Environmental Protection Agency
Region 6
PROTECTING
TRIBAL
AIR QUALITY
OPTIONS AND OPPORTUNITIES
FINAL
(Revised December, 2015)
Page 1 - December, 2015
-------
Environmental Protection Agency, Region 6
PROTECTING TRIBAL AIR
OPTIONS AND OPPORTUNITIES
Revised December, 2015
Contributing Staff:
Air Program Sections
RTOC Tribal Air Subcommittee
Multimedia Planning and Permitting Division
Environmental Protection Agency, Region 6
The December 2015 draft revision of the above document replaces the original
document approved on October 2, 2012 "Protecting Tribal Air: Options and
Opportunities" to update vital information.
Page 2 - December, 2015
-------
Contents
INTRODUCTION
a. The EPA Disclaimer
b. Funding Background
c. Statutory/Regulatory Framework for Tribal Air Programs
d. Clean Air Act Amendments
e. Tribal Authority Rule (40 CFR Part 49, Subpart A)
f. Environmental Program Grants for Tribes (40 CFR Part 35, Subpart B)
EPA CLEAN AIR ACT FUNDING MECHANISMS
a. Clean Air Act Statutory Authorities
b. Solicitation Information
c. Grant Process Timeline
d. Proposal and Submission Information
e. Evaluation Criteria
f. Selection Process
g. Award Notification
h. Application Package for Approved Proposals
AIR PROGRAM ACTIVITIES
a. Air Quality Assessments for Monitoring
b. Emissions Inventory
c. Air Permitting
d. Air Enforcement and Compliance
e. Regional Planning Organizations
f. Air Toxics
RESOURCES AND TRAINING OPTIONS
a. Training Options
b. The EPA Region 6 Air Contacts
APPENDICES
a. Tribal Authority Rule (Fact Sheet)
b. 40 CFR Parts 31 and 35
c. Tribal Air Grants Framework (A Menu of Options)
d. Environmental Results Policy (EPA Order 5700.7A1)
e. Checklist of Key Questions for Proposal Development
f. Air Quality Acronyms
g. Frequently Asked Questions (FAQ)
Page 3 - December, 2015
-------
INTRODUCTION
Page 4 - December, 2015
-------
Introduction
EPA Disclaimer
While the Environmental Protection Agency (EPA) has made every effort to ensure the accuracy
of the content in this document, the obligations of tribes and the regulated communities are
determined by statues, regulations, or other legally binding requirements. In the event of a
conflict concerning the context of this document and any statute or regulations, this document
would not be controlling.
Please note that the general descriptions provided may not apply to all situations. Interested
parties are free to raise questions and objections about the substance and implementation of this
guidance. The EPA decisions makers retain the discretion to adopt approaches on a case-by-case
basis that differ from those described in this document where appropriate.
This is a living document and may be revised periodically without public notice. The EPA
welcomes public input on this document at any time.
Funding Background
Federally recognized tribes seeking to establish an environmental presence on their reservation(s)
have been provided the ability and resources to do so through several funding mechanisms
administered by the EPA. The General Assistance Program (GAP) (General Assistance Program
Act, 42 U.S.C. § 43686), which is maintained through the Region 6 Office of Environmental
Justice and Tribal Affairs, is used to support infrastructure and capacity building efforts. When a
tribe's focus shifts more specifically to air related concerns, an alternative funding mechanism
provided through Section 103 of the Clean Air Act (CAA) is available to support tribal interests in
conducting various projects to develop initial determinations regarding air quality. Finally, the
CAA Section 105 provides for grants to support the implementation of long term activities and
programs to address air quality management.
Statutory/Regulatory Framework for Tribal Air Programs
The air quality in Indian country has important implications for human health and quality of life,
culture and religion, economic development, jurisdictional considerations, and other significant
areas of concern to the tribes. The CAA authorizes EPA to treat a tribe in the manner similar to a
state for the regulation of "air resources within the exterior boundaries of the reservation or other
areas within the tribe's jurisdiction." CAA section 301(d)(2)(B). The EPA believes that this
statutory provision, viewed within the overall framework of the CAA, establishes a territorial
view of tribal jurisdiction and authorizes a tribal role for all air resources within the exterior
boundaries of Indian reservations without distinguishing among various categories of on-
reservation land. 63 FR 7254; see also CAA sections 110(o), 164(c). The CAA includes
provisions that further promote tribal air quality and management through the following goals and
objectives:
Page 5 - December, 2015
-------
To assist the tribes in developing and administering (in whole or part) effective air quality
management programs authorized under the CAA.
To establish model air programs that are responsive to tribal concerns and facilitate the
participation and involvement of the tribes to the maximum extent possible.
To assist the tribes in developing air quality assessments including monitoring of air
quality and/or emissions inventory development of stationary, area, and mobile sources
located on tribal lands.
To assist the tribes in developing comprehensive implementation strategies for attaining
and maintaining air quality standards on tribal lands.
To facilitate the development of air quality management programs that are responsive to
problems and concerns of the tribes generally and each tribe specifically.
To develop and support tribal consortia and other cooperative partnerships among the
tribes that are designed to provide management skills, technical expertise, and resources
necessary for administering specific the CAA administrative functions.
To provide the tribes with information to apply for and obtain financial assistance,
including grants for assessing tribal air quality conditions (CAA Section 103(b)(3)) and
grants for implementing the CAA control programs or attaining air quality standards
(CAA Section 105).
To educate the tribes on pollution prevention and market-based environmental programs.
Clean Air Act Amendments
In the 1990 CAA Amendments, Congress provided for tribal authority to implement the CAA
programs. This action recognized the inherent sovereignty of the tribes and the federal trust
responsibility to protect the rights of the tribes to continue to exist as self-governing communities.
Congress permitted the EPA to treat the Indian tribes in a similar manner to states and instructed
the EPA promulgate regulations specifying those provisions of the CAA for which it is
appropriate to treat the tribes as states.
Tribal Authority Rule (40 CFR Part 49, Subpart A)
In response to the directive of Section 301(d)(2) of the CAA Amendments, the EPA promulgated
the Tribal Authority Rule (TAR) in April 1998. This rule specifies the particular provisions for
which a tribe may develop and implement one or more of its own air quality programs under the
Act and for which the EPA may treat a tribe in a similar manner to a state, establishes the
requirements that the Indian tribes must meet if they choose to be found eligible, and modifies the
regulatory and administrative limitations on the manner in which tribes qualify for and obtain
awards of federal financial assistance to address their air quality problems.
Page 6 - December, 2015
-------
The rule provides that the tribes may be treated in the same manner as a state for all the CAA
programs, except for those identified in 40 CFR § 49.4. The rule notes that Congress provided for
a grant of authority over all resources within the exterior boundaries of a reservation (including
non-Indian owned fee lands) to tribes that have programs approved under the CAA. For non-
reservation areas, the tribes must demonstrate the basis for jurisdiction. See 40 CFR 49.7(a)(3).
Pursuant to CAA Sections 301(d)(2) and 302(r), to be eligible for treatment as a state (TAS), a
tribe must demonstrate:
(1) The applicant is an Indian tribe recognized by the Secretary of the Interior;
(2) The Indian tribe has a governing body carrying out substantial governmental duties and
functions;
(3) The functions to be exercised by the Indian tribe pertain to the management and
protection of air resources within the exterior boundaries of the reservation or other
areas within the tribe's jurisdiction; and
(4) The Indian tribe is reasonably expected to be capable, in the EPA Regional
Administrator's judgment, of carrying out the functions to be exercised in a manner
consistent with the terms and purposes of the CAA and all applicable regulations.
CAA Sections for which the tribes may obtain TAS status:
• Grants for support of air pollution planning and control programs
[CAA Section 105; 42 USC § 7405]
• Interstate Air Quality agencies; program cost limitations
[CAA Section 106; 42 USC § 7406]
• Air quality control regions
[CAA Section 107; 42 USC § 7407]
• State implementation plans for national primary and secondary ambient air quality
standards
[CAA Section 110; 42 USC § 7410]
• Hazardous air pollutants
[CAA Section 112 42 USC § 7412]
• Interstate pollution abatement
[CAA Section 126; 42 USC § 7426]
• Non-attainment plan provisions in general
[CAA Section 172]
• Notification to Administrator and contiguous states
[CAA Section 505(a)(2)]
The EPA Regulations CAA Regulatory Development:
• 40 CFR Part 70 - State Operating Permit Program
[Title V]
Page 7 - December, 2015
-------
General information on treatment in the same manner as a state may be found at
http ://www. epa. gov/tribal.
Environmental Program Grants for the Tribes (40 CFR Part 35, Subpart B)
The regulations regarding grants to the Indian tribes and Intertribal consortia are located in 40
CFR Part 35, Subpart B. This subpart supplements the requirements of specific grants and
programs which contains sections relating to environmental program grants for the tribes.
Page 8 - December, 2015
-------
EPA CLEAN AIR ACT
FUNDING MECHANISMS
Page 9 - December, 2015
-------
EPA Clean Air Act
Funding Mechanisms
CLEAN AIR ACT STATUTORY AUTHORITIES
The EPA awards State and Tribal Air Grants (STAG) to help tribal governments carry out their
air quality related activities and responsibilities. STAG grants are comprised of grants issued
pursuant to CAA Sections 103 and Section 105.
Section 103(b)(3) of the CAA authorizes the Administrator to issue grants for conducting and
promoting the coordination and acceleration of research, investigation, experiments,
demonstrations, surveys, and studies relating to the causes, effects (including health and welfare
effects), extent, prevention, and control of air pollution. These grants known as "Section 103
grants" serve as the tools used to support short term projects aimed at accomplishing these goals
on tribal lands. Activities supported by these funds have included emissions inventory of air
pollution sources, air quality monitoring baseline studies, training and community education and
outreach projects.
* Please note that Section 103 does not provide authority to award grants for "implementing" air
pollution control programs. The Office of General Counsel (OGC) has interpreted the
demonstration grant authority to involve only new or experimental technologies, methods, or
approaches, where the results of the project will be disseminated so that others can benefit from
the knowledge gained in the demonstration project.
Section 105 of the CAA provides authority to award grants to air pollution control agencies for
developing and implementing programs for the prevention and control of air pollution or the
implementation of national primary and secondary ambient air quality standards. The CAA
defines "air pollution control agency" to include an agency of a federally-recognized Indian tribe.
See CAA § 302(b)(5). Further, "implementing" means any activity related to the planning,
developing, establishing, carrying-out, improving, or maintaining of such programs. Please see
CAA § 105(a)(1)(A).
The tribes approved for awards under Section 105 are required to provide a minimum 40% match
unless approved for treatment in a manner similar to a state, in which case a reduced match of 5%
is required for the first two years of funding. If funding continues after two years, then the
required match is raised to 10%. The required match may be waived (0%) if a tribe successfully
demonstrates financial hardship [40 CFR 35.575(a)],
SOLICITATION INFORMATION
The EPA Region 6 estimates that $1,000,000 - $1,300,000 annually will be available regionally
for the award of air quality related projects. The number of awards will depend on the individual
proposal costs, the final aggregate amount of federal funding for all proposals, and the total
amount of federal funding available.
Page 10- December, 2015
-------
GRANT PROCESS TIMELINE
Funding Announcement
Proposals (Work Plan & Budget Narrative) to the EPA by
The EPA will begin Internal Review
The EPA will notify selected applications and begin negotiations
Final Application package to the EPA no later than
December XXXX
..February XXXX
March XXXX
.. April XXXX
... June XXXX
Proposal Submission Date
The closing date for applicants to submit proposals is February, XXXX.
The estimated project period for awards resulting in a solicitation is October 1, through
September 30.
Proposals evaluated but not selected may be retained for a period of 3 months from date of
selections for future awards if additional funds become available.
The EPA reserves the right to partially fund submissions by funding discrete activities,
portions, or phases of the proposed project. If the EPA decides to partially fund the
proposed project, it will do so in a manner that does not prejudice any applicants or affect
the basis upon which the proposed project, or portion thereof, was evaluated and selected,
and that maintains the integrity of the selection/evaluation process.
PROPOSAL AND SUBMISSION INFORMATION
Eligibility Information
All federally-recognized tribes and tribal consortia in Region 6 are eligible to receive funding
under this grant opportunity. A Tribal Consortia is defined as a partnership between two or more
tribes authorized by the governing bodies of those tribes to apply for and receive assistance under
the particular the EPA grant program.
Eligibility Activities
Section 103 of the CAA serves as the tool used to support short term projects aimed at conducting
and promoting the coordination and acceleration of research, investigation, experiments,
demonstrations, surveys, and studies relating to the causes, effects (including health and welfare
effects), extent, prevention, and control of air pollution. In the past, these activities have included
emissions inventory of air pollution sources, air quality monitoring baseline studies, training, and
community education and outreach projects. The tribes are not required to match any funds for a
103 grant.
Applicable Code of Federal Domestic Assistance (CFDA) number is: 66.038
Page 11 - December, 2015
-------
Section 105 of the CAA serves as the tool for implementing programs for the prevention and
control of air pollution or implementation of national primary and secondary air quality standards.
A partial match of funds may be required for a 105 grant.
Applicable Code of Federal Domestic Assistance (CFDA) number is: 66.001
Proposal Requirements
Applicants are required to submit proposals containing:
1. Cover Page
2. Narrative Workplan
3. Budget Narrative
4. Position Descriptions
Workplan Elements
Each project narrative proposal should include the following components to demonstrate that a
successful project or program will be achieved:
1. Cover Page: Include the following information:
a. Project Title.
b. Project Manager:
c. Total Project Cost:
d. Project Period:
e. Type of Grant:
2. Narrative Workplan:
Identify title of your project.
Identify who will serve as the principal party responsible for
accomplishing the activities outlined in the workplan.
Specify total cost of the project (U.S. EPA funding and cost
share). Also, identify funding from any other source that may be
contributing financial support.
Provide beginning and ending dates. Funds will only be
available to begin project/program activities on or after, October
XX, 20XX and end no later than, September XX, 20XX.
Indicate which authority (Section 105 or 103) your
tribe/organization is applying for.
The narrative workplan must explicitly describe how the proposed project meets the
Evaluation Criteria as describe in this document. Do not make assumptions that reviewers
are familiar with your situation or expectation. Refer to the Tribal Menu of Options
(www3.epa.gov/region5/air/tribes/tribal-air-grant-framework-201508.pdf) for further
information on developing workplans involving air components.
a. Project Description: Illustrate the need for the project/program. Please include the
following elements in the Project Description:
Page 12 - December, 2015
-------
i. Problem Statement:
Provide a well supported statement or needs assessment of the problem to be
addressed which demonstrates the reason your tribe should receive funding
support.
ii. Objectives:
Identify the project/program objectives. Objectives should be specific,
measurable, and clearly describe how they are related to and lead to the
project/program goals and expected environmental results or show a link to the
health benefit of the tribal community.
iii. Project Activities (Tasks and Methods):
Outline in detail the necessary tasks that will be conducted to accomplish the
objectives. Describe why you have chosen these activities to obtain the desired
environmental results. The tasks and methods should be realistic and achievable
within the budget and project period of the grant.
iv. Specific Environmental Outputs:
Identify the specific outputs; Deliverables of an environmental activity, effort,
and/or associated work product related to an environmental goal or objective,
which will be developed over a period of time or by a specified date. Outputs
may be quantitative or qualitative but must be measurable during an assistance
agreement funding period. For example, an emissions inventory and raw and
summarized air monitoring data.
v. Desired Environmental Outcomes:
Articulate the desired environmental outcomes; the result, effect or consequence
that will occur from carrying out an environmental program or an activity that is
related to an environmental or programmatic goal or objective. Outcomes may be
environmental, behavioral, health related or programmatic in nature, must be
quantitative, and may not necessarily be achievable within an assistance
agreement funding period. For example, "Significant number of community
members with increased awareness of Indoor Air Quality issues," or "Increased
number of tribal residents breathing cleaner air."
vi. Target Dates & Milestones:
Include an estimated time-line or schedule of expected target dates and
milestones to achieve specific tasks and accomplishments during the budget and
project period.
vii. Performance Measures:
Provide a detailed explanation of how the project/program shall be evaluated
(through quantitative means, if possible). Applicants should develop criteria to
evaluate progress and results. Evaluation should occur during as well as after the
project/program activities are conducted to make sure appropriate adjustments
can be made along the way, if necessary. For example, if you are conducting
Page 13 - December, 2015
-------
inspections for mold, provide a target number of residences/community buildings
that you plan to perform each quarter.
viii. Program Manager/Contactfs):
Identify all individuals or parties who will be involved in the project/program
activities, and a description of their respective roles/responsibilities.
b. Funding Requested: Specify the type of statutory authority (Section 103 or Section
105) and amount you are requesting from the EPA. Also include any recipient cost
shares/matching as is required with Section 105 funding; 40% match for applicants
without TAS eligibility and 5% (ultimately 10%) match for those who have been
approved for TAS prior to solicitation deadline. For Section 105 (programmatic)
workplans, include a description of how the project activities may be sustained beyond
the life of funding.
c. Quality Assurance: If the project/program involves environmentally related
measurements or data generation, a Quality Assurance Project Plan (QAPP) is
required. If the grantee has an EPA approved QAPP, reference this, or assert that the
plan will be developed before any data is generated and/or analyzed.
d. Reporting Requirements: Discuss your commitment to provide quarterly reports, and
a detailed follow-up final report. Applicants are further required to make Commitment
to share all data collected with the EPA for assessment on a regional level.
i. Quarterly Reports:
Include a description of the progress status in meeting environmental outputs and
outcomes on a quarterly reporting basis, project/program assessment, and
submission of short data summaries. Region 6 will establish a reporting schedule
upon approval for funding.
ii. Final Report:
The final report should include a summary of the project, advances achieved
applicable to environmental outputs and outcomes, and costs of the project. In
addition, the final success, lessons learned from the demonstration project that
could help overcome structural, organizational or technical obstacles to
implementing a similar project elsewhere.
NOTE: All ambient, emissions, and compliance data obtained through the use of these funds
shall be entered in the corresponding national data base (i.e. National Emissions Inventory and
Air Quality System). This data is available to the general public. TEISS software is available to
the tribes from the Institute for Tribal Environmental Professionals (ITEP)
http://vvvvvv.nau.edu/itep.
3. Budget Narrative:
Provide a detail itemized budget proposal, including a narrative statement justifying the
expenses for each of the following categories being performed within the grant/project
period.
Page 14- December, 2015
-------
a. Personnel:
Indicate salaries and wages, by job title of all individuals who will be supplemented
with these funds.
For Example - 1 FTE (100%)
Air Quality Specialist @ $XXX/wk (x) 52 weeks = $ XX,XXX
or
Air Quality Specialist @ $XX/hr (x) 40 hrs/wk (x) 52/wks = $ XX,XXX
TOTAL = $ XX.XXX
b. Fringe Benefits:
Indicate all mandated and voluntary benefits to be supplemented with these funds.
For Example -
Health Insurance - (1 FTE) @ $35/month (x) 12/months = $ XXX
Dental - (1 FTE) @ $40/month (x) 12/months = $ XXX
TOTAL = $ XXX
c. Travel:
Indicate the number of trips to be taken, number of individuals travelling (per trip),
destination, and reason for travel.
For Example -
Trip #1 - TEISS Training (Dallas, Texas)
Air Fare - 1 FTE (x) $750 = $ XXX
Per Diem - 1 FTE (x) $43 (x) 3 days = $ XXX
Hotel - 1 (FTE) (x) $100/night (x) 2 nights = $ XXX
Trip #2 - Air Monitoring Conference (Dallas, Texas)
Local Travel Mileage - 200 miles (x) $0.55 = $ XXX
TOTAL = $ X.XXX
d. Equipment:
The EPA regulations defines "equipment" as items costing $5.000 or greater. Identify
items to be purchased such as air quality related instruments used in support of
workplan objectives and provide an estimated cost for each.
For Example -
(1) Ozone Monitor - $ X.XXX
(1) Ozone Analyzer - $ X.XXX
(2) PM 2.5 Monitor ($5,000 or more per unit) - $ X.XXX
TOTAL = $ XX.XXX
Page 15 - December, 2015
-------
e. Supplies:
Indicate any items to be purchased and used in support of air project/program
workplan objectives.
For Example -
(1) General Office Supplies (pens, notebooks, paper-clips, computer
printer ink, and paper) -
$xxx
TOTAL = $XXX
f. Contractual:
Indicate any proposed contractual items that are reasonable and necessary to carry out
the workplan objectives. Examples of contractual items include sample analysis, and
rental or lease of property being utilized in support of workplan objectives.
For Example -
(1) ABC Lab - Ozone Analysis (52 samples @ $100) = $ XXX
TOTAL = $ XXX
g. Other:
Indicate general (miscellaneous) expenses necessary to carry out the objectives stated
in the workplan.
For Example -
(1) Outreach Materials (brochures/pamphlets, etc.) - $ XXX
(2) Office needs (postage, phone, fax, etc.) - $ XXX
TOTAL = $ XXX
h. Total Direct Costs:
Summary of all costs associated with each object-class category.
TOTAL = $ XX.XXX
i. Total Indirect Costs:
The tribe/organization must provide documentation of a federally approved indirect
cost rate (percentage) reflective of proposed project/grant period. Applicant should
indicate if the tribe/organization is in negotiations with appropriate federal agency to
obtain a new rate.
For Example -
(IDC Rate - 16% of Total Direct Costs) = $ X.XXX
TOTAL = $ X.XXX
j. Total Costs:
Indicate overall figure of all direct and indirect costs.
For Example -
TOTAL BUDGET = $ XX.XXX
k. Position Descriptions:
Provide a description of the role/responsibilities required for each of the position(s) to
be supplemented with these grant funds.
Page 16 - December, 2015
-------
Confidential Business Information (CBI): In accordance with 40 CFR 2.203, applicants may
claim all or a portion of their application/proposal as confidential business information. The EPA
will evaluate confidential claims in accordance with 40 CFR Part 2. Applicants must clearly mark
applications/ proposals or portions of applications/proposals they claim as confidential. If no
claim of confidentiality is made, the EPA is not required to make the inquiry to the applicant
otherwise required by 40 CFR 2.204 (c) (2) prior to disclosure. Note that under Public Law No.
105-277, data produced under a grant award are routinely available under the Freedom of
Information Act.
Evaluation Criteria
Region 6 recognizes that each tribe/consortia is unique and is at a different stage in developing an
air program. The funding priorities listed below, therefore, are meant to allow for the varied
projects and priorities that individual tribes have, while still emphasizing overall regional goals
throughout Indian country. For example, refer to the Tribal Menu of Options at
http://www3.epa.gov/air/tribal/pdfs/thetribalairgrantsframework menuofoptionsOQ 29 15.pdffor
further guidance on developing workplans involving air components.
1. Project Overview (Various Types of Programmatic/Project Opportunities):
Each proposal will be evaluated to determine if it meets one of the following:
a. Proposal identifies a significant air pollution problem relating to a specific source
of pollutant such as:
• Recorded health related complaints to a tribal office,
• Suspected or documented pollution problem from a specific source,
• Lack of air emissions inventories,
• Demonstrated high levels of air pollution relative to national standards and/or
regional and local levels, or
• Need for monitoring or other method of air quality assessment,
If the project described has already achieved 3 years of monitoring or has
generated sufficient data, Region 6 will re-evaluate the project to determine if
further monitoring is warranted.
b. Proposal demonstrates that the tribal government has a long term commitment to
development and implementation of an air program. This may be demonstrated by:
• Developed or developing air code or regulations for tribal lands,
• CAA program delegations or authorizations,
• Plans to submit a partial or whole Tribal Implementation Plan for approval,
• Developed or developing pollution prevention strategies, or
• Fostering government to government relationships through partnering and
outreach activities.
Page 17 - December, 2015
-------
c. The proposal demonstrates that the tribal government/consortium participates in
environmental policy and planning through National/Regional/Tribal workgroups
or organizations (i.e., the National Tribal Air Association, TECO, IRAC, RTOC,
CAAAC, RPOs) and disseminates relevant information to other Region 6 tribes.
Additionally, the proposal demonstrates a commitment to providing assistance to
the tribal government members of their consortium.
2. Workplan Review:
Proposals will be evaluated based on applicant's ability to demonstrate reasonable and
achievable goals and objectives, including specific outputs (deliverables) and outcomes
(overall environmental impact). All grant work plans must include well defined outputs
and, to the extent practicable, well-defined outcomes (reference the EPA Order 5700.7A1
- Environmental Results Policy at: http://www.epa.gov/grants/epa-order-environmental-
results-under-epa-assistance-agreements). Applicants must discuss anticipated
environmental outcomes and outputs in proposed work plan objectives and performance
measures.
Expected environmental outcomes mean the result, effect or consequence that will occur
from carrying out an environmental program or activity that is related to an environmental
or programmatic goal or objective. Outcomes may be environmental, behavioral, health
related or programmatic in nature, must be quantitative, and may not necessarily be
achievable within an assistance agreement funding period. For example, outcomes may
include, but are not limited to, "significant number of community members with increased
awareness of Indoor Air Quality issues" and/or "increased number of tribal residents
breathing cleaner air."
Expected environmental outputs (or deliverables) refer to an environmental activity,
effort, and/or associated work products related to an environmental goal or objectives, that
will be produced or provided over a period of time or by a specified date. Outputs may be
quantitative or qualitative but must be measurable during an assistance agreement funding
period. Examples of environmental outputs may include, but are not limited to, an
emissions inventory, air monitoring data, or identification of a particular number of
residences/community buildings that will receive indoor air quality inspections.
Evaluators will determine the proposal's ability to illustrate the need for the project
or program through the following:
a. Problem Statement(s) identifying the needs assessment to be addressed through
project or programs grant assistance agreement.
b. Objectives which are specific, measurable, and clearly describe how they are
related to and lead to the project or program's goals and expected environmental
results, as well as "public" benefit applicants are seeking to obtain.
c. Project Methods, outlining in detailed, the specific tasks and activities necessary
to accomplish the objectives as outlined in the proposed workplan.
Page 18 - December, 2015
-------
d. Environmental outputs identifying the work products and deliverables resulting
from the activities to be accomplished during the grant's project period.
e. Environmental outcomes identifying the overall environmental impact resulting
from the activities to be accomplished in relation to this grant in conjunction with
previous and future efforts.
f. Timeline indicating estimated target dates and milestones anticipated to be
accomplished during the budget and project period.
g. Performance measures explaining how the project or program will be evaluated
during and after the project.
h. Cost effectiveness for funding the greatest environmental benefit to improve or
sustain tribal culture, (i.e. why fiscal resources should be awarded in support of
this tribe's project or program.)
To aid your tribe/consortium in the development of a thorough proposal, you may utilize the
checklist provided in Appendix E. This checklist is a nonexclusive list of key questions for your
tribe/consortium to consider when developing an air quality proposal and is not meant to serve as
a funding decision matrix or document.
3. EPA Strategic Plan Linkage and Anticipated Outcomes/Outputs:
Evaluators will determine the proposal's ability to illustrate the effectiveness of
applicant's plan for tracking and measuring progress toward achieving expected outputs
and outcomes.
In keeping with the mission of protecting human health and the environment, the EPA
requires that proposed grant activities be linked to the goals and objectives in the EPA's
Strategic Plan (http://www.epa.gov/sites/production/files/2015-
04/documents/overview to fv 16-17 npm guidances 4 20 15.pdf). For example,
proposed activities related to ambient air (outdoor) projects and programmatic activities fit
within Goal 1 - Clean Air and Global Climate Change and Objectives 1.1 Healthier
Outdoor Air, 1.1.1 More People Breathing Cleaner Air and 1.1.2 — Reduced Risk from
Toxic Air Pollutants. Proposed activities related to indoor air projects and programmatic
activities fit within Goal 1 - Clean Air and Global Climate Change and Objective 1.2 -
Healthier Indoor Air. Finally, proposed activities related to enforcement concerns in
Indian country fall within Goal 5 - Compliance and Environmental Stewardship and
Objective 5.3 Build Tribal Capacity.
4. Programmatic Capability:
The EPA will evaluate the applicant's programmatic capability to perform the work in the
proposal. This evaluation includes consideration of applicant's:
Page 19 - December, 2015
-------
a. Past performance in successfully completing federally and/or non-federally funded
projects similar in size, scope, and relevance to the proposed project or program
activities; and
b. Tribe/Consortium's history of meeting reporting requirements on prior or current
assistance agreements with federal and/or non-federal organizations and submitting
acceptable final (technical/programmatic) reports.
NOTE: Region 6 will make determinations based on previous working relationships, as well as
consider information from other sources including agency files. If your tribe/consortium has no
history of administering a grant assistance agreement with the EPA, you may provide a short
narrative indicating your ability to achieve the objectives of your workplan.
