U.S. Environmental Protection Agency
DEVELOPING DESIGNATION
RECOMMENDATIONS FOR
AREAS OF INDIAN COUNTRY
September 2018

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Developing Designation Recommendations for Areas of Indian Country
CONTENTS	
TABLES	v
LIST OF ACRONYMS AND ABBREVIATIONS	vi
I.	INTRODUCTION	7
A.	WHAT IS THE PURPOSE OF THIS DOCUMENT?	7
B.	HOW DOES THIS DOCUMENT APPLY TO ME?	8
C.	WHAT IS THE CLEAN AIR ACT?	8
D.	WHAT ARE THE NATIONAL AMBIENT AIR QUALITY STANDARDS AND WHICH POLLUTANTS DO THEY
ADDRESS?	11
E.	HOW DOES THE EPA SET THE NAAQS	11
F.	WHAT IS THE TRIBAL AUTHORITY RULE?	12
G.	SUMMARY POINTS AND FURTHER INFORMATION	13
II.	UNDERSTANDING DESIGNATIONS FOR THE NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)	13
A.	WHAT DOES DESIGNATION MEAN?	13
B.	WHY ARE DESIGNATIONS MADE?	14
C.	WHEN ARE DESIGNATIONS MADE?	15
D.	WHAT IS A DESIGNATION RECOMMENDATION AND HOW DO I DETERMINE WHAT TO RECOMMEND ?
..15
E.	ARE TRIBES REQUIRED TO SUBMIT DESIGNATION RECOMMENDATIONS?	16
F.	WHAT IS THE EPA'S ROLE IN THE DESIGNATION OF INDIAN COUNTRY?	16
G.	HOW WILL THE EPA ENGAGE TRIBES IN DESIGNATION ACTIVITIES?	18
H.	WHAT IS THE TRIBAL ROLE IN THE DESIGNATIONS PROCESS?	18
I.	SUMMARY POINTS AND FURTHER INFORMATION	19
III.	DESIGNATION CATEGORIES	20
A.	NONATTAINMENTAREA DESIGNATION	20
B.	ATTAINMENT AREA DESIGNATION	22
C.	UNCLASSIFIABLE AREA DESIGNA TION	23
IV.	TRIBAL PARTICIPATION IN THE DESIGNATIONS PROCESS	25
A.	HOW CAN / PARTICIPATE IN THE DESIGNATIONS PROCESS?	25
B.	WHAT IS THE PROCESS FOR ESTABLISHING A SEPARATE DESIGNATION FOR INDIAN COUNTRY?	26
C.	WHAT ARE THE PROS AND CONS OF SUBMITTING A DESIGNATION RECOMMENDATION?	27
D.	HOW ARE DESIGNATION RECOMMENDATIONS RELATED TO THE TRIBAL AUTHORITY RULE,
TREATMENT IN A MANNER SIMILAR TO A STATE, AND TRIBAL IMPLEMENTATION PLANS?	28
E.	KEY POINTS AND FURTHER INFORMATION	28
V. DEVELOPING A DESIGNATION RECOMMENDATION FOR AREAS OF INDIAN COUNTRY	29

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Developing Designation Recommendations for Areas of Indian Country
A.	HOW DO I DEVELOP A DESIGNATION RECOMMENDATION?	29
B.	CAN / PARTICIPATE IN THE DESIGNATIONS PROCESS FOR SOME CRITERIA POLLUTANTS AND NOT
OTHERS?	30
C.	WHAT ARE THE FIVE FACTORS THAT I NEED TO ANALYZE?	30
D.	WHAT IF I DO NOT SUBMIT A MULTI-FACTOR ANALYSIS?	31
E.	DO I NEED TO ANALYZE ALL FIVE FACTORS?	31
F.	WHAT EVALUATION TOOLS AND DATA ARE AVAILABLE FOR MY USE?	31
G.	WHAT OTHER INFORMATION SHOULD I INCLUDE IN THE DESIGNATION RECOMMENDATION?	32
H.	KEY POINTS AND FURTHER INFORMATION	32
VI.	THE FACTORS TO CONSIDER WHEN DEVELOPING A DESIGNATION RECOMMENDATION	33
A.	AIR QUALITY DATA	34
B.	EMISSION-RELATED DATA	36
C.	METEOROLOGY	40
D.	GEOGRAPHY/TOPOGRAPHY	43
E.	JURISDICTIONAL BOUNDARIES	44
F.	OTHER RELEVANT INFORMATION	47
VII.	SUBMITTING THE DESIGNATION RECOMMENDATION	48
A.	WHERE AND WHEN DO I SEND THE DESIGNATION RECOMMENDATION LETTER AND MULTI-FACTOR
ANALYSIS?	48
B.	WHEN IS THE DESIGNATION RECOMMENDATION DUE?	48
C.	WHAT IS THE PROCESS FOR REVIEWING MY DESIGNATION RECOMMENDATION?	48
D.	WHAT HAPPENS IF THE EPA AGREES WITH MY DESIGNATION RECOMMENDATION?	49
E.	WHAT HAPPENS IF THE EPA DOES NOT AGREE WITH MY DESIGNATION RECOMMENDATION?	49
F.	KEY POINTS AND FURTHER INFORMATION	50
VIII.	APPENDIX 51
APPENDIX A: INFORMATION ON CRITERIA POLLUTANTS	53
APPENDIX B: SAMPLE TRIBAL DESIGNATIONS CONSULTATION LETTER	57
APPENDIX C: EPA HEADQUARTERS AND REGIONAL OFFICES TRIBAL CONTACTS	59
APPENDIX D: DECISION MATRIX.	60
APPENDIX E: EPA REGIONAL ADMINISTRATORS	61
APPENDIX F: AIR QUALITY EDUCATION AND TRAINING RESOURCES	62
APPENDIX G: AIR QUALITY MONITORING INFORMATION AND DATA SOURCES	63
APPENDIX H: AIR POLLUTION EMISSIONS INFORMATION AND DATA SOURCES	64
APPENDIX I: DESIGNATIONS RECOMMENDATION SUBMISSIONS CHECKLIST	67
APPENDIX J: EPA TECHNICAL SUPPORT DOCUMENT FOR PM2.5 DESIGNATIONS	68
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Developing Designation Recommendations for Areas of Indian Country
TABLE	
Table 1. EPA's Role in the Process for Designations of Indian Country	17
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Developing Designation Recommendations for Areas of Indian Country
LIST OF ACRONYMS AND ABBREVIATIONS
AQS	Air Quality System
BIA	Bureau of Indian Affairs
CAA	Clean Air Act
CASAC	Clean Air Scientific Advisory Committee
CFR	Code of Federal Regulations
CO	Carbon Monoxide
DHEC	Department of Environmental Health and Control
EPA	United States Environmental Protection Agency
FIP	Federal Implementation Plan
FR	Federal Register
HYSPLIT	HYbrid Single-Particle Lagrangian Integrated Trajectory
ISA	Integrated Science Assessment
NAAQS	National Ambient Air Quality Standards
NEI	National Emission Inventory
N02	Nitrogen Dioxide
NOx	Oxides of Nitrogen
NOAA	National Oceanic and Atmospheric Administration
NSR	New Source Review
03	Ozone
OAR	Office of Air and Radiation
OAQPS	Office of Air Quality Planning and Standards
PA	Policy Assessment
Pb	Lead
PM	Particulate Matter
PPM	Parts Per Million
PSD	Prevention of Significant Deterioration
RACM	Reasonably Available Control Measures
RACT	Reasonably Available Control Technology
REA	Risk/Exposure Assessment
RFP	Reasonable Further Progress
SIP	State Implementation Plan
S02	Sulfur Dioxide
TAMS	Tribal Air Monitoring Support Center
TAR	Tribal Authority Rule
TAS	Treatment in the Same Manner as a State
TIP	Tribal Implementation Plan
VMT	Vehicle Miles Traveled
VOC	Volatile Organic Compound
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Developing Designation Recommendations for Areas of Indian Country
I. INTRODUCTION
A. \	'CUMENT?
This manual is intended to serve as a tool to support your understanding of, and
participation in, the recommendation process for designating areas for the National
Ambient Air Quality Standards (NAAQS)1 for your area of Indian country.2 We, the
United States Environmental Protection Agency (EPA), are providing general air quality
background information, and template materials to assist in your decision making and
development of a designation recommendation. This document does not develop new
policy, but more clearly explains "existing policy."
In December 2011, we released two key guidance documents related to the process for
designating areas of Indian country. The first document, Guidance to Regions for
Working with Tribes during the National Ambient Air Quality Standards (NAAQS)
Designations Process3 provides guidance to the EPA regional offices for working with
federally recognized Indian tribes regarding the designations process for Indian country.
The second document, Policy for Establishing Separate Air Quality Designations for
Areas of Indian Country4 sets forth the EPA's policy regarding designating particular
areas of Indian country separately from surrounding or adjacent areas when a tribe
requests a separate designation. Please see these documents for a greater
understanding of the designation recommendation process as it relates to Indian
country.
Section I of this document provides basic information on the Clean Air Act (CAA) air
quality programs. Section II introduces the concept of designations and the designations
process. Section III lists the three different designation categories and the requirements
of each. Section IV discusses how you can participate in the designations process.
Section V covers how to develop a designation recommendation for your area. Section
VI lists and explains the five factors you need to consider when developing a tribal
designation recommendation. Section VII discusses when and where to send your
designation recommendation and describes the EPA review process. The Appendices
1	Pursuant to §107(d)(l) of the Clean Air Act and 40 C.F.R. areas are designated as nonattainment, attainment or
unclassifiable.
2	Indian country, as defined at 18 U.S.C. §1151, means (a) all land within the limits of any Indian reservation under
jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights-of-way
running through the reservation, (b) all dependent Indian communities within the borders of the United States whether
within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and (c) all
Indian allotments, the Indian titles to which have not been extinguished, including rights-of-way running through the same.
3	https://epa.gov/sites/production/files/2017-02/documents/12-20-
ll_guidance_to_regions_for_working_with_tribes_naaqs_designations.pdf.
4	https://www.epa.gov/sites/production/files/2016-02/documents/indian-country-separate-area.pdf.
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Developing Designation Recommendations for Areas of Indian Country
contain valuable information and examples to help guide you through the designations
recommendation process.
Throughout this document "you" means a federally recognized Indian tribe; "we", "our",
and "us" means the EPA. This document is intended solely as an information resource.
The statutory provisions and the EPA regulations described in this document contain
legally binding requirements. This document itself is not a regulation, nor does it change
or substitute for any statutory provisions and regulations. It does not impose legally
binding requirements on the EPA, tribes or the regulated community. This document
also does not confer legal rights or impose legal obligations upon any member of the
public.
While the EPA has made every effort to ensure the accuracy of the discussion in this
document, the obligations of tribes and the regulated community are determined by
statutes, regulations, and other legally binding requirements. In the event of a conflict
between the discussion in this document and any statute or regulations, the statutory
and/or regulatory provisions are the guiding authorities.
The general description provided here may not apply to a particular situation based
upon the circumstances. Interested parties are free to raise questions and objections
about the substance of this guidance and the appropriateness of the application of this
document to a particular situation. The EPA and other decision makers retain the
discretion to adopt approaches on a case-by-case basis that differ from those described
in this document where appropriate.
e. HOW DOES THIS DOCUMENT	ME?
This document provides guidance to federally recognized tribes interested in making a
NAAQS designation recommendation to the EPA for their area of Indian country. It
contains guidelines for understanding, planning, preparing, and submitting your
designation recommendation. If you are uncertain about whether to prepare a
designation recommendation, you can use this document to help you reach a decision.
Although tribes, unlike states, are generally not required to participate in the
designations process, the EPA believes it is important to work with all federally
recognized tribes to provide the opportunity to participate. If a tribe chooses not to
participate in the designations process, the EPA will, in consultation (if requested) with
the tribe, make a designation decision for the relevant area of Indian country.
C. V	T?
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Developing Designation Recommendations for Areas of Indian Country
The Clean Air Act (CAA or the Act)5 is a federal law covering the entire country. State,
local, federal, and eligible tribal governments do much of the work to meet the Act's
requirements. For example, representatives from these governmental bodies work with
companies to reduce air pollution. They also review and approve (or disapprove, as
appropriate) permit applications for construction (new or modification to existing) and
operation of industrial sources that could emit certain pollutants.
History
In October 1948, a thick cloud of air pollution formed above the industrial town
of Donora, Pennsylvania. The cloud, which lingered for five days, killed 20
people and caused sickness in 6,000 of the town's 14,000 people. In 1952, over
3,000 people died in what became known as London's "Killer Fog." The smog
was so thick that buses could not run without guides walking ahead of them
carrying lanterns.
Events like these alerted us to the dangers that air pollution poses to public
health. Several federal and state laws were passed, including the original CAA of
1963, which established funding for the study and the cleanup of air pollution.
But, there was no comprehensive federal response to address air pollution until
Congress passed a much stronger CAA in 1970. That same year, Congress created
the EPA and gave it a primary role in implementing the law. Since 1970, we have
been responsible for developing and implementing a variety of Clean Air Act
programs to reduce air pollution nationwide. However, it makes sense for state
and local governments to take the lead in carrying out the CAA. They are able to
develop solutions for pollution problems that require special understanding of
local industries, geography, housing, and travel patterns, as well as other factors.
State, local, and tribal governments also monitor air quality, inspect facilities
under their jurisdictions and enforce CAA regulations.
In 1990, Congress dramatically revised and expanded the CAA providing us with
even broader authority to implement and enforce regulations reducing air
pollutant emissions. The 1990 Amendments also placed an increased emphasis
on more comprehensive approaches to reduce air pollution.6
Role of the FPA
Our mission is to protect human health and the environment. We are
responsible for setting limits on levels of certain air pollutants to help ensure
basic health and environmental protection from pollution, known as the National
Air Quality Standards (NAAQS). We also limit emissions of air pollutants coming
5	https://www.epa.gov/clean-air-act-overview.
6	https://www.epa.gov/clean-air-act-overview/clean-air-act-highlights-1990-amendments.
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Developing Designation Recommendations for Areas of Indian Country
from stationary (major or minor) and mobile sources. We must approve (or
disapprove, as appropriate) state, tribal, and local agency plans for reducing air
pollution. We can provide research, expert studies, technical support, and
funding to you, the states, tribal, or local agencies to support the development
of air quality plans.
Role of the Tribes
The 1990 revision of the CAA included the first provision of the statute
comprehensively addressing the roles of Indian tribes in implementing CAA air
pollution control programs in their areas of Indian country. Under the Tribal
Authority Rule (TAR),7,8,9 which the EPA promulgated pursuant to the CAA tribal
provision, you may seek eligibility to develop CAA air quality management
programs, write rules to reduce air pollution, and implement, and enforce your
rules as approved under the CAA in Indian country. Unlike state and local
agencies that are required to implement many CAA requirements, you may
choose to develop and implement those programs, or even portions of
programs, that are most relevant to your tribe's air quality needs. The EPA
deemed limited sections of the CAA as inappropriate for tribes, generally
including implementation deadlines and associated sanctions as well as
requirements for criminal enforcement authority as a prerequisite to CAA
program approval.
Key Elements
We implement a variety of programs under the CAA that focus on:
¦	Reducing outdoor, or ambient, concentrations of air pollutants that cause
smog, haze, acid rain, and other problems;
¦	Reducing emissions of toxic air pollutants that are known to, or are
suspected of, causing cancer or other serious health effects; and
¦	Phasing out the production and use of chemicals that destroy stratospheric
ozone (O3).
These pollutants come from stationary sources (like chemical plants, gas
stations, and power plants) and mobile sources (like cars, trucks, and planes) and
area, i.e., small, sources (like dry cleaning facilities and auto body refinishing
7	https://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap85-subchaplll-sec7601.pdf.
8	https://www.gpo.gov/fdsys/pkg/FR-1998-02-12/pdf/98-3451.pdf.
9	https://www.epa.gov/tribal-air/tribal-authority-rule-tar-under-clean-air-act.
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Developing Designation Recommendations for Areas of Indian Country
shops).
D.	\w\ " \ L, ^ . \ \l^\ \l Wh.VT AIR QUALITY
STANDARDS AND WHICH POLLUTANTS DO THEY ADDRESS?
The CAA requires us to set the NAAQS10 levels for air pollutants that:
1.	Can endanger public health or welfare, and
2.	Come from numerous and diverse sources.
To date, we have set NAAQS for six common air pollutants, also known as "criteria
pollutants." They are particle pollution (often referred to as particulate matter or PM),
ground-level ozone (O3), carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide
(NO2), and lead (Pb).11 These pollutants can harm your health and the environment. Of
the six pollutants, PM and ground-level O3 are the most widespread health threats.
We call these pollutants "criteria" air pollutants because we regulate them by
developing human health-based and/or environmentally-based criteria (science-based
guidelines) for setting permissible levels of pollution.12 The standards based on
protecting human health are called primary standards. The standards intended to
prevent environmental and property damage are called secondary standards. Every five
years, the EPA is required to review the science upon which the standards for that
particular pollutant are based and, as necessary, revise them to protect human health
and the environment with an adequate margin of safety.
E.	T THE NAAQS
On a periodic basis specified by the CAA, the EPA reviews the NAAQS which are set for
each of the six "criteria" pollutants (PM, O3, CO, SO2, NO2, and Pb).13 In doing so, the
EPA staff undertakes an extensive review of the currently available science regarding
the public health and environmental effects associated with the presence of the criteria
pollutant in the air. For each review, the EPA staff produces a series of documents,
which include an integrated science assessment (ISA), a risk and exposure assessment
(REA) when warranted, and a policy assessment (PA). Each of these documents is
extensively reviewed by a congressionally mandated group of independent scientific and
10	https://www.epa.gov/naaqs
11	See Appendix A of this document for information on each of the criteria pollutants.
12	National Ambient Air Quality Standards (NAAQS) for six principal pollutants, which are called "criteria" pollutants.
https://www.epa.gov/criteria-air-pollutants.
13https://www. epa.gov/criteria-air-pollutants/process-reviewing-national-ambient-air-quality-standards
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Developing Designation Recommendations for Areas of Indian Country
technical experts known as the Clean Air Scientific Advisory Committee (CASAC).14 This
committee provides independent advice to the EPA Administrator on the adequacy of
the documents to serve as a basis to inform the Administrator's judgments regarding
the adequacy of the current standards and any potential revisions that might be
necessary. At the same time, the EPA makes the draft documents available for review
and comment from the public, which may include representatives from the scientific
community, industry, and public interest groups, as well as interested individuals.
Before the EPA Administrator makes a final decision on a standard's review, the
proposed decision, based on the currently available scientific evidence and
exposure/risk information and on considerations presented in the policy assessment, is
published in the Federal Register (FR)15 for public review and comment. Taking into
consideration the comments received, the Administrator then makes the final decision
to either retain or revise the existing standards. Consistent with requirements of the
CAA, the NAAQS are set to protect the public health with an adequate margin of safety
and the public welfare from any known or anticipated adverse environmental effects.
Congress decided, and the Supreme Court upheld, that the EPA may not consider costs
when setting or revising air quality standards.
F. WHAT IS THE TRIBAL AUTHORITY ROLE?
On February 12,1998, we issued the TAR.16 This rule implements section 301(d) of the
CAA. The TAR identifies those provisions of the CAA for which it is appropriate to treat
eligible federally recognized tribes in the same manner as a state (TAS).17,18 The TAR
outlines the eligibility criteria you must meet to obtain TAS status and specifies the
process by which we will act on tribal TAS applications.
You can obtain TAS for many elements of the CAA including, but not limited to, a
reduced match for programmatic grants under section 105 of the CAA, monitoring, and
developing and implementing a Tribal Implementation Plan (TIP).19 You can apply for
TAS in stages as your program grows. This will allow you to obtain TAS for only those
parts of the CAA you need, but you can also bundle your TAS applications for multiple
elements of the CAA you intend to develop in the future. The TAR also provides a
modular approach for the tribes so that you can take on specific elements of CAA
programs separately as long as those elements are "reasonably severable." Please note
14	https://yosemite.epa.gov/sab/sabpeople.nsf/WebCommittees/CASAC.
15	https://www.federalregister.gov/.
16https://www. epa.gov/tribal-air/tribal-authority-rule-tar-under-clean-air-act.
17	https://www.epa.gov/tribal/tribal-assumption-federal-laws-treatment-state-tas.
18	https://www.gpo.gov/fdsys/pkg/USCODE-2013-title42/pdf/USCODE-2013-title42-chap85-subchaplll-sec7601.pdf.
19	https://www.epa.gov/tribal-air/clean-air-act-summary-content-applicability-tas-titles-i-iii-and-v
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Developing Designation Recommendations for Areas of Indian Country
that even absent TAS, you may participate fully in the designations process and provide
us with air quality information for your areas of Indian country. Please see Section IV.D
below for more information on this topic.
G. SUMMARY POINTS AND FURTHER INFORMATION
•	This manual is a resource for tribal environmental professionals and is intended to
promote an understanding of the designations process for Indian country.
•	This document will help you decide whether to prepare a designation
recommendation.
•	The CAA is a federal law that covers the entire United States.
•	The NAAQS limit the amount (concentration) of criteria pollutants in the air.
•	The air pollutants of concern that are related to designation recommendations are
carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), ozone (O3), particulate
matter (PM), and sulfur dioxide (SO2).
•	The TAR establishes criteria and a process for tribes to become eligible to manage air
quality under the CAA for your areas of Indian country.
•	Tribes are encouraged, but not required, to submit designation recommendations.
For further information on these topics see:
•	The plain language guide to the CAA:
https://www.epa.gov/clean-air-act-overview/plain-english-guide-clean-air-act.
•	EPA's most recent evaluation of air pollution trends for the six criteria pollutants:
https://www.epa.gov/air-trends.
•	The NAAQS and criteria air pollutants:
https://www.epa.gov/naaqs.
•	The Tribal Authority Rule and general tribal air quality management information:
https://www.epa.gov/tribal-air/tribal-authority-rule-tar-under-clean-air-act.
UNDERSTANDING DESIGNATIONS FOR THE NATIONAL
AMBIENT AIR QUALITY STANDARDS (NAAQS)
A. WHAT DOES DESIGNATION MEAN?
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Developing Designation Recommendations for Areas of Indian Country
Designation is a term that describes the air quality status in a particular area with
respect to a NAAQS for any of the six common "criteria" air pollutants: CO, Pb, NO2, O3,
PM, and SO2. After working with the states and tribes, and considering the information
from air quality monitors and all other relevant information, we formally designate
areas as to whether they are meeting or not meeting a new or revised standard.20
The CAA identifies three designation categories:
1.	Nonattainment - not meeting the standard or contributing to air quality in a
nearby area that is not meeting the standard;
2.	Attainment - meeting the standard and not contributing to air quality in a
nearby area that is not meeting the standard; and
3.	Unclassifiable21 - insufficient data to determine whether the area is meeting or
not meeting the standard.
Each designation is for a specific air quality standard for a criteria pollutant. An area can
be in attainment for one standard and nonattainment or unclassifiable for another. The
three designation categories and their requirements are described in more detail in
Section III below.
e. WHY ARE DESIGNATIONS MADE?
CAA section 107(d)22 establishes, among other things, the requirement for us to
designate all areas following promulgation of a new or revised NAAQS. Designating an
area as nonattainment, attainment or unclassifiable is an indication of the area's air
quality. Establishing area designations is the first step in determining whether further
action is needed in an area to attain (comply with) the NAAQS and provide the health
and/or environmental protection intended by the CAA.
Generally, within three years after the effective date of the designation, a state area
designated as nonattainment is required to develop and submit to the EPA for approval,
a State Implementation Plan (SIP)23 to demonstrate how the area will improve air
quality to meet the NAAQS. For areas of Indian country that are designated as
nonattainment, tribes may develop Tribal Implementation Plans (TIPs), but are not
20	https://www.epa.gov/criteria-air-pollutants/naaqs-designations-process
21	Historically, for initial designations after the EPA established a new or revised NAAQS, the EPA has used a designation
category of unclassifiable/attainment for areas that are monitoring attainment or that do not have monitors and that are
not contributing to a nearby violation. We expect to continue to use the unclassifiable/attainment category for future
designations.
22	https://www3.epa.gov/airquality/greenbook/caa-tlp.html.
23	https://www.epa.gov/criteria-air-pollutants/naaqs-implementation-process.
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Developing Designation Recommendations for Areas of Indian Country
required to do so.24 Should these tribes choose not to develop TIPs, the EPA will develop
the implementation plan, where necessary or appropriate, which is known as a Federal
Implementation Plan or FIP.
C.	1/ J ARE DESIGNATIONS MADE?
We must finalize area designations no later than two years from the date a new or
revised NAAQS is promulgated unless the EPA Administrator has insufficient information
to promulgate designations by that time. In this case, the Administrator may extend this
period for up to one year beyond the original deadline.
D.	WHAT IS A DESIGNATION RECOMMENDATION AND HOW DO I
DETERMINE WHAT TO RECOMMEND?
A designation recommendation is a formal submittal to an EPA regional office from an
authorized state or tribal official. Typically, on letterhead, the official specifically
identifies the geographic areas and recommends for each area whether the designation
category be nonattainment, attainment, or unclassifiable for the specified NAAQS.
A designation recommendation is based on certified air quality data and other relevant
information that you submit. It also may include other relevant information commonly
called a multi-factor analysis (also known as the five-factor analysis). The analysis
evaluates the following five factors: air quality data, emissions-related data,
meteorology information, geography/topography information, and jurisdictional
boundaries. Section VI below contains information on the five factors to consider when
developing a designation recommendation.
The following examples generally illustrate designations that could be appropriate for
areas of Indian country:25
•	Indian country with a regulatory air quality monitor showing a violation of the
NAAQS would be designated as nonattainment.
•	Indian country with a regulatory air quality monitor showing that the NAAQS is being
met could be designated as attainment provided all criteria are met such as three
consecutive calendar years of quality-assured, certified air quality from a certified
regulatory monitor. However, it would be designated nonattainment if sources on
Indian country are contributing to a violation of the NAAQS in a nearby area (outside
of the Indian country boundary).
24	https://www.epa.gov/criteria-air-pollutants/naaqs-designations-process.
25	Note that for sulfur dioxide (SO2) designations only, air agencies have the flexibility to use modeling to characterize air
quality around a source or source region as a surrogate for ambient monitoring.
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Developing Designation Recommendations for Areas of Indian Country
• Indian country that is lacking a regulatory monitor and is located within an area that
includes one or more counties or states (also known as a multi-jurisdictional area)
with a violating regulatory monitor that is not representative of the Indian country
could be recommended as unclassifiable. However, the Indian country could be
designated as nonattainment when: 1) sources on Indian country are contributing
to a violation of the NAAQS in the nearby state area, and/or 2) air quality modeling
shows that the NAAQS is being violated in the Indian country area.26
E.	IT DESIGNATION
4ENDATI0NS?
Tribes are not required, but are encouraged, to submit designation recommendations
for their areas of Indian country. The CAA section 107(d) requires us to designate all
areas of the country in a timely manner following promulgation of a new or revised
NAAQS. Therefore, if a tribe does not submit a recommendation, the EPA, under our
CAA authorities, will promulgate an appropriate designation for the relevant area of
Indian country. Although under the TAR tribes are not required to meet the same
schedules as states, the CAA requires the EPA to act in a timely manner. Therefore, in
order for your recommendation to influence our final designation decision, your
submittal should be in the same time frame as the states.27
F.	WHAT IS THE EPA'S ROLE IN
COUNTRY?
We are primarily required to designate all areas of the country. In this process, our
December 20, 2011 memorandum, Guidance to Regions for Working with Tribes during
the NAAQS Designations Process, identifies how we will consult with and assist
interested tribes with development of their designation recommendations.28 The
EPA's 1984 Indian Policy29 indicates that we will "give special consideration to tribal
interests in making Agency policy and to ensure the close involvement of tribal
governments in making decisions and managing environmental programs affecting
26	This only applies to the NAAQS for SO2 where both monitoring and modeling are used to establish violations.
27	See EPA Memorandum, Policy for Establishing Separate Air Quality Designations for Areas of Indian Country,
December 20, 2011 at https://www.epa.gov/sites/production/files/2016-02/documents/indian-country-separate-area.pdf.
28	See EPA Memorandum, Guidance to Regions for Working with Tribes during the National Ambient Air Quality Standards
(NAAQS) Designations Process, December 20, 2011 at https://www.epa.gov/sites/production/files/2017-02/documents/12-
20-ll_guidance_to_regions_for_working_with_tribes_naaqs_designations.pdf.
29	See the EPA's 1984 Indian Policy at https://www.epa.gov/tribal/epa-policy-administration-environmental-programs-
indian-reservations-1984-indian-policy.
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Developing Designation Recommendations for Areas of Indian Country
reservation land." The following are some of the principles the EPA committed to in
order to meet these objectives:
•	We stand ready to work directly with Indian tribal governments on a one-to-one
basis (the "government-to-government" relationship), rather than as a political
subdivision of states or other governmental units.
•	We recognize tribal governments as the primary parties for making environmental
policy decisions and managing programs for reservations, consistent with federal
environmental standards and regulations.
•	Until tribal governments are willing and able to assume full responsibility for
delegable programs, we will retain responsibility for managing programs on
reservations (unless the state has an express grant of jurisdiction from Congress
sufficient to support delegation to the state government).
Our role in the designations process for Indian country is further discussed in the
Guidance to Regions for Working with Tribes during the NAAQS Designations Process.
Table 1 below provides an excerpt from this memorandum that outlines the designations
process.
Table 1. The EPA's Role in the Process for Designations of Indian Country
STEP
ACTIVITY
1
Final NAAQS promulgated and published in the Federal Register.
2
Education and outreach conducted by the EPA headquarters and regional offices on the
designations process.
3
Letters sent by the EPA regional offices to tribes requesting designations
recommendation and offering consultation. Letters should inform tribes of the
following:
•	The promulgation of a new or revised NAAQS;
•	An opportunity for "government-to-government" consultation with the EPA;
•	The opportunity and process (including timeline) for submitting initial designation
recommendations;
•	The date by which the EPA requests that tribes notify the EPA if they wish to engage
in consultation and/or participate in the designations process;
•	The potential nonattainment designation for their Indian country (if applicable);
•	The time frame in which the EPA intends to promulgate designations; and
•	Specific contact information for questions and follow up on the letter.
4
Consultation conducted by the EPA regional offices.
5
Tribes provide designation recommendations.
6
EPA review recommendations and conducts own analysis (e.g., multi-factor analysis).
7
If the EPA intends to modify a tribe's recommendation, the EPA regional offices offer
tribal staff an opportunity for technical dialogue.
8
120-day letters (which provide an opportunity for consultation) sent by the EPA regional
offices to the following tribes:
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Developing Designation Recommendations for Areas of Indian Country

