Regions should encourage as much 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 Headquarters, the Regions, ITEP, TAMS,
RPOs, state monitoring organizations and through various national organizations.
It is an EPA requirement to have a QAPP in place and approved before an environmental data
operation begins (see Question 18).
MONITORING REQUIREMENTS AND DATA REPORTING
17. Why is it important to both EPA and tribes for tribes to report their ambient air data
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 from the CASTNET or IMPROVE networks at this time.). 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 through participation in the Air Quality Index.
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• Makes data available to EPA tribal staff who 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 which eliminates the need for this
programming at 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 which is like getting a database for free for life. AQS
provides:
- Enhancements to the data bases and reports. Recent enhancements to AQS
eliminated tribal concerns regarding use of state codes to enter tribal data.
- Training
- Support team for assistance through help desks and conference calls
• Taking 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 is in the AQS system. 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.
As indicated in answers to Question 20, only about 70 percent the tribes performing air
monitoring are presently submitting data to AQS. This needs to change. OAR has worked with
ITEP to develop a strategy to increase the number of tribes reporting data to AQS through a
number of approaches that the Regions will have to communicate to the tribes. However, the
first approach will be to ensure that grant conditions require the submission of data to AQS for
relevant tribal air monitoring programs.
There does not appear to be any acceptable alternative to tribal submissions to AQS that would
not increase burdens on EPA Regions or OAR staff to support such an alternative system. Prior
to AQS re-engineering, when the system was mainframe based, there was a monitor type "9" that
was used to secure certain monitoring data from access to the general public. During the re-
engineering process OAR discussed this secured data with general counsel and it was determined
that this process should be discontinued. Most tribal concerns related to data submission stem
from other entities with an "agenda" being able to access the raw data and make assessments that
could be detrimental to tribal issues. Any alternative system that would provide data to EPA
(e.g., in 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 headquarters 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.
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18. Why is it important that tribes adopt and follow a quality assurance project plan
(QAPP)?
Although tribes are not bound by EPA's monitoring rules, they are bound by grant
regulations which include the development of quality systems for any project that involves
environmental data operations, which include air monitoring. EPA QA Policy 5360.114
requires that all organizations funded by EPA for environmental data collection develop
quality management plans (QMPs) and quality assurance project plans (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 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 look at 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 delays and downtime in various phases of the monitoring program until new
personnel are found and brought up to speed. 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 the QAPPs and SOPs to defend an agencies data; without them, data may be
considered suspect.
Guidance for the development of these QA documents can be found on the EPA Quality Staffs
website14. In addition, EPA has provided flexibility to EPA organizations on how they
implement this policy, allowing for use of a graded approach. Since 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 are necessary. For example, data
collection for the purpose of comparison to the NAAQS will require more stringent
requirements, while monitoring programs for special purposes may not require the same level of
quality assurance. The level of detail of QMP and QAPPs, as explained by the EPA quality Staff
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 QMP and QAPPs. In April,
2007 the graded approach15 was distributed to the Regional Tribal Air Coordinators and the
Regional Ambient Air Contacts.
http://www.epa.gov/qualityl/
15 http://www.epa.gov/ttn/amtic/geninfo.html
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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 can be (and are
suggested) adopted by the monitoring organization by providing written confirmation to the EPA
Regions. There is an opportunity for tribes and states to consolidate monitoring sites into one
primary quality assurance organization (PQAO). This will allow tribes to adopt one QAPP and
set of SOPs. However, there should be written confirmation of this activity that is on file in the
Regional Office, the QAPP should identify all monitoring sites and organizations for which the
QAPP/SOPs apply, and each tribe should have these documents available at their 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 software like Turbo-Tax to lead
tribal monitoring personnel through the development of their project specific ambient air
monitoring QAPPs. Turbo-QAPP should help tribes by providing most of 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 the funding organization 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.
19. How does EPA help tribal monitoring programs satisfy the 40 CFR 58 Appendix A
requirement to have adequate and independent performance evaluation audits (NPAP and
PEP)?