SELECTION PROCESS
Region 6 project officers and technical staff with knowledge of air quality management elements,
located in the Multimedia Planning and Permitting Division, Air Branch, will review proposals
submitted and provide recommendations to senior management acknowledging whether an
applicant's proposal should be considered for approval or denial of available funding.
AWARD NOTIFICATION
Region 6 will notify both successful and unsuccessful applicants in writing. Applicants selected
for approval will have an opportunity to negotiate (minor) elements of their workplan and budget
narrative after final applications are submitted.
APPLICATION PACKAGE FOR APPROVED PROPOSALS
Applicants whose proposals are selected for funding will need to submit one original completed
and signed federal grant application package, which may be downloaded from the EPA's Office
of Grants and Debarment website at: http://www.epa.gov/grants/how-applv-grants.
A complete application for selected proposals must contain the following forms and
documentation:
1. SF-424 Application for Federal Assistance, with original signature;
2. SF-424 A (Budget by Categories and Indirect Cost Rate);
3. SF-424 B (Assurances for Non-Construction Programs);
4. EPA Form 4700-4 (Pre-award Compliance Review Report);
5. Certification Regarding Lobbying;
6. Copy of Negotiated Indirect Cost Rate Agreement, if applicable;
7. Standard Form LLL (Lobbying), if applicable;
8. Key Contacts Form;
9. Workplan (including a Cover Page, Narrative Workplan, and Budget Narrative); and
10. Quality Assurance Narrative Statement, if applicable.
NOTE: The EPA reserves the right to negotiate appropriate changes in workplans after the
selection process and before final award of assistance agreement. The notification, which advises
Page 20- December, 2015
-------
that the applicant's proposal has been selected and is being recommended for award, is not an
authorization to begin performance. The assistance agreement signed by the EPA award official is
the authorizing document and will be provided by postal mail. At a minimum, this process can
take 60 days from the date the final application is received by the EPA.
Application Submission: Final Applications, if selected, should be submitted through
www.grants.gov by the date specified in the notification of proposal
status correspondence (which will be sent via an email from the
project officer to the applicant.
The electronic submission of your application must be made by an
official representative of your institution who is registered with
Grants.gov and is authorized to sign applications for Federal
assistance. For more information on the registration requirements
that must be completed in order to submit an application through
grants.gov, go to www.grants.gov and click on "Applicants" on the
top of the page and then go to the "Get Registered" link on the page.
If your organization is not currently registered with Grants.gov,
please encourage your Tribal leader to designate an Authorized
Organization Representative (AOR) and ask that individual to
begin the registration process as soon as possible.
Please note, the registration process also requires that your
organization have a DUNS number and a current registration with
the System for Award Management (SAM) and the process of
obtaining both could take a month or more. Applicants must ensure
that all registration requirements are met in order to apply for this
opportunity through grants.gov and should ensure that all such
requirements have been met well in advance of the submission
deadline. Registration on grants.gov, SAM.gov, and DUNS number
is FREE.
Region 6 Contacts: Aunjanee Gautreaux
Project Officer
(214) 665-7127
gautreaux. auni anee@epa. gov
Donnett Patterson
Project Officer
(214) 665-7418
Patterson.donnett@epa.gov
Page 21 - December, 2015
-------
AIR
PROGRAM ACTIVITIES
Page 22 - December, 2015
-------
Air Program Activities
Air Quality Assessments for Monitoring
It is important to be aware of EPA's general environmental data quality assurance (QA)
requirements set forth in the EPA quality policy (www.epa.gov/irmpoli8/polices21060.pdf and
www.epa.gov/quality/qapps.html) as well as additional quality assurance requirements set forth in
ambient air monitoring regulations by the Office of Air and Radiation in order to compare
ambient air monitoring data to the National Ambient Air Quality Standards (NAAQS) (40 Code
Federal Regulations Part 58 and its associated appendices). This will assist the tribes with
compliance of the grant's technical requirements once a program begins. Before data collection
can occur, the following activities must be performed to ensure that the data meets applicable
Quality Assurance (QA) requirements, and is reported to the EPA Air Quality System (AQS)
database within the required timeframe.
•S Selection of Monitoring Site: Possible sites should be identified and proposed. There
should be coordination with the EPA Region 6 to select the final monitoring site that
satisfies the site location requirements of 40 CFR Part 58, Appendix E and that will
provide the data needed for the desired purpose.
•S Types of Pollutants: Ambient air monitoring is a specific data collection activity that
collects data for NAAQS, Hazardous Air Pollutants (HAPs), air toxics, etc. Most of the
tribal air monitoring projects in Region 6 to date have focused on tribal needs associated
with targeted ozone, particulate matter, and lead issues. For relevant NAAQS or criteria
pollutant information, see URL: http://www3.epa.gov/ttn/naaqs/criteria.html. HAPs or air
toxics are more complex, not only in environmental assessment, but in air monitoring
methods (see URL: http://www3.epa.gov/ttnamtil/airtoxpg.html). The goal, purpose, and
technical feasibility of the air monitoring project are critical considerations in determining
the needed support.
•S Timing of Monitoring: Upon grant approval, monitoring and data reporting is expected to
commence within an appropriate and agreed upon time period.
•S Quality Assurance: Appropriate quality assurance systems should be developed and
implemented for any air monitoring prior to commencement of the collection of data. The
development of a Quality Assurance Project Plan (QAPP) is defined and required by the
EPA's quality policy, see associated www.epa.gov./irmpoli8/policies/21060.pdf or
www.epa.gov/quality/qapps.html. The QAPP describes how the organization intends to
control measurement uncertainty to an appropriate level in order to achieve the objectives
for which the data are collected. If the objective of the monitoring site is to determine
compliance with the NAAQS, the QAPP must include all QA requirements identified in
40 CFR Part 58, Appendix A, including monitoring performance audits, checks, third
party audits, data processing documentation, data verification, data validation etc. Courses
and other assistance on a QAPP development are available through the Institute for Tribal
Environmental Professionals (ITEP) (http://www.nau.edu/itep).
Page 23 - December, 2015
-------
¦S Data: Monitoring results as well as the required monitoring systems performance audits
and checks should be reported to the EPA's Air Quality System (AQS:
http://www2.epa.gov/aqs) or the appropriate national database. Data should be reported
within 90 days of generation. Annual data certifications are required to be submitted on
May 1 of each calendar year. Data reported to the EPA's AQS should meet 75% data
completeness for each calendar quarter.
•S Quarterly Monitoring Reports: Quarterly reports should be prepared and submitted to
the grant project officer at EPA Region 6 and should
a) Identify all days where air monitoring concentrations exceeded the regulatory
comparison levels and any potential sources associated with that event.
Note: Comparison concentrations vary by criteria pollutant so refer to its respective
regulation;
b) Identify all days where the concentrations exceeded the respective standard, and
potential sources associated with that event; and
c.) Report on the completion of all routine calibrations, QA checks, and third party audits
of the monitor, as specified in the QAPP.
S Annual Monitoring Reports: The annual report should:
a) Identify all days where the concentrations exceeded the respective comparison levels
and the potential sources associated with that event;
b.) Identify all days where the comparison standard was exceeded and the potential
sources associated with that event; and
c.) Determine the relevant concentrations based on the data analysis for the full year of
collected data.
Note: Issues and problems in monitoring operations that may have caused the loss of data
should to be reported to the EPA Region 6 in a timely manner. Such losses should be
reported if there was a loss of 120 hours of data of it the loss will affect the goal of 75%
data completeness for the full year of monitoring.
S Monitoring Completion: Expectations regarding the length of the monitoring project
should be agreed upon by the tribe and the EPA. The length should be based on the
objective of the monitoring activity and subsequent data evaluation, and should be
articulated in the annual grant workplan. Any tribal monitoring should be assessed
annually to determine the need of continuation.
S Technical Support: Technical assistance is available from the following sources:
General information concerning the availability of air program grant support or request for
a technical contact can be obtained from a Region 6 Tribal Air Coordinator
(http://www.epa.gov/tribal)
Technology Transfer Website with updated technical information at:
http ://www3. epa. gov/ttn/amtic/
Institute for Tribal Environmental Professionals (ITEP) (http://vvvvvv.nau.edu/itep);
Tribal Air Monitoring Support Centers (TAMS) (http://vvvvvv7.nau.edu/itep/main/tams/);
tribal consortia such as the Inter-Tribal Environmental Council
http://www.itecmembers.org/). and private contractors.
Page 24- December, 2015
-------
Examples of Types of Ambient Air Monitoring Projects
Evaluation of Ambient Air Quality in Airshed:
• Considers Ambient Air Quality status in the Airshed/Area
• Uses Criteria Pollutant Regulatory Requirements/Guidelines
• May include Air Toxics and other Air Pollutants in Targeted Areas of Concern
National Ambient Air Monitoring Programs: CASTNet. NCore, mercury monitoring etc. These projects
are typically collaborations between OAQPS, Tribes and Regions with resources leveraged between
OAQPS and the Tribe.
In all cases the technical strength, i.e., connection with sources, potential population exposure, and
applicable ambient air monitoring requirements/regulations of the proposed monitoring project is
critical.
For a list of approved air monitoring methods for criteria pollutants see:
http://www3.epa.gov/ttnamtil/files/ambient/criteria/reference-equivalent-methods-list.pdf
T
Page 25 - December, 2015
-------
> Technical Guidance for the Development of Tribal Air Monitoring Programs; EPA-456/B-
07-002, August, 2007:
http://www3.epa.gov/ttn/caaa/tl/memoranda/techguidancetribalattch.pdf
> EPA Air Program Resources Website:
http://www3.epa.gOv/air/tribal/airprogs.html#ambmon
> URL for the EPA's The Tribal Air Grants Framework: A Menu of Options for Developing
Tribal Air Grant Work Plans and Managing Grants for Environmental Results, revised
2015:
http://www3.epa.gov/air/tribal/pdfs/thetribalairgrantsframework menuofoptions09 29 15.
pdf
> URL for the EPA's Office of Air Quality and Planning Standards Website:
http://www3.epa.gov/airqualitv/montring.html
> URL for the EPA's Technology Transfer Network Website: http://www3.epa.gov/ttn/
> URL for the EPA's Tribal Air: Tools and Resources Webpage:
http://www3.epa.gov/air/tribal/toolsresources.html
> URL for the EPA's Tribal Air: Tribe-to-Tribe Webpage:
http://www3.epa.gov/air/tribal/tribetotribe.html
> URL for the EPA's QA Handbook: http://www3.epa.gov/ttnamti 1/qalist.html
> URL's for the EPA's QAPP Guidance: http://www2.epa.gov/quality:
http://www2.epa.gov/qualitv/epa-qar-5-epa-requirements-qualitv-assurance-proiect-
plans.html; http://www2.epa.gov/qualitv/guidance-qualitv-assurance-proiect-plans-epa-
qag5
Page 26 - December, 2015
-------
Conducting a Air Quality Assessment for Monitoring
Background: Description of the major
characteristics of tribal lands including
geographical features, boundaries, area, types
of vegetation, and land use. Include a map of
the lands showing these features.
Data Summary. Summary of any past air
monitoring data collected on tribal lands using
EPA approved methods, and/or data collected
adjacent to tribal lands by a state or local air
agency.
Airshed Characterization: Description of the
airshed covering tribal lands. This should
include the topography, seasonal weather
patterns, population distribution, source
distribution, and any other factors affecting air
quality in the airshed.
*
Identification of Air Pollution Sources:
Identification of major (Title V) point sources on
tribal lands and their emission inventories. If
information is available, identify and estimate
emissions of area sources, residential sources
(woodstove, fire places), agricultural burning
sources, and mobile sources. Identify major
sources of air pollution outside of tribal lands
and describe how these sources may be
impacting air quality within tribal lands.
Conclusions: If needed, propose next steps for
further characterizing the air quality in each
airshed. If it appears that monitoring data is
needed, explain how the data collected will be
used to either: (a) further characterize the air
quality, (b) answer additional questions about
air quality, or (c) help to implement a control
strategy.
Summary Report: A summary report covering
the above elements as well as any further
justification for conducting monitoring, the type
of monitor considered most appropriate for the
purpose identified, and the probable location
for siting of such monitor to be able to best
serve its intended purpose(s). If possible, attach
a map with points relevant to the assessment
idendified.
*
Technical Guidance for the Development of Tribal Air Monitoring Programs;
http://www3.epa.gov/ttn/oarpg/tl/memoranda/techguidancetribalattch.pdf
Page 27 - December, 2015
-------
Creating an emissions inventory is a process in which air quality managers collect information on
the emissions for particular pollution sources within a specific area, such as a reservation or tribal
boundaries, to use in making planning and policy decisions.
It is important to note that an emissions inventory serves a different purpose than air quality
monitoring but may inform monitoring. An emissions inventory tells a tribe what sources are
emitting which pollutants into the air. Air quality monitoring samples the air to measure which
pollutants are present and in what amounts, but does not tell where the pollutants are coming
from. Emissions inventories and air quality monitoring are both valuable tools for identifying and
addressing air quality concerns on tribal lands, and the EPA Regional contacts and/or the
Regional Tribal Operations Ccommittee (RTOC) subcommittee members can help the tribes
decide where to start.
An Emissions Inventory Helps the Tribes Evaluate Air Quality
An emissions inventory can help a tribe understand air quality on its lands and whether an air
pollution control program is needed. A tribal emissions inventory can include information about
criteria air pollutants, hazardous air pollutants, greenhouse gases, major and minor point sources,
area sources, and mobile sources. The tribes may choose to complete an emissions inventories to
help:
Identify sources of air pollution and problem areas,
Track trends in air quality on tribal lands,
Measure progress toward air quality goals,
Establish a baseline for future planning for air quality management,
Determine the need for ambient air monitoring and to site monitors,
Take an active and constructive role in regional and national air quality planning
processes,
Demonstrate jurisdiction and capacity of the tribes to address air quality on tribal lands,
Establish a basis for developing on-reservation permitting programs,
Provide input for human health risk assessment studies, and
Improve the EPA's and the tribe's knowledge about air quality nationwide and potentially
be included in the National Emissions Inventory (NEI).
A tribal emissions inventory would include one year of emissions data for sources associated with
tribal lands. Sources of emissions could include:
point sources: large stationary sources of emissions that are identified individually in the
inventory, such as power plants and factories;
nonpoint (area) sources: smaller facilities or activities whose individual emissions do not
qualify them as point sources, such as dry cleaners, open burning, wood stoves, residential
hot water heaters, etc.;
off-road mobile sources: airplanes, trains, farm and construction equipment, marine
engines, and lawn mowers; and
on-road mobile sources: automobiles, trucks, buses, and motorcycles.
Emissions inventories are the fundamental building block of an air program. They indicate what is
the baseline or starting point for assessing the status of a source's or area's air quality programs.
Page 28 - December, 2015
-------
A high quality emissions inventory provides the information needed to determine the type and
extent of controls that may be required. The inventory assists in the formulation of control and
maintenance strategies. Inventories are also indirect indicators of overall air quality changes.
Inventories also give perspective on the nature of air quality problems, i.e., whether the problems
are the result of emissions from point, area, or mobile sources, and what specific sources may
need to be targeted. It is difficult to plan and implement a meaningful and successful air quality
program without the benefit of a good emissions inventory.
Pollutants of Concern
The pollutants that are addressed in tribal emissions inventories usually fall into two general
categories: criteria air pollutants (CAPs) and hazardous air pollutants (HAPs).
The Clean Air Act (CAA) requires the EPA to set National Ambient Air Quality Standards for six
common air pollutants. These commonly found air pollutants (also known as "criteria pollutants")
are found all over the United States. The criteria pollutants include: particle pollution (often
referred to as particulate matter or PM), ground-level ozone (O3), carbon monoxide (CO), sulfur
oxides (SOx or SO2), nitrogen oxides (NOx), and lead (Pb). These pollutants can harm human
health and the environment, and cause property damage including damage to agricultural crops
and livestock. The EPA calls these pollutants "criteria" air pollutants because it regulates them by
first developing human health-based and/or environmentally-based criteria (science-based
guidelines) for setting permissible levels, and then by setting standards for the maximum
concentration of the criteria pollutants in the ambient air. Those standards are known as National
Ambient Air Quality Standards (NAAQS). The set of limits based on human health are called
Primary NAAQS. Another set of limits intended to prevent environmental and property damage
are called Secondary NAAQS.
Of the six criteria pollutants, particle pollution and ground-level ozone present the most
widespread human health threats. The EPA has established different NAAQS for particulate
matter of different sizes -one set of NAAQS for particulate matter less than 10 microns in
diameter (PM10) and another set of NAAQS for particulate matter that is less than 2.5 microns in
diameter (PM2.5).
In preparing tribal emissions inventories for criteria pollutants, it is important to note that not all
fine particle pollution (PM2.5) and very little ozone is emitted by sources. These pollutants,
especially ozone, are generally formed in the atmosphere by photochemical reactions of other,
precursor pollutants that are emitted by sources. For example, the precursor pollutants that react in
the atmosphere to form ozone are nitrogen oxides and volatile organic compounds (VOCs).
Precursor pollutants for fine particulate matter can include nitrogen oxides, sulfur oxides, VOCs,
and ammonia. For this reason, emissions of ammonia and VOCs are often included in emissions
inventories of criteria pollutants.
Hazardous Air Pollutants (HAPs), also known as toxic air pollutants or air toxics, are those
pollutants that cause or may cause cancer or other serious health effects, such as reproductive
effects or birth defects, or adverse environmental and ecological effects. The 1990 amendments to
the CAA identified 189 specific chemicals or classes of chemicals as HAPs and required the EPA
to identify primary sources of these pollutants and develop regulations to reduce their emissions.
The EPA has the authority to modify the list of HAPs by adding or deleting specific chemicals;
Page 29 - December, 2015
-------
currently there are 187 listed HAPs. Examples of HAPs include benzene, which is found in
gasoline; perchlorethlyene, which is emitted from some dry cleaning facilities; and methylene
chloride, which is used as a solvent and paint stripper by a number of industries. One of the
criteria pollutants, lead (and compounds of lead), is also a hazardous air pollutant.
More information on CAPs is available at the following websites: http://www3.epa.gov/ttn/naaqs/
and http://www3.epa.uov/airqualitv/urbanair/. More information on HAPs is available at the
EPA's Air Toxics Website: http://www3.epa.uov/ttn/atw/al 1 about.htm 1.
Each tribal emissions inventory should be tailored to the needs of the tribe that creates it. A tribal
emissions inventory could include only major sources and criteria pollutants, or a tribe might
choose to inventory just hazardous air pollutants or area sources. The tribes can also use an
emissions inventory to collect information about sources of greenhouse gas emissions. Each tribe
should determine the best scope for its inventory.
National Emissions Inventory (NEI)
The EPA Office of Air Quality Planning and Standards (EPA OAQPS) uses the data from
individual emissions inventories submitted by state, local, and tribal governments to compile the
National Emissions Inventory (NEI).
Features of the NEI
• Lists sources and what was emitted for one year.
• Covers the entire United States.
• Includes criteria air pollutants and hazardous air pollutants.
• Compiled every third year (2005, 2008, 2011, etc).
• Created from data submitted through the Emissions Inventory System (EIS).
Under the Tribal Authority Rule the tribes are not required to develop an emissions inventory or
submit it to the EPA OAQPS for the NEI, but the EPA strongly encourages the tribes to do so.
The tribes also are not required to meet a due date for submitting an emissions inventory, so they
may miss the deadline for inclusion in the NEI. However, the EPA OAQPS will accept and store
all data submitted since the data is useful as a starting point for local planning, more refined air
quality analysis, and future versions of the NEI.
How Complex Should a Tribal Emissions Inventory Be?
The level of complexity for a tribal emissions inventory should be based on the purpose for
conducting the EI. Volume 6, Chapter 2, of the Technical Report Series prepared for the EPA's
Emissions Inventory Improvement Program discusses four levels of complexity for emissions
inventories (see pages 2.1-5). The emissions inventory levels and purposes, increasing order of
complexity, are:
Level 4: developed from existing data sources for informational purposes. Level 4 inventories
are usually compiled from previously published emissions data.
Level 3: used for general assessments or research. Level 3 inventories may include data
gathered from specific sites but generally are not detailed enough to directly support
rulemaking activities.
Page 30 - December, 2015
-------
Level 2: used for strategic decision making. Level 2 inventories are usually detailed enough to
directly support decision-making and setting of standards, such as development of State
Implementation Plans (SIPs) and air quality standards. Site- or region-specific information is
generally required; and
Level 1: supports enforcement, compliance, or litigation activities. Level 1 inventories require
the highest degree of defensibility and are based on very detailed, site-specific data. The
results of Level 1 inventories can be used directly in enforcement actions or litigation support
if sufficient in scope.
Page 31 - December, 2015
-------
Steps to Create an Emissions Inventory
The Tribal Emissions Inventory Software Solution (TEISS) is free to all federally recognized
tribes and was designed specifically to help the tribes develop emissions inventories. The TEISS
is a software program that helps tribal air professionals calculate, organize, store, and report on air
pollution emissions on tribal lands. The TEISS provides guidance on what type of data to enter,
conducts calculations and unit conversions, and creates clear reports and maps for analysis. The
TEISS was developed by Lakes Environmental, Inc. for the Institute for Tribal Environmental
Professionals (ITEP) at Northern Arizona University, in partnership with the tribes, the EPA, and
the Western Regional Air Partnership (WRAP).
There are 5 basic steps for the tribes to create an emissions inventory using the TEISS.
Step 1: Plan the inventory
• Use the TEISS to complete an Inventory Preparation Plan (IPP). If the tribe received an
EPA grant for the emissions inventory, the tribe is required to complete a Quality
Assurance Project Plan (QAPP). A Quality Assurance Project Plan (QAPP) describes the
activities of an environmental data operations project involved with the gathering of
environmental information whether generated from direct measurements activities,
collected from other sources, or compiled from computerized databases and information
systems. The QAPP documents results of a project's technical planning process, providing
in one place a clear, concise, and completed plan for the environmental data operation and
its quality objectives and identifying key project personnel.
It is the EPA policy that all work funded by the EPA in which environmental data will be
collected, evaluated, used, or reported (including the use of existing data and modeling), or
which involves the design, construction, and operation of environmental technology, have
approved the QAPP, or equivalent documents as defined by the EPA's Guidance for
Quality Assurance Plans (EPA QA/G-5) or similar quality description. For further
information, please reference www.epa.gov/quality or you may reference ITEP's website
at: http://vvvvvv.nau.edu/itep
• The tribe can use the IPP as the basis of the QAPP, which the EPA requires to ensure that
data collected is valid and can be relied upon for its intended purpose. The tribe should
work on developing an EPA-approved QAPP with the EPA Tribal Air Coordinator.
• Identify the purpose, geographic boundary, and time period of the inventory.
• Identify the sources and pollutants of interest to the tribe. Previous emissions inventories,
the NEI, the TRI, and other sources of information on emissions from industrial sources
can be used to develop a list of emissions sources.
Step 2: Collect data to estimate emissions
• Gather detailed information about sources and what they emit. Sources of data can include
reports from the sources, data from other inventories such as the NEI or a state inventory,
air permits, TRI reports, questionnaires, etc.
Page 32 - December, 2015
-------
Step 3: Enter data into the TEISS
• Use the TEISS to calculate emissions estimates for each source and organize the results.
• Analyze what the results show about air pollution and its impact on the tribal community.
Step 4: Apply quality assurance/quality control (QA/QC) procedures
• Document all data collection efforts and calculations.
• Use the TEISS to document the emissions estimating methods.
Step 5: Write a summary report on the results organized in the TEISS
• Submit the report to the EPA Regional Office (if this was a requirement under a grant)
and/or the Institute for Tribal Environmental Professionals (ITEP) for review.
• Receive feedback from the EPA Regional Office and/or the ITEP so the report can be
finalized.
• Provide the final report to tribal leaders for use in setting tribal environmental priorities.
• Publish the emissions inventory results for the community to access.
• File the report internally so the tribe can use it as a starting point when the emissions
inventory needs to be updated.
* EPA encourages the tribes to add Step 6.
Step 6: Submit the emissions inventory to the EPA OAQPS for the NEI.
• Transmit data to the EPA OAQPS through the Emissions Inventory System (EIS).
Some tribes may have agreed to submit an emissions inventory to an EPA Regional Office under
the terms of a grant, but Regions do not submit tribal emissions inventories to OAQPS for the
NEI. A tribe can submit an emissions inventory to the OAQPS for the NEI on its own, or the
ITEP can submit the emissions inventory on the tribe's behalf. All submissions for the NEI must
be formatted in the Consolidated Emissions Reporting Schema (CERS) and submitted to the
OAQPS through the new Emissions Inventory System (EIS). The TEISS will be updated to be
compatible with the EIS.
The tribes should set a schedule for updating and maintaining the emissions inventory in the
TEISS as a reference for future air quality management planning. The EPA also encourages the
tribes that have an older, paper-only emissions inventory on file to enter the data into the TEISS.
Having the older data in the TEISS will give the tribe a head start on updating future inventories.
Help is Available
The ITEP can provide technical assistance, including QA and TEISS help. Most EPA Regions
also have technical resources available to the tribes for review and QA of emissions inventories.
The ITEP contact is Angelique Luedeker (Angelique.Luedeker@nau.edu); phone number: (928)
282-8101. For technical assistance from the EPA's Region 6 Office, contact Carl Young
(Young.Carl@epa.gov); phone number (214) 665-6645.
Page 33 - December, 2015
-------
Learn More with Online Training
The EPA recommends two online courses to tribal air professionals interested in completing an
emissions inventory.
Beginner course
This session is designed for individuals with no knowledge or limited knowledge of completing
an emissions inventory. This course is hosted on the EPA's Air Pollution Training Institute
website at http://www.apti-learn.net.
Intermediate course
This session is for tribal air professionals and others interested in learning how to use the TEISS
to complete an emissions inventory. The TEISS is available at no cost to all federally recognized
U.S. Indian Tribes. The training helps a tribe choose the type of emissions inventory that best
suits its needs. This course is hosted on the ITEP website at http://www.nau.edu/itep
Note: This training remains the best resource for learning to use the TEISS during the EPA's
transition to the Emissions Inventory System (EIS) in 2009. The EIS is the system that state, local,
and tribal governments will use to report data to the EPA OAQPS for the NEI.
Other Resources
The tribes can consult these resources for additional information on emissions inventories.
For technical information
• EPA's Clearinghouse for Inventories and Emissions Factors (CHIEF)
http://www3 .epa.gov/ttn/chief/
• ITEP resource page (includes information on how to get the TEISS)
http://www.nau.edu/itep
For grant information
• Tribal Air Grants: A Menu of Options at
• http://www3.epa.gov/air/tribal/pdfs/thetribalairgrantsframework menuofoptionsOQ 29 15.
pdf
Page 34 - December, 2015
-------
EI Flowchart
Plan for EI
• ID key issues
• Describe inve
• Contrast estir
• Describe type
ntory approach
nation approach
s of emissions
r
Prepare Inventory Preparation Plan (IPP)
> Determine intended use of data
> Determine time period, geographic and pollutants
> Determine usefulness of existing data
> Determine how data is collected and managed
> Determine how data will be QC'd
Start Your EI
Develop Inventory Work Plan
and QA plan
Identify data Source
' NEI Tribal
> Dept of Transportation
> Dept of Agriculture
> Census Bureau
Data Collection
Reporting
T
Complete Inventory Includes:
• Contact each point source
• Conduct survey
questionnaire
• Interview plant personnel
• Review Drocess schematics
Concurrent
• Inventory Guidance
• Existing emissions data
• Emissions factor resources
• Models resources
• Description of process, operating
parameters, equipment used, emissions
generated and type of output
'
Submit completed EI to EPA Region 6 for
review
Submit completed EI to NEI (ITEP)
Enhanced inventory report to NEI
1
Helpful Links:
http://www.nau.edu/itep
http://www.apti-learn.net
http://www3.epa.gov/ttn/chief/
http://www3.epa.gov/ttnchiel/conference/eil2/tribal/richards.pdf
http://www3.epa.gov/air/tribal/pdfs/thetribalairgrantsframework menuofoptions09 29 15.pdf
Page 35 - December, 2015
-------
Air Permitting Programs
Title V Permits
A Title V permit consolidates all air pollution control requirements into a single, comprehensive
"operating permit." The regulations for Title V permits issued by states and tribes with approved
programs are found at 40 CFR Part 70, and the regulations for federally-issued permits and permits
issued by tribes that take delegation of the federal permits program are at 40 CFR Part 71. The
permit covers all aspects of a source's year-to-year air pollution activities which include monitoring,
recordkeeping and reporting requirements for compliance with all emissions limits and standards.