•	All tribes that submitted initial designation recommendations;
•	All tribes with Indian country that the EPA intends to designate as nonattainment;
and
•	All tribes with TAS status for CAA section 107(d) purposes.

9
Tribes have the opportunity to submit further technical information, if they disagree
with intended designation.
10
Consultation (if requested) conducted by the EPA regional offices and additional
information evaluated.
11
Final designations determined.
12
Final designations signed by the EPA Administrator and published in the Federal
Register.30
13
Education and outreach conducted by the EPA headquarters and regional offices on final
designations.
G.	HOW WILL THE EPA ENGAGE TRIBES IN DESIGNATION
TIVITIES?
We believe it is important to work with all federally recognized tribes to provide the
opportunity to participate in the designations process for their areas of Indian country.
We want to ensure early, transparent, and effective communication in proposing area
designations. Therefore, we intend to solicit relevant air quality information and
designation recommendations from, and offer consultation to, all tribes regardless of
theirTAS status. (See Appendix B for an example of a consultation letteryou would
receive from the EPA.) Even if you have not obtained TAS for the purposes of
designations (CAA section 107(d)), we intend to solicit relevant air quality information
and designation recommendations from you for your areas of Indian country. This
approach is consistent with the federal government's trust responsibility to federally
recognized Indian tribes as well as various policies relating to tribes.
We intend to conduct outreach and offer consultation to all tribes on a schedule that
provides sufficient time for you to be involved in the designations process and to submit
relevant air quality information and recommended designations. Although tribes are
generally not required to participate in this process, it is important to us to provide the
opportunity to participate to all federally recognized tribes. Table 1 above lists the key
points of communication beginning with initial education and outreach following
promulgation of a new or revised NAAQS.
H.	WHAT IS THE TRIBAL ROLE IN THE DESIGNATIONS PROCESS?
The tribe can choose whether or not to participate in the designations process. If you
choose to participate, you decide what level of involvement is best for you based on
30 https://www.federalregister.gov/.
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Developing Designation Recommendations for Areas of Indian Country
your interest, priorities, and available resources. For example, you may choose to
submit air quality data or other information, if available, that supports your
recommendation. This is discussed more in Section VI below. Note that we are required
to designate all areas of the country, regardless of whether you submit a
recommendation.
I. SUMMARY POINTS AND FURTHER INFORMATION
•	Designation is a term that describes the air quality status in a particular area.
•	The CAA section 107(d) requires the EPA to designate all areas of the country in a
timely manner.
•	Designations are generally made two years from the date a new or revised NAAQS is
promulgated.
•	A designation recommendation is a formal request/recommendation from an official
authorized to make the request on behalf of the tribe.31 Initial designations
recommendations should be submitted on the same schedule that applies to states.
However, tribes, unlike states, are not required to submit designation
recommendations.
•	The EPA intends to solicit air quality information and designation recommendations
from, and offer consultation to, all federally recognized tribes regardless of their TAS
status.32
•	The EPA intends to engage with interested tribes in the designation progress.
•	Tribes can choose the degree to which they will participate in the designations
process.
For further information on designation topics see:
•	Ground-level ozone (O3) designations:
https://www.epa.gov/ozone-designations.
31	Although the CAA section 107(d) does not explicitly reference Indian tribes or Indian country, tribes are able to
participate in the designations process. For instance, under section 301(d) and the Tribal Authority Rule (TAR) (63 FR 7254,
February 12,1998), tribes may seek treatment in a similar manner as a state (TAS) for purposes of section 107(d)
designations. Even absent TAS for section 107(d) purposes, the EPA may solicit air quality information and designation
recommendations from tribes for their areas of Indian country.
32	The Executive Order (EO) 13175, the Agency's 1984 Indian Policy, and the EPA Policy on Consultation and Coordination
with Indian Tribes (May 4, 2011) call for the EPA to consult with tribes on actions and decisions, such as designation of their
Indian country, that affect their interests.
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Developing Designation Recommendations for Areas of Indian Country
•	Fine particle (PM) designations:
https://www.epa.gov/particle-pollution-designations.
•	Nitrogen dioxide (NO2) designations:
https://www.epa.gov/nitrogen-dioxide-designations.
•	Lead (Pb) designations:
https://www.epa.gov/lead-designations.
•	Sulfur dioxide (SO2) designations:
https://www.epa.gov/sulfur-dioxide-designations.
•	Carbon Monoxide (CO) designations:
https://www.epa.gov/green-book/green-book-carbon-monoxide-1971-area-
information.
III. DESIGNATION CATEGORIES
After we establish or revise a primary and/or secondary NAAQS, section 107 of the CAA
requires us to designate areas as "nonattainment" (not meeting the standard or contributing to
a nearby area that is violating the standard), "attainment" (meeting the standard and not
contributing to a nearby area that is not meeting the standard), or "unclassifiable"33
(insufficient information to determine whether the area is meeting or not meeting the
standard) after analyzing monitoring data and other information collected by state, local, and
tribal governments. An area may be designated attainment for some criteria pollutants and
nonattainment for others.
A state recommendation for designation of an area that surrounds Indian country does not
dictate the designation for Indian country. However, the conditions that support the state's
designation recommendation, such as air quality data and the location of sources, may suggest
that similar conditions exist in Indian country.
A. NONATTAINMENT	fATION
1, Definition
A nonattainment area is a geographic area in which the level of one of the
criteria air pollutants is higher than the level allowed by the federal standards, or
33 Historically, for initial designations after the EPA establishes a new or revised NAAQS, the EPA has used a designation
category of unclassifiable/attainment for areas that are monitoring attainment or that do not have monitors and that are
not contributing to a nearby violation. We expect to continue to use the unclassifiable/attainment category for future
designations.
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Developing Designation Recommendations for Areas of Indian Country
sources within the area are contributing to a nearby area with a violating
monitor.
An area is generally designated nonattainment when:
•	A regulatory monitor indicates the area is violating the NAAQS.
•	Existing sources of the pollutant or pollutant precursors contribute to
ambient air quality in a nearby area that does not meet the NAAQS for the
pollutant.
2, Requirements
In a nonattainment area, the goal is to implement a strategy that will bring the
area into attainment with the relevant NAAQS by reducing emissions of the
specific criteria pollutant or precursor emissions. A federal or tribal
implementation plan may include, as necessary or appropriate:34
¦	An emissions inventory to identify the sources of air pollution, their location,
and the types of pollutants emitted;
¦	Control measures, such as Reasonably Available Control Measures/
Reasonably Available Control Technology (RACM or RACT),35 which may
include the adoption of appropriate emission limits;
¦	Evidence that the emission limits will reduce emissions enough to prevent
NAAQS violations in Indian country and in other areas (i.e., an attainment
demonstration);
¦	A new source review preconstruction permit program to ensure that new
and modified sources of pollution do not impede progress toward cleaner air
or cause a deterioration of current air quality;
¦	Major sources locating in Indian country that is designated nonattainment
for any pollutant are subject to the Tribal New Source Review (NSR) Rule,36
and
34	Although we encourage tribes to develop plans to address NAAQS-related requirements, where tribes do not develop
TIPs, the EPA is authorized to promulgate federal implementation plan (FIP) provisions as are necessary or appropriate to
protect air quality. (See 49 CFR § 49.11(a)).
35	Reasonable Available Control Measures (RACM) including Reasonable Available Control Technology (RACT): Control
measures (measures that reduce pollution) that are technologically feasible and economically cost effective to implement
for sources in a nonattainment area to reduce air pollution.
36	https://www.gpo.gov/fdsys/pkg/FR-2011-07-01/pdf/2011-14981.pdf.
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Developing Designation Recommendations for Areas of Indian Country
¦	Contingency measures that can be implemented in the event that an area
does not attain the standard by the statutory attainment, or fails to meet
Reasonable Further Progress (RFP)37 requirements.
3, Redesignation
EPA can redesignate a nonattainment area to attainment if:
¦	The area has monitored attainment of the air quality standard,
¦	The area has a fully approved implementation plan,
¦	The EPA has determined that the improvement in air quality is due to
permanent and enforceable reductions in emissions,
¦	The EPA approves a maintenance plan for the area, and
¦	The area has met all other applicable CAA requirements.
The EPA may approve or deny the redesignation request based on air monitoring
information, the activities listed in the implementation plan, and the comments
submitted by the public. Nonattainment areas that later are designated to
attainment is considered maintenance areas. The steps to maintain air quality
are defined in a maintenance plan. Generally, the control measures used to
improve air quality to a level at or below the NAAQS will remain in place after
redesignation occurs.
The maintenance plan must demonstrate continued compliance, considering
projected growth, for a period of ten years. If outdoor air monitors record a
violation of the standard, the maintenance plan includes a commitment to
determine appropriate measures to address the cause of the violation. Pursuant
to section 107 of the CAA, the EPA can also redesignate an attainment or
unclassifiable area to nonattainment.
B. ATTAINMENT AREA DESIGNATION
1, Definition
An attainment area is a geographic area in which the ambient air level
(concentration) of the specific criteria air pollutant meets the NAAQS for that
37 Reasonable Further Progress (RFP): Annual incremental pollution reduction in a nonattainment area to help assure the
attainment of the NAAQS by its statutory attainment date.
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Developing Designation Recommendations for Areas of Indian Country
pollutant and the area does not contribute to ambient air quality in a nearby
area that does not meet the NAAQS for the pollutant.
2, Requirements
In an attainment area, the goal is to maintain air quality that meets or is cleaner
than the NAAQS. A tribal or federal program in an area of Indian country may
include, as necessary or appropriate:
¦	A program to limit the impacts of emissions from new and modified major
stationary sources, and
¦	Provisions to prevent significant contribution by sources located in Indian
country to NAAQS violations in other jurisdictions.
Major sources locating in Indian country that is designated attainment for any
pollutant are subject to the federal program for the Prevention of Significant
Deterioration (PSD).38 PSD requirements apply to all areas on the effective date
of the NAAQS.
C. UNCLASSI.fiABLE AREA DESIGNATION
1,	Definition
An unclassifiable area is a geographic area that cannot be classified, on the basis
of available information, as meeting or not meeting an air quality standard for a
particular criteria pollutant.
2,	Requirements
In an unclassifiable area, the goal is to collect sufficient air quality information to
determine whether the area is meeting or not meeting the NAAQS. A tribal or
federal program in an area of Indian country may include, as necessary or
appropriate:
¦	A program to limit the impacts of emissions from new and modified major
stationary sources, and
¦	Provisions to prevent significant contribution by sources located in Indian
country to NAAQS violations in other jurisdictions.
38 https://www.epa.gov/nsr/prevention-significant-deterioration-basic-information.
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Developing Designation Recommendations for Areas of Indian Country
Major sources locating in Indian country that is designated unclassifiable for any
pollutant would be subject to the federal PSD program. PSD requirements apply
to all areas on the date that the designation becomes effective.
KEY POINTS AND FURTHER INFORM 11»
•	Attainment means an area meets the national standard for a particular criteria
pollutant and the area is not contributing to ambient air quality in a nearby area that
does not meet the NAAQS for the pollutant.
•	The area must maintain good air quality.
•	Unclassifiable means there is not sufficient available information for an area to
determine whether the area is meeting or not meeting the standard.
•	Nonattainment means an area does not meet the national standard for a particular
criteria pollutant and includes areas that are contributing to ambient air quality in a
nearby area that does not meet the NAAQS for that pollutant. The area must
improve its air quality to meet the standard.
•	Nonattainment areas can be redesignated to attainment once they meet the NAAQS
and satisfy certain conditions spelled out in CAA section 107, including having an
approved maintenance plan.
For further information on designation topics see:
•	Ground-level ozone (O3) designations:
https://www.epa.gov/ozone-designations.
•	Fine particle (PM) designations:
https://www.epa.gov/particle-pollution-designations.
•	Nitrogen dioxide (NO2) designations:
https://www.epa.gov/nitrogen-dioxide-designations.
•	Lead (Pb) designations:
https://www.epa.gov/lead-designations.
•	Sulfur dioxide (SO2) designations:
https://www.epa.gov/sulfur-dioxide-designations.
•	Carbon Monoxide (CO) designations:
https://www.epa.gov/green-book/green-book-carbon-monoxide-1971-area-
information.
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Developing Designation Recommendations for Areas of Indian Country
•	Guidance to Regions for Working with Tribes during the National Ambient Air Quality
Standards (NAAQS) Designation Process, December 2011:
https://www.epa.gov/sites/production/files/2017-02/documents/12-20-
11 guidance to regions for working with tribes naaqs designations.pdf.
•	Policy for Establishing Separate Air Quality Designations for Areas of Indian Country,
December 2011: https://www.epa.gov/sites/production/files/2016-
02/documents/ind ian-country-separate-area.pdf.
IV. TRIBAL PARTICIPATION IN THE DESIGNATIONS PROCESS
A. HOW CAN I PARTICIPATE IN THE DESIGNATIONS PROCESS?
To inform your decisions regarding whether to participate in the designations process,
we intend to provide outreach and offer consultation to all federally recognized tribes
following the promulgation of a new or revised NAAQS. While not required, your
participation in the designations process is encouraged and supported by the EPA. As
noted above, you decide how involved you want to be in the designations process based
on your interest, priorities, and available resources. You may choose not to be involved,
you may choose to submit a designation recommendation and multi-factor analysis to
the EPA for review and consideration, or you may choose any level of participation in
between.
Regardless of your level of participation, the EPA will promulgate a designation for the
area. For reference, a list of tribal air program staff at EPA headquarters and regional
offices is provided in Appendix Cto this document.
Examples of past tribal participation:
•	Tribe does nothing.
•	Tribe only participates in the consultation process.
•	Tribe submits a recommendation letter to EPA without a multi-factor analysis.39
•	Tribe submits a designation recommendation with a detailed multi-factor analysis.
•	Tribe submits a designation recommendation for a separately designated area of
Indian country (separate from surrounding or adjacent areas) with the
accompanying documentation of the Indian country boundary and the multi-factor
analysis.
39 As discussed elsewhere in this document, tribes are not required to submit a multi-factor analysis; however, your
designation recommendation will be better supported if it is accompanied by a multi-factor analysis of the available data.
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Developing Designation Recommendations for Areas of Indian Country
e. WHAT IS THE PROCESS FOR ES '	as .IWhWl
DESIGNATION FOR INDIAN COUNTRY?
In the past, the EPA generally designated Indian country as part of the surrounding area,
usually based on county boundaries. Prior to 2011, the EPA did not have a policy in place
for considering a tribal request for designation separate from the larger area. Since
then, several tribes have established well-developed air programs and have engaged in
the designations process. Some of these tribes submitted designation recommendations
to the EPA and had their Indian country boundaries designated separately from the
surrounding or adjacent, non-Indian country area.
The EPA's Policy for Establishing Separate Air Quality Designations for Areas of
Indian Country, released in December 2011, now informs our decisions on these
recommendations or requests on a case-by-case basis, after consultation (if requested)
with the tribe and considering all other relevant information. This document provides
the EPA's policy regarding designating areas of Indian country separately from
surrounding or adjacent areas for the NAAQS. Consistent with this policy, if we receive
an initial designation recommendation or a boundary change request for a previously
designated multi-jurisdictional area from a tribe seeking to have its Indian country
designated as a separate area, we will make decisions regarding these
recommendations or requests on a case-by-case basis, after consultation (if requested)
with the tribe, and considering the weight of evidence from the multi-factor analyses
and other relevant information. Listed below are examples of scenarios covered by the
2011 policy:
•	The tribe recommends/requests a separate attainment area from an adjacent
attainment area;
•	The tribe recommends/requests a separate attainment area from the adjacent
nonattainment area;
•	The tribe recommends/requests a separate nonattainment area or different
nonattainment classification from the adjacent nonattainment area;40 or
•	The tribe recommends/requests a separate nonattainment area from the adjacent
attainment area.
It is important for you to make certain submittals associated with an initial designation
recommendation or boundary change request. These submittals include:
40 For certain NAAQS (e.g., ozone), the EPA "classifies" an area based on the severity of their air quality problem.
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Developing Designation Recommendations for Areas of Indian Country
•	A formal request/recommendation from an official authorized to make the request
on behalf of the tribe.
•	Documentation of the tribal boundary of the area of Indian country to which the
request for separate designation pertains, and concurrence with the EPA's intent to
include that area in the designation tables in 40 CFR Part 8141 should we separately
designate the area.
•	A multi-factor analysis (see Section VI for more information on the factors for
analysis) to support the recommendation/request.
C. WHAT ARE THE PROS AND CONS OF SUBMITTING A
DESIGNATION RECOMMENDATION?
Tribes are not required to submit designation recommendations; however, you may
have an interest in doing so. Participating in the designations process will give you an
opportunity to build your knowledge base of the EPA's NAAQS programs and the
designations process. You will also gain knowledge of what is expected should you
decide to submit a designation recommendation in the future. In addition, participation
in the designations process can help to build your air program's capacity to take on
more responsibility. It may also raise the EPA's awareness that your tribe is interested in
participating in air quality management; however, you are not required to participate in
any of these activities. Some tribes see participation in the designations process as an
assertion of tribal sovereignty.
In making a designation recommendation, you should consider the possible implications
which may be raised in establishing the boundary of your area of Indian country if you
are requesting a separate designation. This is particularly important if you have disputed
boundaries or other jurisdictional issues. If you are requesting a separate nonattainment
designation based on your boundaries, you should consider possible needs for an
implementation plan or other programmatic and workload issues in order to later
redesignate your area from nonattainment to attainment. Another area for
consideration is how general and transportation conformity would apply in a separately
designated tribal nonattainment area. Activities in areas that are designated
nonattainment that are conducted or supported by federal agencies must "conform" to
the purpose of an applicable implementation plan, as required by section 176(c) of the
CAA. The EPA's general conformity rules apply to federal activities within nonattainment
areas and areas that have moved from nonattainment to maintaining the standards (i.e.,
areas that are redesignated as attainment). If general conformity obligations are
determined to apply to emissions from a federal agency action, the general conformity
41 The table at 40 CFR Part 81 lists the designation of areas for air quality planning purposes, http://www.ecfr.gov/cgi-
bin/text-idx?SID=7c7922b602fdfca80alaa627ceb73cc2&mc=true&node=pt40.20.81&rgn=div5.
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Developing Designation Recommendations for Areas of Indian Country
rules provide federal agencies with the following options for demonstrating conformity
in nonattainment or maintenance areas: (1) obtaining emission offsets (generated in
the area or certain nearby areas) for the total emissions from the new project, (2)
showing that the project's emissions are already included in, or accommodated by, the
applicable SIP for the area (or in the absence of an applicable SIP, showing that the
project's emissions will not increase the baseline emissions used in the most current
emissions inventory), or (3) obtaining a written commitment from the Governor for the
area or the Governor's designee for SIP actions, to include the project's emissions in a
forthcoming revision of the applicable implementation plan. You should work closely
with your EPA regional office to anticipate possible implications associated with
designating your area separately.
When deciding whether or not to submit a designation recommendation, you should
also consider the resources and knowledge required to develop and submit to the EPA
the multi-factor analysis (see Section VI below). The attached, Appendix D - Decision
Matrix, may also help you to decide whether or not to submit a designation
recommendation.
You are not required to request a separate designation; but if you make a separate
designation recommendation, you should consider the possible legal implications which
may be raised in establishing the actual boundary of your area of Indian country if you
are requesting a separate boundary. This is particularly important if you have disputed
boundaries or other jurisdictional issues. If you are requesting a separate nonattainment
designation based on your boundaries, there may be workload issues for your tribe in
developing a TIP or other documents and requirements mandated under the CAA in
order to later redesignate your area from nonattainment to attainment. You should
work closely with your EPA regional office to anticipate possible implications associated
with designating your area separately.
HOW ARE DESIGNATION RECOMMENDATIONS RELATED TO
THE TRIBAL AUTHORITY RULE, TREATMENT IN A MANI
SIMILAR TO A STATE, AND TRIBAL IMPLEMENTATION
PLANS?
For the purposes of making a designation recommendation, you do not need to obtain
TAS status pursuant to the TAR. The EPA intends to solicit relevant air quality
information and designation recommendations from, and offer consultation to, all
federally recognized tribes irrespective of their TAS status for designation purposes.
However, tribes may apply to be treated in the same manner as a state for CAA section
107(d) if you choose.
KEY POINTS AND FURTHER INFORMATION
• Your participation in the designations process is encouraged, but not required.
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Developing Designation Recommendations for Areas of Indian Country
•	You may want to discuss the pros and cons of participating in the designation
recommendation process with your EPA regional office.
•	You may make designation recommendations that seek to have your area of Indian
country designated separately from the surrounding or adjacent multi-jurisdictional
area. You may want to discuss the pros and cons of a separate designation with your
EPA regional office.
For further information on designations process topics see:
•	Guidance to Regions for Working with Tribes during the National Ambient Air Quality
Standards (NAAQS) Designation Process, December 2011:
https://www.epa.gov/sites/production/files/2017-02/documents/12-20-
11 guidance to regions for working with tribes naaqs designations.pdf.
•	Policy for Establishing Separate Air Quality Designations for Areas of Indian Country,
December 2011: https://www.epa.gov/sites/production/files/2016-
02/documents/ind ian-country-separate-area.pdf.
DEVELOPING A DESIGNATION RECOMME. \T	aK ,
fXRY
A. Uw\
The following steps will help you develop a designation recommendation:
1.	Decide whether or not to submit a designation recommendation. You will receive a
letter from us offering the opportunity to submit a designation recommendation for
a particular NAAQS and offering consultation. Consider your priorities and resources
and talk with your EPA regional office. Participation with your EPA regional office
and consultation where appropriate will help inform your decision. If you choose not
to submit a designation recommendation, the EPA will promulgate a designation for
your area of Indian country after consultation, if requested, and consideration of all
relevant information. (Note, we intend to offer an opportunity for consultation to all
tribes.)
2.	Consult with your EPA regional office. If you decide to submit a designation
recommendation, consultation (if requested) with your EPA regional office will help
you understand the technical requirements for developing and submitting your
designation recommendation.
3.	Perform the multi-factor analysis. See Section VI below for the five factors to
consider when making a designation recommendation, if appropriate.
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Developing Designation Recommendations for Areas of Indian Country
4.	Make an informed decision. Based on the most current data, and where possible a
multi-factor analysis, and other relevant supporting information decide which
designation to recommend. Ensure that tribal leadership understands the process
and the potential implications of your recommendation, including the possible legal
implications which may be raised by establishing the actual boundary of your area of
Indian country (particularly, if you are requesting a separate designation of your
Indian country).
5.	Submit your formal designation recommendation and multi-factor analysis. This
information should be submitted to your EPA Regional Office Administrator from an
authorized tribal official. (See Appendix E for a list of EPA Regional Office
Administrators.)
6.	Follow-up with your EPA regional office. The opportunity to submit further
information happens after the EPA sends your tribe a notification letter with our
intended designation. The EPA will send the letter no later than 120-days before
making the final designation decision (commonly known as a 120-day letter). If more
data becomes available to support your designation recommendation, contact your
EPA regional office.
CAN I PARTICIPATE IN THE DESIGNATIONS PRO
so\n	v\ rs and not others?
Yes, each time the EPA promulgates a new or revised NAAQS for a specific criteria
pollutant, you can choose whether to participate in the designations process for that
NAAQS. Your decision about which criteria pollutants to submit a recommendation for
should be based on your air quality issues, priorities, and resources. For example, you
could opt to participate for one pollutant but not for others, depending on which
criteria pollutants are of concern to your tribe.
The designations process for a particular criteria pollutant will generally not occur more
than once every five years, in coordination with our CAA-required five-year review of
the NAAQS for each criteria pollutant. When a NAAQS is revised or a new NAAQS is
promulgated, the EPA will inform you and offer you an opportunity to participate in the
designations process. (Note that the NAAQS reviews for the different criteria pollutants
are on different five-year schedules.)
WHAT ARE THE FIVE FACTORS THAT I NEED TO ANALYZE?
There are five factors which typically need to be included as part of your multi-factor
analysis:
•	Air quality data,
•	Emissions-related data,
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Developing Designation Recommendations for Areas of Indian Country
•	Meteorology,
•	Geography/topography, and
•	Jurisdictional boundaries.
See Section VI below for detailed information on each of the five factors.
WHAT IF I DO NOT SUBMIT AMU! V\ FAt x. x W V M\^
As discussed elsewhere in this document, tribes are not required to submit a
designation recommendation or multi-factor analysis. We understand that you may not
have the resources to conduct the level of investigation generally required in a multi-
factor analysis; however, your recommendation will be better supported if it is
accompanied by a multi-factor analysis of the available data. In addition, if you submit a
multi-factor analysis, your EPA regional office will review it and, if we plan to make any
modification to the recommendation, we will provide you with an opportunity for
technical dialogue and further consultation (if requested).
When submitting a request/recommendation for a separately designated area of Indian
country, consistent with EPA's 2011 policy for separately designated areas of Indian
country, a multi-factor analysis should be submitted as part of your request/
recommendation. The multi-factor analysis supports determining whether an area of
Indian country located within or next to a larger multi-jurisdictional area should be
excluded from that area and potentially designated separately, or whether it should be
designated consistent with the rest of the area.
DO I NEED TO ANALYZE ALL FIVE FACTORS?
There may be instances when not all of the above listed five factors are relevant to a
specific designation request and therefore would not need to be included in your multi-
factor analysis. For example, if a tribe were to request the designation of a separate
attainment area from an adjacent attainment area, it is possible that only the air quality
data factor and/or jurisdictional boundaries factor would be applicable to the given
situation. The EPA regional offices are available to assist you with developing your multi-
factor analyses and determining which factors are most relevant to your specific
situation.
WHAT EVALUATION TOOLS AND DATA ARE AVAILABLE FOR
MY USE?
The EPA has many useful websites and tools available to help you prepare a designation
recommendation. In addition, other agencies have information and resources available.