Most of the QA requirements in 40CFR 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
organizations, are being performed through federally implemented programs using STAG funds.
The Appendix A QA 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 purpose 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 contracting 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
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some cases where a Regional Office or the states may be able to perform these audits for the cost
of consumable supplies.
Tribes requiring the audits or wishing to participate in them need to make this decision each
year. In April, 2007 OAR developed a whitepaper that explained the options available to the
tribes. There are a number of ways presented in this paper that might be applicable to tribes
within the Region. 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, could be used during the grant application process to collect
the information needed to address implementation decisions each year.
STATUS OF MONITORING NETWORKS
20. 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
it's inception in 1996. Currently (as of 2007) 120 tribes receive grant support and are operating
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. Eighteen tribes have conducted emissions inventories that have
been submitted to NEI and we continue to provide training and technical support for this activity.
This assessment work continues as new tribes become engaged in the air quality program and
gain the staffing and expertise to begin this work.
Other tribes have begun to move beyond the assessment phase into program development.
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 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.
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). The best
available information is a recent (though incomplete) survey of the Regional Air Tribal
Coordinators compiled by ITEP (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 Regions 6, 8, 9 and 10. To date, approximately 70
percent 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 ( another tribe, an EPA Regional Office, a State
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agency or a contractor). Of the six criteria pollutants, data is being collected primarily for ozone,
o, and PM2.5.
21. How does EPA help a tribe understand its air quality as well as possible if the tribe
cannot get EPA funding to run a monitoring program or not enough funding?
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 Programs,
which was developed to help tribes gain a better idea of the ambient air monitoring process and
provide information on resources and tools that help to build and sustain air environmental
monitoring programs. Within this document, a section has been developed for tribes that are not
implementing air monitoring that provides information on various web-based tools for air quality
assessments and the types of models available and how they are used. In addition, the document
provides an attachment (Attachment G) that provides web links to many ambient air data sources
and tools, most of which are available on the OAR website16.
EPA has been very successful at building various data assessment tools but tribes also need to
understand the basis for using these tools and require training on various aspects of air quality
monitoring and assessment. There are many avenues available for training. In particular, EPA
works with the Institute of Tribal Environmental Professionals (ITEP)17 to sponsor training
courses at the Tribal Air Monitoring Support Center (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, both Headquarters and the
Regions, participate in many of the training activities and this assistance should continue to be
encouraged.
Many EPA Regions offer training on various aspects of air monitoring. If Regions have
particular strengths in certain areas and are willing to provide training, it would be very useful to
share this expertise with other Regions. For example, if a few Regions have expertise in AQS
reporting they might be able to provide this training to tribes in Regions that are not as familiar
with AQS or do not have the same capacity to help tribes in this area.
ADDITIONAL INFORMATION
22. 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)18 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, relevant documents and articles,
16 http://www.epa.gov/air/airpolldata.html
17 http://www4.nau.edu/itep/index.asp
18
http ://www .epa. gov/ttn/amtic/
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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 regions to help provide review/critique to make this website more useful.
The guidance document mentioned in Question 21, 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 includes:
• 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 does
contain fact sheets (Appendix A) of many of the major national air monitoring programs like
IMPROVE, CASTNET, PAMS etc. Each of these facts sheets contain the pertinent web
addresses where more information on the programs objects, methods, guidance or data attributes
can be found. The document was completed in August, 2007 and will be posted on the OAR
Tribal Website19 in September, 2007
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.
19 http://www.epa.gov/air/tribal/airprogs.html
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APPENDIX A
THE TRIBAL AIR APPLICATION PROCESS
Summary of Significant Features of the Tribal Air Application Process:
• Progressive application process: Proposals and abstracts only by deadline, followed by
internal EPA review, negotiation with the applicant, and full application package
submitted after work plans and budgets have been finalized.
• Proposals may be mailed (Return Receipt Requested) or emailed to EPA. A Project
Officer will contact the applicant's staff after the internal review period to arrange
timelines for revisions and submission of the final application.
• Tribes currently receiving financial support through CAA §105 will receive priority for
ongoing funding. Multi-year work plans will be accepted from current recipients with
demonstrated administrative, financial and programmatic capability.