40 CFR 70.6(a)(3). The program is designed to make it easier for sources to understand and comply
with control requirements by putting all applicable requirements in one document, and results in
improved air quality. Generally, operating permits must be renewed every five years or earlier if
there are any changes to the facility or for incorporation of new applicable requirements. A Title V
permit is required by:
• Sources that have a Potential to emit (PTE) of 100 TPY or more of any regulated air
pollutant, [See http://www.epa.gov/title-v-operating-permits for additional information];
• Sources that have a major source permit under (PSD or NA NSR);
• Sources in nonattainment areas with the PTE at or above certain TPY;
• Sources that are major for HAP (CAA Section 112) that have >10 TPY or more of any
given HAP pollutant (40 CFR Part 63), cumulative >25 TPY or more HAP, or a lesser
quantity of a given pollutant, if the Administrator so specifies;
• Any other source, including an area source, subject to HAP standard under Section 112;
• Sources that have an applicable (CAA Section 111) New Source Performance Standard
(NSPS);
• Affected sources under the acid rain provisions of Title IV; and
• Any other stationary source in a category the EPA designates, in whole or in part by
regulation, after notice and comment.
The Title V Operating Permit Program gives the public an opportunity to review and comment on
the proposed operating permit, the ability to petition the EPA, and the ability to track compliance
by reviewing reports and certifications.
For further information, please reference the following websites:
The Clean Air Act Amendments (CAAA) website: http://www.epa.gov/air/caa/
Title V Operating Permits can be found on the EPA Website at:
http://www.epa.gov/title-v-operating-permits
Guidance documents:
http://www.epa.gov/title-v-operating-permits/title-v-operating-permit-policv-and-guidance-
document-index
Page 36 - December, 2015
-------
Under the Tribal Authority Rule (TAR) [40 CFR Part 49], Subpart A, the tribes may develop and
submit for approval their own Title V Air operating permitting program. At present no tribe in
Region 6 has applied for nor received authorization for Title V Program. As a result the EPA
implements the program in Indian country.
The EPA encourages any tribe that is interested in applying for a Title V program to contact the
Region 6 Tribal Air Coordinator early to discuss the requirements and feasibility of obtaining
program authorization. In the early stages the EPA will assist a tribe with determining whether or
not such authorization is feasible and will work with the tribe to determine the best way to achieve
its desired goals.
For the Title V program, for example, feasibility will depend on a number of factors such as
location of the tribe (i.e. Oklahoma must comply with the Cooperative Agreement of the
SAFETEA-LU), and whether or not a tribe can develop a program that meets all requirements the
CAA.
New Source Review
The New Source Review (NSR) program requires new major sources, existing sources with major
modifications in both nonattainment areas and attainment areas, and new or modified minor sources
to obtain preconstruction permits. The definition of major stationary source and major modification
varies with the air quality status of the area and the type of pollutant. In general, major sources are
sources that emit over a certain amount of a pollutant (the "major source threshold for that
pollutant); minor sources are sources that emit less than that amount. A major modification means
any physical change in or change in the method of operation of a major stationary source that would
result in a significant net emissions increase of any pollutant subject to regulation under the CAA.
See Table I below for more information on major source thresholds.
As an example, in attainment and unclassifiable areas a major stationary source is defined as any
source that emits, or has the potential to emit, 250 tons per year (or, for specific types of sources,
100 tons per year) of any pollutant subject to regulation under the CAA. See Table II below for
more information. Serious particulate matter nonattainment areas and moderate, serious, severe,
and extreme ozone nonattainment areas have lower thresholds for determining a major source.
The NSR permit requirements are determined on a case-by-case basis. The permits specify
emissions limits and control requirements for each emissions point at a source, as well as the
monitoring, record keeping, and reporting requirements.
Page 37 - December, 2015
-------
Types of Preconstrucation Permits
Implementation of the federal NSR programs can be delegated to a tribe or approved under a
Tribal Implementation Plan (TIP). If a tribe does not adopt a NSR program, the EPA will
implement NSR for new and changing sources in non-reservation Indian Country. Both the major
and minor NSR programs focus primarily on the criteria pollutants regulated by the NAAQS. The
Tribal Minor NSR program cover additional pollutants, including many toxic air pollutants.
The core procedures in the major NSR programs are:
(a) evaluating the consequences of allowing facilities to construct or to modify;
(b) requiring the most appropriate emissions control measures for these facilities, and
(c) including informed public participation in the evaluation of consequences and selection
of emissions control measures.
The above procedures must occur before the construction or modification of a facility begins.
There may be additional requirements if emissions from a new PSD source or major PSD of
modification may affect a national park or wilderness area such as the evaluation the impact of
emissions on visibility and natural and cultural resources in the park or wilderness area.
Table below list the major source thresholds and the net emissions increases for
modifications at a source that would require a construction permit.
Page 38 - December, 2015
-------
Table I
Major and Minor Thresholds for NSR
ATTAINMENT
NONATTAINMENT
POLLUTANT
MAJOR SOURCE
MINOR
MAJOR SOURCE (tpy)
MINOR
(tpv)
SOURCE (tpy)
SOURCE (tpy)
Carbon Monoxide
(CO)
10
100 (moderate) 50 (serious)
5
Nitrogen Oxide
(NO,J
10
100 (marginaVmoderate) 50
(serious) 25 (severe) 10
(extreme)
5
Sulfur Dioxide
10
100
(502)
Volatile Organic
Compounds
(VOC)
5
100 (marginaVmoderate) 50
(serious) 25 (severe) 10
(extreme)
2
Total Particulate
Matter
10
100 (moderate) 70 (serious)
5
Particulate Matter-
10 microns or less
diameter (PM 10)
5
100 (moderate) 70 (serious)
1
Particulate Matter -
2.5 microns or less
diameter (PM2.5)
250 tpy or 100 tpy
if source is one of
28 source
categories listed in
40 CRF
3
100 (moderate) 70 (serious)
0.6
Lead (Pb)
0.1
100
0.1
Fluorides
1
Sulfuric Acid
52.21(b)(1)
o
Mist
L
Hydrogen Sulfide
2
Total Reduced
Sulfur (including
2
H2S)
Reduced Sulfur
Compounds
(including H2S)
2
Not Applicable
Municipal Waste
Combustor
2
Emissions
Municipal Solid
Waste Landfills
10
Emissions
Page 39 - December, 2015
-------
Nonattainment NSR Program (40 CFR § 49.166-49.175)
Numerous requirements in the CAA apply to new major sources and major modifications at
existing sources in nonattainment areas. For example, a facility must install control equipment
ensuring the Lowest Achievable Emissions Rate (LAER). The economic costs are not considered
when defining the applicable control technology to obtain LAER. The LAER is defined as the
more stringent of the following limitations:
(a) The most stringent emissions limitation contained in a Federal, tribal or state
implementation Plan for any permit for the same class or category of source (unless it is
demonstrated that this limitation is unachievable), or
(b) The most stringent emissions limitation achieved in practice.
Another requirement of the nonattainment NSR program is that increases in emissions from new
major sources and major modifications must be matched by equal or greater emissions eductions
from other sources (called "offsets"), thus ensuring that progress is made toward decreasing the
total emissions for the area and meeting the NAAQS. Nonattainment NSR programs must meet all
the requirements established in the Code of Federal Regulations (CFR) at 40 C.F.R. § 51.160-165,
and Title 1, Part D of the CAA. State air regulators have developed nonattainment NSR programs
which the tribes can use as models when developing their programs. Officials at the EPA Region
6 can also provide assistance and guidance. The NSR guidance documents are available at the
EPA at http://www.epa.gov/nsr/new-source-review-policv-and-guidance-document-index
PSD Permitting Program
The purpose of the Prevention of Signification Deterioration (PSD) permitting program is to
prevent air quality that is better or cleaner than the NAAQS from deteriorating and getting close
to or exceeding the NAAQS. If the air quality over tribal lands is currently better than the
NAAQS, a tribe may want to adopt a PSD permitting program which would allow for air quality
goals more protective than the NAAQS. The PSD permitting program applies to all new major
sources or major modifications of existing major sources in attainment and unclassifiable areas. A
major PSD source is a source that has a PTE of 100 TPY or more of a regulated NSR pollutant for
the 28 named categories or 250 TPY for all other sources. A major modification is defined as a
net increase in actual emissions that equal or are greater than the Significant Emissions Rate
(SER) in table III below.
Page 40 - December, 2015
-------
Table II
28 Named Category of Sources for PSD
1. Coal cleaning plants (with thermal dryers) 15, Coke oven batteries
2. Kraft |H(t)i ii*.
3. Portland cement plants
4. Primary zinc smellers
5. Iron and steel mis
6. Primary aluminum ore reduction plants
7. Primary copper smelters
21 Secondary metal production plants
18. Primary lead smellers
19. Fuel conversion plants
zu. wintering plants
18. Sulfur recovery plants
tT, Carbon btoek plants {furnace process)
8 Municipal incinerators capable of charging 22. Chemical process plants
more than 250 tons of refuse per day
9. Hydrofluoric acid plants
23. Petroleum storage and transfer units with a total
13, Lime plants
10. Sulfuric acid plants
11, Nitric acid plants
12. Petroleum re fineries
storage capacity exceeding 300,0)0 barrels
24, Taceoite ore processing plants
25, Glass fiber processing plants
28. Charcoal production pfents
2?, Fossil fuel-fired steam electric plants of mow than 250
14, Phosphate rock processing plants
million British thermal unite (BTU) per hour heat input
28. Fossil-fuel boitets (or combination thereof) totaling
more than 250 million BTU/ hour heat input
With a PSD program, a tribe must require the Best Available Control Technology (BACT) to be
installed when PSD sources are constructed or modified within its jurisdiction. In order to obtain
a permit, a source and the permitting authority must:
(a) Evaluate the BACT, which is based on the most stringent control available for a similar
type of source that is technically and economically feasible,
(b) Perform an ambient air impact study, and
(c) Conduct additional impact studies including visibility, soils, and vegetation.
Under the PSD permitting program, the "baseline" concentration of regulated pollutants must be
determined. The baseline is the ambient concentration level of a pollutant that exists at the time of
the first application for a PSD permit. The ambient concentration resulting from total emissions
from all sources (both permitted and non permitted sources) is not allowed to exceed the baseline
plus an increment set in the CAA. These increments are in 40 CFR 52.21(c).
Owners of new and growing facilities must show how much the increase in emissions will
increase the concentrations of air pollutants on the tribe's lands. The total effect of the increased
emissions from a new or modified source on pollutant concentrations may not exceed the baseline
plus the increment, nor exceed the NAAQS. In most cases, the baseline plus the increment will
result in an emissions ceiling more stringent than the NAAQS.
The increments are smallest for Class I areas and largest for Class III areas.
Class I areas were established by Congress and cannot be redesignated to any other classification.
These areas include national parks, national wilderness areas, national monuments, national
seashores, other areas of special natural, recreational, scenic, or historic value, and areas
reclassified as Class I. Class I areas receive the greatest protection. Only very minor degradation
of air quality is allowed in Class I areas. To permit a major new facility or major modification of
Page 41 - December, 2015
-------
an existing facility in a Class I area, an offset from another facility in the area may be necessary.
All other areas of the country were initially determined by Congress to be Class II areas. Class II
areas can accommodate normal well managed industrial growth. Class III areas have the
possibility of having the largest amount of development, but to date (2012) there have been no
redesignations made to establish Class III areas. The CAA automatically classifies most
attainment areas as Class II, but a federally recognized tribe may apply to change the
classification of its lands to Class I or Class III. Reservations that have been reclassified from
Class II to Class I include those of the Northern Cheyenne, Flathead, Fort Peck, Spokane, and
Forest County Potawatomi Indians. The increments are smallest for Class I areas and largest for
Class III areas.
Table III
SIGNIFICANT EMISSIONS RATES
Pollutant
SER(tpy)
Pollutant
SER(tpy)
Carbon Monoxide
100
Sulfuric Acid Mist
7
Nitrogen Oxides
40
Hydrogen Sulfide (H_,S)
10
Sulfur Dioxide
40
Total Reduced Sulfur (Includes
h2S)
10
Particulate Matter
(PM10)
15
Reduced Sulfur Compounds
(Includes H,S)
10
Particulate Matter
(PM2.5)
10; 40 for VOCs, NOx
orS02
Municipal Waste Combustor
Organics
3.5* 10"6
Ozone
40 VOCs or NOx
Municipal Waste Combustor
Metals
15
Lead
0.6
Municipal Waste Combustor for
Acid Gases
40
Fluorides
3
Municipal Solid Waste Landfills
Emissions
50
Additional details on the major NSR program can be obtained at: http://www.epa.gov/nsr/learn-
ab out-new- source-revi ew
Page 42 - December, 2015
-------
Minor NSR Program 40 CFR § 49.151-49.165
Minor NSR programs apply in both attainment and nonattainment areas and apply to smaller new
facilities and modifying facilities that are not large enough to qualify as major new sources or
major modifications. Examples of common minor sources include gasoline stations, automobile
refinishing shops, dry cleaners, incinerators, and small industrial facilities. A minor NSR program
allows EPA or a tribe to exercise oversight over the pollution from minor sources on its lands to
ensure such sources will not cause or contribute to a violation of the NAAQS, while still allowing
growth to occur. General permits designed for specific categories of sources such as dry cleaners,
rock crushers, and gasoline dispensing stations, allow quicker permit review and implementation.
Also in minor NSR, a source with a potential to emit above the major source threshold can agree
to enforceable emissions limits below the major source threshold. The source would not be
required to meet the more stringent major NSR requirements at the lower practically enforceable
emissions limits. Such a source is called a "synthetic minor" source.
On July 1, 2011, the EPA finalized a Federal Implementation Plan (FIP) under the Clean Air Act
(CAA or Act) for Indian country (76 FR 38748) 1. The FIP includes two NSR regulations for the
protection of air resources in Indian country. The first rule applies to new and modified minor
stationary sources (minor sources) and to minor modifications at existing major stationary sources
(major sources) throughout Indian country. EPA has also proposed a revised definition of Indian
country in § 49.152(d) to comport with a court decision that addressed EPAs jurisdiction to
implement the Federal Indian Country Minor NSR rule: Oklahoma Dept. of Environmental
Quality v. EPA, 740 F.3d 185 [D.C. Cir. 2014], For purposes of the NSR program EPA is
authorized to issue permits only in reservation areas in Indian country and any other areas of
Indian country for which a tribe or EPA has demonstrated that the tribe has jurisdiction. The
second rule (nonattainment major NSR rule) applies to new and modified major sources in areas
of Indian country that are designated as non attainment for any of the National Ambient Air
Quality Standards (NAAQS). These rules can be implemented by either the EPA or a tribe or
both. The tribes may request and the EPA may approve delegation of the program so that the
tribes may assist the EPA with implementation on tribal lands (see 40 CFR 49.161(b) and 49.
173).2 TAS approval is not required for such a delegation. However, should a tribe seek full
responsibility for a program, it must do so through an approved TIP (40 CFR 49.161(a) and
49.173(a)). TAS approval is required for full tribal implementation prior to TIP approval.
Additional information about the FIP and tribal implementation of the NSR programs may be
found in the July 1, 2011, Federal Register notice (see http://www.gpo.gov/fdsvs/pkg/FR-2011-
07-01/pdf/201 l-14981.pdf) or on the EPA's Tribal NSR permitting website located at:
http://www.epa.gov/air/tribal/tribalnsr.html).
1 On January 17, 2014, the DC Circuit Court of Appeals vacated part of this FIP for non-reservation areas of Indian
country. Oklahoma Dept. of Environmental Quality v. EPA, 740 F.3d 185 (D.C. Cir. 2014). As a result of this decision,
EPA or a Tribe may no longer implement the program in non-reservation areas of Indian country including
allottments and dependent Indian communities. As a result of this decision, the EPA has proposed a revised
definition of Indian country in § 49.152(d) to comport with a court decision. Because of this decision, and for
purposes of the NSR program, EPAmay only issue permits in reservation areas in Indian country and any other areas
of Indian country for which a tribe or EPA has demonstrated that the tribe has jurisdiction.
2 The Administrator's ability to object to the issuance of a permit and the Administrator's enforcement authority
may not be delegated to a tribe. 40 CFR 49.161(c).
Page 43 - December, 2015
-------
The Region 6 website that indicates existing and potential facilities with a Title V permit or an
NSR permit is: http://www.epa.gov/caa-permitting/tribal-nsr-implementation-epas-south-central-
region
Creating a Preconstruction Permit Program
A tribe's emissions inventory of air emissions sources on its lands will help it identify those
sources a preconstruction permit program will need to regulate. In addition, Region 6 can give
guidance about any existing NSR or minor NSR programs that may be useful models for the tribe
to consider using as a model when developing its preconstruction permit program. See
http://vvvvvv3.epa.gov/air/tribal/tribalnsr.html for additional information.
Page 44 - December, 2015
-------
Air Enforcement and Compliance
Approved Programs and Tribal Implementation Plan
For facilities within its jurisdiction, a tribe may be able to obtain concurrent enforcement authority
with the EPA under the CAA to ensure compliance with federally approved tribal regulations for
air quality. In order for a tribe to get such tribal enforcement authority, the tribe must first request
and receive TAS approval followed by federal approval of its air quality program. Enforcement
authority under an approved program may include civil enforcement authority, but may not
necessarily include criminal enforcement authority beyond that included in 40 CFR 49.8. For
program approval, the tribes must demonstrate that they have the necessary legal authority to
initiate an enforcement action, as appropriate, for any CAA program violations found during
inspections. Once it receives the approval for a particular program, the tribe is then the proper
authority to conduct inspections of facilities, issue enforcement actions, and assess and collect
penalties for that federal program. Although the tribes are the primary enforcement authority
under an approved program, the EPA retains concurrent enforcement authority as it does with all
approved programs - state or tribal. In addition to enforcement under a federally approved
program, the tribes may enact more stringent or substantively different tribal laws, which it could
enforce in tribal courts.
Delegated Programs
The tribes may assist the EPA with the CAA program implementation pursuant to a delegated
program. Under such delegated programs, the EPA remains the sole enforcement authority under
the the CAA. As with approved programs, however, the tribes may always pursue enforcement in
tribal courts of parallel non-federal air quality requirements.
Permits/Enforcement Interface
For a tribal permitting program to be effective under a TIP the tribe must have an enforcement
program in place to ensure facilities comply with their issued permits. If a facility is violating its
permit, a tribe having enforcement authority can bring the facility back into compliance by issuing
an enforcement action with injunctive relief requiring compliance and monetary penalty,
including collecting any economic benefit from a violation.
Air Inspections
Air emissions inspections are a major tool for ensuring compliance with air regulations for
facilities located within Indian country. An inspection is a tool for investigating citizen complaints
about nuisances or air quality issues. An inspection program is a method to determine if facilities
comply with their air permits. Trained inspectors can determine if a facility self-reports correctly
and that it meets its permit requirements. Also, a regular inspection program helps ensure that all
facilities regulated comply with air rules. Currently, the Region 6 Air Enforcement Program
specifies that the State and Tribal Enforcement Programs follow the Compliance Monitoring
Strategy issued by EPA's Office of Compliance in Washington, D.C., dated July 14, 2014. The
inspector becomes familiar with the community and its industries that would likely require a
permit, and identify and document violations of air regulations.
Page 45 - December, 2015
-------
Because of the importance of trained air program inspectors, the tribe should prepare individuals
for this role by sending them to safety training and the EPA's inspector training course. They
should also have a scientific or industrial background so they can readily understand how
emission sources operate and the regulations concerning them. It is also preferable that inspectors
take part in the EPA training on air pollution control equipment and processes.
Under the regulations, tribes must develop inspection plans and perform inspections of facilities
within their jurisdiction to ensure compliance. The inspections should involve periodic visits to
review a facility's operation and to ensure it complies with applicable permit and regulatory
requirements.
Regional Planning Organizations
Air pollution can travel many miles from urban centers and affect visibility in rural areas. The
CAA establishes special goals for visibility in many national parks and wilderness areas. In 1999,
the EPA published the Regional Haze Rule, which requires states to establish goals for improving
visibility in national parks and wilderness areas and to develop long- term strategies to reduce
emissions of air pollutants that cause visibility impairment. The EPA strongly encourages states
and tribes to work together on a regional level to develop and implement these strategies.
Today, there are five Regional Planning Organizations (RPOs) that span the-continental
United States:
~ the Mid-Atlantic Northeastern Visibility Union (MANE) in the Northeast;
~ the Visibility Improvement State and Tribal Association of the Southeast (VISTAS) in
the Southeast;
~ the Midwest Regional Planning Organization around the Great Lakes Area;
~ the Central Regional Air Planning Association (CenRAP) in the Central United States;
and
~ the Western Regional Air Partnership (WRAP) in the West
The Region 6 states and tribes are divided between two RPOs. New Mexico and the tribes located
in New Mexico pertain to the Western Regional Air Partnership (WRAP), while the other Region
6 States (Arkansas, Louisiana, Oklahoma, and Texas) and all the tribes located in those states will
work with the Central Regional Air Planning Association (CenRAP).
Western Regional Air Partnership (WRAP)
The Western Regional Air Partnership is an outgrowth of the Grand Canyon Visibility Transport
Commission, and covers approximately the western half of the continental United States. Because
the WRAP has a longer history than the other four RPOs, it is significantly further along in its
study of the Regional Haze problem and must respond to different timelines and requirements.
The states and tribes are equally represented on the WRAP board. Stakeholders (industry,
environmental groups, local governments, and the general public) are actively involved in both
policy and technical committees, as well as the Initiatives Oversight Committee. The only body
from which stakeholders are excluded is the WRAP Board itself, which is composed of states,
Page 46 - December, 2015
-------
tribes, Federal Land Managers (who do "vote" if a consensus decision cannot be reached), and the
EPA (non-voting).
Central States Air Resources Agencies (CenSARA)
The Central States Air Resources Agencies (CenSARA) and the Central Regional Air Planning
Association (CenRAP) are two distinct but related organizations. The CenSARA and CenRAP
share the same staff and cover the same geographic area down the Central United States from
Canada to Mexico. The CenSARA is a state-only organization funded directly by contributions
from its member States: Minnesota, Iowa, Nebraska, Kansas, Missouri, Oklahoma, Arkansas,
Texas, and Louisiana. The CenSARA was founded to promote cooperation among the member
states to resolve ozone problems and to provide training for the states. When the EPA decided to
fund five regional planning organizations, CenSARA was chosen as the funding agency to form
the CenRAP. Historically, the tribes have participated in CenRAP discussions on Regional Haze
and other tribal air quality issues.
Air Toxics
Toxic air pollutants, also known as hazardous air pollutants, are those pollutants that are known or
suspected to cause health effects or adverse environmental effects. Most air toxics originate from
human-made sources, including mobile sources (e.g., cars, trucks, buses) and stationary sources
(e.g., factories, refineries, power plants), as well as indoor sources (e.g., some building materials
and cleaning solvents). Some air toxics are also released from natural sources such as volcanic
eruptions and forest fires. The EPA is working to assess and reduce air toxics releases of 188
pollutants to the environment (see http://www3.epa.gov/ttn/atw/allabout.html)
Controls for Industrial and Commercial Sources of Air Toxic
The EPA has issued rules covering over 96 categories of major industrial sources, such as
chemical plants, oil refineries, aerospace manufacturers, and steel mills, as well as categories of
smaller sources, such as dry cleaners, commercial sterilizers, secondary lead smelters, and
chromium electroplating facilities. These standards are projected to reduce annual air toxics
emissions by about 1.7 million tons. For more information about these rules, see the EPA's,
website on Taking Toxics Out of the Air, which is found at
http://www3.epa.gov/ttn/atw/allabout.html
Controls for Cars and Trucks
The EPA has reduced emissions of benzene, toluene, and other air toxics from mobile sources by
requiring the use of reformulated gasoline and placing limits on tailpipe emissions. Important new
controls for fuels and vehicles are expected to reduce selected motor vehicle air toxics from 1990
levels by more than 75% by 2020. For more information, on Mobile Source Air Toxics, see
http://www3.epa.gov/otaq/toxics.htm
• Indoor Air
Page 47 - December, 2015
-------
The EPA, in close cooperation with other Federal agencies and the private sector, is actively
involved in efforts to better understand indoor air pollution and to reduce people's exposure to air
pollutants in offices, homes, schools, and other indoor environments. For more information, see
http://www.epa.gov/iaq/.
The EPA's Technology Transfer Network Air Toxics Website (http://www.epa.gov/ttn/atw/)
includes more details about efforts underway to reduce air toxics. The EPA is in the process of
moving from an air toxics program based on technical emissions source standards to a risk-based
air toxics program.
To ensure that air toxics strategies used will protect public health in local communities the EPA
has additional efforts underway to evaluate and address releases of air toxics. These efforts
include collection and analysis of information on air toxics emissions, ambient air concentrations
as well as the development of strategies, workplans and pilot projects to help local stakeholders
reduce air toxics emissions and any potentially unacceptable risks they may pose.
Additional information on health effects from air toxics as well as risk estimation, exposure and
assessment procedures are available from the following resources:
The Health Effects Notebook for Hazardous Air Pollutants
http ://www. epa. gov/ttn/atw/hlthef/hapindex.html
Detailed information about the health effects of hazardous air pollutants (HAPs) is
available in separate fact sheets, for nearly every one of the 188 HAPs specified in the
CAA Amendments of 1990.
• Air Pollution and Health Risk
http://www.epa.gOv/ttn/atw/3 90 022.html
Find out how we know when a risk from a hazardous substance is serious. Learn how
researchers estimate risk, and how the government uses this information to develop
regulations that limit our exposure to hazardous substances.
Evaluating Exposures to Toxic Air Pollutants: A Citizen's Guide
http://www.epa.gov/ttn/atvv/3 90 023.html
This publication explains the process that the EPA uses to determine how much of a toxic
air pollutant people are exposed to and how many people are exposed.
Risk Assessment for Toxic Air Pollutants: A Citizen's Guide
http://www.epa.gOv/ttn/atw/3 90 24.html
Find out more about risk assessment, which is the process used to estimate the risk of
illness from a specific human exposure to a toxic air pollutant.
Page 48 - December, 2015
-------
RESOURCES AND
TRAINING OPTIONS
Page 49 - December, 2015
-------
Training Options
The EPA provides free training for state, local, and tribal Air Pollution Control Agencies. This is
accomplished by providing funds to various universities in the United States. The training centers
for Region 6 are:
Air Pollution Training Institute (APTI)
Institute for Tribal Environmental Professionals (ITEP)
Tribal Air Monitoring Support Center (TAMS)
It is the goal of the APTI to present the latest course materials and training in various subject
areas for air pollution control. These materials and courses are frequently updated by nationally
recognized experts.
The APTI also has various types of self-instructional courses, which include both video courses
and self-paced courses using manuals. Go to the APTI website (http://www.apti-learn.net) for a
current catalog which contains a list of self-instructional courses.
Depending on availability, grant funds may be used to provide training locally for the states and
tribes. This training is only available if the state or tribe can commit to having at least twenty
people attend any given training course.
For APTI class enrollment questions contact Maryann Warner, APTI Registrar, at
wamer.maryann@epa.gov or at (919) 541-1192. Consult the APTI website for specific course
dates and times.
Northern Arizona University (NAU) is another outstanding source of Tribal Air Training. The
EPA and NAU formed a partnership in 1993, with the EPA providing grant funding to NAU for
the creation of the Institute for Tribal Environmental Professionals and its American Indian Air
Quality Training Program. The NAU courses are developed for audiences of specific levels, and
emphasize tribal instructors/facilitators, along with the EPA participants and outside experts.
Additionally, the courses and workshops are developed with sensitivity toward the Native
American cultural heritage in providing knowledge and skills for prospective air quality program
managers and technical personnel. See ITEP online at http://www.nau.edu/itep.
For NAU workshop and application information, contact Lydia Scheer at (928) 523-6887 or
Lydia.Scheer@nau.edu.
The Institute for Tribal Environmental Professionals (ITEP) was created in 1992 to act as a
catalyst among tribal governments, research and technical resources at Northern Arizona
University (NAU), in support of environmental protection of Native American natural resources.