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Developing Designation Recommendations for Areas of Indian Country
See Section VI and the Appendices below for links to many resources.42'43'44
G.	WHAT OTHER INFORMATION SHOULD I INCLUDE IN THE
DESIGNATION RECOMMENDATION?
In addition to an analysis of the five factors, you can submit to the EPA any other
information you believe is relevant to your designation recommendation. For example,
you may have information and data related to air pollution transported from sources
upwind of your area. See Section VI below for more information on this topic.
H.	KEY POINTS AND FURTHER INFORMATION
•	You can decide whether or not to develop a designation recommendation for your
area of Indian country.
•	If you decide not to develop a designation recommendation, the EPA will
promulgate an appropriate designation for your Indian country after consultation
with you (if requested).
•	Designation recommendations are developed for each individual NAAQS set for a
specific criteria air pollutant.
•	There are five factors you typically need to consider when developing the multi-
factor analysis that accompanies your recommendation.
For further information on developing a designation recommendation see:
•	Guidance to Regions for Working with Tribes during the National Ambient Air Quality
Standards (NAAQS) Designation Process, December 2011:
https://www.epa.gov/sites/production/files/2017-02/documents/12-20-
11 guidance to regions for working with tribes naaqs designations.pdf.
•	Policy for Establishing Separate Air Quality Designations for Areas of Indian Country,
December 2011: https://www.epa.gov/sites/production/files/2016-
02/documents/ind ian-country-separate-area.pdf.
•	Ground-level Ozone Designations Guidance and Data:
https://www.epa.gov/ozone-designations/ozone-designations-guidance-and-data.
42	See Appendix F of this document for Air Quality Education and Training Resources.
43	See Appendix G of this document for Air Quality Monitoring Information and Data Sources.
44	See Appendix H of this document for Air Pollution Emissions Information and Data Sources.
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Developing Designation Recommendations for Areas of Indian Country
•	Particle Pollution Designations Guidance and Data:
https://www.epa.gov/particle-pollution-designations/particle-pollution-
designations-guidance-and-data.
•	Lead Designations Guidance:
https://www.epa.gov/lead-designations/lead-designations-guidance.
•	Sulfur Dioxide Designations - Guidance and Technical Information:
https://www.epa.gov/sulfur-dioxide-designations/sulfur-dioxide-designations-
guidance-and-technical-information.
THE FACTORS TO CONSIDER WHEN DEVELOPING A
DESIGNATION RECOMMENDATION
When a new or revised national ambient air quality standard (NAAQS) is promulgated, the EPA
issues designations guidance that provides specific information about the NAAQS as well as
information to assist states and tribes with submitting area designations recommendations for
that NAAQS. The EPA will also send you a letter offering the opportunity for government-to-
government consultation (commonly referred to as a "consultation letter") notifying you of the
designations process and conveying detailed designation information. This information will be
specific to the particular pollutant and NAAQS that was promulgated and provide
comprehensive information to help you develop your multi-factor analysis using the five
factors. We may also have timely links to web-based information on air quality and emissions
for the pollutant of interest.
The submission of your designation recommendation of nonattainment, attainment, or
unclassifiable-may include your multi-factor analysis of one or more of the five factors listed
below, as well as any other supporting information. An analysis of the factors also supports
determining whether an area of Indian country located within or next to a larger area should be
excluded from that area and potentially designated separately, or whether it should be
designated consistent with the rest of the area. Although you may submit a recommendation
letter only, your recommendation will be better supported if it is accompanied by a multi-factor
analysis of the available data.
In instances where not all of the factors listed below are applicable to your area of Indian
country, it would be helpful if your recommendation addresses why they are not relevant. For
example, if a tribe were to request the designation of a separate attainment area from an
adjacent attainment area, it is possible that only the air quality data factor and/or jurisdiction
boundaries factor would be relevant to that given situation. We intend to work with tribes with
developing their multi-factor analyses to determine which factors are most relevant to the
specific request for a separate area. Note that your tribe may submit a recommendation that
does not request a separate designation. You should carefully weigh the statutory, regulatory,
political, workload, and sovereignty concerns in making a decision on your recommendation.
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Developing Designation Recommendations for Areas of Indian Country
AIR QUALITY DATA
1,	Definition
The air quality data factor involves consideration of data from the national
network of monitors operated to measure air quality. After promulgation of a
new or revised NAAQS, the CAA requires the EPA to designate as nonattainment
any area that does not meet the NAAQS or that is contributing to a nearby area
that does not meet the NAAQS. A monitor on your area of Indian country or a
nearby state run monitor may be representative of the air quality in your area.
The monitored data should also be of sufficient quality to be used for
designation purposes.
Monitoring data are collected to measure how much pollution is in the air. These
data are used to calculate a "design value." The design value describes the air
quality status of a given monitor or area relative to the level of a NAAQS. Design
values are often based on multiple years of data, ensuring a stable indicator.
Design values are typically used to designate areas as to whether they are
meeting or not meeting the NAAQS, assess progress towards meeting the
NAAQS, and develop control strategies to attain and maintain the NAAQS. Design
values are computed and published annually by the EPA's Office of Air Quality
Planning and Standards (OAQPS) and reviewed in conjunction with the EPA
regional offices.
2,	Information to include in the analysis of air quality data
Data from both regulatory monitors and non-regulatory monitors can be
included as part of the air quality data factor analysis. While only qualified data
from regulatory monitors can be used to determine the designation status
(nonattainment, attainment, or unclassifiable) for an area of Indian country, data
from non-regulatory monitors can be used to support a geographic boundary
determination for that designation category. By monitoring the level of pollution
at the up-wind boundary compared to the boundary further down-wind, a tribe
may be able to show whether air pollution is generally coming from sources up-
wind of your areas of Indian country or is locally-generated pollution.
Regulatory monitors are those that:
¦	Have a monitoring objective that is intended for comparing design values
against the level of the NAAQS (NAAQS comparison), and
¦	Have adequately achieved the quality assurance and data requirements for
regulatory decision making.
Non-regulatory monitors are those that:
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Developing Designation Recommendations for Areas of Indian Country
¦	Have been designated as a non-regulatory monitor type in the EPA's Air
Quality System (AQS),45 meaning that they have monitoring objectives other
than NAAQS comparison, and therefore are not required to meet all of the
quality assurance and data requirements necessary for regulatory decision
making, or
¦	May have the objective of NAAQS comparison and have not adequately
achieved the quality assurance and data requirements necessary for
regulatory decision making.
We recognize that appropriate air quality data may not be available for your area
of Indian country. It is also possible that despite the absence of air quality data
for a particular area of Indian country, other technical information is available
that characterizes air quality. For example, a nearby state regulatory monitor
could be determined to be representative of air quality in your area. In these
circumstances, it may be appropriate for other technical information to be used
in the air quality data factor analysis.
In cases where a tribe submits a recommendation for a attainment area separate
from an adjacent nonattainment area, or a nonattainment area separate from an
adjacent attainment area, such recommendations are best supported by air
quality data from a regulatory monitor located in the relevant area of Indian
country. However, we can consider non-regulatory monitoring data and other
data as supporting information. For example, if the tribe is monitoring but does
not yet have a complete set of data, we can consider your information in the
designations process.
3, Example: air quality factor
This example comes from the Forest County Potawatomi Community's (FCPC)
March 2009 O3 designation recommendation.
FCPC R/T/F/A Lands within Forest County
Ozone is monitored at the FCPC's single air monitoring site located in its
Reservation on Sugarbush Hill in the Lincoln Township within Forest
County, 4.5 miles east of the City of Crandon. The data used in this
recommended designation letter was collected in accordance with the
requirements of 40 CFR part 58, Appendix A.
The fourth-highest daily maximum 8-hour average ozone concentrations
in 2006 through 2008 ranged from 0.066 to .073 ppm, resulting in a
design value of 0.068 ppm (see attached USEPA AQS AMP450 Quick Look
Report). Hence, because these values are below the 2008 0.075 ppm
45 https://www.epa.gov/aqs.
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Developing Designation Recommendations for Areas of Indian Country
standard, the FCPC recommends that EPA designate the FCPC R/T/F/A
lands located within Forest County as "in attainment
4, Sources of air quality data
•	The Air Quality System (AQS)46 is the EPA's repository of ambient air quality
data. AQS stores data from over 10,000 monitors, 5,000 of which are
currently active. State, local, and tribal agencies collect the data and submit it
to AQS on a periodic basis: https://www.epa.gov/aqs.
•	EPA's AirData website gives you access to air quality data collected at
outdoor monitors across the United States:
https://www.epa.gov/outdoor-air-quality-data.
•	For the current criteria pollutant design values see:
https://www.epa.gov/air-trends/air-quality-design-values.
•	General information on the EPA's ambient air monitoring programs:
https://www.epa.gov/amtic.
•	The Tribal Air Monitoring Support Center (TAMS) training and support is
available without charge to all federally recognized tribes. See the TAMS
website for more information: http://www7.nau.edu/itep/main/tams/.
B. EMISSION-RELATED DATA
1,	Definition
Emission-related data includes information on the location of important nearby
emission sources and the actual and/or estimated emissions from those sources
that contribute to the air pollution in your area. Emissions data indicates the
potential for an area to contribute to violations of the NAAQS, making it useful in
assessing boundaries of nonattainment areas.
Emission-related data includes source emission data and activities related to
traffic and commuting patterns, and population density, and degree of
urbanization as potential sources of pollution. Data for these sources will identify
the location and magnitude of emissions.
2,	Information to include in the analysis of emission-related data
46 https://www.epa.gov/aqs.
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Developing Designation Recommendations for Areas of Indian Country
Include a list of the important facilities in and around your area of Indian
country. Are there certain sources that are key contributors during specific
seasons? If applicable, include information on traffic and commuting patterns
such as location of major transportation arteries, traffic volume, and commuting
patterns in and nearby your areas of Indian country. For example, you can
include an examination of the number of commuters in your area who drive to
an urban area, the percent of total commuters who commute to another area,
the percent of total commuters in the surrounding area who drive into the area
of Indian country, as well as the total vehicle miles traveled (VMT) for your area.
VMT is a measure of the extent of motor vehicle operation-the total number of
vehicle miles traveled within a specific geographic area.
Also identify population characteristics, such as density and population growth
of the area, and indicate the level of commercial development. Analyze growth
rates and patterns. Is the area affected by urban sprawl? The growth analysis is
an evaluation of actual and/or projected percent population growth for an area
over a period of time (e.g., ten years). Population data can indicate the likelihood
of population-based emissions that might contribute to violations.
3, Example: emission-related data factor
This example, which focuses on mobile vehicle emissions, demographics and
commuting patterns, comes from the Catawba Indian Nation's February 2012
designation recommendation for the 2008 O3 NAAQS. As part of their emission-
related data analysis, the Tribe included tables and maps showing NOx and VOC
emissions, population and growth statistics, and Bureau of Indian Affairs (BIA)
traffic and road data.
Emissions and Emission-Related Data
There are no point sources of air quality emissions within or directly adjacent to
the boundaries of the Catawba Indian Nation. Several permitted facilities with
significant NOx (7,031 tons/year) and VOC (11,840 tons/year) emissions are
located within York County; however, these sources are at least two miles away
and it is unclear whether or not they are impacting tribal lands or tribal
member's health. It is clear that these facilities do contribute to local air pollution
and the formation of ozone within non-attainment areas downwind.
EPA and South Carolina Department of Environmental Health and Control (DHEC)
have determined that a significant portion of NOx and VOC emissions come from
area and mobile sources in the Charlotte-Gastonia-Salisbury,
NC-SC area. Areas of rapidly increasing urbanization and population density
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Developing Designation Recommendations for Areas of Indian Country
and associated increased motor vehicle emissions may contribute to ozone
formation and ozone standard violations in nearby areas. US Census Bureau
data shows that during the period of 2000-2010, the population of York County
increased 36% from 165,705 to 226,073.
Data provided by DHEC in the March 12, 2009 South Carolina Ozone
Nonattainment Boundary Recommendations report states that the eastern Non-
Attainment Area of York County contains approximately 90% of the county
population and 94% of the vehicle miles traveled. The DHEC report also mentions
that 60% of workers who live in York County work within the county, however,
neglects to mention that 36% of workers that live in York County travel north and
work in North Carolina. Although data suggests that eastern York County is
experiencing rapid population growth and significantly contributes to mobile
source emissions problems in the regions, this information does not accurately
reflect the conditions of the Catawba Indian Nation.
Catawba Indian Nation Demographics and Statistics
The Catawba Indian Nation along the eastern border of York County, outside the
urban cluster of Rock Hill, remains less densely populated and is considerably
more rural in character. The Catawba Indian Nation consists of two tracks of land
along the Catawba River with a total land base of approximately 1,000 acres,
which comprises only 0.002% of the land area of York County and 0.004% of the
York Non-Attainment Area. The Catawba Indian Nation members living on the
Reservation comprise only about 0.003% of the population of York County with
close to zero population growth. The most recent and accurate demographic
data for the Catawba Indian Nation indicates the population consists of 586
tribal members living in 312 homes on the reservation, many of which (42%) are
children and elderly, who do not work or regularly commute off the reservation.
There are 340 adult tribal members who are of working age living on the
reservation, however, the reservation has a high unemployment rate and many
adults do not have transportation. It is important to mention that in 2011, the
Catawba Indian Nation initiated a public transit program to do their part in
helping to reduce vehicle emission in the area as well as provide assistance to
many tribal members who have limited or no transportation. This information
further supports the conclusion that the Catawba Indian Nation does not
significantly contribute to the high vehicle miles traveled (VMT) and mobile
emissions source calculations that are more relevant along the 1-77 commuter
corridor within York County. Furthermore, the Catawba Indian Nation lands are
located at the end of the roadways serving them so there is no thru-traffic or
additional mobile emission from vehicles traveling or commuting through the
reservation to other areas.
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Developing Designation Recommendations for Areas of Indian Country
4, Sources of emission-related data
•	Two brief EPA documents that will help introduce you to emission
inventories:
¦	Introduction to Emission Inventories for Tribes, October 2008,47
and
¦	Emission Inventory Basics for Tribal Air Coordinators, October
2008.48
•	The EPA keeps track of the amount of pollution that comes from a variety of
sources such as vehicles, power plants, and industries. The emissions data
reported to the EPA by state and tribal environmental agencies can be an
actual reading taken at a source or an estimate made using a mathematical
calculation. Emissions data can be obtained from:
¦	Air Emissions Sources website49 (for general summaries), and
¦	National Emissions Inventory (NEI)50 (for detailed reports).
•	EPA's draft 2008 National Emissions Inventory, Version 3 Technical Support
Document, September 2013, explains the sources of information included in
the emission inventory. This document can be found at:
https://www.epa.gov/sites/production/files/2015-
07/documents/2008 neiv3 tsd draft.pdf.
2008 NEI Appendices: https://www.epa.gov/sites/production/files/2015-
07/documents/2008 neiv3 appendices draft O.pdf.
•	You can find emission inventory data in the NEI at:
https://www.epa.gov/air-emissions-inventories.
•	EPA's Air Emissions website is designed to make emissions data for six
common pollutants easy to find and understand:
https://www.epa.gov/air-emissions-inventories/air-emissions-sources.
•	Based on the latest National Emissions Inventory, this site uses charts and
Google Earth files to answer the user's questions. Users can look at overall
47	https://www.epa.gov/sites/production/files/2016-09/documents/introtoemissioninventoriestribes2008.pdf.
48	https://www.epa.gov/sites/production/files/2016-09/documents/emisioninventorybasics2008.pdf
49	https://www.epa.gov/air-emissions-inventories/air-emissions-sources.
50	https://www.epa.gov/air-emissions-inventories/national-emissions-inventory-nei.
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Developing Designation Recommendations for Areas of Indian Country
emissions, emissions by type of industry, or emissions by largest polluter.
Learn more about this tool to view the geographical distribution of emission
sources: https://www3.epa.gov/air/emissions/where.htm.
•	County to county worker flow files (for the 2000 census) for commuting data:
http://www.icpsr.umich.edu/icpsrweb/ICPSR/themes/census2000/workerflo
w.jsp.
•	Information from the U.S. Census on commuting patterns at the county level:
http://www.census.gov/population/www/cen2000/commuting/index.html.
•	County VMT data (for 2006):
https://www3.epa.gov/pmdesignations/2006standards/final/TSD/tsd J cou
nty vmt data.pdf.
•	To prepare VMT estimates for your area see:
https://www3.epa.gov/pmdesignations/2006standards/final/TSD/tsd 1.0 to
c intro.pdf.
•	Census information for population data:
http://www.census.gov/. and
https://www.census.gov/quickfacts/fact/table/US/PST045217.
•	Census data on urban and rural classification and data on metropolitan and
micropolitan statistical areas:
http://www.census.gov/geo/www/ua/urbanruralclass.html. and
https://www.census.gov/programs-surveys/metro-micro.html
•	Population estimates and growth data can be found at:
http://www.census.gov/popest/. and
https://www.census.gov/data.html.
METEOROLOGY
1, Definition
The evaluation of meteorological data helps to determine the effect of
meteorological conditions on the fate and transport of emissions contributing to
the pollutant concentrations and to identify areas potentially contributing to the
monitored violations. This section provides recommendations for summarizing
meteorological data and results in support of appropriate nonattainment area
boundaries. One basic meteorological analysis involves assessing potential
source-receptor relationships in the area using summaries of emission, wind
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Developing Designation Recommendations for Areas of Indian Country
speed, and wind direction data. A more sophisticated assessment involves
modeling air parcel trajectories.
A simplified meteorological assessment may include identifying the frequency of
surface level wind speed and direction on days with high observed pollutant
concentrations and comparing this frequency to the frequency of wind speed
and direction for other meteorological periods, years or seasons, for example.
A more sophisticated meteorological assessment would employ trajectory
models to help understand complex transport situations by illustrating the three-
dimensional paths traveled by air parcels to violating monitors. The HYSPLIT
(HYbrid Single-Particle Lagrangian Integrated Trajectory) modeling system may
be useful for some areas to produce air parcel trajectories.
2, Information to include in the analysis of meteorology
The evaluation of meteorological data helps to determine the effect on the fate and
transport of emissions contributing to ozone concentrations and to identify areas
potentially contributing to the monitored violations. One basic meteorological analysis
involves assessing potential source-receptor relationships in the area using summaries
of emissions, wind speed, and wind direction data. A more sophisticated assessment
involves modeling air parcel trajectories to help understand complex transport
situations. The HYSPLIT (HYbrid Single-Particle Lagrangian Integrated Trajectory)
modeling system may be useful for some areas to produce trajectories that illustrate the
3-dimensional paths traveled by air parcels to a violating monitor. The EPA is providing
back trajectories in the Ozone Mapping Tool for violating monitors, for each day of high
ozone concentration (i.e., daily maximum 8 hour values that exceed the NAAQS) at
those monitors. States or tribes can choose to do additional HYSPLIT modeling and
guidance is provided in the ozone designations guidance document.
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Developing Designation Recommendations for Areas of Indian Country
3,	Example: meteorology factor (weat ransport patterns)
This example comes from the Catawba Indian Nation's February 2012
designation recommendation for the 2008 O3 NAAQS.51 As part of their
meteorology analysis, the Tribe provided a wind rose showing the wind direction
for high O3 days:
Meteorology (Weather/Transport Patterns)
EPA's analysis of National Weather Service data indicates that during the ozone
season, the predominant wind direction is from the south/southwest. Therefore,
precursor emission from NOx and VOC point sources and mobile vehicle sources
that contribute to ozone formation will move primarily from south to north. For
this reason, EPA has determined that the eastern urbanized area of York County
does contribute to air guglity problems gnd ozone stgndgrd violgtions in the
Chgrlotte non-gttginment greg. Using this gnglysis gnd logicgl regsoning, the
York County ozone monitor locgted in thefgr southwest rurgl greg of the York
non-gttginment greg more gccurgtely represents upwind, bgckground levels of
ozone. The Arrowood ozone monitor (design vglue 0.076ppm) locgted
immedigtely gdjgcent gnd downwind from Rock Hill urbgn greg is likely to more
gccurgtely reflect ozone concentrgtion from the egstern York County non-
gttginment greg, gt legst during times of prevgiling southwesterly winds.
4,	Sources of meteorology information
Information sources related to meteorological data and air quality models can be
found at:
¦	Meteorological Data and Processors:
https://www3.epa.gov/ttn/scram/metdataindex.htm.
¦	National Oceanic and Atmospheric Administration's (NOAA)
HYSPLIT - Hybrid Single Particle Lagrangian Integrated Trajectory Model:
http://readv.arl.noaa.gov/HYSPLIT.php.
¦	NOAA's National Climate Data Center:
https://www.ncdc.noaa.gov/.
51 http://www.epa.gov/glo/designations/2008standards/rec/staterem/R4_Catawba_120Resp.pdf
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Developing Designation Recommendations for Areas of Indian Country
GEOGRAPHY/TOPOGRAPHY
1,	Definition
Geography and topography includes the physical features of the land that might
define the airshed and thus affect the formation and distribution of pollution.
Mountains, narrow valleys, or other physical features may affect the location of
emissions sources and the distribution of emissions in the airshed and may help
define the boundaries of violating areas and areas contributing to violating
areas. Areas with flat topography may experience a more even distribution of air
quality.
2,	Information to include in the analysis of geography/topography
The geography/topography analysis involves an examination of the physical
features of the land that might affect the airshed and, therefore, the potential
distribution of air pollutants over the area. In your analysis of this factor, include
a description of any significant physical features of the land. For example, an
area located in a valley bordered by mountains could experience very different
effects to the airshed than an area with generally uninterrupted flat terrain.
Tribes that seek a designation separate from the surrounding area may be able
to support their recommendation using this factor, if they can show that their
Indian country is physically separated from the adjacent area by topography or
other geographic feature such as a mountain range or other barriers that
significantly limit air pollution transport from or onto their lands. You may
include topographical maps of your specific areas in the technical analyses.
3,	Example of geography/topography factor
The following example comes from the Pechanga Band of Luiseno Indians'
December 17, 2007 designation recommendation for the PM2.5 NAAQS:
Geography
The Pechanga Reservation is located on a total land base of
approximately 5,600 acres. The Reservation is in Southern Riverside
County with its southern border at the San Diego County line. The City of
Temecula is located to the northwest, the town of Rainbow to the
southwest, and the Cleveland National Forest to the southeast. The
Reservation is comprised of mountains and plateaus, with elevations
ranging from 1,100 feet to 2,600feet in the southeastern portion. Agua
Tibia Mountain and Wild Horse Peak are located to the southeast and
east, and Mount Olympus and Gavilan Mountain are located to the
southwest and west.
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Developing Designation Recommendations for Areas of Indian Country
4, Sources of geography/topography information
¦	U.S. Geological Survey topographic information:
https://www.usgs.gov/products/maps/topo-maps.
¦	Google Earth is also a tool that can be used for a three dimension look at
geography/topography analysis:
https://www.google.com/earth/.
¦	Microsoft Bing Maps is another tool that can be used to develop maps:
http://www.microsoft.com/maps/.
JURISDICTIONAL BOUNDARIES
1, Definition
The jurisdictional boundaries factor considers the defined legal boundaries of the
area that pertains to the designation recommendation. Examples of
jurisdictional boundaries include tribal reservations and other Indian country,
counties, and metropolitan planning organizations. An analysis of the planning
and organizational structure of an area should also be considered to provide
insights into how air quality planning and enforcement would be carried out in a
potential nonattainment area.
The jurisdictional boundaries factor is one of the five factors that the EPA
considers in the designations decision making process. It is important to note
that while we intend to recognize tribal sovereignty and the jurisdictional status
of Indian country in the decision making process and understand that tribal
status is different than county or state status; decisions will be made after a
consideration of all factors. We also know tribes retain important sovereign
authorities over their territories and that jurisdiction in Indian country generally
rests with the relevant tribe and the federal government.
In general, when we are deciding whether to grant a tribal request for
designation of a separate area, the jurisdictional boundaries factor analysis may
be the most relevant.
Several example decision making scenarios for considering tribal
recommendations/requests are included below. These scenarios are meant to
provide general examples, and do not suggest a definitive decision. Ultimately,
the EPA's decision regarding whether to designate an area of Indian country
separately will depend upon a consideration of all factors and other relevant
data/information submitted by a tribe with their recommendation/request.
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¦ Tribe submits a recommendation/request for a separate nonattainment area
with the same or a different area classification (e.g., Moderate, Serious, etc.)
than an adjacent nonattainment area.
-	Tribe either has its own regulatory monitor demonstrating violation
of the NAAQS or has shown that a proximate regulatory monitor
violating the NAAQS outside of Indian country is sufficiently
representative of air quality in the Indian country area.
-	There are no significant emissions sources in Indian country that are
contributing to nonattainment in the adjacent area.
-	Indian country area is impacted only by sources within the Indian
country.
-~ Indian country area could be designated as a separate nonattainment
area or with a different area classification.
¦	Tribe submits a recommendation/request for a separate nonattainment area
from an adjacent nonattainment area.
-	Tribe either has its own regulatory monitor demonstrating violation
of the NAAQS or has shown that a proximate regulatory monitor
outside of Indian country violating the NAAQS is sufficiently
representative of air quality in the Indian country area.
-	Indian country area has emissions sources that are contributing to
nonattainment in the adjacent state area.
-	Indian country area is impacted by sources outside of Indian country.
-	Indian country area is meteorologically and topographically
integrated with the surrounding area.
-> Indian country area could be designated as part of a multi-
jurisdictional nonattainment area, such that the tribe is one of the
governing bodies within the area.
¦	Tribe submits a recommendation/request for a separate attainment area
adjacent to a nonattainment area.
-	Tribe has its own regulatory monitor demonstrating the NAAQS is
being met.
-	There are no significant emissions sources in the Indian country area
that are contributing to nonattainment in the adjacent area.
-	Indian country area is separated from adjacent nonattainment area
by topography or other geographic features.
-> Indian country area could be designated as a separate attainment
area.
¦ Tribe submits a recommendation/request for a separate nonattainment area
adjacent to or within a surrounding attainment area.
- Tribe has its own regulatory monitor demonstrating the NAAQS is
being violated.
45