• Tribes or consortia seeking to apply for funding to assist EPA with implementation of the
CAA rules and regulations should clearly indicate this on their proposals.
• Tribes with questions about what authority they should seek funding under can discuss
the available options with EPA once their proposal is accepted for further negotiation.
Funding Opportunity Description:
Background and Purpose: It is EPA policy to work with tribes on a government-to-government
basis to enhance environmental protection in Indian country and tribal communities. The 1990
Clean Air Act Amendments included several provisions authorizing tribal governments to
develop Federally enforceable programs to manage air quality in Indian country. The Tribal
Authority Rule of 1998 created the Treatment as an Eligible State mechanism through which
tribes could qualify to assume responsibility for incremental portions of the CAA, as they
developed the capacity and desire to do so. Until tribes have the technical capacity and choose to
develop independent air quality management programs, EPA has the responsibility to implement
the CAA throughout Indian country. EPA welcomes tribes to partner with them in carrying out
CAA implementation activities.
Eligibility Information:
Matching Costs: A contributing match is required of applicants under CAA §105. However, no
match is required of grant recipients under CAA §103 or DITCAs.
Eligible Recipients: Federally-recognized tribes and tribal consortia are eligible to receive funds.
A tribal consortium is defined as a partnership between two or more tribes authorized by the
governing bodies of those tribes to apply for and receive assistance under the particular EPA
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grant program. A tribal consortium is eligible to receive grants if the consortium can adequately
document compliance with the following requirements:
1. A majority of its member tribes meet the eligibility requirements to receive CAA
grants;
2. All member tribes that meet the eligibility requirements authorize the consortium to
apply for and receive the grant; and
3. Only member tribes that meet eligibility requirements will directly benefit from the
grant project and the consortium will agree to a grant condition to that affect;
4. Consortia must include tribal resolutions or other official documentation from each -
eligible member tribe with its full application. Resolutions should specify the period of
time authorized by the member tribe to apply for the consortia project.
Eligible Activities:
CAA §105: Implementation of programs for the prevention and control of air pollution
or implementation of national primary and secondary ambient air quality standards,
including activities related to the planning, developing, establishing, carrying-out,
improving, or maintaining of such programs.
DITCAs: Assisting EPA with any activity required to implement the Clean Air Act or its
supporting regulations.
CAA §103: Investigations, experiments, demonstrations, surveys and studies relating to
the causes, effects, extent, prevention, and control of air pollution..
Funding Priorities:
This grant opportunity for tribes and tribal consortia is exempt from the EPA Grants Competition
Policy (EPA Order 5700.5A1) under Section 6(c)2. All applications that meet the requirements
set forth in program regulations and guidance will be funded so long as funds are available, with
funding priority based on the three factors of (1) severity of air pollution, (2) sources of air
pollution subject to tribal jurisdiction, and (3) size and population of the reservation. Less
funding is available to tribes and tribal consortia in federal fiscal year 2006 than in recent years.
Base Funding: We anticipate that an increasingly large portion of grant funding to be first
awarded to assure base funding for all federally recognized tribes and consortia having
established eligibility under CAA §105 or with whom DITCAs have been negotiated. For that
reason, we expect to provide much less funding for special projects and initial air quality
assessment needs. Tribes are encouraged to explore the availability of other sources of funding
for these activities, simultaneously with submitting proposals under this grant opportunity. Any
proposals that are also being submitted to other funding sources for consideration should be so
indicated clearly on their face page, stating the name of the other program and the extent to
which there are similar objectives in both grant applications.
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• Consistent with the national CAA allocation formula, base funding is considered not less
than $25,000 per year for most tribes. Tribes with large reservations may receive up to
$150,000, although there is no limit and funding is based on workplan negotiations with
the appropriate Regional Office
• We would like to provide funding for up to three years to those existing recipients with a
strong record of achieving outputs and outcomes and otherwise demonstrating sound
grants management. Multi-year proposals are encouraged; but applicants should discuss
these with their project officer before submitting them.