Page 50 - December, 2015
-------
Mission: "To serve the tribes through outstanding, culturally-relevant education and training that
increase environmental capacity and strengthen sovereignty. " ITEP accomplishes its mission
through several programs profiled on our website. ITEP is a national organization and to date
has served over 500federally recognized the tribes with environmental education, training
courses, technical assistance and other resources. For further information regarding ITEP see
http://www.nau. edu/itep
The Tribal Air Monitoring Support Center (TAMS) offers different training courses that focus on
a variety of topics related to ambient and indoor air quality monitoring. TAMS Center courses
have been designed to complement other American Indian Air Quality Training Program courses,
and generally address more advanced air quality issues. Each course is designed with tribal
audiences and issues in mind, integrating tribal case studies and tribal professionals as part of
the instructional team in every course. Class size is kept a minimum to ensure a higher level of
interaction and one-on-one training opportunities with the instructors. For further information
regarding TAMS see htty://www 7. nau. edu/itey/main/tams/.
Page 51 - December, 2015
-------
EPA Region 6 Air Grant Contacts
EPA Region 6
Mailing Address : 1445 Ross Avenue, Suite 1200
Dallas, TX 75202
Fax Number: (214) 665-6762
AIR GRANTS
Contact Name
and Title
Phone Number and
Email Address
Program Location and
Mail Code
Fran Verhalen
Chief
(214) 665-7242
Verhalen.francos r/coa.nov
Air Monitoring/Grants Section
(6MM-AM)
Mary Stanton
Chief
(214)665-8377
Stanton. marva(3),epa. gov
State Implementation B Section
(6MM-AB)
Jeff Robinson
Chief
(214) 665-6435
Robinson.jeffrev r/ eoa.nov
Air Permits Section
(6MM-AP)
Margaret Osbourne
Chief
(214) 665-6508
Osbourne.margaretfo),epa.gov
Air Toxics Enforcement
Section
(6EN-AT)
Aunjanee Gautreaux
Tribal Air Project Officer
(214) 665-7127
Gautreaux. auni anee ®,et>a. aov
Air Monitoring/Grants Section
(6MM-AM)
Donnett Patterson
Tribal Air Project Officer
(214) 665-7418
Patterson. donnett <7 eixi.aov
Air Monitoring/Grants Section
(6MM-AM)
Cindy Parker
Air Monitoring/Grants
Communications
(214) 665-7291
Parker. cindv(S>epa. aov
Air Monitoring/Grants Section
(6MM-AM)
Page 52 - December, 2015
-------
APPENDICES
Page 53 - December, 2015
-------
TRIBAL AUTHORITY RULE
FACT SHEET
CLEAN AIR ACT FINAL RULE
INDIAN TRIBES: AIR QUALITY PLANNING AND MANAGEMENT
(63FR 7271)
OVERVIEW
The Clean Air Act (CAA) authorizes the EPA to issue regulations specifying the provisions
of the CAA for which the Indian tribes may be treated in the same manner as states.
This final rule implements the provisions of section 301(d) of the Act to authorize eligible
the tribes to implement their own tribal air programs.
HIGHLIGHTS OF THE RULE
Applicable CAA Programs
The rule provides that the tribes will be treated in the same manner as states for virtually
all the CAA programs.
The rule notes that Congress provided for a grant to the tribes - with approved the CAA
programs - of authority over all air resources within the exterior boundaries of a
reservation (including Non-Indian owned fee lands). For non-reservation areas, the tribes
must demonstrate the basis for jurisdiction.
Eligibility for Treatment in a Manner Similar to States (TAS)
Tribal eligibility requirements include demonstrating:
(1) The applicant is an Indian tribe recognized by the Secretary of the Interior;
(2) The Indian tribe has a governing body carrying out substantial governmental duties
and functions;
(3) The functions to be excercised by the Indian tribe pertain to the management and
protection of air resources within the exterior boundaries of the reservation or other
areas within the tribe's jurisdiction;
(4) The Indian tribe is reasonably expected to be capable, in the EPA Regional
Administrator's judgment, of carrying out the functions to be exercised in a manner
consistent with the terms and purposes of the CAA and all applicable regulations
The EPA generally will simultaneously review tribal applications for eligibility and CAA
program submittals.
Page 54 - December, 2015
-------
Flexibility
The rule authorizes the tribes to submit CAA programs; however, it does not require the
tribes to develop CAA programs.
The tribes may implement those programs, or even portions of programs, that are most
relevant to the air quality needs of the tribes.
Page 55 - December, 2015
-------
Federal Register Notice
Part VI
Environmental Protection Agency
40 CFR Parts 31 and 35
Environmental Program Grants for Tribes; Final Rule
http ://www. gpo. gov/fdsvs/pkg/CFR-1999-title40-vol 1/pdf/CFR-1999-title40-vol 1 -part31 .pdf
http ://www. gpo. gov/fdsvs/pkg/CFR-1999-title40-vol 1/pdf/CFR-1999-title40-vol 1 -part3 5.pdf
Page 56 - December, 2015
-------
THE TRIBAL AIR GRANTS FRAMEWORK
A MENU OF OPTIONS
For
Developing Tribal Air Grant Work Plans and
Managing Grants for Environmental Results
Revised 2015
http://www3.epa.gov/air/tribal/pdfs/thetribalairgrantsframework menuofoptionsOQ 29 15.pdf
Page 57 - December, 2015
-------
THE TRIBAL AIR GRANTS FRAMEWORK:
A Menu of Ontions
For
Developing Tribal Air Grant Work Plans & Managing Grants for Environmental Results
Introduction 1
Menu Items:
Air Quality Administration and Infrastructure Development 3
Air Quality Monitoring Activities 6
Air Toxi c s Ri sk Reducti on 9
Basic Air Quality Assessment 11
Diesel Emission Reduction Projects 14
Emissions Inventory 16
Energy Efficiency and Greenhouse Gas Reduction 19
FARR Implementation (.Region 10 Only) 23
Indoor Air Quality Assessment and Training 26
Local or Unique Air Quality Issues 29
Participation in Policy Development Groups 32
Radon Risk Reduction 34
Residential Wood Smoke Reduction Program 36
Road Dust Emissions 38
Rulemaking and Enforcement 41
Glossary of Terms and Acronyms 45
Sample Workplan Example 48
Sample Budget Template 50
Page 58 - December, 2015
-------
TRTBAT, ATR GRANTS FRAMEWORK: A MENU OF OPTIONS
for
Developing Tribal Air Grant Work Plans & Managing Grants for Environmental Results
Introduction:
The Environmental Protection Agency (EPA) is committed to working with tribes to
develop and to implement Clean Air Act (CAA) programs in Indian country. One of EPA's
primary tools in this effort is to award CAA grants in order to help build tribal knowledge and
increase tribe's capacity to manage air quality issues. CAA §103 and §105 allow EPA to
provide grant support to tribes for this purpose. To assist tribes in writing effective grant
applications and work plans, we have developed this " Tribal Air Grants Framework: A Menu of
Options." EPA revised and updated the Framework for the fourth time in 2015.
The purpose of this tool is to assist tribes that apply for CAA funding to draft more
effective work plans for projects that will develop tribal knowledge of air quality issues and
build tribal expertise to manage air quality on reservations and tribal trust land. The CAA
envisions an approach to air quality management that includes:
¦ Goals and standards to protect public health and the environment;
¦ Assessing air quality through emissions inventories and monitoring;
¦ Determining necessary reductions in pollution;
¦ Federal, State or Tribal Implementation Plans;
¦ Education or outreach programs and other voluntary measures; and
¦ Implementing and enforcing control measures.
Tribal air programs, like their state counterparts, may include activities that involve
different elements of this framework. However, unlike the states, the tribes often do not have
resources available to build and run their own CAA programs. Instead, the CAA provides
mechanisms to allow them to develop their capacity, authority, regulations, and other
components on an incremental and as-needed basis. These menu options suggest some of the
more common activities involved in achieving primary air quality objectives. Tribes can select
the work that is most appropriate considering their individual circumstances and needs.
Approvable work plans need to have (1) one or more objectives, (2) activities that support
the achievement of the objectives, and (3) outcomes or deliverables that will produce
environmental results within the objective. Therefore, each menu is structured to provide
suggestions for all of these critical work plan elements. Some menus include performance
measures that EPA uses to measure national progress on achieving environmental results in
Indian country. Through the grant negotiation process, applicants produce work plans with
supporting budgets to address both the needs of the particular reservation or tribal community, as
well as EPA priorities.
While funding limitations and other considerations of the grant process prevent any
Tribal Air Grants Framework June 2015 Page | 1
-------
guarantee that a particular grant proposal will be selected for funding, it is hoped that these
menus will help tribes efficiently develop proposals that can effectively address air quality issues
in Indian country - from initial assessment of air pollution sources to advanced regulatory
development and implementation. This guidance is intended to serve as a reference for both
tribal and EPA staff during CAA grant and program development.
The menus do not represent the only categories of work that EPA will fund under the
CAA authorities, nor are the activities the only ones that may produce the stated objectives.
However, the framework is intended to provide options that will be useful to tribes in developing
work plans both for assessing their air quality and in building the capacity to manage a
reservation's air quality. It is also hoped that the use of this tool will streamline the EPA review
of work plans and help us to better assist tribes in managing CAA grants
Before submitting an application, applicants are encouraged to contact their EPA Region
for information on applicable procedures before developing a work plan and supporting budget
around the air quality objectives for which they seek funding. Additionally, the tribe and Project
Officer will normally negotiate final work plan deliverables and budget amounts prior to the tribe
submitting a signed, formal application in response to a particular Region's grant announcement.
Note: Many of the activities and objectives included in these menu options may also be
appropriate for work plans eligible for funding under other EPA grant programs, such as the
Indian General Assistance Program (IGAP). Contact the EPA Tribal Office in your Region for
further information.
Tribal Air Grants Framework
June 2015
Page | 2
-------
Menu Item lor Air Quality Administration & liil'iiisti ucluio Development
Tribal Air Work pian Objective: Develop and maintain the requisite staff, infrastructure
and administrative capacity needed to accomplish effective air quality objectives and grant
management activities of the proposed work plan.
Background: Air Quality Administration and Infrastructure needs will be based upon what
resources already exist in a grant applicant's administrative structure or environmental
program. Building the requisite infrastructure to support an air quality project would
include ensuring that all equipment, training, office support and staff needs are in place so
that compliance with applicable EPA grant terms and conditions can be met and identified
program outputs produced.
Funding Mechanism: This objective and supporting activities may qualify for EPA
financial support primarily through the authority of either the Indian General Assistance
Program (IGAP) or Clean Air Act §103 grants. Contact your nearest Regional EPA Tribal
or Program Office for further information.
Activities/ Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a work plan including administrative and infrastructure development.
Adapting these needs to respond to the needs of a specific reservation or tribal community is
encouraged, taking into consideration the existing infrastructure. EPA Regional Offices are
available to provide assistance and advice on what a particular tribe may require to adequately
support their proposed workplan activities. A timeline is then created by estimating the dates
by which each task, and sub-task, will be completed in order to accomplish the objective by the
planned date.
¦ Write job/position descriptions for staff that will be needed to accomplish work plan tasks
and objectives.
¦ Identify and hire appropriate personnel, either from existing tribal staff or new hire, with
background and/or potential to be able to handle activities in work plan.
¦ Arrange for office space and equipment sufficient to accomplish the work plan activities.
¦ Set up a record keeping system for grant and air related activities, including tracking of
grant terms and conditions, fiscal data, equipment, timekeeping records, work plan
performance, milestones, and deliverables.
¦ Identify training needs of staff and write a training plan; make necessary arrangements for
registration and attending the appropriate classes.
¦ Attend training courses, workshops and conferences that will provide background and
skills to accomplish the work plan.
¦ Make contacts with other tribes, state and local air professionals, through tribal, local,
regional and national organizations and conferences that will provide sources of support
and collaborative efforts that can help with air quality work on the reservation, particularly
surrounding jurisdictions in the same or neighboring air sheds.
Tribal Air Grants Framework
June 2015
Page | 3
-------
¦ Write quarterly reports, comparing activities and accomplishments with work plan
milestones, timeline, and objectives, to ensure that work progresses at a rate that will allow
completion of the deliverables within the project period. If problems are encountered that
may prevent progress, promptly notify the grant project officer and discuss how the
problems will be addressed.
¦ Communicate regularly with tribal grants and fiscal personnel involved with submitting
the financial reports for the grant to ensure that all appropriate records are being
maintained and reports, such as Reimbursement Requests and Financial Status Reports, are
submitted appropriately and according to the terms of the grant.
¦ Draw down grant funds at regular intervals as soon as is appropriate.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the
information below.
An output:
• is an activity, effort, and/or associated
work products related to an
environmental and/or programmatic
goal or objective:
• will be produced or provided over a
period of time or by a specific date;
• may be quantitative or qualitative, but
must be measurable during an
assistance agreement funding period.
An outcome:
• is the result, effect or consequence
that will occur from carrying out the
funded activity or program that is
related to an environmental and/or
programmatic goal or objective;
• may be environmental,
behavioral, health-related or
programmatic in nature;
• must be quantitative;
• may be intermediate in nature (i.e.,
may not be the desired end
environmental result but will help
lead to it); and may not necessarily
be achievable within an assistance
agreement funding period.
Tribal Air Grants Framework
June 2015
Page | 4
-------
Possible Outputs: [These are examples of outputs for this objective; there may be others.]
¦ Staff hired appropriate to the j ob description with the capabilities to complete the work
plan activities by the end of the project period, given appropriate training.
¦ Training plan written that supports the work plan objectives.
¦ The training courses, identified as necessary for the staff to develop the capacity to carry
out the work plan objectives, are satisfactorily completed.
¦ Office management and administrative procedures established and maintained that ensure
that all needed records are kept, that grant terms and conditions are satisfied, such as
submission of quarterly Progress Reports and annual Financial Status Reports, and agreed
outputs provided to EPA.
Possible Outcomes'. [This is an example of an outcome for this objective; there may be
others.]
¦ Staff hired appropriate to the j ob description with the capabilities to complete the work
plan activities by the end of the project period, given appropriate training.
¦ Training plan written that supports the work plan objectives.
¦ The training courses, identified as necessary for the staff to develop the capacity to carry
out the work plan objectives, are satisfactorily completed.
¦ Office management and administrative procedures established and maintained that ensure
that all needed records are kept, that grant terms and conditions are satisfied, such as
submission of quarterly Progress Reports and annual Financial Status Reports, and agreed
outputs provided to EPA.
Possible Outcomes'. [This is an example of an outcome for this objective; there may be
others.]
Expressed as a result of an individual Tribal grant:
¦ Tribe demonstrates successful grant management and air project management
capabilities through the timely compliance with all (100%) grant terms and conditions
and completion of work plan deliverables.
Expressed as a measure of overall Tribal urogram performance (over a stated baseline or
cumulative total):
¦ Increase in the number of tribes who have demonstrated successful grant management
and air project management capabilities through the timely compliance with all grant
terms and conditions and completion of work plan deliverables. [Or other indicator of
the capacity demonstrated for successful environmental grant management for
achieving the goals of the Clean Air Act in Indian country.]
F.PA Nationai PerformanceMfasttrfYs^
The following is an example of how performance by EPA may be measured in this area:
Tribal Air Grants Framework
June 2015
Page | 5
-------
¦ Number of tribes with currently employed staff that have received training
on Clean Air Act grant management and/or are demonstrating compliance
with terms and conditions of a current Clean Air Act grants.
Tribal Air Grants Framework
June 2015
Page | 6
-------
Menu llcm lor' ('oiuhiclinu Air Qusililv Monhoriii" Activities
Tribal Air Work pian Objective: To identify, through collection of quality-assured
monitoring data, the nature and level of air pollution on a reservation or in a tribal community
over a particular period of time.
Background: Air Quality Monitoring is undertaken to establish a baseline of air quality data,
as well as to collect targeted data when air pollution may be adversely impacting the
reservation community. Either a Basic Air Quality Assessment or an Emissions Inventory
(See Menu Items for each) can provide preliminary information from which it can be
determined whether and what type of additional air quality data would best assist in
managing air pollution concerns. Air quality monitoring data is one of several inputs into
decisions about air quality management in a particular airshed.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial
support through the grant authority of either the Indian General Assistance Program (IGAP)
or Clean Air Act §103 to the extent the activities involve assessment or baseline monitoring.
They may qualify for funding under Clean Air Act §105 if they involve air quality
management-related work. Contact your nearest Regional EPA Tribal or Program Office
for further information.
Acttvtttes / Tasks: Grant applicants should consider the following tasks or activities as
options in developing a work plan that includes air monitoring. Applicants are encouraged to
adapt these tasks and activities to respond to the needs of a specific reservation or tribal
community, taking into consideration the purpose for which they will use the monitoring data.
EPA Regional Offices are available to provide technical advice that a particular tribe may
require to adequately support their proposed work plan activities. The applicant should create a
timeline by estimating the dates by which each task, and sub-task, will be completed in order to
accomplish the objective by the planned date.
¦ Identify the Need for and Type of Monitoring Data: Identify why air monitoring data is
needed and how it will be used in making decisions about air quality management.
Identify the most appropriate type of monitoring data to collect: Learn what other
monitoring is being conducted by surrounding jurisdictions and what the data shows.
Through information from basic air quality assessment activities, evaluate the possible
options for additional air quality data that could assist the tribe in managing its air quality
or assist other jurisdictions in managing air quality.
¦ Selecting less expensive and or simple technologies may be best for initial screening of
pollutants. Research the applicability and suitability of the "Next Generation Air
Monitoring Technologies", such as Air Sensors, to find information about air pollution
in your community, supplement existing monitoring data (to fill a gap in coverage
area) and/or to identify and characterize sources. Borrow equipment and/or consult
with the TAMS center to conduct an initial, limited term, study before investing in
more expensive technology.
Tribal Air Grants Framework
June 2015
Page | 7
-------
¦ PM 10 or 2.5 can be monitored using either continuous, filter-based monitors or Air
Sensors depending on how the data will be used. Compare Air Sensors, FRM and
continuous FEM monitors to understand the advantages and disadvantages of the
available monitoring methods.
¦ Assess the need for meteorological data when appropriate and based on an EPA-
approved QAPP, install and operate a met station in conjunction with monitoring
equipment to provide additional information about the sources of air pollution or to
help assist in forestry or agriculture smoke management plans.
¦ Obtain training on topics related to Quality Assurance Project Plans (QAPPs) and
appropriate monitoring technology, data logging, data transfer and AQS reporting.
¦ QAPP and Siting: Prepare a QAPP for the type of monitoring determined (with EPA
assistance) to be appropriate and useful to the tribe, the air shed, or the region. The
QAPP will provide basis for siting the monitor(s) and procedures to be followed to
ensure quality of data collected. Note that an EPA approved QAPP is required before
data can be collected using EPA grant funds.
¦ Monitor based upon the QAPP and EPA-approved siting, install and operate the
monitor for appropriate period of time. As data is collected, provide written analysis
of what the data indicates about air pollution levels.
¦ Continuous Monitoring for PM: Based upon types of sources identified on the
reservation, continuous monitoring may be used to provide ongoing information about
sources that produce peaks in air pollution, such as agricultural burning or forestry
burning. Data can be provided on a real-time basis to reservation communities for
decisions about residential burning, or health concerns. Linking to a tribal web page is
an optional way of disseminating the data.
¦ Provide AQ Data to EPA: The quality assured and validated data should be uploaded into
the EPA AQS system or provided to EPA in other applicable formats on a quarterly
basis. Data submittal to AQS is an EPA grant requirement.
¦ Baseline Data: Once a baseline is established for the air pollution levels, assess need for
ongoing monitoring in a written report.
¦ Interim Reports of Air Quality Data: Provide EPA and Tribe information on what levels
of air pollution the monitors show on a regular basis.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For an explanation of outputs and outcomes please see
the Menu Item for Air Quality Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ Quality assured data provided to EPA and uploaded into the AQS database (as
required).
¦ A report analyzing the air quality data for EPA and the Tribe, providing information
such as how the data compares to NAAQS limits, identification of the impacts of
particular sources on or off the reservation.
Tribal Air Grants Framework
June 2015
Page | 8
-------
Possible Outcomes: [These are examples of outcomes for this objective; there may be
others]
ExpressedasaresultofanindividualTribalgrant:
¦ Air quality within the Tribe's jurisdiction is accurately characterized, and its condition
and threats to its condition are understood by the Tribe, EPA and others.
ExpressedasameasureofoverallTribalprogramperformance:
¦ Increase in the percentage of reservations (or communities in Indian country) with
potential air quality problems that have been assessed or monitored.
¦ Increase in the number of tribes operating particular types of monitors on their
reservations at locations that are potentially impacted by the pollutant, and providing
the data to AQS.
¦ Increase in reports on how tribes have used assessment or monitoring data to better
manage their air quality.
¦ Increase in the percentage of reservations for which air quality levels for particular
NAAQS pollutants have been determined through monitoring, modeling, or other
assessment activities.
Nationai FPA Performance IVIfasiirfYs>:
EPA will use the following to measure performance in this area:
¦ Number of Tribes that are operating ambient monitors and submitting
complete, quality-assured data to EPA's Air Quality System (AQS) database.
Tribal Air Grants Framework
June 2015
Page | 9
-------
Menu llem for Implementing Air Toxics Kisk Reduction
Tribal Air Work plan Objective: To identify and address air toxics issues for the
tribal community or reservation through activities that will reduce the risk to human
health and the environment.
Background: Air Toxics Risk Reduction activities may relate to any of the 187 air
toxics or hazardous air pollutants listed in the Clean Air Act. Many are gaseous, or
particulates so they vary in their behavior in the environment. They also have varied
health and environmental impacts so it will be important to determine what the
pollutant(s) of concern are and how they affect the community. Based on this
information control strategies may be determined for your area.
Funding Mechanism: This objective and supporting activities may qualify for EPA
financial support through the grant authority of either the Indian General Assistance
Program (IGAP) or Clean Air Act §103 to the extent the activities involve assessment
or baseline monitoring. They may qualify for funding under Clean Air Act §105 if they
involve air quality management-related work. Contact your nearest Regional EPA
Tribal or Program Office for further information.
Activities/ Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes air toxics activities. Adapting these needs
to respond to those of a specific reservation or tribal community is encouraged. EPA
Regional Offices are available to provide technical advice on what a particular tribe may
require to adequately support their proposed workplan activities. A timeline is then created
by estimating the dates by which each task, and sub-task, will be completed in order to
accomplish the objective by the planned date.
¦ Obtain training on air toxics risk characterization and control methodology.
¦ Conduct a risk characterization which might include: monitoring, inventory
development, GIS, dispersion modeling or other analysis. (Guidance is available on
EPA's community based projects website or the CARE website.)
¦ Identify potential areas for emissions reductions or controls or opportunities to work
with States where sources impacting the community are located. [NOTE the Agency
recommends that this effort be conducted with the community members involved as
much as possible.]
¦ Develop a workplan to proceed with implementation of identified activities.
¦ Evaluate implementation efforts.
¦ Submit report to Regional Office.
Work pi,an Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Tribal Air Grants Framework
June 2015
Page | 10
-------
Item for A ir Quality Administration Infrastructure
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ Risk characterization assessment conducted for the reservation.
¦ Air toxics report that identifies potential areas for emissions reductions or
controls or opportunities to work with States where sources impacting the
community are located.
Possible Outcomes: [These are examples of outcomes for this objective; there may be
others]
ExpressedasaresultofanindividualTribal grant:
¦ EPA, the Tribe, and others are aware of the sources of air toxics impacting the
Reservation, the overall air toxics risk to the Reservation's population, and the
degree of risk to the individual resident (?).
¦ Actions to reduce risk and measured reduction in air toxics risk. Expressedasa
measureofoverall Tribal programperformanceCoverastatedbaselineor cumulativetotal):
¦ Increase in number of reservations for which a risk assessment has been
conducted.
Nationai F/PA Performance IVIfasiirfYs>:
EPA will use the following to measure performance in this area:
¦ Number of Tribes with staff that have attended air toxics-related outreach and
training events.
¦ Number of Tribes that are participating in community scale monitoring or
community air toxics projects.
Tribal Air Grants Framework
June 2015
Page
-------
Menu 11cm lor Conducting a IJnsic Air Qiiiililv Assessment
Tribal Air Work plan Objective: To identify the existence of and possible sources of air
pollution that may be of concern to the tribe and reservation communities, identifying any need
for and nature of further air quality work.
Background: Conducting a Basic Air Quality Assessment is an early step to understanding
what air quality issues may be of most concern. This is typically undertaken by a Tribe to
determine the amount and nature of air pollution that exists within its community or
reservation in order to provide information upon which decisions about what further
monitoring, inventory, or air quality management work the Tribe may choose to pursue.
Funding Mechanism: This objective and supporting activities typically may qualify for
financial support through the grant authority of either the EPA Indian General Assistance
Program (IGAP) or Clean Air Act §103 project grant. Contact your nearest Regional EPA
Tribal or Program Office for further information.
Acttvtttes / Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes basic air quality assessment. Adapting these
needs to respond to those of a specific reservation or tribal community is encouraged; taking
into consideration for what purpose the assessment will be used. EPA Regional Offices are
available to provide technical advice on what a particular tribe may require to adequately
support their proposed workplan activities. A timeline is then created by estimating the dates
by which each task, and sub-task, will be completed in order to accomplish the objective by the
planned date.
Conductsourceinventoryandcategorization:
¦ Training: Obtain training related to basic air quality assessment issues.
¦ Identify stationary sources through such activities as:
D Phone book/Internet review of businesses operating on the reservation.
D "Windshield survey" of businesses operating and activities on the reservation
and other reservation characteristics that influence air quality.
D Contact neighboring jurisdictions for relevant information.
D Use of EPA's MyEnvironment (http://www.epa.gov/myenvironment/). which
draws environmental information from several databases, to find local sources
¦ Area and mobile sources: Identify the major types of area and mobile sources, such
as agricultural practices, forestry burning, wood stoves, vehicle counts, unpaved
roads, etc.
¦ Smoke management issues: Is there agricultural or forestry burning on or near the
reservation that impacts the reservation communities? Is there a smoke
management program for agricultural or forestry burning? Is there a permitting
program for burning? If so, contact managers and determine what procedures and
Tribal Air Grants Framework
June 2015
Page | 12
-------
equipment are used in the management.
¦ Contact surrounding jurisdictions: For sources off reservation that may impact air
quality on the reservation. [Are there common air quality issues that should be
addressed with any of the surrounding jurisdictions?]
Trackandevaluateairqualitvcomplaints:
¦ Research past history of air quality complaints: Contact relevant tribal and local
offices (e.g. environmental or resource management, public health, hospitals,
neighboring state/local/tribal air quality offices) that may have received complaints
about air quality problems. Identify how many over what period of time, time of
year, possible causes that may be generating the problem.
¦ Establish a system for tracking air quality complaints that will provide ongoing
information on the type and severity of air quality problems of greatest concern to
the residents of the reservation.
¦ Indoor Air Quality: Contact housing, health and other relevant tribal departments
to document whether there has been a history of complaints associated with indoor
air. Contact EPA Regional IAQ for information on available assistance for such
complaints and training that may be available.
EvaluateAirMonitoringlnformation:
¦ Existing or past monitoring: Determine whether there has been or is currently any
air quality monitoring conducted on the reservation, its type and what the data
collected has shown about air quality.
¦ Off reservation monitoring: Identify any off reservation air quality or
meteorological data monitoring that may be collecting useful information for the
reservation and arrange to meet with the responsible agency to learn and establish
an information sharing agreement, as appropriate.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure
Possible Outputs: [These are examples of outputs for this objective; there may be others.]
¦ Report identifying: number and type of businesses, their locations, potential air
pollution produced, and the significant characteristics of the reservation that
should be considered in evaluating air pollution issues. Report should include a
map, if possible, with significant sources, population centers, and relevant
reservation characteristics annotated.
¦ Identify need for additional air quality activities such as a smoke management plan
for agricultural or forestry burning, regulatory development, education and
outreach, indoor air quality assessments, or other targeted projects.
Tribal Air Grants Framework
June 2015
Page | 13
-------
¦ Report of history and nature of air quality related complaints identified through
tribal agencies and other contacts.
¦ Written evaluation of additional data that would assist in more completely
evaluating air quality problems, such as emission inventory or monitoring,
including the type and how such additional data would be used to inform air
quality management decisions.
Possible Outcomes'. [These are examples of outcomes for this objective; there may be
others]
ExpressedasaresultofanindividualTribal grant:
¦ Tribe has identified any major sources or areas of concern
¦ Tribe has completed an air quality assessment for its reservation.
¦ Tribe has assessed the existence and nature of its indoor air quality problems.
ExpressedasameasureofoverallTribalprogramperformanceCoverastatedbaselineor
cumulativetotaD:
¦ Increase in the number of tribes who have completed a basic evaluation of all
sources of air pollution on the reservation supported by a report summarizing these
and identifying what the tribe considers may be the major sources of concern, if
any.
¦ Increase in the number of reservations for which an air quality assessment has
been completed.