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Developing Designation Recommendations for Areas of Indian Country
-~ Indian country area could be designated as a separate nonattainment
area.
¦ Tribe submits a recommendation/request for a separate attainment area
adjacent to or within a surrounding attainment area.
- Tribe either has its own regulatory monitor demonstrating attainment
of the NAAQS or has shown that a proximate regulatory monitor
outside of Indian country that is attaining the NAAQS is sufficiently
representative of air quality in the Indian country area.
-> Indian country area could be designated as a separate attainment
area.
2,	Information to include in the analysis of jurisdictional boundaries
If you are seeking to have your lands designated separately from the surrounding
or adjacent areas include a map and documentation of the boundary of the area
of Indian country to which the request for a separate designation pertains.
Consultation with us (if requested) will help ensure that those tribes who are
interested in submitting a recommendation for their area of Indian country, to
be designated separately from the adjacent area, are aware of the implications
for their tribe (e.g., air quality planning and permitting) if their recommendation
is granted.
If you do not seek to have your areas of Indian country designated separately
from the surrounding or adjacent areas, you do not need to provide a
description of the exterior boundaries of your lands. The EPA examines
jurisdictional boundaries for the purposes of providing a clearly defined legal
boundary for carrying out the air quality planning and enforcement functions for
the area.
3,	Example: jurisdictional boundaries factor
This example comes from the Catawba Indian Nation's February 2012
designation recommendation for the 2008 O3 NAAQS. As part of their
jurisdictional boundary analysis, the Tribe included maps and aerial photos of the
Catawba Indian Nation lands. Note that the Tribe was seeking to have their
reservation designated as unclassifiable, when the surrounding area was
classified as nonattainment:
Jurisdictional Boundaries
The "Indian Country" of the Catawba Indian Nation is located entirely within York
County and the Rock Hill-Fort Mill Area Transportation Study (RFATS)
Metropolitan Planning Organization (MPO) area. The Tribe recognizes that the
South Carolina Air Quality State Implementation Plan (SIP) and other regulatory
policies and procedures do currently apply to the Catawba Indian Nation and
46