Additional Funding Opportunities: Regions expect to have sufficient funding for a limited
number of CAA §103 special projects. Because the funding opportunities are expected to be
limited, EPA is requesting a limited amount of information about proposed projects. Consortia
and tribes without reservations may wish to apply under this provision. Abstracts are due by the
same deadline as base funding proposals. All abstracts will be reviewed, and applicants with
projects having a good likelihood to be funded will be requested to develop full work plans and
budgets for those projects.
Circuit Riders: Tribes or consortia interested in pursuing funding for CAA activities or support
on multiple reservations may wish to consider a CAA §103 proposal based upon using a "circuit
rider" where there are common needs by two or more tribes within a reasonably lose
geographical area. This could increase the likelihood of funding for tribes with relatively low
priority based upon the four factors that will be used in the evaluation
Required Proposal Elements:
Base Funding Proposals: Proposals should be postmarked and must contain the following
information to be considered:
— Work plan, to contain the following elements:
1) Narrative description of risks to human health and the environment to be addressed by
the applicant, and their relation to any environmental assessment or strategy efforts
conducted to date.
2) Plans describing how the proposed work will help address environmental and
human health risks;
3) Outputs (i.e. grant deliverables) related to the proposed activities and objectives and
description of how these outputs are expected to contribute to eliminating or reducing
environmental and human health risks; and
4) For each set of planned actions to be funded under the grant; the estimated work
years, estimated funding amounts and a time frame for their accomplishment;
5) A performance evaluation process and reporting schedule in accordance with 40
CFR35.515.
— Budget Narrative: A budget narrative, broken out by federal object categories
and by each year of the project, must be included in the proposal.
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Management Capacity:
All grant applicants must demonstrate sound financial, administrative and programmatic
management capability.
For current or previous recipients, this includes:
• timeliness and completeness of reports;
• progress under the current work plan;
• absence of duplicative activities in proposed work plan and budget; and
• amount of unexpended funds.
For recipients with past performance issues, the application should include a discussion of the
steps the applicant has taken to address issues and correct past administrative, financial or
programmatic challenges.
If the applicant has not applied for an EPA grant in the past, or past performance merits the
review of the applicant's administrative or financial systems, a pre-award review may
be required prior to the submission of an application. A Project Officer will contact the applicant
to schedule this review if necessary.
Award Administration:
Applicants awarded funding must comply with the terms and conditions of the grant award as
well as the federal regulations governing the award and the administration of environmental
programs for tribes and tribal consortia, found in Title 40 of the Code of Federal Regulations
(CFR), Parts 31 and 35, SubpartB (40 CFR 35.500-35.518). EPA highly recommends that grant
applicants carefully review and understand all grant award documents prior to accepting the
grant. If questions or concerns arise during that review, contact your tribal coordinator.
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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 who are not already familiar with this material, 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 section 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
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tribal monitoring) is provided as part of the National Ambient Air Monitoring Strategy.
That strategy and other relevant information (including types, purposes, history, funding)
of monitoring networks, including tribal programs, are provided at the following
addresses:
— http ://www. epa. gov/oar/oaqps/qa/monprog.html# Ambient
— 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/tribetotribe.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 the public 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 major
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 public and environmental welfare, and 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
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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. 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/m onitor.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 agencies
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 Centers mission is to strive 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 training programs and services available to tribal programs are
provided at the following Internet addresses:
— http: //www4. nau. edu/itep/
— http: //www4. nau. edu/tam s/
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National Emissions Inventory (NEI)
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 will be ready
in early 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) 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. Also available is the Model Clearinghouse which is designed 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
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cause or contribute to a violation of state or national air quality standards or cause an adverse
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 2003 Report on the
Environment makes extensive use of indicators in assessing the status of health and ecosystem
effects; preparation of a report that reflects 2006 has begun. 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/cmprpt/arp03/summary.html
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
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National Air Toxics Assessment (NATA)
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/natal999/
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 avoided. Internet addresses with
additional information on radon and mold, associated effects, and mitigation strategies available
for consideration by tribes 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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