¦ Increase in the number of tribes that have assessed existence and nature of Indoor
Air Quality problems.
Nationai FPA Performance IVIfasiirfYs>:
No specific factor has been established to measure performance in this area by EPA. The
following would be an example of such a future measure.
¦ Number of reservations for which a basic air quality assessment has been
completed and a report submitted to EPA
Tribal Air Grants Framework
June 2015
Page | 14
-------
Menu Item lbi Diesel Kinission Reduction Projects
Program Ob.tfcttvf: To assist state and federally recognized tribal communities in the
development and implementation of clean diesel retrofit programs that reduce health risks
associate
Activities/Tasks: The following tasks or activities are options for potential grantees to consider
in developing a work plan that includes diesel emissions reduction activities. Adapting these
needs to respond to those of a specific reservation or tribal community is encouraged, taking into
consideration the type of diesel equipment being used and needs of the tribe. EPA Regional
Offices are available to provide technical advice on what a particular tribe may require to
adequately support their proposed workplan activities. The EPA Regional offices have formed
seven Regional Collaboratives that will issue Requests for Proposals each year to establish clean
diesel projects.
¦ Identify a willing fleet, develop inventory of vehicles and engines and identify
appropriate technology and/or cleaner fuel for those vehicles or engines;
¦ Use EPA tools to quantify the potential emissions reductions;
¦ Develop proposal including timeline for completing retrofit project, and key partners
involved in implementation;
¦ Submit reports to Regional offices containing information regarding progress and
effectiveness.
Work plan Results: Results from EPA grant funded activities (also known as "deliverables")
are characterized as either outputs or outcomes. Both are important means of documenting grant
accomplishments. For explanation of outputs and outcomes see the Menu Item for Air Quality
Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ Identify fleet(s) which will be targeted for activities.
¦ Develop a plan for reducing diesel emissions from existing vehicles and
equipment.
¦ Select technologies or equipment to be used to target specific emissions.
¦ Develop plan for modifying the specific vehicles with technologies.
¦ Estimate pollution reduction (EPA encourages you to use the Diesel Emissions
Quantifier found at www.epa.gov/cleandiesel.)
Possible Outcomes: [These are examples of outcomes for this objective; there may be
others]
¦ Short term outcomes such as increased understanding of the environmental or
economic effectiveness of the implemented technology; dissemination of the
Tribal Air Grants Framework
June 2015
Page | 15
-------
increased knowledge via listserves, websites, journals, and outreach events; and
fine-tuned and improved use of the demonstrated technology.
¦ Medium term outcomes such as widespread adoption of the implemented
technology; documented emissions reductions from these and other sources of
diesel emissions in multiple states (emission reductions should be calculated using
the Diesel Emissions Quantifier tool); or acceptance of new technology by users
and manufacturers.
¦ Long term outcomes such as reductions in the number of children with asthma or
documented improved ambient air quality.
Nationai FPA Performance Mfasurfs:
Performance by EPA in this area is measured by:
¦ Number of diesel projects completed on Reservations.
Tribal Air Grants Framework
June 2015
Page | 16
-------
Menu llem lor conducting an Emissions Inventory
TRTBAL ATR WORK PLAN OH.IICTIVK: To prepare an emissions inventory for a
geographic area either within the boundaries of, or affecting a tribal reservation or Indian
community.
Background: An Emission Inventory is a process whereby air quality managers collect
information on the emissions from particular pollution sources within a specific area,
such as a reservation, to use in making planning and policy decisions on how to most
effectively reduce the quantity and impact of air pollution on human health and the
environment within that geographical area. A Tribe may consider the activities in this
Menu Item, when it determines that available sources and emissions information is not
sufficient for air quality planning and management.
Funding Mechanism: This objective and supporting activities may qualify for EPA
financial support through the authority of the Indian General Assistance Program (IGAP),
a Clean Air Act §103 projects, or a Clean Air Act §105 program grant among others.
Contact your nearest Regional EPA Tribal or Program Office for further information.
ACTTVTTTLS / TASKS: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes development of an Emissions Inventory.
Adapting these needs to respond to those of a specific reservation or tribal community is
encouraged, taking into consideration the specific air quality purpose for which the inventory
will be used. EPA Regional Offices are available to provide technical advice on what may be
required to meet the intent of specific situations. A timeline is then created by estimating the
dates by which each task, and sub-task, will be completed in order to accomplish the objective by
the planned date.
¦ Obtain emission inventory development training.
¦ Conduct a source inventory [Review and describe on-reservation pollution sources.
Identify applicable CAA requirements, if any. Write a report documenting sources
identified.]
¦ Conduct a source categorization.
¦ Prepare an Emissions Inventory Preparation Plan (describing what inventory will cover
and how it will be developed) for EPA review.
¦ Conduct emissions inventory according to EPA-reviewed Inventory Preparation Plan
¦ Prepare draft emissions inventory report for EPA review.
¦ Prepare final emissions inventory report.
¦ Evaluate the significance of the sources and emissions, including implications for
monitoring or regulatory program, noticing significance of and possibly a comparison to
any nearby attainment/nonattainment areas.
¦ Submit inventory data to National Emissions Inventory database.
WORK PLAN RESULTS: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
Tribal Air Grants Framework
June 2015
Page | 17
-------
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective; there may be others.]
Source inventory report.
¦ Inventory Preparation Plan.
¦ Draft emissions inventory report.
¦ Final emissions inventory.
Possible Outcomes: [These are examples of outcomes for this objective: there may be others]
Expres sedasaresultofanindi vi dual Trib al grant:
Submission of inventory data to National Emission Inventory database.
Expressedasameasureofoverall Tribal programperformanceCoverastatedbaselineor
cumulativetotal):
¦ Increase in number of Tribes that have completed basic source inventory.
¦ Increase in number of reservations or tribal communities for which emissions inventories
have been submitted to the National Emission Inventory database.
NATTONAF FPA PERFORMANCE MEASURED:
The following will be used to measure performance in this area by EPA:
• Total number of current emissions inventories in the National Emission Inventory
database for reservations or tribal communities.
Tribal Air Grants Framework
June 2015
Page | 18
-------
coiii/imcd Menu lieni lor Emissions Inventory
Objective: To prepare an emissions inventory for a geographic area within the boundaries of a
tribal reservation.
Possible Activities to Achieve Objective:
Note: The following tasks are options for grantees to consider in developing a work plan that
includes this objective. They should be modified and augmented as necessary to suit the
particular needs and circumstances of the grant applicant.
¦ Obtain emission inventory development training.
¦ Conduct a source inventory [Review and describe on-reservation pollution sources.
Identify applicable CAA requirements, if any. Write a report documenting sources
identified.]
¦ Conduct a source categorization.
¦ Prepare Inventory Preparation Plan (describing what inventory will cover and how it will
be developed) for EPA review.
¦ Conduct emissions inventory according to EPA-reviewed Inventory Preparation Plan
¦ Prepare draft emissions inventory report for EPA review.
¦ Prepare final emissions inventory report.
¦ Evaluate the significance of the sources and emissions, including implications for
monitoring or regulatory program and possibly a comparison to any nearby
attainment/nonattainment areas.
¦ Submit inventory data to National Emissions Inventory database.
Deliverables:
¦ Source inventory report
¦ Inventory Preparation Plan.
¦ Draft emissions inventory report.
¦ Final emissions inventory.
¦ Submission of inventory data to National Emission Inventory database.
National Reportable Outcomes:
¦ Number of Tribes who have completed a basic inventory of all sources of air pollution on
the reservation.
¦ Number of Tribes who have submitted reservation inventory to National Emission
Inventory database.
Tribal Air Grants Framework
June 2015
Page | 19
-------
Menu 11 em lor Promoting Unergy Efficiency, Renewable liner&v Jf (ireenliouse (ias
Reduction
Trtrat, Air Work pt, an Ob.tfcttvf To promote energy efficiency (EE) and renewable
energy (RE) options within the tribal administration and community, and throughout the
reservation, thereby ensuring multiple benefits such as comfort, cost effectiveness, energy
security, protection of air quality, and prevention of greenhouse gas emissions; demonstrate
leadership by reducing energy used in tribally owned buildings and planning for production
and use of onsite renewable and clean energy technologies.
Background: The energy used in our homes, schools, and businesses is a major source of
air pollution. Commercial buildings alone are responsible for 20% of U.S. greenhouse gas
emissions. The energy used in the average home can cause twice as many greenhouse gas
emissions as operating a vehicle for one year. Homeowners and businesses can typically
cut their energy use by one third with similar savings on energy bills and greenhouse gas
emissions. Saving energy in homes and other buildings are likely options on tribal lands.
Improving EE in buildings saves money, reduces emissions, and improves the reliability of
energy supplies by reducing the stress on sources and distribution systems.
Renewable and clean energy technologies - solar, wind, geothermal, hydropower, biomass,
and combined heat and power - are becoming increasingly cost-effective in an expanding
set of residential, commercial, and industrial applications. These technologies hold
potential for reducing air pollutants from power generation and primary energy use.
Investigating local renewable resources can also help tribes become more energy
independent. The U.S. Department of Interior (DOI) offers information relevant to energy
resource development activities on tribal lands at: http://teeic.anl.gov
Funding Mechanism: EE is usually self-financing; the money saved on future energy bills
pays for improvements to equipment, management practices, and operations. Significant
energy savings can be achieved with little or no capital investment, and numerous
technological options pay for themselves very quickly (e.g. lighting upgrades.) ENERGY
STAR® provides free information, tools, and resources to help businesses, governments,
homeowners and consumers improve energy performance and save money. Information
on the program and resources can be found at www.energystar.gov Special offers and
rebates occasionally offered by ENERGY STAR partners can be found at:
http://www.energvstar.gov/inde\.cfm?fuseaction=rebate.rebate locator
The U.S. Department of Energy (DOE) Office of Renewable Energy and Energy
Efficiency's Tribal Energy Program offers technical assistance, informational and
training resources along with limited funding assistance to tribes. Using DOE funds
administered under the 2009 American Recovery and Reinvestment Act (ARRA), many
tribes took preliminary EE and RE planning steps and can build on these initial efforts.
Home page: http://www.eere.energy.gov/tribalenergy/; Financial Opportunities page:
http://apps 1.eere.energy.gov/tribalenergy/financial.cfm; Project Financing Process page:
http://wwwl.eere.energv.gov/tribalenergy/guide/fmancing.html
Tribal Air Grants Framework June 2015 Page | 20
-------
The U.S. Department of Agriculture (USDA) Rural Development offers financial
programs to support essential public facilities and services such as electric service.
Federally recognized Native American and Alaskan Native groups and organizations can
apply for funds. Home page: www.rurdev.usda.gov
State-level funding for EE and RE can come from state public benefit funds (PBF),
Renewable Portfolio Standards or other EE and RE incentives or policies. In most states,
tribes are treated as other electricity customers, and are eligible to receive rebates,
participate in programs, and receive services which can reduce the cost of EE or RE
investments. To find out what programs are available, contact your local utility or the
state energy office (SEO) closest to your home.
Find contact information for SEOs: http://www.naseo.org/members/states; More
information on State PBFs from the Center for Climate and Energy Solution:
http://www.c2es.org/what s being done/in the states/public benefit funds.cfm
Find updated info about state PBFs, as well as funding and/or incentives for developing EE
or RE programs using the Database of State Incentives for Renewable Energy
(DSlRE):http://www.dsireusa.org/index.cfm?&CurrentPagelD=9 or the American Council
for an Energy-Efficient Economy Policy Database: http://vvvvvv.aceee.org/sector/state-
PQlicv
Acttvtttfs/ Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes air quality-related objectives. Adapting these
needs to take advantage of the best opportunities for EE and RE technologies in a specific
reservation or tribal community is encouraged. EPA Regional Offices are available to
coordinate training and provide technical advice on what a particular tribe may require to
adequately support their proposed workplan activities. A timeline or milestones are then
created by estimating the dates by which each task, and sub-task, will be completed in order to
accomplish the objective by the planned date.
Developacomprehensivecleanenergyplantosupporteconomicgrowthandemissions
reductions.
Energy Planning:
¦ Designate a tribal clean energy manager to champion and lead planning efforts;
¦ Conduct an inventory of energy use and forecasts on tribal land, specifying
end-use sectors and energy supply sources (natural gas, propane, type of power
generation on tribal land, electricity imports)
Evaluating Options:
¦ Calculate emissions attributable to energy use by end use sectors, estimate
energy efficiency to reduce emissions;
¦ Investigate EE technologies and RE sources on tribal land (distributed
renewables, waste heat, etc) and their potential for their use to reduce emissions.
Tribal Air Grants Framework
June 2015
Page | 21
-------
Organization Development:
¦ Research revenue sources for tribal investment in EE and clean energy sources
(utility programs, power sales agreements, performance contracts, etc);
¦ Identify effective implementation strategies for the tribal energy plan;
¦ Conduct education and outreach programs on emissions and climate change
effects.
Improveenergyperformanceoftriballvownedormanagedbuildingssuchasschoolsor
childcarefacilities:
¦ Determine how much energy buildings are using;
¦ Develop plans to improve energy performance
¦ Implement plans and track results using ENERGY STAR's portfoliomanager
benchmarki ngtool;
¦ Promote awareness and utilization of training available from EPA for building
owners and facility managers;
¦ Establish tribal purchasing and procurement policies and raise awareness for energy
efficient products such as ENERGY STAR rated products 1
ImproveEEinhome s:
¦ Promote tools to help improve EE in homes by using online tools such as the Home
Energy Advisor. HomeEnergyYardstick. and the consumerhomeimprovement
website;
¦ Promote do-it-vourselfEEmeasures such as sealing air leaks and installing
insulation;
¦ Provide training to tribal community members on how to perform EE
improvements and/or how to assess a home's EE.
Produceanduserenewableandcleanenergy
¦ Look for opportunities to integrate distributed RE into the tribe's energy
procurement process. Examples might be: agricultural methane to electricity,
landfill methane, biomass, wind, combined heat and power, geothermal and
photovoltaics (particularly when electricity is required for remote usages);
¦ Develop plans to identify renewable and clean energy resources on tribal lands;
¦ Utilize EPA's GreenPowerPartnership (GPP) tools to integrate green power
purchasing options into tribal electricity procurement;
¦ Become a member of EPA's CombinedHeatandPower (CHP) Partnership
program by promoting combined heat and power resources.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means
documenting grant accomplishments. For explanation of outputs and outcomes see the
Menu Item for Air Quality Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective: there may be others]
Tribal Air Grants Framework
June 2015
Page
-------
¦ Draft of tribal clean energy plan.
¦ Track number and square footage of facilities benchmarked.
¦ Number of training sessions and number of building managers, home builders, etc.
trained.
¦ Number of residential home assessments and energy audits conducted.
¦ Purchasing policies adopted and implemented.
Possible Outcomes'. [These are examples of outcomes for this objective: there may be others.]
ExpressedasaresultofanindividualTribal grant:
¦ Increased understanding of energy use and supply on tribal land.
¦ Increased knowledge of methods for improving EE based on number of residents
participating in programs.
¦ Percentage improvements in energy performance at benchmarked facilities.
¦ Increase in installed RE and combined heat and power capacity enabled by grant.
ExpressedasameasureofoverallTribalprogramperformanceCoverastatedbaselineor a
cumulativetotaD
¦ Inventories of energy use and supply completed for tribal lands.
¦ Cumulative total emissions reduction potential identified by tribal clean energy
plans.
¦ Number of tribal facilities and square footage benchmarked along with percentage
improvements in energy, GHG emissions, and energy costs in EPA's Portfolio
Manager tool over baseline.
¦ Increase in energy generated by renewable sources and combined heat and power
capacity over baseline.
National EPA Performance Measiire(s^: No factor has been specifically established to
measure EPA's performance in this area. The following would be an example of such
measures.
¦ Number of tribal facilities benchmarked.
¦ Number of tribes and businesses that are ENERGY STAR, Green Power
Partnership, and Combined Heat and Power partners.
¦ Number of ENERGY STAR labeled homes and buildings constructed on tribal
lands.
¦ Total energy use reductions in tribal facilities.
¦ Amount of green power purchased (kWh).
Tribal Air Grants Framework
June 2015
Page | 23
-------
McnullcmlbiTWKK 1111 piement:ilion
Objective: To partner with EPA Region 10 on implementation of the Federal Air Rules for
Reservations in Idaho, Oregon and Washington (FARR) and build tribal capacity to implement
a regulatory program.
Background: FARR implementation includes many different types of activities that
contribute toward the prevention of air pollution within the boundaries of Reservations.
Tribes can assist EPA in carrying out the FARR in a variety of ways depending upon their
capacity, experience, and air quality priorities. They also can request to be delegated
administrative responsibility for implementation of specific FARR sections on their
Reservation, increasing their CAA regulatory capabilities. The FARR currently applies on
39 Reservations in ID, OR, and WA, listed in the Appendix to 40 CFR Part 49, Subpart M.
Grant Funding: This objective and supporting activities may qualify for EPA financial
support through the authority of Indian General Assistance Program (IGAP), Clean Air Act
103 project grants, or CAA 105 program grants. For further information Tribes in Oregon
and Washington should contact Justin Spenillo (206/553-6125 or spenillo.Justin@epa.gov)
and in Idaho Michael McGown (206/378-5764 or mcgown.Michael@epa.gov).
Activities/ Tasks: The following tasks or activities are options for a grant applicant to
include in a work plan that includes FARR-related objective. Adapting these to respond to the
needs of a specific reservation or tribal community is encouraged. EPA Region 10 Air Program
staff should be contacted for technical and programmatic advice on what steps may be needed
to accomplish the objectives for specific situations.
¦ FARR Knowledge: Become informed on the FARR rules and how they apply to
your Reservation through Region 10 training and guidance, participation in FARR
workshops and conferences and online information. Share information on the FARR
with Tribal environmental, resource management and fire safety staff and managers,
as well as the reservation community See: http://www.epa.gov/rlOearth/farr.htm
¦ Outreach: Provide education and outreach to the community, tribal leadership, and
to emission sources on FARR requirements - particularly outdoor burning rules and
source registration requirements. Communicate and work cooperatively with local
fire departments and local air agencies with regard to FARR and related air quality
issues.
¦ Burn Bans: Participate in EPA conference calls to declare and publicize burn bans
when warranted by pollution levels and weather conditions.
¦ Complaint Response: Assist EPA FARR Complaint Hotline with response by
complaints and referring possible violations of the FARR to EPA enforcement staff.
Work with EPA to develop a protocol for handling FARR complaints received by the
Tribe. Provide records on the number and nature of complaints to EPA on quarterly
Tribal Air Grants Framework
June 2015
Page | 24
-------
basis.
¦ Source Registration: Help EPA verify applicability of FARR registration rule to
point sources on the Reservation.
¦ FARR Delegation: Explore the value of seeking delegation of one or more FARR
rules that will help manage air pollution within the Tribe's boundaries.
¦ FARR Rule Revision: Participate in the FARR rule revision process by providing
input and information to EPA on how new rules or changes to existing rules could
increase the effectiveness of the FARR in reducing air pollution risks.
Work plan Results: These are ways to measure and document that the above activities and
tasks are achieving the intended objective. These measures (outputs/outcomes) need to be
tracked for purposes of individual grant accountability, reporting to tribal community and
leadership, and describing the value of funding such work more broadly to Congress,
taxpayers, and the public.
Suggested Outputs: Parameters to set goals, track progress, and document accomplishments
and deliverables. Grant workplans must have clear outputs that will be produced for each
objective. Outputs should be linked to short term, medium term, and long term outcomes.
¦ FARR Outreach:
D Number of complaint response or outreach events at which FARR information was
provided to raise awareness about applicability of rules
D Number of people reached at each encounter or event.
D Report of other evidence of increased public awareness of the FARR and behavior
changes resulting.
¦ Burn Bans:
D Number of burn ban calls actively participated on along with EPA Region 10 and
Tribes,
D Number of times a burn ban was called on the Reservation, and associated efforts
made to publicize the burn ban on the Reservation.
¦ Complaint Response: Number and summary of air pollution complaints:
(a) ... responded to and the outcome,
(b) .. .referred to FARR Complaint Hotline or
(c) ... on which assistance was given to the Region 10 Hotline.
¦ Source Registration:
D Number of sources contacted in order to further their compliance with FARR
registration requirements.
¦ Delegation Agreement:
D A request to have one or more sections of the FARR delegated to the Tribe has been
formally submitted for consideration and approval.
Tribal Air Grants Framework
June 2015
Page | 25
-------
D A Delegation Agreement has been entered into with EPA for the Tribe to assume
administrative responsibility for implementation of particular sections of the FARR.
D Delegation Agreement terms are carried out successfully each year and results
reported to EPA.
Targeted Outcomes: Evidence of increased public awareness, changed behaviors,
reduced health risks, and/or improved air quality.
Tobereportedby Tribe asameasureofprogressand/orevidenceofaccomplishments:
D Compliance with Outdoor Burning and Burn Ban Rules: Change in knowledge,
attitudes or behavior of community members regarding Outdoor Burning practices,
and Burn Ban regulations, and other pertinent FARR rules based upon outreach,
education, compliance assistance and complaint response.
D Prohibited Outdoor Burning: Number of complaints received about prohibited
outdoor burning decline over time.
D Registration Compliance: Point sources made aware of their need to register under
the FARR sources assisted with registering, and sources that subsequently do
register as a result of increased awareness and assistance provided. Tobe
reportedasaRegional measureofprogress-towhichtribaloutputsmav contribute:
D Burn Ban and Outdoor Burning Compliance: Amount of illegal burning during
burn bans or in violation of the FARR outdoor burning rule decreases over time
improving air quality on reservation.
D Registration: Percentage of known sources that have had the applicability of the
FARR registration requirement verified and, if applicable, have submitted all
required registration information.
D Delegation Agreements: Number of Tribes that have signed Delegation
Agreements with EPA for one or more FARR rules.
Nattonat F,PA Performance Mf.asiirfYst: These are ways in which grant funded
activities can produce national level outputs that Regions and Tribes are tracked and which c
impact that allocation of funding and resources to a Region.
¦ Number of tribes that have been delegated responsibility for implementation of one or
more sections of the Clean Air Act or of a Federal Implementation Plan, such as the
Federal Air Rules for Reservations. [Note: This measure impacts the amount of CAA
Tribal grant funding allocated to a Region under the OAR formula of 2006 as evidence
of a Tribe that has taken on regulatory responsibilities for protecting air quality on their
Reservation.]
¦ Number of tribes with reservations or tribal trust lands that have CAA protections
through the implementation of comprehensive FIPs (such as the Region 10 FARR) or
TIPs to effectively "level the playing field" with surrounding air regulatory jurisdictions.
[Note: At this time, this is a possible future measure.]
Tribal Air Grants Framework
June 2015
Page
-------
Menu llcm for Indoor Air Qimlhv Assessment & Trniniii"
Tribal Air Work pian Objective: To assess the extent of indoor air pollution in
reservation and tribal buildings and respond to indoor air quality (IAQ) complaints; to evaluate
the potential relation of adverse health impacts to poor IAQ; and to provide training for tribal
housing, health, and environmental professionals and members of the public on IAQ issues.
Background: Poor Indoor Air Quality has the potential to produce severe adverse human
health impacts. EPA supports voluntary measures to educate and help homeowners and
building managers understand the causes and prevention of poor indoor air quality and
measures they may wish to undertake to ensure that the air will not have detrimental effects
on the health of inhabitants. Assessment is often the first step in determining whether such
voluntary measures are appropriate. Addressing the causes of indoor air pollution often
involves no or little cost; such mitigation costs do not fall within the financial authority of
EPA.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial
support through the grant authority of either the Clean Air Act §103, Indian General
Assistance Program, and special Indoor Air Quality grant opportunities. Contact your
nearest Regional Tribal, Air Program Office for further information. You may also wish to
contact your nearest Housing & Urban Development (HUD) or Indian Health Service (IHS)
offices to find out what assistance they may be authorized to provide.
Acttvtttes / Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a workplan that includes indoor air quality-related objectives. Adapting
these needs to respond to those of a specific reservation or tribal community is encouraged,
taking into consideration the types of buildings that may be of highest priority and potential
resources available for remediation. EPA Regional Offices are available to provide technical
advice on what a particular tribe may require to adequately support their proposed workplan
activities. A timeline is then created by estimating the dates by which each task, and sub-task,
will be completed in order to accomplish the objective by the planned date.
Possible Activities:
¦ Educate tribal elders, Tribal leadership (Housing, Health, Education, Environmental, etc.)
to build community partnership and advocacy to ensure safe and healthy indoor
environments in Tribal homes, schools, and buildings.
¦ Obtain assistance and/or training on conducting IAQ assessments and community
outreach.
¦ Conduct basic assessment of tribal homes and buildings; conduct walkthrough
inspections that are primarily observational looking for pollutant sources, water and
moisture problems, ventilation, hygiene, bio-contaminants, and observations about
Tribal Air Grants Framework
June 2015
Page | 27
-------
temperature and humidity, etc. Checklists may be beneficial to this effort. A
Quality Assurance Project/Program Plan may be required, depending on the extent
of any monitoring pursued.
¦ Gather information about health issues related to IAQ in tribal buildings or housing.
¦ Provide indoor air training for tribal facilities, health, and environmental staff,
including common pollutants, health effects, prevention, assessment, and clean up.
¦ Provide training to building residents/members of the public on IAQ issues,
including common pollutants, health effects, prevention, assessment, and clean up.
Focus on what a residents and building occupants can do to prevent IAQ problems.
¦ Incorporate Indoor Air improvements as part of tribal construction and renovation
planning.
¦ Introduce Green building codes with IAQ provisions (e.g. Energy Star/IAQ Plus).
¦ Include IAQ planning in tribal new home construction and renovations.
Note: Remediation work that may be needed to resolve IAQ problems is typically not a
fundable activity under CAA grants. However, plans for how needed remediation will be
accomplished should be considered in developing an indoor air quality program. Many
needed changes can be accomplished easily by the building owner. Also, there may be
other funding sources available to carry out larger renovations.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective: there may be others.]
¦ Summary report of home IAQ assessments including the number of homes assessed,
a summary of all data and ongoing concerns or issues identified.
¦ Summary of health issues related to IAQ in tribal buildings.
¦ Summary report of training & workshops held for tribal staff or professionals and
community members, including number of tribal personnel trained. Include a course
evaluation and a summary of evaluation results (Note: Results from training could
be an outcome. See Possible Outcomes' below).
¦ Demonstration projects to train tribal members/personnel/others in IAQ assessment
and remediation.
¦ Establishing tribal healthy building targets and plans in four areas: culturally
sensitive IAQ awareness & education, IAQ assessments, IAQ remediation activities,
new construction/renovation projects addressing IAQ.
¦ Green (including Healthy IAQ) Building codes introduced / passed
¦ Tribal Weatherization projects that address IAQ
Tribal Air Grants Framework
June 2015
Page | 28
-------
Possible Outcomes: [These are examples of outcomes for this objective: there may be
others]
¦ Report on any available data that indicates improvement in indoor air quality, health
outcomes, behavior changes as a result of grant-funded work.
¦ Documented change in knowledge, attitudes or behavior of students successfully
completing IAQ training courses.
¦ Development and application of Tribal technical skills & capabilities for IAQ
assessment and remediation.
¦ Development of tribal building codes incorporating IAQ provisions.
¦ Increase in the number of reservations or tribal communities where IAQ assessments
or training were provided.
¦ Increase in the number of indoor air quality assessments in buildings on reservations
and problems subsequently remedied.
Nationai F/PA Performance IVIfasiirfYs>:
No factors have been established to measure performance by EPA in this area. The following
would be examples of what such measures might be:
¦ Number of tribal residences and buildings that have had indoor air quality
assessments.
¦ Number of residents or building owners that have been reached with training or
information on how to assess or improve indoor air quality.
¦ Number of tribes that have implemented the Tools for Schools program.
¦ Number of tribes that have instituted smoking reduction campaigns targeted to
reduce smoking rate generally and to protect children and others at risk populations
from the risks of second hand smoke.
Tribal Air Grants Framework
June 2015
Page | 29
-------
Menu llcm lor acklicssinu Local or I niqiic Air Qunlily Issues
Tribal Air Work pian Objective: To identify special or unique local air quality issues,
their impact on human health and the environment, options for addressing the concerns
identified, and, as appropriate, implementing solutions.
Background: Local or Unique Air Quality Issues encompass a variety of air pollution
problems that do not fall within any of the broader, more common, concerns that are found
on reservations or in tribal communities. These, perhaps more than most Menu Item
objectives, may require a customized response and may require research to determine what
would be appropriate to the particular circumstances.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial
support through the grant authority of the Indian General Assistance Program (IGAP), or
either of the Clean Air Act Sections §103 or §105 depending upon if the work is assessment
of or investigation into causes and prevention the air quality problem, or actual
implementation of a control strategy. Contact your nearest Regional EPA Tribal or Program
Office for further information.