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Developing Designation Recommendations for Areas of Indian Country
Reservation lands. The proposed separate ozone designation of "attainment" for
the Catawba Indian Nation is not expected to have any adverse effects on local
air quality planning, permitting, or enforcement functions for the surrounding
non-attainment areas. The Catawba Indian Nation will continue to serve as an
active member of RFATS working on transportation conformity planning while
also working toward increasing our participation and involvement in local and
regional air quality monitoring, planning, and pollution control programs and
strategies. We intend to fully protect and exercise the sovereign status and
federal trust relationship we have with the United States Government and U.S.
Environmental Protection Agency to insure that human health and the
environment are adequately protected and the Clean Air Act is properly
implemented on our tribal lands and in our region.
OTHER RELEVANT INFORMATION
We plan to consider the above five factors, along with any other relevant information
you submit, in determining the appropriate designation for your lands. The factors listed
above, while generally comprehensive, are not intended to be exhaustive. You may
submit additional information you believe is relevant for the EPA to consider.
For examples of designation recommendations and associated technical analyses
submitted to the EPA by tribes and the EPA's responses to the submitted documents,
see the following websites:
•	Area designations for the 2015 ground-level ozone (O3) standards:
https://www.epa.gov/ozone-designations/2015-ozone-standards-tribal-
recommendations.
•	Area designations for the 2012 24-hour fine particle (PM2.5) standards:
https://www3.epa.gov/airquality/particlepollution/designations/2012standards/trib
alrec.htm.
•	Area designations for the 2010 nitrogen dioxide (NO2) standards:
https://www.epa.gov/nitrogen-dioxide-designations/2010-nitrogen-dioxide-
standards-tribal-recommendations-and-epa.
•	Area designations for the 2008 lead (Pb) standards:
https://www.epa.gov/lead-designations/2008-lead-standards-tribal-
recommendations-and-epa-responses.
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Developing Designation Recommendations for Areas of Indian Country
¥0. SUBMITTING THE DESIGNATION RECOMMENDATION
A.	WHERE AND WHEN DO I SE1
EMENDATION LETTER AND Ml- / I ! ACTOR ANALYSIS?
Shortly after promulgation of a new or revised final NAAQS, your EPA regional office will
send a letter that will request your designation recommendation by a date specified in
the letter and offer consultation. This letter will also provide the mailing address for
your designation recommendation.
Given the CAA requirement to designate all areas in a timely manner, we intend to
designate all areas of the country on the same schedule. It is therefore, important, that
you submit your designation recommendation no later than the deadline provided in
the EPA regional office letter. This will ensure that we have adequate time to conduct
appropriate consultation (if requested), and will allow us to make informed, timely
decisions on any requests for separately designated areas of Indian country.
Your designation recommendation and accompanying multi-factor analysis should
be submitted to your EPA Regional Office Administrator for consideration.52 Your
submittal should be accompanied by a formal letter from an authorized tribal official to
your EPA Regional Administrator. We recommend that you review the checklist found in
Appendix I to ensure completeness of your designation recommendation prior to
submission.
B.	WHEN IS THE DESIGNATION RECOMMENDATION DUE?
The designation time frame is controlled by CAA section 107(d) which establishes the
requirement for the EPA to finalize the area designations no later than two years from
the date a new or revised NAAQS is promulgated. However, the EPA may extend the
deadline by up to one year if the EPA has insufficient information to complete the
designations in two years. Recommendations are typically due one year from
promulgation of the NAAQS, although the EPA has the authority to set an earlier
deadline. The request letter that the EPA sends to you will provide the due date for your
designation recommendation.
C.	WHAT IS THE PROCESS FOR REVIEWING MY DESIGNATION
4ENDATI0N?
Your EPA regional office, along with the EPA headquarters offices, will review your
designation recommendation and multi-factor analysis. We will consider, as
appropriate, available air quality monitoring or, for SO2, modeling or emissions data that
52 See Appendix E of this document for a list of the EPA Regional Administrators.
48