Acttvtttes / Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that include activities related to unique or local air quality
issues. Adapting these needs to respond to those of a specific reservation or tribal community is
encouraged; taking into consideration for what purpose the information will be used. EPA
Regional Offices are available to provide technical advice on what a particular tribe may require
to adequately support their proposed workplan activities. A timeline is then created by
estimating the dates by which each task, and sub-task, will be completed in order to accomplish
the objective by the planned date.
¦ Based upon an initial air quality assessment (See menu topic: "Basic Air Quality Needs
Assessment"), evaluate the existence and significance of any unique air quality issues
or concerns, through direct observation, conversations with community, managers,
council, adjoining air quality jurisdictions, EPA and other federal agencies, and other
appropriate sources. Such unique concerns may include: open burning of solid waste,
agricultural field burning, forestry prescribed-burning, developments such as casinos,
pollutants that may affect cultural resources and indoor air quality, radon and others.
¦ Network with others involved in addressing the same problem such as the solid waste
program. Participate in policy groups that may exist for developing a regulatory
response.
¦ Attend training to understand the causes and possible solutions to the problem.
¦ Provide education and outreach to the reservation community and tribal leadership on
the issue, impact on tribe, and options for responding to the problem. Determine
public and tribal position on the seriousness of the problem to the community,
Tribal Air Grants Framework
June 2015
Page | 30
-------
preferred responses, priority among other environmental and air quality concerns.
¦ Develop recommended approach to mitigating or monitoring the problem in the future.
¦ If regulatory response is an option, develop a plan for instituting a regulatory response
and subsequent enforcement.
¦ For burning on Indian-owned land that is not on the reservation (e.g., land clearing for
off-reservation casino development), evaluate the affected state's open-burning rules
and consider them as guidelines for Tribal activities.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ A report analyzing the nature of the problem, its impact on human health and
environment on the reservation, and sources of information used to identify the problem
and its potential impact.
¦ A report on the networking with potential collaborators/resources, policy groups and
other agencies contacted, meetings attended, membership in policy groups and
outcomes from such connections.
¦ A report on courses attended and how information gained was useful or not to
understanding the problem and potential solutions.
¦ A report on education and outreach conducted and what was learned about the various
positions held with regard to the air quality problem. This could include number of
pamphlets distributed, number of speaking engagements, and changes to school
environmental curricula.
¦ A report which evaluates options for addressing the problem, and recommends
options, including why they are preferred. This should include coordination with the
tribe's environmental management programs and include documentation of the report
being presented to tribal leadership and their response.
¦ Report on any regulatory type activities, copies of regulations proposed or passed,
records of enforcement, improved practices, and any evidence of mitigation of the
problem.
Possible Outcomes: [These are examples of outcomes for this objective; there may be others.]
Expres sedasaresultofanindi vi dual Trib al grant:
Please, note: Several of the outputs (noted above with italics) can also be outcomes
for an individual grant under this Menu Item. Thus, a report produced or a meeting
held is indeed an output. However, if the report describes information gained, or
changes resulting, or ameliorative actions, etc. then it is describing an outcome.
Tribal Air Grants Framework
June 2015
Page | 31
-------
Expressedasameasureofoveral 1 Tribal pro^rainperfonnancefoverastatedbaselineor
cumulativetotal):
¦ Increase in the number of tribes that have participated in addressing a particular air
quality concern and the nature of participation.
¦ Increase in instances where tribal effort on a local issue has made a documented
impact in its being addressed, either by the tribe, or other state, local or federal
agencies. For example, creation of an ongoing work group that developed a new
strategy for dealing with the problem that became a model for others.
¦ Reduction in the number of complaints received regarding outdoor burning practices
Tribal Air Grants Framework
June 2015
Page | 32
-------
Menu Ik-ni lor Pnrticipnlion in Policy Development (ironps
TRIBAL AIR WORK PLAN OBJECTIVE: To identify special or unique local air quality
issues, their impact on human health and the environment, options for addressing the concerns
identified, and, as appropriate, implementing solutions.
Background: Local or Unique Air Quality Issues encompass a variety of air pollution
problems that do not fall within any of the broader, more common, concerns that are
found on reservations or in tribal communities. These, perhaps more than most Menu
Items objectives, may require a customized response and may require research to
determine what would be appropriate to the particular circumstances.
Funding Mechanism: This objective and supporting activities may qualify for EPA
financial support through the grant authority of the Indian General Assistance Program
(IGAP), or either of the Clean Air Act §103 or §105 depending upon if the work is
assessment of or investigation into causes and prevention the air quality problem, or
actual implementation of a control strategy. Contact your nearest Regional EPA Tribal or
Program Office for further information.
ACTTVTTTES / TASKS: The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes participation in air policy development
workgroups. Adapting these needs to respond to those of a specific tribal professional's interests
is encouraged. EPA Regional Offices are available to provide guidance on the workgroups that
are currently involved in policy development and how a tribal professional may become
involved. A timeline is then created by estimating the dates by which each task, and sub-task,
will be completed in order to accomplish the objective by the planned date.
• Participate in Regional Planning Organizations (RPOs), national tribal organizations/ forums/
workgroups, or other tribal, local, state, regional or national/EPA organizations, such as:
National Tribal Air Association, EPA's 8 Hour Ozone Designations Workgroup, RTOCs, or
NTOCs, the TAMS Steering Committee, etc.
• Select a particular work group of an air related organization that tribal professional can join
and commit to actively become involved. Commit to a specific amount of time that will be
devoted to this participation or percentage of work under the grant.
• Periodic reports on contributions made to the group and information and issues addressed in
the group to EPA and the tribal council and community, as a means of building tribal
capacity to understand broader air quality issues and participate in policy development.
WORK PLAN RESULTS: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
Tribal Air Grants Framework
June 2015
Page | 33
-------
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure
Possible Outputs: [These are examples of outputs for this objective; there may be others]
• Report of meetings attended and subjects addressed at each, as well as how this information
was then communicated to the tribal government and/or community, including at council
meetings, powwows, schools, or similar events.
Possible Outcomes: [These are examples of outcomes for this objective; there may be others]
Expres sedasaresultofanindi vi dual Trib al grant:
• Documentation of participation, including details of participation in the various groups, the
nature of participation, decisions or policy developed through
ExpressedasameasureofoverallTribalprogramperformance:
• Increase in number of tribes that have participated in development of air quality policy at
regional or national level.
Increase in breadth of policymakers' understanding of the tribal perspective on air quality
issues.
• Policy development that better takes into consideration the air quality issues on reservations
and in tribal communities and the unique tribal perspectives on these.
NATTONAE EPA PERFORMANCE MEASURE:
No specific measures for tribal participation in policy development exist at this time.
Tribal Air Grants Framework
June 2015
Page | 34
-------
Menu llcm lor Kndon Kisk Reduction in Tribal Indoor Undon (irunts
fas ilcsci ihcil in Stale Indoor Ration (Irani SJR( i I'roifrani)
Program Objective: To assist states and federally recognized Indian Tribes in the
development and implementation of programs and projects reducing health risks associated
with radon exposure.
Background: Each year EPA Headquarters allocates funds to the ten EPA Regional
Offices for award to recipients. The Regional Offices are responsible for determining the
amount of Federal funding for each individual recipient within its jurisdiction. Subsequent
funding is dependent on EPA's evaluation of recipients' performance during the current
and prior grant years, on the most recent radon risk information available for the recipient,
and on the degree of success and documented risk reduction being achieved.
Funding Mechanism: The Office of Radiation and Indoor Air oversee the State (Tribal)
Indoor Radon Grant Program (SIRG). Funding authorities include the Indoor Radon
Abatement Act, 15 U.S.C. 2661, Section 306, which are awarded with a match
requirement.
Activities/Tasks: The following tasks or activities are options for grantees to consider in
developing a work plan that includes radon risk reduction objectives. Adapting these needs to
respond to those of a specific reservation or tribal community is encouraged; taking into
consideration for what purpose the monitoring data will be used. EPA Regional Offices are
available to provide technical advice on what a particular tribe may require to adequately support
their proposed workplan activities. Applicants should refer to the SIRG Program Guidance and
Handbook - Chapter 3, for specific program and project information. A timeline is created for
the activities by estimating the dates by which each task, and sub-task, will be completed in order
to accomplish the objective by the planned date.
¦ Educating tribal members, real estate professionals, tribal housing authority and home
inspectors, builders, Tribal Council and local building code officials, and others;
¦ Persuading home builders to include radon-resistant techniques in their new homes;
¦ Encouraging Tribal Council to adopt radon-resistant building codes; and
¦ Promoting testing and mitigating in residential real estate transfers by home sellers and
buyers.
Tribal Air Grants Framework
June 2015
Page | 35
-------
Work plan Results: Results from EPA grant funded activities (also known as "deliverables")
are characterized as either outputs or outcomes. Both are important means of documenting grant
accomplishments. For explanation of outputs and outcomes see the Menu Item for Air Quality
Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ Development of plans for radon testing and mitigation in homes and schools.
¦ Setting targets for programmatic results in four areas: testing, mitigation, radon resistant
new homes, and innovative educational awareness activities (i.e. conferences, workshops,
press/media events).
¦ Report on the number of activities which result in increased radon testing and mitigation
in homes.
¦ Report on the number of demonstration projects to train participants in radon risk
reduction techniques.
¦ Participation in Radon outreach activities, particularly in conjunction with Radon Action
Month (January).
¦ Number of project results to support radon risk reduction such as: calls received, meetings
held, etc.
¦ Incorporation of weatherization techniques in mitigation practices. (DOE study)
Possible Outcomes. [These are examples of outputs for this objective; there may be others]
¦ Number of new homes and tribal facilities built radon-resistant.
¦ Number of home mitigations in conjunction with Tribal outreach programs.
¦ Number of school mitigations.
¦ Number of results-oriented, collaborative partnerships formed.
¦ Number of homes and facilities retested after mitigation and homes retested every 2-3
years.
¦ Less lung cancer deaths.
NationalFPA PerformanceMf.asttrf.s:
EPA has not established specific factors to measure performance in this area. The following
would be examples of possible measures:
¦ Number of tribes with established radon mitigation programs and the total number of
mitigations.
¦ Number of tribes which have adopted radon-resistant building codes or practices.
¦ The total number of new homes built radon-resistant.
Tribal Air Grants Framework
June 2015
Page | 36
-------
Menu llcm lor Residential W ood Smoke Reduction Program
Trtrat, Air Workpt,an Ortfcttvf: To reduce emissions from residential wood burning and
improve ambient and indoor air quality; mitigate the negative health effects of wood smoke exposure
for community residents; and contribute to area compliance with Clean Air Act requirements.
Background: Emissions from Wood Smoke can result in adverse human health impacts. EPA
supports measures, including education, outreach, and more proactive control measures to reduce the
detrimental effects of wood smoke emissions on the health of inhabitants.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial support
through the grant authority of either the Clean Air Act § 103, Indian General Assistance Program,
and special Indoor Air Quality grant opportunities. Contact your nearest Regional Tribal, Air
Program Office for further information. You may also wish to contact your nearest Housing &
Urban Development (HUD) or Indian Health Service (IHS) offices to find out what assistance they
may be authorized to provide.
Activities/Tasks: The following tasks or activities are options for grantees to consider in developing a
work plan that includes wood smoke risk reduction objectives. EPA Regional Offices are available to
provide technical advice on what a particular tribe may require to adequately support their proposed
workplan activities. A timeline should be created for the activities by estimating the dates by which each
task, and sub-task, will be completed in order to accomplish the objective by the planned date.
• Assess the level of residential wood combustion at Tribal community to see if it is a
problem. Note, EPA has county inventories available that may help.
• Obtain funding for remediation activities if a wood smoke problem is perceived.
• Identify any wood burning appliances that have generated complaints against nearby residents.
• Make use of any secured funding for remediation activities to replace non-EPA certified wood
appliances, mainly through implementation of change-out programs. Prioritize appliances
generating complaints.
• Discourage installation or continued use of hydronic heaters.
• Distribute information available on EPA's Burn Wise website.
• Evaluate impact of program via EPA's wood stove and fireplace calculator.
WORKPrANRFSTTTTS: Results from EPA grant funded activities (also known as "deliverables") are
characterized as either outputs or outcomes. Both are important means of documenting grant
accomplishments. For explanation of outputs and outcomes see the Menu Item for Air Quality
Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective; there may be others]
¦ Report the number of wood burning appliances that have generated complaints against
nearby residents.
¦ Report if funds were secured for remediation activities.
Tribal Air Grants Framework
June 2015
Page | 37
-------
¦ Report the number of wood stoves, wood heaters, fireplaces and outdoor wood-fired
boilers changed out, scrapped and destroyed or converted.
¦ Report the number of residents educated on and regularly using clean burning practices.
¦ Report the impact of program via EPA's wood stove and fireplace calculator.
Possible Outcomes. [These are examples of outputs for this objective; there may be others]
¦ Reduction of indoor and outdoor particulate levels.
¦ Reduction of occurrence of asthma and other health impacts of wood smoke.
¦ Improvement in visibility.
¦ Reduction in the number of chimney fires.
¦ Reduction of visible smoke reports on burn curtailment days.
¦ Reduction in total volume of wood burned community-wide.
Nationai F/PA Performance Mfasurfs:
EPA has not established specific factors to measure performance in this area. The following would be
examples of possible measures:
¦ Number of tribes with established wood smoke reduction programs and the total number of
mitigations.
¦ The total number of wood stoves, wood heaters, fireplaces and outdoor wood-fired boilers
changed out.
Tribal Air Grants Framework
June 2015
Page | 38
-------
Menu llcni lor Addressing Uoad Dust Emissions
Guidance for developing a Grant Workplan element to address Road Dust in rural Alaska
Trtbat, Air Workptan Objfcttvf: To address road dust emissions in tribal communities
and on reservations through activities that will reduce human exposure to particulate matter.
Background: Emissions from Road dust have the potential to result in adverse human health
impacts. EPA supports measures, including education, outreach, and more proactive control
measures to reduce the detrimental effects that road dust emissions may have on the health of
inhabitants.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial
support through the grant authority of either the Clean Air Act §103, Indian General
Assistance Program, and special Indoor Air Quality grant opportunities. Contact your
nearest Regional Tribal, Air Program Office for further information. You may also wish to
contact your nearest Housing & Urban Development (HUD) or Indian Health Service (IHS)
offices to find out what assistance they may be authorized to provide.
Acttvtttfs/ Tasks: The following tasks or activities are options for a grant applicant to
consider in developing a workplan that includes indoor air quality-related objectives. Adapting
these needs to respond to those of a specific reservation or tribal community is encouraged,
taking into consideration the types of buildings that may be of highest priority and potential
resources available for remediation. EPA Regional Offices are available to provide technical
advice on what a particular tribe may require to adequately support their proposed workplan
activities. A timeline is then created by estimating the dates by which each task, and sub-task,
will be completed in order to accomplish the objective by the planned date.
Education and outreach to the community on how they can help to reduce the impacts from dirt
roads by:
¦ Reducing unnecessary driving, particularly during the dust season. Plan trips such that
several things can be accomplished at once.
¦ Prohibit unnecessary four-wheeler or other vehicle use when conditions are dry.
¦ Make public announcements when driving needs to be curtailed due to dust and wind
conditions.
¦ Have teachers talk to their classes about the harm that road dust can cause to health and the
environment. Dust aggravates existing heart and lung disease, damages lung tissue and
most seriously impacts children, seniors and people with asthma and heart conditions.
¦ Encourage driving at steady but slow speeds to avoid kicking up dust. Stop and start
evenly.
Speed limits and speed bumps: Impose speed limits and create speed bumps that will force
traffic to slow down.
Tribal Air Grants Framework
June 2015
Page | 39
-------
Road treatments:
Waterapplications: Applying water on the days when road dust is high seems to be a common
solution. It requires a water spreader and the availability of water for application, of course. A
tank truck for water is sometimes used or water can be applied by an appropriate trailer pulled by
a truck or four-wheel vehicle. Most air strips need to have some method to reduce their runway
dust and may be able to be a partner in the operational and maintenance costs. Someone needs to
be available to drive the water truck on an as needed basis.
Palliatives: Chemical palliatives are available commercially that will bind with the road dust and
form a harder surface for varying periods of duration. The factors to consider with these is
whether the chemicals then degrade into the soil or water in a way that will be harmful to
vegetation or health "down the road." Searching on "road dust control" on the Web will generate
some of these options. Gravelamendments: Gravel can help substantially to reduce road dust,
although how long it lasts can vary and whether it is cost effective depends upon how readily
available it is in the local area.
Paving: Although paving may temporarily help with road dust, paved roads are costly to install
and maintain in rural Alaska. Also, when they are used for a while, dust gets tracked onto them
and is then re-entrained into the air by traffic, just as with unpaved roads.
Work plan Results: Results from EPA grant funded activities (also known as
"deliverables") are characterized as either outputs or outcomes. Both are important means of
documenting grant accomplishments. For explanation of outputs and outcomes see the Menu
Item for Air Quality Administration Infrastructure.
Possible Outputs: [These are examples of outputs for this objective: there may be others.]
¦ Report on the strategy developed for addressing and reducing road dust, including
options considered and advantages of the approach selected.
¦ Outreach events conducted and people reached with information on how they can
help reduce road dust and its impacts.
¦ Measures of success in reducing road dust.
Possible Outcomes'. [These are examples of outcomes for this objective: there may be
others]
Expres sedasaresultofanindi vi dual Trib al grant:
¦ Report on any available data that indicates improvement in air quality, health
outcomes, behavior changes as a result of work on road dust.
¦ Documented change in knowledge, attitudes or behavior of public, community
leaders, students, etc. on how they can help reduce road dust.
Expressedasameasureofoverall Tribal programperformanceCoverastatedbaselineor
cumulativetotal):
¦ Increase in the number of reservations or tribal communities where a strategy for
Tribal Air Grants Framework June 2015 | 40
-------
reducing road dust problems have been developed and number implemented,
including results of implementation on reduction in road dust and its impacts on
public health.
Tribal Air Grants Framework
June 2015
Page | 41
-------
Menu llcni lor Parlicipalinu in Uiilcmsiking sind r.nl'orccincnl
Tribal Air Work pian Objective: To reduce emissions of criteria pollutants or air toxics
by setting and enforcing emission standards or work practice requirements for stationary, area,
or mobile sources of air pollution on tribal lands.
Background: Participating in Rulemaking and Enforcement activities normally follows after
a Tribe has assessed the nature and seriousness of air pollution and its impact on their
reservation communities and evaluated what types of rules are needed to protect air quality
and prevent pollution. Rulemaking may involve the drafting and promulgation of tribal rules
or a Tribal Implementation Plan (TIP), or participating in the federal rulemaking process,
either through a Federal Implementation Plan (FIP) or a State Implementation Plan (SIP), for
example to bring a NAAQS Non-attainment Area into attainment or to maintain the air
quality of a NAAQS Attainment Area. Enforcement of air quality rules may be under tribal
authority, through assisting with federal rules enforcement or through delegation of
enforcement authority under specific Clean Air Act sections.
Funding Mechanism: This objective and supporting activities may qualify for EPA financial
support through the grant authority of, principally, Clean Air Act §105 program grants.
Contact your nearest Regional Air Program Office for further information.
Activities/ Tasks The following tasks or activities are options for a grant applicant to
consider in developing a work plan that includes rulemaking and enforcement. Adapting these
needs to respond to those of a specific reservation or tribal community is encouraged. EPA
Regional Offices are available to provide technical advice on what a particular tribe may require
to adequately support their proposed workplan activities. A timeline is then created by
estimating the dates by which each task, and sub-task, will be completed in order to accomplish
the objective by the planned date.
¦ Assist EPA with enforcement responsibilities, as appropriate, by:
D Identifying point sources on the reservation subject to EPA regulation and
enforcement.
D Discussing the opportunities for Tribal involvement with compliance monitoring
and compliant response with EPA Regional Enforcement Office.
D Obtaining appropriate training on inspection and enforcement procedures of
value to the reservation sources.
D If of mutual interest to EPA Region and Tribe, consider applying for EPA
federal inspector credentials for tribal staff to assist EPA with compliance
monitoring of sources.
D If tribe and EPA agree that tribal inspectors with federal credentials will be
valuable in assisting EPA and will build tribal capacity, take required steps to get
training and approval for authorized credential issuance.
Tribal Air Grants Framework
June 2015
Page | 42
-------
D When EPA inspector credentials are issued tribal staff will conduct inspections
on EPA's behalf and prepare appropriate reports for EPA's enforcement.
¦ Preparation of delegation request for federal regulations (such as Part 71, PSD, NSPS,
NESHAP, MACT, etc.) following delegation guidance.
¦ Adopt and implement regulations with emission standards or work practice
requirements for:
D stationary sources (e.g., reasonably available control technology or RACT
standards for NOx and VOC sources)
D area sources (e.g., burn barrel restrictions, asbestos demolition work practice
standards, waste dumping restrictions)
D mobile sources (e.g., idling prohibitions, motor vehicle inspection and
maintenance requirements)
¦ Adopt and implement New Source Review (NSR) permit regulations for major or
minor stationary sources.
¦ Adopt and implement Title V permit program regulations.
¦ Adopt and implement source-specific regulations to restrict potential emissions.
¦ Preparation of TIP following TIP guidance.
Note: TIPs give tribal programs federal authority and backing, however, tribes have
inherent authority to develop regulations in an Air Quality Management Program without
federal authority and backing, if they choose.
¦ Preparation of TIP continued:
D regulatory programs
D source specific programs
D area-wide limits/controls
D mobile source issues
D point source issues (e.g., burn barrel restrictions)
D inspection/enforcement NOx
D attainment strategies source
D pre-construction permits
D regional haze plans
¦ Operat; an air enforcement program:
D Plan enforcement activities and target inspections/investigations
D Conduct inspections, draft inspection reports, and conduct compliance
analyses
D Review compliance certifications and stack test or continuous emission
monitor (CEM) reports
D Issue notices of violations (NOVs), administrative orders or administrative
complaints
D Negotiate settlements or proceed with enforcement actions
Work plan Results: Results from EPA grant funded activities (also known as "deliverables")
Tribal Air Grants Framework
June 2015
Page | 43
-------
are characterized as either outputs or outcomes. Both are important means of documenting grant
accomplishments. For explanation of outputs and outcomes see the Menu Item for Air Quality
Administration Infrastructure
Possible Outputs:
¦ Tribe with EPA inspector credentialed staff and sources inspected by tribal inspectors.
¦ Compliance assistance provided to sources and complaints responded
¦ Reduced complaints about air pollution from regulated sources.
¦ Regulations codified or ordinances enacted by Tribal government.
¦ Enforcement actions taken (e.g., number of NOVs, administrative orders or
complaints).
¦ TIP submitted to EPA.
¦ Delegation request submitted to EPA.
¦ Dollars in penalties collected or dollars in value of environmentally beneficial
supplemental enforcement projects (SEPs) completed impacting tribal air quality.
Possible Outcomes'.
Expressed as a result of an individual Tribal grant:
¦ Number of tons/pounds of pollution removed from the air as result of promulgated
regulations.
¦ Number of people breathing cleaner air and resulting improved health
Expressedasameasureofoveral 1 Tribal pro^rairiperforinancefoverastatedbaselineor
cumulativetotal):
¦ Increase in the number of tribes who have enacted tribal air quality regulations or
ordinances.
¦ Increase in the number of tribes who have submitted a Tribal Implementation Plan
(TIP).
¦ Increase in the number of Tribes who have been granted an approved TIP.
¦ Increase in the number of tribes assisting with implementation of Federal
Implementation Plans or other regulations.
¦ Increase in the number of Tribes who have requested delegation of a Clean Air Act
regulatory program.
¦ Increase in the number of Tribes who have been granted delegation of a Clean Air Act
regulatory program
¦ Increase in the number of tribal air quality enforcement actions taken.
¦ Increase in the number of tons/pounds removed from the air as result of tribal
regulations.
Nationai F/PA Performance IVIfasiirfYs>:
The following illustrates how EPA may measure performance in this area.
Tribal Air Grants Framework
June 2015
Page | 44
-------
¦ Number of tribes actively participating in regulatory air quality management,
including submitting a TIP to EPA for approval, substantial assistance with
the implementation of a FIP, or direct implementation of their own tribal air
quality regulations to reduce the level or impact of air pollution
Tribal Air Grants Framework
June 2015
Page | 45
-------
Glossary of Terms and Acronyms
Area Sources: Sources, either facilities or activities whose individual emissions do not qualify
them as point sources.
AQI: Air Quality Index - Used to inform the public about the potential health impacts of ambient
air quality at a particular time and location.
CAA: Clean Air Act - Federal Laws enacted to improve the air quality or prevent its
deterioration so that it is not a danger to public health and welfare. 42 United States Code
§§7401 et seq.
EI: Emissions Inventory - A detailed listing of pollutants emitted from specific sources in a
defined area. Els can include point sources, area sources and mobile sources.
EPA: Environmental Protection Agency - Executive Branch agency responsible for
implementation and enforcement of the CAA and other environmental statutes.
FIP: Federal Implementation Plan - Federal rules in the Code of Federal Regulations that are
established to manage air quality on one or more reservations.
HAP: Hazardous Air Pollutant - An air pollutant (other than the six criteria pollutants) that is
regulated through control measures applicable to the sources through Maximum Available
Control Technology (MACT) standards, rather than ambient standards.
Major Sources: Generally point sources that have the potential to emit over a certain number of
tons of specified pollution per year and are regulated under Title 5. Often called a Title V
source.
Mobile Sources: On-road and off-road vehicles, including trucks, cars, buses, motorcycles,
airplanes, trains, farm and construction equipment, marine engines, and lawn mowers
NAAQS: National Ambient Air Quality Standards - Standards or maximum levels set for the six
criteria pollutants (PM, ozone, NOx, Sox, lead, and CO) in the ambient air as measure of
whether an area is in "attainment" or "non-attainment" for air quality purposes.
NCh:
Nitrogen Oxide
SO2:
Sulfur Oxide
Pb:
Lead
O3:
Ozone
CO:
Carbon Monoxide
PM10:
Particular matter less than 10 microns in size
PM2.5:
Particulate matter less than 2.5 microns in size
Tribal Air Grants Framework June 2015 P a g e | 46
-------
NESHAP: National Emissions Standardfor Hazardous Air Pollutants - National standards
applicable to point and area sources of hazardous air pollutants.
NSPS: New Source Performance Standards - EPA standards that apply to new point sources of
air pollution.
NSR: New Source Review - EPA rules that govern the construction and modification of
stationary sources.
NTAA: National Tribal Air Association - An organization for tribes to develop and participate
on air policy issues in a similar manner as the State and Territorial Air Pollution Program
Administrators/Association of Local Air Pollution Control Officials (STAPPA/ALAPCO).
Point Sources: Large, stationary sources of emissions that release pollutants in quantities above
an emission threshold.
PSD: Prevention of significant deterioration - A standard that prevents sources of pollution from
causing a significant deterioration in the air quality in areas that meet the NAAQS.
RPO: Regional Planning Organization - Organizations of federal, state, local, and tribal air
quality managers who work on air policy issues for a particular region. Examples are the
Western Regional Air Partnership (WRAP) and CENRAP (Central Regional Air Partnership).
SIP: State Implementation Plan - State rules that have been approved by EPA and made part of
the Code of Federal Regulations.
TAR: Tribal Authority Rule - This 1998 rule establishes a flexible approach to tribal air quality
management, a Amodular@ approach, allowing tribal governments to implement those provisions
of the Clean Air Act that will address most effectively the air quality concerns of their individual
reservations. Includes TAS (see below) requirements.
TAS: Treatment in the Same Manner as a State - Also known as an "Eligibility Determination"
for a tribe to exercise a authority under a particular CAA section, this process and approval
requires that the tribe demonstrate that it: (1) is federally recognized; (2) has a governing body
carrying out substantial governmental duties and powers; and (3) is capable of implementing the
program consistent with the CAA and applicable regulations. The tribe must also identify the
exterior boundaries of the reservation and, for non-reservation areas, must demonstrate the basis
for jurisdiction.
Tribal Air Grants Framework
June 2015
Page | 47
-------
TIP: Tribal Implementation Plan - Tribal rules to manage air quality on a reservation that have
been approved by EPA, entered into the Code of Federal Regulations and become federally
enforceable.
VOC: Volatile Organic Compounds
Tribal Air Grants Framework
June 2015
Page | 48
-------
Sample Workplan Template
Tribe or Entity Name
Program Project
Name
Project Period
Project Cost
Date drafted/edited
Tribal Grant
Name:
Contact Information
Phone:
E-mail:
EPA Project Officer
Name:
Contact Information
Phone:
E-mail:
Background
Information and
Problem Statement
Reference to Strategic
Plan - Goal and
Objective
Commitment 1:
Air Quality Administration & Infrastructure Development
Workplan Commitments
Outputs and
Deliverables
Outcomes
Timeframes and
cost estimate
Progress Report
Task 1:
Write job/position
descriptions for staff that
will be needed to accomplish
work plan tasks and
objectives.
Staff hired
appropriate to
the job
description with
the capabilities
to complete the
work plan
activities by the
end of the
project.
Tribe
demonstrates
successful
grant
management
and air
project
management
capabilities.
Within 2 months
from project start
date
Tribal Air Grants Framework
June 2015
Page | 49
-------
Task 2:
Identify training needs of staff
and write a training plan; make
necessary arrangements for
registration and attending the
appropriate classes.
Training plan
written that
supports the
work plan
objectives.
Highly
trained staff
is able to
successfully
execute
projects
activities.
Within 2 months
of project start
date
Task 3: add more tabs as
needed
Commitment 2:
Indoor Air Quality
Management
Task 1:
Obtain training on
conducting IAQ
assessments and
community outreach.
IAQ walk through
training completed.
Staff able to
conduct
assessments and
provide findings to
the residents, as
well as begin to
collect information
about IAQ risks on
the reservation.
First 3-5 months
of the project
start date
Task 2:
Develop a QAPP for
conducting IAQ Assessments
Information on
QAPP requirements
gathered. QAPP
written and
submitted for
approval.
The Tribe is able
to gather quality
assured data that
can be replicated if
necessary.
Within 90 days
from project start
date
Commitment #: Add more
tabs as needed
Quality Assurance statement
Other relevant/ required
information
Tribal Air Grants Framework
June 2015
Page | 50
-------
Sample Budget Template
Name of Project -Tribe's Name
Category
Detail
Federal
Share
Tribal
Match
Total
1. Personnel
Provide a breakdown for
personnel. (Applicant's budget
detail must identify the
personnel and Title by Full-
Time Equivalent (FTE),
including percentage of FTE
for part-time employees and
number of personnel proposed
for each category. This will
include the FTE Title, Salary
per hr./monthly/or yearly.)
Air Monitoring Specialist
$20.00/hr x 2080 hours
=$41,600
$39,520
$2,080
$41,600
Program Manager-
$22/hr*40 hr*52 weeks=
$45,760
$34,320
$34,320
$0
$0
$0
$0
Total Personnel Cost
$73,840
$2,080
$75,920
2. Fringe Benefits
Fringe benefits include, but are
not limited to, employee
insurance, pensions, and
unemployment benefit plans.
The cost of leave can be
included under either Personnel
or Fringe Benefits, at the
applicant's discretion. Please
indicate how the fringe benefits
are calculated (i.e. % x
Personnel).
Based on 30% of
Personnel costs
Air Specialist salary
$41,600x30% = $12,480
$11,856
$624
$12,480
$13,728
Based on 30% of
Personnel costs
Program Manager salary
$45,760x30%= $13,728
$13,728
$0
$0
$0
$0
Total Fringe Cost
$25,584
$624
$26,208
3. Travel
Travel costs are the expenses
for proposed/estimated
transportation, lodging,
subsistence, and related items
incurred by employees who are
Annual Tribal Air
Conference
Air Quality Technician
Traveling for 4 days. Air
Fare = $250, hotel =
$120*4, per diem = $75*4
$1,030
$0
$1,030
in travel status on official
$0
business. In a narrative
statement, for each trip list the
title of all travelers, the reason
$0
$0
$0
Tribal Air Grants Framework
June 2015
Page | 51
-------
and purpose of the travel,
number of days, which types of
costs are included (i.e. lodging,
per diem, air fare, other). If
specific destinations are known
$0
for each trip indicate those.
Additional information on
travel expenses may be found
at 2 CFR 225, AppB.
ToUil Trsivel Cosl
SI.O.iO
So
SI. 030
4. Equipment
This category includes only
equipment proposed to be
purchased as a direct cost.
Equipment is defined as
tangible, non-expendable,
personal property having a
useful life of more than one
Logging Equipment at
$22,000
$1,045
S348
$1,393
year and an acquisition cost of
$0
$5,000 or more per unit
$0
although a lower dollar amount
$0
threshold can be established by
$0
the applicant. If the applicant
uses a lower threshold for
$0
equipment, please indicate this
in the budget information.
(Note: Equipment does not
include: 1) equipment planned
to be leased/rented, including
lease/purchase agreements; or
2) equipment service or
maintenance contracts. These
types of proposed costs should
be included in the "Other"
category.)
ToUil l'.t|iiipiiicnl Cost
SI.045
S34X
SI.393
5. Supplies
Supplies are tangible personal
Very Sharp Cut cyclone at
$1500x2 = $3000
SI,U00
$3,000
property other than equipment.
Any single item valued at
$5,000 or more in this category
should be moved to the
"Equipment" category. Non-
tangible goods and services
associated with supplies, such
$0
as printing services, photocopy
$0
Tribal Air Grants Framework June 2015 Page I 52
-------
services, and rental costs
should be included in the
"Other" category. The budget
narrative must include a brief
description of the supplies
required to perform the work.
These costs should be listed by
major supply categories and
include the estimated costs by
category.
o lo lo
Total Supplies Cost
S2.ooo
SI.ooo
S3.000
6. Contractual
Contractual/consultant services
are those services to be carried
out by an individual or
organization other than the
applicant in the form of a
procurement relationship.
For each planned contract, the
applicant should list the
proposed contract activities
along with a brief description
of—the scope of work or
services to be provided,
proposed duration, proposed
procurement method
(competitive or non-
competitive), and deliverables
if known. Also provide a basis
for the cost calculation (e.g.,
number of samples x price per
analysis, average hourly rate x
estimated hours, etc.).
ERG Contract for AQS
Data Entry at $5000 for 12
months
$4,000
$1,000
$5,000
$0
$0
$0
$0
$0
Total Contractual Cost
S4. ooo
SI.ooo
S5.000
7. Other
This category should include
only those types of direct costs
that do not fit in any of the
other budget categories.
Examples of costs that may be
in this category are: insurance,
rental/lease of equipment or
supplies, equipment service or
maintenance contracts, printing
Printing and Photocopying
$100
S1U0
So
$100
$0
$0
Tribal Air Grants Framework
June 2015
Page | 53
-------
or photocopying, and sub-
award costs and USGS costs.
If the Tribe chooses to
categorize costs that are
regularly considered indirect
costs (i.e. rent, phone, utilities,
space allocation, etc.), please
include a statement that these
are not part of the Tribe's
indirect cost rate pool and
indicate how these costs are
calculated.
$0
$0
$0
Tolal Oilier Cos!
SI DO
SO SI(M)
8. Total Direct Charges
Summary of all costs
associated with each object-
class category.
$59,551
S5,052
$64,603
Tolal Direr! Cosls
S11)7.5 w S5.D52
S64.603
9. Total Indireet Costs
Include Indirect Cost Rate (IDC) amount and costs covered under the IDC rate. Provide how the
IDC rate was calculated (i.e. rate x base included).
Tolal 1 iitlirod Costs
SO
SO
SO
Total Cost
Indicate o\eiall liuuic of nil direct and indirect costs
Tolal Cosls
SI 07.599
S5.052
SI 12.651
-------
EPA Order
Classification No.: 5700.7A1
httD://www.eDa.gov/sites/Droduction/files/201503/docunients/eDa order 5700 7al.pdf
2
-------
EPA Order
Classification No.: 5700.7A1
Effective Date: 01/01/2005
Review Date: 10/01/2013
Environmental Results under the EPA Assistance Agreements
1. PURPOSE
This Order establishes Environmental Protection Agency (EPA) policy for addressing environmental
results under EPA assistance agreements, including results that advance EPA's environmental and
human health mission.
2. BACKGROUND
The mission of EPA is to protect human health and the environment. To help carry out its mission, EPA
awards approximately one-half of its budget annually in assistance agreements to State, Tribal, local
government, educational institutions, and non-profit partners. EPA's Grants Management Plans (GMP)
e.g., Goal 5 of EPA's 2003-2008 GMP, "Support Identifying and Achieving Environmental Outcomes,"
and Goal 1 of EPA's 2009-2013 GMP, "Demonstrate the Achievement of Environmental Results"
explicitly recognize the importance of linking assistance agreements to the Agency's performance goals
and include specific objectives to ensure that assistance agreement solicitations, work plans, and funding
recommendations discuss anticipated environmental results and how they will be measured.
This Order is intended to implement GMP objectives by ensuring that EPA assistance agreements are
results-oriented, aligned with the Agency's strategic goals, and demonstrate achievement of
environmental results and/or public health protection.
3. APPTJCABTT TTY AND EFFECTIVE DATE
This Order applies to all non-competitive funding packages/funding recommendations submitted to the
Grants Management Offices after October 1, 2013, all competitive assistance agreements resulting
from competitive funding announcements issued after October 1, 2013, and competitive funding
announcements issued after October 1, 2013.
This Order applies to supplemental funding amendments awards made after October 1, 2013 when the
scope of work has changed. This Order applies if recipients are currently negotiating workplans after
October 1, 2013. This order is not intended to require recipients renegotiate workplans to comply with
the order. This Order applies to all EPA assistance agreement programs except the Senior
Environmental Employment (SEE) Program. It does not apply to Fellowship awards.
3
-------
4. POETCY
It is EPA policy, to the maximum extent practicable, to: (1) link proposed assistance agreements to the
Agency's Strategic Plan; (2) ensure that outputs and outcomes are appropriately addressed in assistance
agreement competitive funding announcements, work plans and performance reports; and (3) review the
results from completed assistance agreement projects and report on how they advance the Agency's
mission of protecting human health and the environment.
5. DEETNTTTONS
a. The term "outcome" means the result, effect or consequence that will occur from carrying out an
environmental program or activity that is related to an environmental or programmatic goal or objective.
Outcomes may be environmental, behavioral, health-related or programmatic in nature, must be
quantitative, and may not necessarily be achievable within an assistance agreement funding period.
b. The term "output" means an environmental activity, effort, and/or associated work products related to
an environmental goal or objective, that will be produced or provided over a period of time or by a
specified date. Outputs may be quantitative or qualitative but must be measurable during an assistance
agreement funding period.
c. The term "Strategic Plan" means the five year Strategic Plan EPA is required to prepare under GPRA.
EPA's current Strategic Plan can be found at http://intranet.epa.gov/ocfo/plan/plan.htm.
6. COMPETITIVE ETTNDTNG ANNOUNCEMENTS
a. Section I of all competitive funding announcements for assistance agreements must (1) describe the
linkage between the work intended to be accomplished under the assistance agreement and EPA's
Strategic Plan and (2) contain a concise discussion of any expected outputs and outcomes.
b. All competitive funding announcements for assistance agreements must include ranking criteria for
evaluating the applicant's plan for tracking and measuring its progress toward achieving the expected
outputs and outcomes identified in Section I of the announcement.
c. All competitive funding announcements for assistance agreements must include ranking criteria for
evaluating the applicant's past performance in reporting on outputs and outcomes.
d. EPA's Grants Competition Advocate may issue such guidance as may be necessary to implement the
requirements of this Section, including guidance on the evaluation of applicants under paragraph c. that
lack past performance history. Current guidance is located at:
http://intranet.epa.gov/ogd/competition/compet/competition past performance evaluation guidance.htm.
7. ASSISTANCE AGREEMENT WORK PEANS
a. Program offices, in negotiating an assistance agreement work plan, must ensure that the work plan
contains well-defined outputs and, to the maximum extent practicable, well-defined outcomes designed
to achieve environmental results and/or public health protection. For State and Tribal assistance
agreements under 40 CFR Part 35, Subparts A and B, program offices may satisfy this requirement by
ensuring compliance with 40 CFR §§35.107 (State work plans) and 35.507 (Tribal work plans).
4
-------
b. Prior to approving an assistance agreement work plan, program offices must ensure that they can link
the workplan to EPA's Strategic Plan as required by Section 8 of this Order. Additionally, for State
workplans under 40 CFR § 35.107, program offices must ensure compliance with the "Essential
Elements" approach outlined in Grants Policy Issuance 11-03, State Grant Workplans and Progress
Reports,
http://intranet.epa.gov/ogd/policv/fmal grants policy issuance 11 03 state grant workplans.pdf.
Attachment A of GPI11-03 lists the 14 categorical state grant programs for which this is applicable.
c. To supplement this Order, the Office of Grants and Debarment, in coordination with the Office of
Planning, Analysis and Accountability, may periodically issue guidance on outputs and outcomes and
linking workplans to EPA's Strategic Plan.
8. ASSISTANCE AGREEMENT FTTNDTNG RECOMMENDATIONS
a. Program offices must include in the funding recommendation for a proposed assistance agreement, a
description of how the program/project fits within the Agency's Strategic Plan. The description must
identify all applicable EPA strategic goal(s) and objective(s).
b. The description must also contain an assurance from the program office that: (1) it has reviewed the
assistance agreement work plan; and (2) the work plan meets the requirements of Section 7(a) of this
Order.
c. Except for State and Tribal assistance agreements under 40 CFR Part 35, Subparts A and B, award
officials must include in assistance agreements the applicable recipient performance reporting term and
condition specified in Appendix A of this Order, or a program-specific term and condition approved by
the Director of the Office of Grants and Debarment.
9. RECIPIENT PERFORMANCE REPORTING AND EPA REVIEW
a. Program offices must review performance reports, both interim and final, submitted by recipients
under 40 CFR §§30.51 and 30.71, and interim and final construction and non-construction grant
performance reports submitted by recipients under §§31.40 and 31.50 (i.e., Monitoring and Reporting
Program Performance and Closeout, respectively), to determine whether the recipient achieved the
environmental and/or public health outputs and outcomes contained in the assistance agreement work
plan. This includes ensuring that performance reports provide a satisfactory explanation if outcomes or
outputs were not achieved. The review is to be documented in the official project file.
b. For State and Tribal program grants under 40 CFR Part 35, Subparts A and B, program offices may
satisfy the requirements of this Section by ensuring compliance with 40 CFR §§ 35.115 and 35.515
(Evaluation of Performance).
10. ADVANCED MONTTORTNG
In conducting advanced monitoring under EPA Order 5700.6 (Policy on Compliance, Review and
Monitoring), program offices must assess the recipient's progress in achieving the outputs and
outcomes set forth in the assistance agreement work plan. In accordance with guidance issued by the
Director of the National Policy, Training and Compliance Division, program offices must record the
results of this assessment in the Grantee Compliance Database.
5
-------
11. RFVTF/W AND REPORTING OF RFSTTFTS INFORMATION
a. Program offices must report on significant results information from completed assistance agreements
through reporting processes established by the National Program Manager.
b. National Program Managers must report significant results information from completed assistance
agreements as part of the Agency's Annual Performance Report process and in their internal evaluation
systems.
12. COMPT JANCF WTTH THF FFDFRAF GRANT AND COOPERATIVE
AGRFFMFNT ACT AND THF PAPERWORK REDUCTION ACT
a. Nothing in this Order authorizes EPA to treat assistance agreements like contracts. Under the Federal
Grant and Cooperative Agreement Act, and associated EPA Order 5700.1 (Policy for Distinguishing
Between Assistance and Acquisition) the principal purpose of any proposed EPA assistance agreement
must be, unless otherwise provided by statute, to support a recipient in carrying out a public purpose
authorized by EPA's statutory authorities, as opposed to providing goods or services for the direct
benefit or use of EPA or the Federal Government.
b. When implementing this Order, EPA officials must comply with the applicable provisions of the
Paperwork Reduction Act of 1995.
13. ROT/FS AND RESPONSTBTT JTTES
a. Program offices and National Program Managers must ensure that: (1) competitive funding
announcements, work plans, funding recommendations, and performance reports contribute to the
Agency's programmatic goals and objectives and demonstrate achievement of environmental results
and/or public health protection in compliance with the requirements of this Order; and (2) the results of
assistance agreements are reviewed and reported in accordance with the requirements of this Order.
b. Grants Management Offices will return funding packages/funding recommendations that do not meet
the requirements of sections 8(a) and (b) of this Order.
c. Award officials are responsible for including in assistance agreements the applicable term and
condition described in section 8(c) of this Order.
14. WATVFRS
a. In response to requests submitted by approval officials, the Director, Office of Grants and Debarment
or designee, may grant individual or class waivers from the non-statutory requirements of this Order,
except for requirements under Section 6, where compliance would be impracticable or otherwise not in
the public interest.
b. In response to requests submitted by approval officials, EPA's Grant Competition Advocate may
grant individual or class waivers from the ranking criteria described in Section 6 of this Order if the
Program office can demonstrate that such criteria are inappropriate for a particular competition or
program.
6
-------
15. STTPFRSFSSTON AND RI VIIW
This Order supersedes Order 5700.7. The Office of Grants and Debarment will periodically review this
Order to assess its effectiveness and issue supplemental guidance as may be necessary to address future
needs.
7
-------
Appendix
A
RECIPIENT PERFORMANCE
REPORTING
Except for State and Tribal assistance agreements authorized under 40 CFR Part 35, Subparts A and
B, award officials must include in assistance agreements the applicable recipient performance
reporting term and condition specified below or a program-specific term and condition approved by
the Director of the Office of Grants and Debarment.
Recipients subject to 40 C.F.R. Part 30
Performance Reports
In accordance with 40 CFR § 30.51 (d), the recipient agrees to include in performance reports
submitted under this agreement brief information on each of the following areas: 1) a comparison of
actual accomplishments with the anticipated outputs/outcomes specified in the assistance agreement
work plan; 2) reasons why anticipated outputs/outcomes were not met; and 3) other pertinent
information, including, when appropriate, analysis and explanation of cost overruns or high unit costs.
In accordance with 40 CFR § 30.51 (f), the recipient agrees that it will notify EPA of problems, delays,
or adverse conditions which materially impair the ability to meet the outputs/outcomes specified in the
assistance agreement work plan.
Recipients subject to 40 CFR Part 31 (other than recipients of State or Tribal Program
grants under 40 CFR Parts 35 Subparts A or B)
Performance Reports
In accordance with 40 CFR §31.40, the recipient agrees to submit performance reports that include
brief information on each of the following areas: 1) a comparison of actual accomplishments to the
outputs/outcomes established in the assistance agreement workplan for the period; 2) the reasons for
slippage if established outputs/outcomes were not met; and 3) additional pertinent information,
including, when appropriate, analysis and information of cost overruns or high unit costs.
In accordance with 40 CFR § 31.40 (d), the recipient agrees to inform EPA as soon as problems,
delays or adverse conditions become known which will materially impair the ability to meet the
outputs/outcomes specified in the assistance agreement work plan.
-------
Checklist of Key Questions for Proposal
Development
Page 2 - December, 2015
-------
Checklist of Key Questions for Proposal Development
Project Summary and Overall Approach:
~ If applicable, ensure proposal identifies activities and environmental outcomes from previously
received Tribal Air Capacity Building Air Grant or any other type of award which included air
quality related activities and environmental outcomes.
~ If applicable, identify air grant awards received during the past three years? If awards were
received, explain or justify the need for the perceived repetitive activities (i.e., repeated funding
to the same recipient can undermine the fairness and transparency of the grant process).
~ If applicable, are tribal lands located in an area that has been designated by the Region 6 or the
Environmental Protection Agency (EPA) as "non-attainment" for one of the pollutants for which
there are National Ambient Air Quality Standards (NAAQS)? If yes, for which pollutant(s)?
~ If tribal land is not located in a "non-attainment" status, did the proposal adequately identify and
justify pollutants of concern and efforts to maintain "attainment" status?"
~ Does the proposal describe any Clean Air Act Title V major sources of air pollution located
within their tribal jurisdiction?
~ Does the proposal describe other non-major air pollution sources of concern located within tribal
jurisdiction (e.g., minor sources, open burning, etc.), particularly, facilities such as casinos, dry
cleaners, gas stations, sand and gravel operations, oil and gas processing, restaurants, auto and
auto body shops, internal combustion engines, and electric generators?
~ Does the proposal describe other air pollution problems, for example: transport of air pollution
from off the reservation (including nearby stationary sources and urban areas) or any other air
pollution problem that is a concern for the tribe?
~ Does the proposed air activities fall within one of the national tribal STAG allocation factors
(i.e., emissions inventories, non-attainment area, TAS, TIP development, toxics, monitoring,
etc.)?
~ Does the tribe have an approved Quality Management Plan (QMP)?
~ Does the proposed budget costs support or justify the proposed workplan activities?
~ Does the proposal provide budget narrative for the proposed activities?
~ Does the proposal describe past performance in successfully completing air or other the EPA
grant projects?
~ As in previous EPA grant awards, does the proposal fulfilled requirements such as workplan
tasks submitted required progress and financial reports and comply with all applicable grant
conditions? If not, did we provide information or explain circumstances for not complying?
Technical Activities
~ Does the proposal identify the air pollutant(s) to be monitored, document justification or need to
accomplish air monitoring, and the type of air monitoring equipment to be used to monitor and
collect data?
~ Does the proposal identify approved QAPP or identify activities or process to develop the QAPP
for technical activity?
~ Does the proposal identify that the collected data will be used for regulatory purposes (e.g.,
comparing the tribe's air quality data to the National Ambient Air Quality Standards for planning
purposes) or for informing the tribe only?
Page 3 - December, 2015
-------
~ Does the proposal identify completion of an Emissions Inventory or Source Identification?
~ Does the proposal describe air quality legislation enacted by the tribal government?
~ Does the proposal describe air permitting/compliance activities?
~ Does the proposal describe air quality regulations promulgated by the tribal government?
Air Quality Outreach, Participation, and Collaboration
~ Does the proposal describe activities that involve the dissemination of information regarding air
pollution and air quality concerns to the community and/or tribal leadership?
~ Does the proposal describe efforts the tribe has made to participate in both national and regional
air quality concerns or initiatives on an ongoing basis?
~ Does the proposal demonstrate or propose collaboration, information sharing, or provided
technical assistance to other tribes and other stakeholders (i.e., local, regional, and national air
quality organizations)?
Results - Outcomes and Outputs
~ Does the proposal describe a plan for tracking and measuring the progress toward achieving
expected outputs and outcomes identified in the Agency's Strategic Plan?
~ Does the proposal identify expected or proposed Environmental Results?
Page 4 - December, 2015
-------
Acronyms and Definitions
Page 5 - December, 2015
-------
Acronyms and Definitions
Note: Definitions and explanations are provided in reference to air quality (or biased toward their effects
on air quality). Some definitions provided may be different and could be misused if you are looking for
a generic understanding.
A-21: Entitled "Cost Principles for Educational Institutions," a circular published by the federal Office
of Management and Budget (OMB) that establishes the principles for determining the costs applicable to
grants, contracts, and other government agreements with educational institutions (also known as
Sponsored Projects).
Aerosol: Suspensions of tiny liquid and/or solid particles in the air. Aerosols can be found naturally
(from volcanic activities or dust, etc.) and/or human-made (from burning of fossil fuel and coal, etc.) but
both can reduce visibility and degrade air quality.
Air Pollutant: Chemicals or other materials suspended in the air from natural or human-made processes
that can threaten human health and welfare. There are currently "Six Common Air Pollutants", also
known as "Criteria Pollutants", regulated by the U.S. EPA.
Air Pollution: Degradation of air quality resulting from chemicals or other materials suspended in the
air from natural processes or human-made.
Air Quality: Degree of purity of air to which people, natural and heritage resources are exposed. It is
routinely compared with "standards" of maximum acceptable pollutant concentrations as determined by
the EPA under the Clean Air Act. In the United States (though used in slightly different forms around
the world) the degree of purity of air is expressed in a color-coded system known as Air Quality Index
(AQI)
Allocable Costs: Those allowable costs that actually benefit the grant or contract to which they are
being charged.
Allowable Costs: Those categories of costs that can be charged to a grant, such as salaries and
equipment. Certain types of costs, such as the cost of alcoholic beverages are not allowable and may not
be charged to a contract or grant.
API: Air Quality Index is a color-coded index for reporting air quality information and forecast to the
public. It was originally developed by the Maryland Department of the Environment and the American
Lung Association in the 1994 and was adopted by the US EPA in 1988 as part of the federal Air Quality
Index (AQI) to present air quality information and forecasts to the public.
AOS: The EPA's Air Quality System. Visit TTN AIRS AQS website for details at
http://www2.epa.gov/aqs.
AOS ID/Code: 9-digit site identification number in AQS database consisting of 2-digit state code, 3-
digit county code, and 4-digit site number. For instance, the AQS code for HU-Beltsville monitoring
station in Prince Georges County, MD is "24-033-0030".
Page 6 - December, 2015
-------
Area Sources: Sources, either facilities or activities whose individual emissions do not qualify them as
point sources.
Atmospheric Deposition: The process by which gases and particles suspended in the air are transferred
from the atmosphere to the surface of the earth. See Dry and Wet Depositions for additional
information.
Attainment: Air pollution levels at a site or a geographic extent are below (meet) the National Ambient
Air Quality Standards (NAAQS).
Attainment Area: A geographic extent consisting of one or more counties where air pollution levels are
below (meet) the National Ambient Air Quality Standards (NAAQS).
Audit: A formal examination of an organization's or individual's accounts or financial situation. An
audit may also include examination of compliance with applicable terms, laws, and regulations.
Award: Funds that have been delegated by a funding agency for a particular project.
BAM: Beta Attenuation Mass Monitor is an instrument that measures continuous (hourly or sub-hourly)
particulate matter mass.
BACT: Best Available Control Technology is a source emissions limitation based on the best currently
available technology producing the greatest reduction of air pollutant emissions with considerations
on energy, environmental, economic, and other costs. Major sources are required to use BACT unless it
can be demonstrated that it is not feasible for energy, environmental, or economic reasons.
BART: Best Available Retrofit Technology is a source emissions limitation based on the best currently
available technology producing the greatest reduction of air pollutant emissions with considerations
on energy, environmental, economic, and other costs. Sources emitting air pollutants that reduce
visibility including particulate matter and its constituents (NOx, S02, VOCs, and ammonia) under the
regional haze rule. Visit the EPA webpage for Visibility Regulatory Actions for more information.
Bequests: A type of donation or gift. Bequests and gifts are awards given with few or no conditions
specified. Gifts may be provided to establish an endowment or to provide direct support for existing
programs. Frequently, gifts are used to support developing programs for which other funding is not
available. The unique flexibility, or lack of restrictions, makes gifts attractive sources of support.
Broad Agency Announcement (BAA): An announcement of a federal agency's general research
interests that invites proposals and specifies the general terms and conditions under which an award may
be made.
Budget: The detailed statement outlining estimated project costs to support work under a grant or
contract.
Budget Period: The interval of time, usually twelve months, into which the project period is divided for
budgetary and funding purposes.
Page 7 - December, 2015
-------
Budget Adjustment: The act of amending the budget by moving funds from one category or line item
to another.
CAA: Clean Air Act of 1970, passed by Congress authorizing the Environmental Protection Agency to
establish National Ambient Air Quality Standards for pollutants shown to threaten human health and
welfare. Visit CAA website for more information. Federal Laws enacted to improve the air quality or
prevent its deterioration so that it is not a danger to public health and welfare. 42 United States Code
§§7401 et seq.
CAAA: Clean Air Act Amendments
CHIEF: Clearinghouse of Inventory Emissions Factors.
Close Out: The act of completing all internal procedures and sponsor requirements to terminate or
complete a research project.
CENRAP: Central RegionalAir Planning Association is one of the five organizations consisting of
tribal, local, state, federal air pollution agencies, and other interested parties. The goal of an RPO is to
work collaboratively in developing regional strategies to solve air pollution, addressing regional haze,
and related issues. CENRAP includes states and tribal areas of Nebraska, Kansas, Oklahoma, Texas,
Minnesota, Iowa, Missouri, Arkansas, and Louisiana. Other RPOs include: MANE-VU, Midwest RPO,
VISTAS, and WRAP. See each listed RPO to learn more or visit the EPA website on RPO for a
regional map and links.
CMAQ: Community MultiscaleAir Quality is an active open-source development project of the U.S.
EPA Atmospheric Science Modeling Division consisting of a suite of programs for conducting air
quality model simulations. CMAQ modeling is used by many agencies as part of the State
Implementation Plan demonstrations for ozone and fine particulate matter.