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Developing Designation Recommendations for Areas of Indian Country
you submit in support of your recommendation and all other relevant information/data.
We will ensure that the data you submit with your designation recommendation are
accurate and represent your current air quality status.
If the EPA intends to make any modifications to your recommendation, we intend to
offer an opportunity for you to participate in technical dialogue regarding the
recommendation. This will help ensure that tribal staff members have time to engage
with their tribal leaders before they receive written notification from the EPA.
Following our review, we will send you a letter indicating our intended designation of
your area (as nonattainment, attainment, or unclassifiable). Our intended designations
are based on your initial recommendation and multi-factor analysis, as well as
consideration of all other relevant information. (See Appendix J for an example of an
EPA review of the multi-factor analysis that accompanied a designation
recommendation.)
D. WHAT HAPPENS IF THE EPA AGREES WITH MY DESIGNATION
IENDATION?
If we agree with your designation recommendation, we will send a letter informing you
that we accept your designation recommendation. The EPA will then officially
promulgate (via publication in the FR) a final designation decision that reflects your
recommendation.
E. WHAT HAPPENS IF THE EPA DOES NOT AGREE WITH MY
DESIGNATION RECOMMENDATION?
If, after careful consideration and appropriate consultation, we do not agree with your
initial designation recommendation and we intend to modify it, we will notify you in a
letter (commonly referred to as a "120-day" letter) no later than 120 days prior to our
final action to designate your area. As appropriate, consultation will be conducted after
you receive the 120-day letter. Following receipt of our 120-day letter, if you have
additional information that you want us to consider, we request that such information
be submitted to your EPA Regional Office Administrator within 60 days after receiving
our 120-day letter. This will help ensure that we can fully consider the additional
information prior to issuing final designations. (See Table 1, step 8, page 17.)
Because of the potential implications for tribes, we will send letters containing our final
designation decisions to:
•	All tribes that submitted a designation recommendation regardless of whether the
EPA intends to modify or agrees with the recommendation;
•	All tribes within Indian country that we are designating as nonattainment; and
•	All tribes with TAS status for CAA section 107(d) purposes.
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Developing Designation Recommendations for Areas of Indian Country
Although tribes are generally not required to submit designation recommendations, the
CAA does establish statutory requirements for the EPA to promulgate designations
within a certain time frame. During consultation (if requested), we plan to fully inform
you of this statutory requirement. This will help ensure that consultation is completed
by the time the final designations are promulgated.
Following consultation and evaluation of any additional information you submit, the EPA
Administrator makes the final designation decisions. The final designations are signed by
the EPA Administrator and published in the Federal Register, along with a date on which
the designations become effective. The effective date is usually 30 to 60 days after
publication, but it may be later.
KK\ Pnm |X 4\r. FOR I HFR i\t Uir\
•	Send your designation recommendation letter and any accompanying multi-factor
analysis to your EPA Regional Office Administrator.
•	The due date for your recommendation is typically one year from promulgation of
the NAAQS; the due date will be included in the letter that you will receive from
your EPA regional office.
•	Your EPA regional office, along with the EPA headquarters offices, will review your
designation recommendation, multi-factor analysis and any other relevant
information. We intend to provide additional opportunities for consultation (if
requested) before the final designation is promulgated.
•	The EPA's review will be done in a timely manner to conform to deadlines set by the
CAA.
•	Your multi-factor analysis will be carefully reviewed for accuracy and to ensure it
represents your current air quality status.
•	We intend to keep you informed of our intended designation decisions and offer the
opportunity for consultation and to submit additional relevant information prior to
final designation decisions.
For further information on submitting your designation recommendations see:
•	Guidance to Regions for Working with Tribes during the National Ambient Air Quality
Standards (NAAQS) Designation Process, December 2011:
https://epa.gov/sites/production/files/2017-02/documents/12-20-
11 guidance to regions for working with tribes naaqs designations.pdf.
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Developing Designation Recommendations for Areas of Indian Country
• Policy for Establishing Separate Air Quality Designations for Areas of Indian Country,
December 2011:
https://epa.gov/sites/production/files/2016-02/documents/indian-country-
separate-area.pdf.
¥01. APPENDIX
This section contains valuable information to assist you in your decision making and to guide you
through the designation recommendation process.
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Developing Designation Recommendations for Areas of Indian Country
APPENDIX
52

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Developing Designation Recommendations for Areas of Indian Country
APPENDIX A: INFORMATION ON CRITERIA POLLUTANTS
Pollutant
Description
Health and Environmental Effects and Common Emission Sources
CO
What Is It?
Carbon
Monoxide
•	Carbon monoxide, or CO, is a colorless, odorless gas that is formed
when carbon in fuel is not burned completely.
•	Higher levels of CO generally occur in areas with heavy traffic
congestion and during the colder months of the year.

Health Effects
•	CO can cause harmful health effects by reducing oxygen delivery to
the body's organs (like the heart and brain) and tissues.
•	For a person with heart disease, a single exposure to CO at low levels
may cause chest pain and reduce that person's ability to exercise;
repeated exposures may contribute to other cardiovascular effects.
•	People who breathe high levels of CO can develop vision problems,
reduced ability to work or learn, reduced manual dexterity, and
difficulty performing complex tasks.
•	At extremely high levels, CO is poisonous and can cause death.

Environmental
Effects
•	CO contributes to the formation of smog (ozone).
•	CO emissions lead to increases in the concentrations of carbon
dioxide, methane, and ozone, which are greenhouse gases.

Common
Emission
Sources
•	Motor vehicle exhaust contributes about 56 percent of all CO
emissions nationwide.
•	Other non-road engines and vehicles (such as construction equipment
and boats) contribute about 22 percent of all CO emissions
nationwide.
N02
What Is It?
Nitrogen Dioxide
•	Nitrogen dioxide (NO2) belongs to a family of highly reactive gases
called nitrogen oxides (NOx).
•	While the EPA's National Ambient Air Quality Standard covers this
entire family of NOx, NO2 is the component of greatest interest and
the indicator for the larger group of nitrogen oxides.

Environmental
Effects
•	Sulfur dioxide and NOx are the two key air pollutants that cause acid
deposition, which can harm lakes and streams and damage trees, crops,
historic buildings, and monuments.
•	NOx emissions contribute to accelerated eutrophication of coastal
waters and estuaries.
•	Nitrous oxide (N2O) is a greenhouse gas.
•	NOx emissions lead to formation of compounds that impair visibility.

Common
Emission
Sources
• NO2 forms quickly from emissions from cars, trucks and buses, power
plants, and off-road equipment.
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Developing Designation Recommendations for Areas of Indian Country
Pollutant
Description
Health and Environmental Effects and Common Emission Sources
03
What Is It?
Ozone
•	Ozone (O3) is a gas composed of three oxygen atoms.
•	At ground level, O3 is created by a chemical reaction between NOx and
volatile organic compounds (VOC) in the presence of sunlight.
•	Ground-level O3 is harmful to health and the environment and is the
primary constituent of smog.
•	Very high in the atmosphere (about 10 to 30 miles above the earth's
surface) "good" ozone occurs naturally and forms a layer that protects
life on earth from the sun's harmful rays.

Health Effects
•	People with lung disease, children, older adults, and people who are
active can be affected when ozone levels are unhealthy.
•	Numerous scientific studies have linked ground-level O3 exposure to a
variety of problems, including: airway irritation, coughing, and pain
when taking a deep breath; wheezing and breathing difficulties during
exercise or outdoor activities; inflammation, which is much like a
sunburn on the skin; aggravation of asthma and increased
susceptibility to respiratory illnesses like pneumonia and bronchitis;
and, permanent lung damage with repeated exposures.

Environmental
Effects
•	Ground-level O3 can have detrimental effects on plants and
ecosystems.
•	These effects include: interfering with the ability of sensitive plants to
produce and store food, making them more susceptible to certain
diseases, insects, other pollutants, competition and harsh weather;
damaging the leaves of trees and other plants, negatively impacting
the appearance of urban vegetation, as well as vegetation in national
parks and recreation areas; and reducing forest growth and crop
yields, potentially impacting species diversity in ecosystems.

Common
Emission
Sources
• Motor vehicle exhaust and industrial emissions, gasoline vapors, and
chemical solvents as well as natural sources emit NOx and VOC that
lead to formation of O3.
Pb
What Is It?
Lead
•	Lead (Pb) is a metal found naturally in the environment as well as in
manufactured products.
•	As a result of the EPA's regulatory efforts to remove lead from
gasoline, emissions of lead from the transportation sector
dramatically declined by 95 percent between 1980 and 1999, and
levels of lead in the air decreased by 94 percent between 1980 and
1999.

Health Effects
•	Lead can adversely affect the nervous system, kidney function,
immune system, reproductive and developmental systems and the
cardiovascular system.
•	Lead exposure also affects the oxygen carrying capacity of the blood.
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Developing Designation Recommendations for Areas of Indian Country
Pollutant
Description
Health and Environmental Effects and Common Emission Sources


•	The lead effects most commonly encountered in current populations
are neurological effects in children and cardiovascular effects in
adults.
•	Infants and young children are especially sensitive to even low levels
of lead, which may contribute to behavioral problems, learning
deficits and lowered IQ.

Environmental
Effects
• Ecosystems near point sources of lead demonstrate a wide range of
adverse effects including losses in biodiversity, changes in community
composition, decreased growth and reproductive rates in plants and
animals, and neurological effects in vertebrates.
PM
What Is It?
Particulate
Matter
•	Particulate matter (PM) is a mixture of extremely small particles and
liquid droplets, including acids (such as nitrates and sulfates), organic
chemicals, metals, and soil or dust particles.
•	As the size of particles is directly linked to their potential for causing
health problems, the EPA groups particle pollution into two
categories.
•	"Inhalable coarse particles," such as those found near roadways and
dusty industries, are larger than 2.5 micrometers and smaller than 10
micrometers in diameter.
•	"Fine particles," such as those found in smoke and haze, are 2.5
micrometers in diameter and smaller.

Health Effects
•	PM particles are so small that they can get deep into the lungs and
cause serious health problems.
•	Numerous scientific studies have linked particle pollution exposure to
a variety of problems, including increased respiratory symptoms, such
as irritation of the airways, coughing, or difficulty breathing, for
example; decreased lung function; aggravated asthma; development
of chronic bronchitis; irregular heartbeat; nonfatal heart attacks; and
premature death in people with heart or lung disease.
•	People with heart or lung diseases, children and older adults are the
most likely to be affected by particle pollution exposure.

Environmental
Effects
•	Fine particles are the major cause of reduced visibility (haze) in parts
of the United States, including many of our treasured national parks
and wilderness areas.
•	Particles can be carried over long distances by wind and then settle on
ground or water. The effects of this settling include: making lakes and
streams acidic; changing the nutrient balance in coastal waters and
large river basins; depleting the nutrients in soil; damaging sensitive
forests and farm crops; and affecting the diversity of ecosystems.
•	Particle pollution can stain and damage stone and other materials,
including culturally important objects such as statues and monuments.
55

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Developing Designation Recommendations for Areas of Indian Country
Pollutant
Description
Health and Environmental Effects and Common Emission Sources

Common
Emission
Sources
• PM can be directly emitted from sources such as forest fires, or they
can form when gases emitted from power plants, industries and
automobiles react in the air.
S02
What Is It?
Sulfur Dioxide
•	Sulfur dioxide (SO2) is one of a group of highly reactive gasses known
as "oxides of sulfur."
•	The EPA's National Ambient Air Quality Standard for SO2 is designed to
protect against exposure to the entire group of sulfur oxides (SOx).
•	SO2 is the component of greatest concern and is used as the indicator
for the larger group of SO2. Other gaseous sulfur oxides (e.g. SO3) are
found in the atmosphere at concentrations much lower than SO2.

Health Effects
•	Current scientific evidence links short-term exposures to SO2, ranging
from 5 minutes to 24 hours, with an array of adverse respiratory
effects including bronchoconstriction and increased asthma
symptoms. These effects are particularly important for asthmatics at
elevated ventilation rates (e.g., while exercising or playing.)
•	Studies also show a connection between short-term exposure and
increased visits to emergency departments and hospital admissions
for respiratory illnesses, particularly in at-risk populations including
children, the elderly, and asthmatics.
•	Emissions of SOx can react with other compounds in the atmosphere
to form PM, which has adverse health effects.

Environmental
Effects
•	SOx and NOx are the two key air pollutants that cause acid deposition,
which can harm lakes and streams and damage trees, crops, historic
buildings, and monuments.
•	SOx emissions lead to formation of compounds that impair visibility.

Common
Emission
Sources
•	The largest sources of SO2 emissions are from fossil fuel combustion at
power plants (73%) and other industrial facilities (20%).
•	Smaller sources of SO2 emissions include industrial processes such as
extracting metal from ore, and the burning of high sulfur containing
fuels by locomotives, large ships, and non-road equipment.
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Developing Designation Recommendations for Areas of Indian Country
APPENDIX B: SAMPLE TRIBAL DESIGNATIONS CONSULTATION LETTER
8
ATTACHMENT B.
SAMPLE TRIBAL DESIGNATIONS CONSULTATION LETTER
(INSERT DATE)
«FIRST» «LAST»
«TITLE»
«TRIBE_NAME»
«ADDRESS»
«CITY», «FULL_STATE» «ZIP»
«Dear «TITLE» «LAST Name»:
The purpose of this letter is to provide you with information and guidance on the U.S. Environmental
Protection Agency's (EPA) designations process for the (INSERT POLLUTANT) national ambient air
quality standard (NAAQS). Your tribe may find it important to engage with us in the process of
assigning designations for Indian country. Although your involvement is not required, we would like to
invite you to participate in the designations process and to offer you consultation. We want to ensure
early, transparent and effective communication in proposing area designations for the revised (INSERT
POLLUTANT) standard.
On (INSERT DATE), EPA revised the primary (INSERT "AND SECONDARY," IF APPLICABLE)
NAAQS for (INSERT POLLUTANT) to provide increased protection of public health and welfare from
(INSERT POLLUTANT) pollution. The new primary (INSERT POLLUTANT) standard was lowered
from (INSERT INFO REGARDING OLD AND NEW STANDARD(S)). (INSERT ANY
ADDITIONAL INFORMATION REGARDING THE STANDARD(S)).
Establishing area designations is a key step in the process of providing the health and/or welfare
protection intended by the Clean Air Act (CAA). Within two years of promulgation of a new or revised
NAAQS, EPA must list and designate all areas in the country as either:
Attainment—areas that meet the standard;
Nonattainment—areas that either do not meet the standard, or are contributing to a nearby area
that does not meet the standard; or
Unclassifiable—areas where there is insufficient information to make a determination.
These designations are based on current air quality information, recommendations from state Governors
and tribal Leaders, and other relevant information discussed in the attached guidance document. We
encourage you to submit your recommendation for designation of your area for consideration in this
process.
[Add if area violating: Preliminarily, we believe your area potentially may be designated nonattainment
for the (INSERT POLLUTANT) standard.y We invite and encourage you to participate in the
designations process. Please notify us by (INSERT DATE) if you are interested in participating in the
designations process and/or consulting with us regarding the process. When requested, consultation will
57

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Developing Designation Recommendations for Areas of Indian Country
9
be conducted in accordance with the EPA Policy on Consultation and Coordination with Indian Tribes
(www.epa.gov/tribal/consultation/consult-policv.htm). If you choose to participate in the designations
process, we ask that you provide your recommendation to EPA by (INSERT DATE).
The enclosed memorandum provides guidance on the process for designating areas under the revised
(INSERT POLLUTANT) NAAQS. We plan to announce our intended designations no later than 120
days prior to promulgating the final designations. Following the announcement of intended designations,
tribes will have an additional opportunity to consult with us on any modifications EPA may propose to a
tribe's original recommendation.
In accordance with section 107(d)(1)(B) of the CAA, we are required to issue final designations by no
later than (INSERT DATE). Our designations will be based on the most recent three calendar years of
certified, quality-assured monitoring data available, and any other relevant information. If a tribe does
not submit a recommendation, we will promulgate an appropriate designation for the relevant area of
Indian country.
As the process moves forward, we will keep you and your staff informed of any additional guidance or
other support activities. We look forward to working with you and your staff to develop area
designations under the revised (INSERT POLLUTANT) standard(s) in a timely manner. If your tribe is
interested in consultation or participating in further discussions or meetings with EPA officials about the
designations process, please do not hesitate to contact me or (INSERT NAME) of my staff at (INSERT
TELEPHONE NUMBER) or (INSERT EMAIL).
Sincerely,
(INSERT NAME)
Regional Administrator
Enclosure
cc: Tribal environmental director
Tribal environmental staff
Appropriate State/local Agencies
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Developing Designation Recommendations for Areas of Indian Country
APPENDIX C: EPA HEADQUARTERS AND REGIONAL OFFICES TRIBAL
CONTACTS
EPA - OAR
EPA - Region 1
EPA - Region 5
EPA - Region 8
James Childers (Pat)
Eugene Benoit
Benjamin Giwojna
Kyle Olson
Senior Indian Program Manager
(617)918-1639
(312) 886-0247
(303) 312-6002
(202) 564-1082
benoit.cuscncir/CDa. sov
s i wo i na. b c n i a m i liiT/c oa. so v
olson. kvle(@,eoa. sov
childers.DatV/CDa. sov




EPA - Region 2
Monika Lacka
EPA - Region 9
EPA - OAQPS
Gavin Lau
(312) 886-6556
Lauren Maghran
Laura McKelvey
(212) 637-3708
lacka. monikaVvcDa. sov
(415) 947-4107
Tribal Coordinator
lau. savinf/coa. sov

mashran.lauren(@et>a. sov
(919) 541-5497

Avi Lapp

mc k c 1 vc v. 1 a ii ra a c oa. ao v
EPA - Region 3
(312) 353-4855
EPA - Region 10

Brian Hamilton
lamavrohom(@et>a. sov
Sandra Brozusky
EPA - OTAQ
(215) 814-5497

(206) 553-5317
Sarah Fowlkes
ha l n i 1 to n. b ri a lif/c oa. so \
EPA - Region 6
b rozusk v. sa ndra a coa. so\
(734)214-4417

Aunjanee Gautreaux

fawlkes. sarah(@et>a. sov
EPA - Region 4
(214) 665-7127
ErinMcTigue

R4T ribal Air(@et>a. sov
sautreaux.aunianee(@,eoa.sov
(206) 553-1254
Lucita Valiere
Ana Oquendo

lnctisuc.cri nf/CDa. sov
(206) 553-8087
(404) 562-9781
Frances Verhalen

valicrc. liicitair/CDa. sov
ociucndo.anaVvcDa. sov
(214) 665-2172
Kayla Krauss


Vc rha 1 c n. fra nc c sV/c oa. sov
(206) 553-2728
EPA - ORIA
Mario Zuniga

krauss.kavlaf/CDa. sov
Chris Griffin
(404) 562-8961
EPA - Region 7

(202) 343-9421
zunisa.mario(@,et>a. sov
11201 Renner Blvd

srifTin.chrisWcDa. sov

Lenexa, KS 66219


Melba Table
Paula Higbee

EPA - OAP
(404) 562-9086
(913)551-7028

Erica Bollerud
tabic. mclbaVvcDa. sov
hisbee.t>aula(@,et>a. sov

(202) 343-9282



bollerud. erica(@,eoa. sov



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Developing Designation Recommendations for Areas of Indian Country
APPENDIX D: DECISION MATRIX
MART
I Final NAAQ.5
promulgated
and pubhshed
in the Fedsrnl
Register J
What level of participation
or involvement does your
tribe want to undertake in
the designation
recommendation process
For
example,
your tribe
may
decide to
Do nothing
OR
Request
consultation
Send a request for
consultation to
your EPA Regional
Office
AND/OR
You receive a letter from your EPA Regional Office offering consultation and the opportunity to submit a
designation recommendation for a new or revised N AA0.5 for a specific criteria pollutant.
Things to Consider
*	Have you considered your tribe's interests,
priorities,, and available resources?
*	Do you have the knowledge and resources to
conduct the levet of analyses generally required
in a multi-factor analyse?
» Have you considered the possible legal
implications if you request a separately
designated area of Indian country? For example,
do you have disputed boundaries or other
pj-risdtctionol issues?
Your EPA Regional Office will consult with you
and discuss the technical requirements
needed, if you are interested in developing
and submitting a designation
recommendation.
Deve
1
op and submit a designation
ecommendation to EPA.
You may choose to:


Submit
with a
designation recommendation 1
letter to EPA
detailed multi-factor analysis. 1
OR


Submit a recommendation letter for a
separately designated area of Indian
country (separate from surrounding or
adjacent areas 1 with documentation of
the Indian country boundary and the
multi-factor analysis.
Prepare and submit your designation
recommendation letter along with a ny
supporting docu mentation. This letter should
be submitted to your EPA Regional Office
Admin istrator From an authorized tribal
official.


1 Stay in touch w rth your
EPA Regional Office. 1
You decide not to
develop or submit a
designation
recommendation.
1
The EPA. Regional Offices will send
120-day letters to the following
tribes (with opportunity for
consultation):
•	AH tribes with Indian country
that the EPA intends to
designate as nan attainment,
and
*	All tribes with TAS status for
CAA section 107(d) purposes.
If you receive a 120-day letter,
work with your EPA Regional
Office for potential next steps.
If, EPA AGREES
with your recommendation.
] [
If, EPA DOES NOT AGREE
with your recommendation.
You will receive a letter that EPA accepts your
designation recommendation and that EPA w3f officially
promulgate the designation decision via publication in
the Federal Register.
You will receive a letter 120 days prior to o-ur final action to
designate your area. You may request to consult on the
decision and provide additional technical information to
your EPA Regional Administrator within 60 days of receipt
of the 120-day letter.
EPA will promulgate an appropriate designation for your area of Indian country
after consultation and evaluation of all relevant information/data.
Final designations are signed by the EPA Admin istrator and published in the
Federal Register along with an effective date.
LEGEND: Green-EPA
Blue-Tribes
60

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Developing Designation Recommendations for Areas of Indian Country
APPENDIX E: EPA REGIONAL ADMINISTRATORS
Region 1 (CT. ME. MA. NH. RI. VT and 10 Tribal Nations)
Region 6 (AR. LA NM. OK. TX and 66 Tribes)
Deborah Szaro (Acting)
5 Post Office Square, Suite 100
Boston, MA 02109-3912
(617)918-1011
szaro.dcbV7,cpa.go\
Samuel Coleman, P.E. (Acting)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 665-2200
gray. davidVvcpa. gov
Region 2 (NJ. NY. PR. USVI and 8 Tribal Nations)
Region 7 (IA KS. MO. NE and 9 Tribal Nations)
Walter Mugdan (Acting)
290 Broadway
New York, NY 10007-1866
(212) 637-5000
mugdan.walter@epa.gov
Ed H. Chu (Acting)
11201 RennerBlvd.
Lenexa, KS 66219
(913) 551-7006
r7actionline@epa.gov
Region 3 (DE. DC. MD. PA VA. WV and 1 Tribe)
Region 8 (CO. MT. ND. SD. UT. WY and 27 Tribal Nations)
Cecil A. Rodrigues (Acting)
1650 Arch Street
Philadelphia, PA 19103-2029
(215) 814-2900
R3_RA@epa.gov
Region 4 (AL FL. GA KY. MS. NC. SC. TN and 6 Tribes)
V. Anne Heard (Acting)
61 Forsyth Street, SW
Atlanta," GA 30303-3104
(404) 562-9900
Region 5 (IL. IN. MI. MN. OH. WI and 35 Tribes)
Robert Kaplan (Acting)
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 886-3000
Deb Thomas (Acting)
1595 Wynkoop Street
Denver, CO 80202-1129
(303) 312-6532
Region 9 (AZ. CA HI. NV. Pacific Islands and 148 Tribes)
Alexis Strauss (Acting)
75 Hawthorne Street
San Francisco, CA 94105
(415) 947-8000
Region 10 (AK. ID. OR WA and 271 Native Tribes)
Michelle Pirzadeh (Acting)
1200 6th Avenue
Seattle, WA 98101
(206)553-1234
Pirzadeh.inichelle@epa.gov
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Developing Designation Recommendations for Areas of Indian Country
APPENDIX F: AIR QUALITY EDUCATION AND TRAINING RESOURCES
Resource
Contact Information
Air Pollution Training Institute (APTI) provides
technical training to tribal air pollution professionals.
Courses are available in classroom and self-instructional
formats.
httDs://\\\w\.aDti-learn.net/LIVIS/EPAHoincPaac.asDx
APTI partners host classroom training and professional
development throughout the United States. Please contact
these partners directly to get a list of available training
and to register for classroom courses.
California Air Resources Board (CARB)
litto ://www. arb. ca. gov/training/training. htm
CenSARA
httr>://censara.org/
LADCO
litto ://www. ladco.org/trainins/index.Bhr)
MARAMA
httr>://www.marama.org/training-center
Metro4/SESARM
httr>://www.metro4-sesarm.ore/
NESCAUM
httr>://www.nescaum.org/tor>ics/training-clean-air-academv
WESTAR
httr>://www. westar.org/trainins.html
Community Modeling and Analysis System (CMAS)
offers semiannual software courses.
httD ://www. cmascenter. org/training/classes. cfm
The Institute for Tribal Enviromnental Professionals
(ITEP) provides assistance (including air quality training
courses to Indian tribes and other public and private
groups) in promoting effective enviromnental-resource
management on Indian lands.
htto ://www4. nau.edu/iteo/air/training aa. aso
National Tribal Air Association (NTAA) provides
information and links to upcoming events such as EPA
webinars and briefings, conferences, proposed
rulemakings, and meetings.
htto ://www. ntaatribalair.org/
The Tribal Air Monitoring Support Center (TAMS)
offers different training courses that focus on a variety of
topics related to ambient air quality monitoring.
htto ://www4. nau.edu/tams/training/
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Developing Designation Recommendations for Areas of Indian Country
APPENDIX G: AIR QUALITY MONITORING INFORMATION AND DATA
SOURCES
Resource
Link/Information Source
Air Pollution Monitoring EPA website contains information
and links to many topics associated with monitoring air
pollution.
lUtDs://\Yww3,cDa.aov/airaiialitv/montri na.html
lUtDs://\Yww.cDa.aoY/outdoor-air-aualitY-data
Air Quality System (AQS) The Air Quality System (AQS) is
EPA's repository of ambient air quality data. AQS stores data
from over 10,000 monitors, 5,000 of which are currently active.
State, local and tribal agencies collect the data and submit it to
AQS on a periodic basis.
httDs://\Yww.cDa.aov/aas
AirTrends Air Quality Monitoring Information each year
EPA tracks the levels of pollutants in the air and how much of
each pollutant (or the pollutants that form them) is emitted from
various pollution sources. The EPA posts the results of our
analyses to this web site.
htft>s://www.et>a.eov/air-trends
Air Pollution Monitoring website is a gateway to
understanding the EPA's monitoring objectives and networks.
httr)s://www3.ei3a.sov/airaualitv/ino ntrins.html
Technical Air Pollution Resources website provides access to
a collection of EPA resources with technical information about
many areas of air pollution prevention technology, regulation,
measurement, and science.
httDs:/Av\v\v.CDa.uov/tcchnical-air-Dol lut ion-resources
Ambient Monitoring Technology Information Center
(AMTIC) EPA website contains information on ambient air
quality monitoring programs, monitoring methods, quality
assurance and control procedures, and federal regulations
related to ambient air quality monitoring. The site is primarily
intended for use by air monitoring staff responsible for
collecting ambient air monitoring data.
htft>s://www.et>a.eov/amtic
Options Available for Tribes to Meet Independent
Performance Evaluation Requirements for the Ambient Air
Monitoring Programs Collecting Data for Comparison to
the NAAQS
httDs://\vww.CDa. aov/sitcs/Droduction/filcs/2016-
02/documcnts/nDaD dcd tribal ootions O.odf
Quality Assurance Handbook for Air Pollution
Measurement Systems: Volume II: Ambient Air Quality
Monitoring Program
lUtDs://\Yww3.CDa.aov/ttnamti l/rilcs/ambicnt/Dm25/cia/Fi
nal%20Handbook%20Document%201 17,ixlf
Technical Guidance for the Development of Tribal Air
Monitoring Programs, August 2007
httDs://\vww.CDa.aov/sitcs/Droduction/filcs/2016-
08/documents/techeuidancetribalattch O.odf
Tribal Air Monitoring Support Center (TAMS) offers
support and training courses that focus on a variety of topics
related to ambient monitoring.
litto ://www7. nau.edu/iteo/main/tams/
63

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Developing Designation Recommendations for Areas of Indian Country
APPENDIX H: AIR POLLUTION EMISSIONS INFORMATION AND DATA
SOURCES
Resource
Link/Information Source
Air Emissions Sources Website is designed to make emissions
data for six common (criteria) pollutants easy to find and
understand. Users can look at overall emissions, emissions by
type of industry, or emissions by largest polluter.
htft>s://www.et>a.eov/air-emissions-inventories/air-
emissions-sources

ICIS-AIR contains compliance and permit data for stationary
source of air pollution regulated by EPA, state and local air
pollution agencies.
htft>s://www.et>a.eov/enviro/icis-air-overview
htft>s://www.et>a.eov/enviro/icis-air-search;
httosy/www.eoa.eov/sites/oroduction/files/wideets/ef-
afs.html
AirData presents annual summaries of air pollution data from
the NEI (National Emission Inventory) database which provides
estimates of annual emissions of criteria and hazardous air
pollutants from all types of sources.
htft>://www.et>a. eov/airdata/
AIRNow Website users search the Air Quality Index to find
ozone maps to learn more about air quality and air pollution.
litto ://airno w. eov/
EJSCREEN is an enviromnental justice screening and mapping
tool that provides EPA with a nationally consistent dataset and
approach for combining enviromnental and demographic
indicators.
httDs://\vww.cDa. eov/ei screen
Emission Inventory Basics for Tribal Air Coordinators,
October 2008
httDs://\\\w\.CDa.ao\/sites/Droduction/filcs/2016-
09/documents/emisioninventorvbasics2008.t>dfh
Clearinghouse for Inventories and Emissions Factors
(CHIEF)
httBsV/www.eoa.sov/cliief:
lUtDs://\Yww.CDa.aov/air-cmissions-monitoriim-
knowledse-base
Introduction to Emission Inventories for Tribes, October
2008
httos ://eoa. eov/sites/oroduction/files/2016-
09/documcnts/introtocmissioninycntoricstribcs2008.D
df
The EIS Gateway, the first component of the Emissions
Inventory System (EIS), was developed to provide registered
users with access to emissions inventory data and to provide
transparency to the emissions inventory process. Registered
users can access facility inventory and emissions data for
sources in their jurisdiction.
htft>s://www.et>a.eov/air-emissions-
inventories/emissions-inventorv-svstem-eis-eatewav
The Emissions & Generation Resource Integrated Database
(eGRID) is a comprehensive source of data on the
enviromnental characteristics of almost all electric power
generated in the United States.
httos://www.ei3a.eov/enerev/emissions-eeneration-
resource-inteerated-database-eerid
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Developing Designation Recommendations for Areas of Indian Country
The National Emissions Inventory (NEI) is a comprehensive
and detailed estimate of air emissions of both criteria and
hazardous air pollutants from all air emissions sources. The NEI
is prepared every three years by the U.S. EPA based primarily
upon emission estimates and emission model inputs provided by
state, local and tribal air agencies for sources in their
jurisdictions and supplemented by data developed by the U.S.
EPA.
htft>s://www.et>a.eov/air-emissions-
inventories/national-emissions-inventorv-nei
The Tribal Emission Inventory Software Solution (TEISS) is
free to all federally recognized U.S. tribes and was designed
specifically to help tribes develop emission inventories.
htto://www7.nau.edu/iteo/main/air/air aat teiss
Window to My Environment (WME) is a powerful web-based
tool that provides a wide range of federal, state, and local
information about enviromnental conditions and features in an
area of your choice.
htft>s://www3 .era. eov/enviro/mvenviro/
Envirofacts Data Warehouse is a single point-of-access to
select and view US EPA enviromnental data. This website
provides access to several EPA databases (including: AFS, PCS,
CERCLIS, ECHO and many more) to provide you with
information about enviromnental activities that may affect air,
water, and land anywhere in the United States.
htft>s://www3 .era. eov/enviro/
65

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Developing Designation Recommendations for Areas of Indian Country
EPA Regional Contacts (for technical help with Emission Inventories):
EPA Region 1
Bob McConnell
Mcconnell.robert@epa.gov
617-918-1046
EPA Region 2
Raymond Forde
forde.raymond@epa.gov
212-637-3716
EPA Region 3
Alice Chow
chow.alice@epa.gov
215-814-2144
EPA Region 4
James Hou
hou.james@epa.gov
404-562-8965
EPA Region 5
Loretta Lehrman
lehrman.loretta@epa.gov
312-886-5482
EPA Region 6
Carl Young
young.carl@epa.gov
214-665-6645
EPA Region 7
Steven Brown
brown.steven@epa.gov
913-551-7718
EPA Region 8
Mark Komp
komp.mark@epa.gov
303-312-6022
EPA Region 9
Larry Biland
biland.larry@epa.gov
415-947-4132
EPA Region 10
Madonna Narvaez
narvaez.madonna@epa.gov
206-553-2117
66

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Developing Designation Recommendations for Areas of Indian Country
APPENDIX I: DESIGNATIONS RECOMMENDATION SUBMISSIONS
CHECKLIST
1.	Is the submittal accompanied by a formal letter from an authorized tribal official to an EPA Regional
Administrator?
2.	Did you consult with your EPA regional office to ensure you have the most current data, information, and
guidance?
3.	If you are requesting a separate designation, did you consider all potential implications in identifying
your Indian country boundaries?
4.	Are you submitting your recommendation on or before the due date?
5.	Did you clearly state your recommended designation as attainment, nonattainment, or unclassifiable?
6.	Did you clearly state the pollutant for which you are submitting the recommendation (for example, 8-
hour ozone, PM2.5, etc.)?
7.	Did you provide the necessary technical analysis (five factors) to support your recommendation?
8.	Is your technical analysis based on the most current data and information available?
9.	Did you include all other available information to support your recommendation?
67

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Developing Designation Recommendations for Areas of Indian Country
APPENDIX J: EPA TECHNICAL SUPPORT DOCUMENT FOR PM2.5
DESIGNATIONS
This appendix provides an example of how the EPA reviewed the technical analysis for the Santa Rosa Band of
Mountain Cahuilla Indians for the 24-hour PM2.5 NAAQS designations. Note that the example below covers nine
factors. Although, the EPA has merged the nine factors into five factors, the required information is the same.
7,0 Santa Rosa Band of Mountain Cahuilla Indians Technical Support
Document
The following chapter contains the technical support document for the 24-hour
PM2.5 NAAQS designations for She Santa Rosa Band of Mountain Cahuilla Indians.
EPA Technical Analysis for the Santa Rosa Band of Mountain Cahuilla Indians
Pursuant to section 107(d) of the Clean Aii Act, following the piomuluation of a
new or revised national ambient air quality standard (NAAQS) for any pollutant under
section 100 of the Clean Air Act. I I'A must designate areas as nonattainment. attainment
or unelassifiable foi that pollutant HP A has re-evaluated the intended nonattainment
designation for the 2000 24-hour fine particle (I'M? a) NAAQS for the lands of the Santa
Rosa Band of Mountain Cahuilla Indians that are located in that part of Riverside County,
California, cunently designated as nonattainment for the 1007 pm, , NAAQS As a
result of this revaluation, in response to the Tribe's recommended designation of
attainment, HPA is designating all of the lands of the Santa Rosa Band of Mountain
Cahuilla Indians, including those located in that part of Riverside County, California, that
are in the existing 1W7 I'Mj 5 nonattainment areas, as attainment for the 2006 24-hour
PM= s NAAQS BP A has based this decision on the weight of e\ idence of the following
nine factors recommended in FPA guidance and any other relevant information:
-	pollutant emissions
-	air quality data
-	population density and degree of urbanization
-	traffic and commuting patterns
-	grow th
-	meteorology
-	geography and topography
-	jurisdictional boundaries
-	level of control of emissions sources
Figure 1 is a map of the Santa Rosa Band of Mountain Cahuilla Indians Reservation and
its location within the State of California, plus other relevant information.
7-1
68

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Developing Designation Recommendations for Areas of Indian Country
Legend
t i»fec. Sew!©* OspiBur
O -'sstrj we 2CM »v :.s 3w:»
O ®V-2 S roller set.* !n 2CCS-23C7
2002 Average Daily Truck Traffic
•D6-3€5-&:Oi-36lQ"-1
I RjSHOux (WW RvefHC i
DV- 556 	
230' -5333
^^w»3' - 13930
^^-533- -2S3C3
33' - 55303
2002 Average Daily Traffic
106-065-6D01-53101-1
Patn5crtr>3»
DV- 19 8
'05-365-'305-38101-11
Rverttse
DV-<6.9
I County seundar;
iy/A •»»
Designations for Particulate Matter PM-2 5
I Nco»tt*nme«
| UKMrtMBMalMiem
People per square mile
51 -250
281 -500	N
3033
yfy'
	| 5.331-53330
WPfo
/''rz
-'sSss'a
¦vtl- ;w
Tribal Lands and PM-2.5 Nonattainment Areas
Figure 1
For this area, EPA previously established PM2.5 nonattainment boundaries for the
1997 PM2.5 NAAQS that included the entire South Coast Air Quality Management
District including the Santa Rosa Band of Band of Mountain Cahuilla Indians
Reservation.
Based on EPA's 9-factor analysis, described below, which contains currently
available information, EPA is designating the lands of the Santa Rosa Band of Mountain
Cahuilla Indians as unclassifiable/attainment for the 2006 24-hour PM2.5 standards.
Based on EPA's technical analysis, this area does not cause or contribute to the violations
of the 2006 24-hour PM2.5 standards.
The following is a summary of the 9-factor analysis for the Santa Rosa Band of
Mountain Cahuilla Indians Reservation.
7-2
69

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Developing Designation Recommendations for Areas of Indian Country
Factor 1: Emissions data
While the Tribe does not monitor or maintain an emissions inventory, there are no
significant sources of PMj 5 on the reservation. Minimal power generation sources
situated atop Toro Peak, and operated sn connection with certain low amperage radio and
antennae transmission devices, are the only industrial sources of PM2 5. Other potential
sources of PM25 are limited to wood smoke andAxr emissions from mobile sources. In
light of the fact that only sixty-seven Tribal Members reside on the 11,000 acre
reservation, such emissions are minimal in both frequency and volume.
EPA has evaluated the information presented by the tribe and concurs that there
are no significant sources of PM; 5 on the Reservation. EPA also concurs that the
contribution from area sources will be small based on the small population of the
Reservation. EPA therefore believes that the potential sources of PM; s are very limited
and unlikely to cause or contribute to violations of the 2QQ<> 24-hour PM; < standards.
Factor 2: Air quality data
There are no PM;< monitors situated on the Santa Rosa Band of Mountain
Cahuilla Indians Reservation. There are violating monitors maintained within the South
Coast PM? < nonattainment area, and these are located in Los Angeles and San
Bernardino Counties, approximately 41 miles from the Santa Rosa Reservation. There is
an additional monitor in Orange County located 50 miles from the Reservation, which is
not violating. Given the large distance involved, as well as the characteristics of the
surrounding environment where these monitors are located, none are indicative of the air
quality of the Reservation. Due to the distance involved, unique topography and
meteorological conditions, those measurements are not representative of air quality on the
Santa Rosa Reservation.
EPA has reviewed the air quality data for the area and concurs that there are not
measured violations of the PM; c NAAQS at or near the Santa Rosa Band of Mountain
Cahuilla Indians Reservation However, this information does not provide conclusive
evidence of the absence or existence of contribution to elevated PM? 5 levels in the South
Coast PM; ? nonattainment area. The contribution of the Santa Rosa Band of Mountain
Cahuilla Indians Reservation to the nearby and violating monitors in the nonattainment
area is discussed further in Factor <>, below.
Factor 3; Population density and degree of urbanization (including commercial
development)
Approximately 67 full-time residents live on the 11,000 acres comprising the
Santa Rosa Reservation All of the Reservation's current land use is agricultural because
it is used as open range land for cattle grazing. There are no cattle feedlots or crop
agriculture on the reservation
7-3
70

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Developing Designation Recommendations for Areas of Indian Country
Due to the small population si/e and low population density at the Santa. Rosa
Reservation. EPA believes that the tribe is riot likely to cause or contribute to a violation
of the 2006 24-hour PM; < NAAQS.
Factor 4; Traffic and commuting patterns
One major highway, US 371, runs through the reservation Truck traffic on that
highway is estimated to be a maximum of 2.000 trucks per day. Average daily vehicle
traffic is estimated to be between 2001 and 5000 vehicles per day This level of vehicle
traffic is very low and an insignificant part of overall vehicular traffic within the South
Coast Air Quality Management District, and its urbanized areas Based on traffic and
commuting patterns as shown by these statistics, it is unlikely that emissions from these
vehicles ha\ e any impact on air quality in the South Coast Air Quality Management
District.
EPA has evaluated the motor vehicle traffic estimate and concurs that the average
vehicle traffic is limited, and together with factor 3. support that there is a not a
substantial commuting pattern to the South Coast Air Basin.
Factor 5: Growth rates and patterns
The Santa Rosa Reservation is relatively remote and sparsely populated.
Historically, there has been little demand for development, and it is expected that this
trend will continue. Presently, there arc no pending or contemplated plans for
development in this area or upon the Reservation
EPA has evaluated this information and concurs that future growth is not likely to
increase emissions. EPA therefore concludes that future growth on the Santa Rosa Band
of Mountain Cahuilla Indians Reservation is unlikely to cause or contribute to a violation
of the PMj j standards.
Factor 6; Meteorology (weather/transport patterns)
The pollution roses for the nearest two monitoring sites in Riverside County
indicate that the Santa Rosa Band of Mountain Cahuilla Indians Reservation is unlikely
to contribute to elevated levels of PIVI2 5 The pollution roses for the nearest two
monitoring sites, Indio (060652002) and Palm Springs (060655001) in Riverside County
are shown below The monitor for Indio reflects 110 periods of elevated levels ofPMn.j
The monitor for Palm Springs depicts only a single day where measured PM; 5 levels
exceeded 35 pg/m3 O11 that date, the wind direction was primarily from the west, and it
is unlikely that the Santa Rosa Reservation contributed to the elevated levels of PM; -- for
this monitor on this day.
7-4
71

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Developing Designation Recommendations for Areas of Indian Country
6
CeiKcmrangn
¦	> 40 Mg m3
¦	35-40 Mg m'
30 - 35 W
¦	<30Mgin'
Season
A cool (Oct-Apr)
O warm (May-Sep)
Set r jr>	MM
CSA. Lo% Ang«te»4.c«g 9Mcr-3-M**cr CA
C8SA	B*TW*n»Cntano. CA
Sir* OGOf52002
'	n« boom
i«j# U mwng•yuM •-no <
>»
0
7-5
72

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Developing Designation Recommendations for Areas of Indian Country
Rivetside County, CA
Pollution Rose. M4-2006
CpiKflHnmen
¦	> 40 Mg m3
¦	35 - 40 Mgm'
30 - 35 ng m'
¦	£ 30 >ig m'
Stavoii
A cool (Oct-Apr)
0 warn (May-Sep)
mtotSpM t*v*i
cuocrrr juasiD*mccfrr_*0(io-j)Hjj
Sot «tr\ n«ng KAA
CSA	CA
C8SA Rrttrx0*-Swi B^mjnjro-O-*-no. CA
Stf OWMSOOI
7-6
73

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Developing Designation Recommendations for Areas of Indian Country
In addition, EPA has reviewed the pollution rose at the Rubidoux (West
Riverside) monitor, shown below. The Santa Rosa Band of Mountain Cahuilla Indians
Reservation is located to the southeast of the Rubidoux monitoring site. For the years
2005-2007, 101 values above 35 (xg/m3 were measured, and 81 are displayed on the
pollution rose below. Of the 81 days above the level of 35 |ag/m3, one day occurs when
the wind is from the southeast, in the direction of the Santa Rosa Band of Mountain
Cahuilla Indians Reservation. The majority of the days with elevated PM2.5 are when the
wind is from the northwest.
EPA has evaluated PM2.5 pollution roses at the two nearest monitors to the Santa
Rosa Band of Mountain Cahuilla Indians Reservation, as well as the Rubidoux
monitoring site. EPA has evaluated this information and determined that the Santa Rosa
Band of Mountain Cahuilla Indians Reservation does not cause or contribute to a
violation of the 2006 24-hour PM2.5 NAAQS in the South Coast PM2.5 non-attainment
area.
Los Angeles-South Coast Air Basin, CA[Riverside Comty, CA]
Pollution Rose, 2005-2007
Design
Value
55-NA
Concentration:
¦	> 40 ng'm3
¦	35 -40 jig/ra3
30 -35 ^ig'm3
¦	<30 ,ug m3
Season:
A cool (Oct-Apr)
Owarni (May-Sep)
Site 060658001
20 exceedance(s) notpbtted
(due to missingor vanade wind data)
Meteorological datattom 11J miles at/ay
MARCH AFB (l(>*23119)
7-7
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Developing Designation Recommendations for Areas of Indian Country
Factor 7: Geography/topography (mountain ranges or other air basin boundaries)
The reservation of the Santa Rosa Mountain Band of Mountain Cahuilla Indians
consists of a land base of approximately 11.000 acres, and spans an ele\ ation ranging
from 4000 ft to nearly 9000 ft The Reservation is divided into four land parcels, one part
is located in the southeastern boundary of the South Coast PM2 ? nonattainment area in
Riverside County and the other three parcels aire located in that part of Riv erside County
that is in attainment lor the 199? PM; < NAAQS.
The Reservation is bounded on the northwest by the Cahuilla Mountains and by
Beauty Mountain to the southeast. The majority on the reservation is uninhabited, as is
the rather substantial adjacent acreage maintained by the Department of Forestry and the
Bureau of I and Management. The city of Hemet is located in southwestern Riverside
County, and is located in the San Jacinto Valley Hemet is south of the city of San
Jacinto, and located near the base of the San Jacinto Mountains. The valley is surrounded
by the Santa Ana Hills and San Jacinto Mountains, and is mostly dry land, except for
Diamond Valley Lake to the south of Hemet
EPA has evaluated the geography/topography information for the Reservation of Santa
Rosa Mountain Band of Mountain Cahuilla Indians, EPA believes that the high
elevation of the reservation (4000-9000 ft.), as well as the meteorology, discussed in
factor 6. above, supports the conclusion that the Resen ation of Santa Rosa Mountain
Band of Mountain Cahuilla Indians is not likely to cause or contribute to a \iolation of
the 2006 24-hour PM; s standards
Factor 8: Jurisdictional boundaries (e.g., existing PM and ozone areas)
Part of the lands of the Santa Rosa Mountain Band of Mountain Cahuilla Indians
are located within the South Coast Air Quality Management District (SCAQMD), which
has been designated by the U.S. EPA as nonattainment for the 2006 PMj s NAAQS. The
SCAQMD encompasses all of Qrange County and the urban portions of Los Angeles,
Riverside, and San Bernardino counties However, the Santa Rosa Band of Mountain
Cahuilla Indians is a sovereign nation and a federally recognized Indian Tribe, governed
by a majority vote of all adult members, meeting as a General Council As such, the
Tribe can recommend a PM; 5 designation for tribal lands over which it has jurisdiction.
The Tribe recommends a designation of attainment/unclassifiable for the entire
reservation, including that portion of the reservation historically including in the South
Coast Basin
EPA had previously designated the South Coast Air Quality Management District
(SCAQMD), including part of the Santa Rosa Mountain Band of Cahuilla Indians
Reserv ation as nonattainment for the 1997 PM;.? standards EPA concurs with the tribe,
that based on an evaluation of the information presented above, that a designation of
attainment/unclassifiable for the entire reservation, including that portion of the
reservation historically included in the South Coast Basin is appropriate for the 2006 24-
hour PM; ? standards
7-8
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Developing Designation Recommendations for Areas of Indian Country
Factor 9; Level of control of emission sources
There are no major sources of PM2.3 on the Santa Rosa Reservation, so this factor
is not a consideration for the Tribe,
EPA has evaluated that emission inventory and concurs that based on the lack of
major sources, this factor is not a consideration for the Tribe.
Conclusion
Based on EPA's 9-factor analysis that contains currently available information,
EPA believes that the Santa Rosa Band of Mountain Cahuilla Indians Reservation should
be designated unclassifiable/attainment for the 2006 24-hour PM; j NAAQS, EPA's
evaluation of this information confirms that it is not likely that emissions from the Santa
Rosa Band of Mountain Cahuilla Indians Resen ation cause or contribute to violations of
the 2006 24-hour PM; 5 NAAQS in the South Coast Air Basin
7.9
END OF DOCUMENT
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