CO: Carbon Monoxide - One of the "Six Common Air Pollutants", also known as "Criteria Pollutants"
and is regulated by the U.S. EPA. Click here to learn more about "Criteria Pollutants".
CQ2: Carbon Dioxide
Close Out: The act of completing all internal procedures and sponsor requirements to terminate or
complete a research project.
Competing Proposals: Proposals that are submitted for the first time or unfunded proposals that are
resubmitted; either must compete for research funds. Ongoing projects must compete again if the term of
the original award has expired.
Continuation Project (Non-Competing): Applicable to grants and cooperative agreements only. A
project approved for multiple-year funding, although funds are typically committed only one year at a
time. At the end of the initial budget period, progress on the project is assessed. If satisfactory, an award
is made for the next budget period, subject to the availability of funds. Continuation projects do not
compete with new project proposals and are not subjected to peer review beyond the initial project
approval.
Page 8 - December, 2015
-------
Cooperative Agreement: An award similar to a grant, but in which the sponsor's staff may be actively
involved in proposal preparation, and anticipates having substantial involvement in research activities
once the award has been made.
Cost-Reimbursement Type Contract/Grant: A contract/grant for which the sponsor pays for the full
costs incurred in the conduct of the work up to an agreed-upon amount.
Cost-Sharing: A general term, used as a noun or adjective, that can describe virtually any type of
arrangement in which more than one party supports research, equipment acquisition, demonstration
projects, programs, institutions. Example: A university receives a grant for a project estimated to have a
total cost of $100,000. The sponsor agrees to pay 75% ($75,000) and the university agrees to pay 250/0
($25,000). The $25,000 is the cost-sharing component.
Criteria Pollutants: Also known as "Six Common Pollutants" which are known to threaten human
health and welfare. Criteria pollutants include "ozone, carbon monoxide, nitrogen dioxide, particulate
matter, sulfur dioxide, and lead." There are threshold concentrations called National Ambient Air
Quality Standards (NAAQS) established for each of them. Click here to learn more about "Criteria
Pollutants".
CSA: Combined Statistical Area is a grouping of metropolitan or micropolitan statistical areas that are
linked by commuting ties. Visit U.S. Census Bureau webpage on Current List of Metropolitan and
Metropolitan Statistical Areas and Definitions for more information.
Datalogger: An electronic device used for measuring analog or digital signals from an instrument and
records the results a storage device.
Direct Costs: Clearly identifiable costs related to a specific project. General categories of direct costs
include but are not limited to: salaries and wages, fringe benefits, supplies, contractual services, travel
and communication, equipment, and computer use.
Donation: Transfer of equipment, money, goods, services, and property with or without specifications
as to its use. Sometimes donation is used to designate contributions that are made with more specific
intent than is usually the case with a gift, but the two terms are often used interchangeably. (Also see
Gift.)
Dry Deposition: The process by which gases and particles are transferred to the surface as a result of
random turbulent air motions. See atmospheric deposition; compare wet deposition.
Emissions: Substance discharge into the atmosphere from both natural and anthropogenic (human-
made). Natural sources include: air-blown dust from deserts; methane emitted by the digestion of food
from animals; smokes from forest fires; sulfur, chlorine, and particles from volcanic
activities; Anthropogenic sources include: exhausts from motor vehicles; smoke plume consisting of
NOx, S02, CO, etc. from power plants, and fossil fuel consumptions; VOCs from paint, hair spray,
aerosol sprays, etc.
Page 9 - December, 2015
-------
Emissions Inventory (EI): A listing by source, of the amount of air pollutants discharged into the
atmosphere from a given area for a specified time period. Emissions Inventory at the present time only
includes anthropogenic (human-made) sources. See National Emissions Inventory (NEI).
EIS: Emissions Inventory System
EPA: U.S. Environmental Protection Agency - Executive Branch agency responsible for
implementation and enforcement of the CAA and other environmental statutes.
Expiration Date: The date signifying the end of the performance period, as indicated on the Notice of
Grant Award.
Extension: An additional period of time given by the sponsor to an organization for the completion of
work on an approved grant or contract. An extension allows previously allocated funds to be spent after
the original expiration date.
FIP: A federally implemented plan to achieve attainment of air quality standards.
FRM: Federal Reference Method is a method of sampling and analyzing for air pollution which has
been accepted by the EPA Administrator to be official as described in Title 40, Code of Federal
Regulations, Part 50 (40 CFR Part 50).
Final Report: The final technical or financial report required by the sponsor to complete a research
project.
Fiscal Year (FY): Any twelve-month period for which annual accounts are kept.
Fixed-Price (FP) Contract/Grant: A contract/grant for which one party pays the other party a
predetermined price, regardless of actual costs, for services rendere Quite often this is a fee-for-service
agreement.
Fringe Benefits: Employee benefits paid by the employer, (e.g., FICA, Worker's Compensation,
Withholding Tax, Insurance, etc.)
Funding Cycle: Range of time during which proposals are accepted, reviewed, and funds are awarded.
If a sponsor has standing proposal review committees (or boards) that meet at specified times during the
year, application deadlines are set to correspond with those meetings. For some sponsors, if proposals
are received too late to be considered in the current funding cycle, they may be held over for the next
review meeting (i.e., National Science Foundation's Target Dates).
Gift: Gifts and bequests are awards given with few or no conditions specified. Gifts may be provided to
establish an endowment or to provide direct support for existing programs. Frequently, gifts are used to
support developing programs for which other funding is not available. The unique flexibility, or lack of
restrictions, makes gifts attractive sources of support. (Also see Donation.)
Page 10 - December, 2015
-------
Grant: A type of financial assistance awarded to an organization for the conduct of research or other
program as specified in an approved proposal. A grant, as opposed to a cooperative agreement, is used
whenever the awarding office anticipates no substantial programmatic involvement with the recipient
during the performance of the activities.
Grant/Contract Officer: A sponsor's designated individual who is officially responsible for the
business management aspects of a particular grant, cooperative agreement, or contract. Serving as the
counterpart to the business officer of the grantee/contractor organization I the grant/contract officer is
responsible for all business management matters associated with the review, negotiation, award, and
administration of a grant or contract and interprets the associated administration policies regulations, and
provisions. (For definition of scientific officer, see Program/Project Officer.)
HAP: Hazardous Air Pollutants are airborne chemicals that cause serious health and environmental
effects. HAP is not covered in the National Ambient Air Quality Standards and they include: asbestos,
beryllium, mercury, benzene, coke oven emissions, radionuclides, and vinyl chloride.
Haze: Atmospheric aerosols and particles that can degrade visibility and air quality.
IMPROVE: Interagency Monitoring of Protected Visual Environments is "a cooperative measurement
effort governed by a steering committee composed of representatives from Federal and regional-state
organizations. The IMPROVE monitoring program was established in 1985 to aid the creation of
Federal and State implementation plans for the protection of visibility in Class I areas (156 national
parks and wilderness areas) as stipulated in the 1977 amendments to the Clean Air Act. Visit
the IMPROVE website for more information.
In-Kind: Contributions or assistance in a form other than money, such as equipment, materials, or
services of recognized value that are offered in lieu of cash.
Incremental Funding: A method of funding grants/contracts that provides specific spending limits
below the total estimated costs. These limits may be exceeded only at the contractor's own risk. Each
increment is, in essence, a funding action.
Indirect Costs: Costs related to expenses incurred in conducting or supporting research or other
externally funded activities but not directly attributable to a specific project. General categories of
indirect costs include general administration (accounting} payroll, purchasing, etc.), sponsored project
administration, plant operation and maintenance, library expenses, departmental administration
expenses, depreciation or use allowance for buildings and equipment, and student administration and
services. (See also Facilities and Administrative Costs.)
Indirect Cost Rate: The rate, expressed as a percentage of a base amount established by negotiation
with the cognizant federal agency on the basis of the institution's projected costs for the year and
distributed as prescribed in OMS Circular A-21. The indirect cost rate is charged on a set of direct costs
known as an indirect cost base.
Interim Funding: Authorization to expend funds on a project to a specified limit before the award
document has been received from the sponsor.
Page 11 - December, 2015
-------
Investigator-Initiated Proposal: A proposal submitted to a sponsor that is not in response to an RFP,
RFA, or a specific program announcement.
ITEP: The Institute for Tribal Environmental Professionals was created in 1992 to act as a catalyst
among tribal governments, research and technical resources at Northern Arizona University (NAU), in
support of environmental protection of Native American natural resources.
LAER: Lowest Achievable Emissions Rate is the emissions control level required of a source seeking a
permit in a nonattainment area. LAER is generally considered to be the most stringent level of control
required under the Clean Air Act.Note that in California, many air pollution control agencies use the
term BACT to refer to LAER.
Key Personnel: The personnel considered to be of primary importance to the successful conduct of a
research project. The term usually applies to the senior members of the project staff.
Matching Grant: A grant that requires a specified portion of the cost of a supported item of equipment
or project be obtained from other sources. The required match may be more or less than the amount of
the grant. Some matching grants require that the additional funds be obtained from sources outside the
recipient organization. Many matching grants are paid in installments, the payments coinciding with the
attainment of pre-specified levels of additional funding. Matching grants are very common in the
sciences, especially for equipment. They are standard practice in some government agencies.
MDN: Mercury Deposition Network is an expansion of the National Atmospheric Deposition Program
(NADP) in 1995. It currently consists of more than 90 sites collecting weekly samples of precipitation
and is analyzed by Frontier Geosciences for total mercury. Visit the NADP website to learn more about
the MDN and others.
Mobile Sources: On-road and off-road vehicles, including trucks, cars, buses, motorcycles, airplanes,
trains, farm and construction equipment, marine engines, and lawn mowers.
Modification: An award document that modifies any aspect of an existing award. Example: Carryover
approvals, adding or deleting special terms and conditions, changes in funding levels, administrative
changes initiated by the agency, extensions that include changes in terms, change of principal
investigator, etc.
MSA: Metropolitan Statistical Area is a "geographic entity defined by the U.S. Office of Management
and Budget (OMB) for use by federal statistical agencies in collecting, tabulating, and publishing
Federal statistics." An MSA consists of a core urban area of at least 50,000 people. Visit the U.S. Census
Bureau webpage on Metropolitan and Metropolitan Statistical Areas for more information.
NAA: Non-attainment Area is a geographic extent consisting of one or more counties where air
pollution levels persistently exceed the National Ambient Air Quality Standards (NAAQS). Visit the
EPA Green Book webpage on Nonattainment Areas for more information.
Page 12 - December, 2015
-------
NAAOS: National Ambient Air Quality Standards are maximum threshold concentrations above which
adverse health effects may occur. The EPA established NAAQS for criteria pollutants (PM, ozone, NOx,
Sox, lead, and CO) based on the 1970 Clean Air Act. Measure of whether an area is in "attainment" or
"non-attainment" for air quality purposes. Visit the EPA Green Book webpage on Criteria Pollutants for
more information.
NADP/NTN: National Atmospheric Deposition Program/National Trends Network is a nationwide
network to collect data on the chemistry of precipitation for monitoring of geographic and temporal
long-term trends. It currently consists of over 250 sites spanning the continental United States, Alaska,
Puerto Rico, and the Virgin Islands. Precipitation collected in the NADP/NTN network is analyzed for
hydrogen (acidity as pH), sulfate, nitrate, ammonium, chloride, and base cations (such as calcium,
magnesium, potassium, and sodium). Visit the NADP/NTN network webpage for more information.
NCore: National Core multi-pollutant monitoring stations are a collection of monitors that integrates
several advanced measurement systems for particles, pollutant gases and meteorology. Visit the
EPA webpage on NCore Network for more information.
NEI: National Emissions Inventory is a database of air emissions information with input from numerous
state and local air agencies, from tribes, and from industry. Visit the EPA webpage on National
Emissions Inventories for more information.
NESHAP: National Emissions Standardfor Hazardous Air Pollutants National standards applicable to
point and area sources of hazardous air pollutants.
New Award: An award not previously awarded or a renewal or continuation award treated as a new
award by the sponsor and given a new agency number.
NO: Nitrogen Oxide
NQ2: Nitrogen Dioxide (ozone precursor)
NOx: Oxides of Nitrogen (ozone precursor)
NOv: Total Reactive Nitrogen Species (Ozone Precursor)
No Cost Time Extension: An extension of the period of performance beyond the expiration data to
allow the principal investigator to finish a project. Usually, no additional costs are provided.
Nonattainment Area: A geographic area in which the level of a criteria air pollutant is higher than the
level allowed by the federal standards. A single geographic area may have acceptable levels of one
criteria air pollutant but unacceptable levels for one or more other criteria air pollutants. Thus, an area
could be both attainment and nonattainment at the same time. It has been estimated that 60% of
Americans live in nonattainment areas.
Notice of Grant Award: The legally binding document that serves as a notification to the recipient and
others that a grant or cooperative agreement has been made; contains or references all terms of the
award; and documents the obligation of funds.
Page 13 - December, 2015
-------
NSPS: New Source Performance Standards the EPA standards that apply to new point sources of air
pollution.
NSR: New Source Review the EPA rules that govern the construction and modification of stationary
sources.
NTAA: National Tribal Air Association An organization for the tribes to develop and participate on air
policy issues in a similar manner as the National Association of Clean Air Agencies (NACAA).
OAOPS: U.S. EPA's Office of Air Quality Planning and Standards.
OMB Circulars: Regulatory circulars issued by the OMB of Management & Budget (OMB). Please
reference the following website for additional information: www.whitehouse.gov/omb/circulars.
Q3: Ozone - One of the "Six Common Air Pollutants," also known as "Criteria Pollutants" and is
regulated by the U.S. EPA.
PAMS: Photochemical Assessment Network is a collection of monitors designed to measure ozone
precursors (approximately 60 volatile hydrocarbons and carbonyl) as required by the 1990 Amendments
to the Clean Air Act. Each ozone non-attainment area designated as serious, severe, or extreme is
required to operate from two to five stations depending on the population of a given area. Visit the
EPA webpage on Ambient Air Monitoring Program for more information.
Pb: Lead
Peer Review: A system using reviewers who are the professional equals of the principal investigator or
program director. It is a form of objective review. Peer review is legislatively mandated in some
programs and in other programs is administratively required.
Point Sources: Large, stationary sources of emissions that release pollutants in quantities above an
emissions threshold.
Prior Approval: The requirement for written documentation of permission to use project funds for
purposes not in the approved budget or to change aspects of the program from those originally planned
and approved. Prior approval must be obtained before the performance of the act that requires such
approval under the terms of the agreement.
Priority Score: A score derived from the rating given to a proposal by each member on a review
committee. It is used to help determine which approved proposals will be granted awards, based on
funds available.
Program Announcement: Describes existence of a research opportunity. It may describe new or
expanded interest in a particular extramural program or be a reminder of a continuing interest in an
extramural program.
Page 14 - December, 2015
-------
Program/Project Officer: A sponsor's designated individual officially responsible for the technical,
scientific, or programmatic aspects of a particular grant, cooperative agreement, or contract. The
program/project officer deals with the grantee/contractor organization staff to assure programmatic
progress and serves as the counterpart to the principal investigator/project director.
Progress Report: Periodic, scheduled reports required by the sponsor summarizing research progress to
date. Technical, fiscal, and invention reports may be required.
Project Period (PP): The total time for which support of a project has been programmatically approved.
A project period may consist of one or more budget periods. (Also see Budget Period.)
Proposal: An application for funding that contains all information necessary to describe project plans,
staff capabilities, and funds requested. Formal proposals are officially approved and submitted by an
organization in the name of a principal investigator.
PTE: Potential to emit
PM: Particulate Matter - One of the "Six Common Air Pollutants," also known as "Criteria Pollutants"
and is regulated by the U.S. EPA. Click here to learn more about Criteria Pollutants.
PM10: Particulate Matter with an equivalent diameter less than or equal to 10mm.
PM2.5: Particulate Matter with an equivalent diameter less than or equal to 2.5mm.
PSD: Prevention of significant deterioration A standard that prevents sources of pollution from causing
a significant deterioration in the air quality in areas that meet the NAAQS.
OA: Quality Assurance is a rigorous process undertaken to ensure the quality of the data collected by a
system or instrument. QA procedures are deployed as part of the data collection process.
OAPP: A document describing in comprehensive detail the necessary QA, QC and other technical
activities that must be implemented to ensure that the results of the work performed will satisfy the state
performance criteria.
QC: Quality Control a rigorous process undertaken to maintain a specified level of data quality. QC
procedures are deployed after data have been collected (or after QA procedures).
Rebudget: The act of amending the budget buy moving funds from one category or line item to another.
(See also Budget Adjustment.)
Regional Haze: A cloud of aerosols and pollution extending up to hundreds of kilometers across a
region and can degrade visibility and air quality. To learn more about Regional Haze Rule and Program,
click here.
Regulations: The contractual rules and procedures governing sponsored research projects.
Page 15 - December, 2015
-------
Renewal: A competitively reviewed proposal requesting additional funds extending the scope of work
beyond the current project period. It is applicable to grants and cooperative agreements only.
Request for Applications (RFA): Announcements that indicate the availability of funds for a special
interest topic. Proposals submitted in response to RFAs generally result in the award of a grant.
Request for Proposal (RFP): Announcements that specify a topic of research, methods to be used,
product to be delivered, and appropriate applicants sought. Proposals submitted in response to RFPs
generally result in the award of a contract. Notices of federal RFPs are published in the Commerce
Business Daily.
RPO: Regional Planning Organization consists of tribal, local, state, federal air pollution agencies, and
other interested parties. The goal of an RPO is to work collaboratively in developing regional strategies
to solve air pollution, addressing regional haze, and related issues. There are five RPO: CENRAP,
MANE-VU, Midwest RPO, VISTAS, and WRAP.See each listed RPO to learn more or visit the
EPA website on RPO for a regional map and links.
Salaries and Wages (S&W): Payments made to employees of the institution for work performed.
Scope of Work: The description of the work to be performed and completed on a research project.
SIP: State Implementation Plan prepared by states and submitted to EPA describing how each area will
attain and maintain national ambient air quality standards. These rules have been approved by the EPA
and made part of the Code of Federal Regulations.
SLAMS: State or Local Air Monitoring Stations is "a network of air monitoring stations for criteria
pollutants using criteria set by the EPA's Office of Air Quality Planning and Standards (AOAQPS) for
their location and operation." Visit the EPA webpage on Ambient Air Monitoring Program for more
information.
Smog: A mixture of air pollutants, smoke, dust, aerosols, etc. that can degrade air quality and
visibility. Smog was traditionally used to refer to ground-level ozone in an urban pollution plume.
SQ2: Sulfur Dioxide - One of the "Six Common Air Pollutants", also known as "Criteria Pollutants" and
is regulated by the U.S. EPA. Click here to learn more about Criteria Pollutants.
Subcontract Subgrant, or Subagreement: A document written under the authority of, and consistent
with the terms and conditions of an award (a grant, cooperative agreement, or contract) that transfers a
portion of the research or substantive effort of the prime award to another institution or organization.
Supplemental (Rebudgeting or Modification) Proposal: A request to the sponsor for additional funds
for an ongoing project during the previously approved performance period. A supplemental proposal
may result from increased costs, modifications in design, or a desire to add a closely related component
to the ongoing project.
Page 16 - December, 2015
-------
TAR: Tribal Authority Rule is the EPA regulations that specify the CAA provisions for which it is
appropriate to treat the tribes as states. This 1998 rule establishes a flexible approach to tribal air quality
management allowing tribal governments to implement those provisions of the Clean Air Act that will
address most effectively the air quality concerns of their individual reservations. Includes TAS
requirements (see below).
TAS: Treatment as State Also known as an "Eligibility Determination" for a tribe to exercise a authority
under a particular CAA section, this process and approval requires that the tribe demonstrate that it: (1)
is federally recognized; (2) has a governing body carrying out substantial governmental duties and
powers; and (3) is capable of implementing the program consistent with the CAA and applicable
regulations. (4) The tribe must also identify the exterior boundaries of the reservation and, for non-
reservation areas, must demonstrate the basis for jurisdiction.
Technical Data: Recorded information, regardless of form or characteristic, of a scientific or technical
nature. Often referred to as the "science" of a proposal.
TEOM: Tapered Element Oscillating Microbalance is an instrument that measures continuous (hourly
or sub-hourly) particulate matter mass.
Terms of Award: All legal requirements imposed on an agreement by the sponsor, whether by statute,
regulation(s), or terms in the award document. The terms of an agreement may include both standard
and special provisions that are considered necessary to protect the sponsor's interests.
TIP: Tribal Implementation Plan is an EPA approved tribal plan for attaining and maintaining national
ambient air quality standards. These are tribal rules to manage air quality on a reservation that have been
approved by the EPA, entered into the Code of Federal Regulations and become federally enforceable.
Title V: Title V of the 1990 Clean Air Act Amendments requires all major sources and some minor
sources of air pollution to obtain an operating permit. A Title V permit grants a source permission to
operate. The permit includes all air pollution requirements that apply to the source, including emissions
limits and monitoring, record keeping, and reporting requirements. It also requires that the source report
its compliance status with respect to permit conditions to the permitting authority.
Total Direct Costs (TDC): The total of all direct costs of a project.
Total Project Costs: The total allowable direct and indirect costs incurred by the institution to carry out
an approved project or activity.
Toxic Air Pollutants: See hazardous air pollutants (HAP).
TRI: Toxic Release Inventory.
U.S. EPA: United States Environmental Protection Agency.
UV: Ultraviolet is "[a type of] electromagnetic radiation with a wavelength shorter than that of visible
light, but longer than short X-rays." Visit Wikipedia webpage on UV for more information.
Page 17 - December, 2015
-------
Visibility: A measure of distance at which an object or light can be discerned.
VOCs: Volatile Organic Compounds are "organic chemical compounds that have high enough vapor
pressures under normal conditions [standard atmosphere] to significantly vaporize and enter the
atmosphere." Organic chemicals all contain the element carbon (C); organic chemicals are the basic
chemicals found in living things and in products derived from living things, such as coal, petroleum and
refined petroleum products. Many of the organic chemicals we use do not occur in Nature, but were
synthesized by chemists in laboratories. Volatile chemicals produce vapors readily; at room temperature
and normal atmospheric pressure, vapors escape easily from volatile liquid chemicals. Volatile organic
chemicals include gasoline, industrial chemicals such as benzene, solvents such as toluene and xylene,
and tetrachloroethylene (perchloroethylene, the principal dry cleaning solvent). Many volatile organic
chemicals are also hazardous air pollutants; for example, benzene causes cancer.
Washout: The process by which gases and particles are removed from the atmosphere through rain.
Wet Deposition: The process by which gases and particles are transferred to the surface through
incorporation with precipitation (rain, snow, mist, etc.). See atmospheric deposition; compare dry
deposition.
Page 18 - December, 2015
-------
Frequently Ask Questions
(FAQ)
Page 19 - December, 2015
-------
Frequently Ask Questions
(FAQ)
1) Q: Can a CAA Section 103 grant be used to develop a Section 105 grant proposal?
A: Yes - according to the Tribal Menu of Options the Funding Mechanism for this objective
and supporting activities may qualify for the EPA financial support through the grant
authority of either the Indian General Assistance Program (IGAP) or Clean Air Act §103
programs.
2) Q: What type of capacity is needed (what is required/what is needed to be in place) for a
tribal environmental department to apply for and be approved for a Section 105 grant?
A: The tribe must be reasonable capable of carrying out the necessary functions in a manner
consistent with the terms and purposes of the CAA and all applicable applications. In
evaluating a tribe's capability, we will consider your tribe's:
• Previous management experience;
• Existing environmental or public health programs administered by the tribe;
• The mechanisms in place for carrying out the executive, legislative, and judicial
functions of the tribal government;
• The relationship between regulated entities and the administrative agency of the
tribal government that will be the regulator; and
• The technical and administrative capabilities of the staff to administer and manage the
program.
3) Q: How can I check my local air?
A: You can check your local air through www.airnow.gov .
4) Q: What is the difference between a primary and secondary National Ambient Air Quality
Standard?
A: Primary standards are set to protect human health. Secondary standards are set to protect
public welfare and take into consideration such factors as crop damage, architectural
damage, damage to ecosystems, and visibility in scenic areas.
5) Q: How is the location of an air monitoring station decided?
A: Sites are selected based on the pollutant or pollutants to be monitored, the population
density, proximity to other monitoring stations (including those in other states) and
operational efficiency.
6) Q: How can I get historical air quality data?
A: Historical air quality data is available on the World Wide Web at: www2.epa.gov/aqs or
http://vvvvvv3.epa.gov/airciualitv/airdata/
7) Q: What is the difference between air pollutants and toxic air pollutants?
A: An air pollutant is any substance in the air that could in high enough concentrations harm
human, animals, vegetation or other natural materials. Pollutants may include almost any
natural or artificial composition of airborne material capable of being airborne. Toxic air
pollutants (or Hazardous Air Pollutants, HAPs) are a subset of air pollutants. Air toxics
Page 20 - December, 2015
-------
are known or suspected to cause cancer or other serious health effects. See the following
EPA web site which explains what an air toxic air pollutant is:
http ://www3. epa. gov/ttn/atw/ allabout. html#what
8) Q: What type of air pollutants are produced by mobile sources?
A: Primarily carbon monoxide, oxides of nitrogen, hydrocarbons, and particulate matter are
significant air pollutants from mobile sources. Greenhouse gases and air toxics are also
important air pollutants from mobile sources.
9) Q: How does a tribe submit comments on a permit during an open comment period,
and how do tribes find out the EPA contact for a permit?
A: The information will be on the public notice for the permit. The public notice will
provide the information on how, when and to whom comments should be sent with an
address or email address. Additionally, the name of an agency contact will be in the
public notice. The tribes should contact "the agency contact" prior to close of comment
period if they have any questions.
10) Q: Who do the tribes contact on a current permit?
A: A tribe can contact the NSR tribal permit coordinator at Region 6. This information will
be on the R6 Tribal permitting webpage at: http://yosemite.epa.gov/r6/Apermit.nsf/AirP
11) Q: What is the time span of a valid Title V permit on a facility?
A: 5 years from the date of issuance.
12) Q: Who has/had delegation over a permit issuance?
A: Currently all permits on tribal lands are being written by Region 6. For other Regions
please refer to the individual Regional WebPages for the tribal delegations.
13) Q: Can a tribe comment on a permit and expect a direct response from the delegated permit
authority than what the average citizen would submit? If so how?
A: The tribes may submit comments on a permit when on public notice and will need to note
the requirements such as closing date for comments and the requirements for sending
comments to the permitting authority. Since the public notice does provide the permit
contact for the permitting action, the tribes should contact the permit contact or the EPA
6 tribal office early and prior to close of comments on a permitting action if they have
questions. All timely written comments will be considered in making the final permit
issuance decision and included in the record on the EPA Region 6 webpage when it is an
EPA issued permit. The_EPA may group similar comments from commenters together in
our response to comments, and we generally do not respond to individuals directly when
they submit comments on permits. We will post on our EPA Region 6 Air Permits
website all final permit documents including any responses to comments received on
draft permits. We will notify any Tribal Nations who submit comments during the public
comment period that we have issued a final permit decision, and as a courtesy make
available to them the final permit and any responses prepared in response to comments
received on draft permits.
Page 21 - December, 2015
-------
14) Q: Are there any limitations with the CAA funding (103 or 105) for non-reservation tribes
such as Oklahoma. If so, please explain further?
A: Once a tribe is determined eligible for Treatment in a Manner Similar to States (TAS)
under Section 301(d) of the CAA and in 40 CFR Part 49, there are no "restrictions" to
applying for and receiving funding directly related to the fact that an Oklahoma tribe does
not have a reservation proper. By law, the term "reservation" includes "Indian country"
as defined in 18 U.S.C. § 1151. Further, the EPA has determined that because there is no
Oklahoma state "agency with federally delegated program authority" for the CAA 103
and 105 grant programs, the tribes are not subject to the cooperative agreement
requirements of Section 10211(b) of the Safe, Accountable, Flexible, Efficient
Transportation Equity Act: a Legacy for Users (SAFETEA-LU), Pub. L. No. 109-59 Stat.
1144 (August 10, 2005).
15) Q: When can I submit a request to the EPA for consideration to merge CAA funding with
PPG?
A: During the program's funding announcement period (please reference Grant Process
Timeline).
16) Q: How can the CAA funding help a tribe achieve attainment status?
A: By providing the tribal community with funds to implement specific programs and/or
measures to reduce emissions of the nonattainment pollutant(s). For example, outreach
and education programs increase awareness of actions that create emissions and provide
solutions to reduce emissions of the nonattainment pollutants(s): also, specific measures
when implemented can reduce emissions of the nonattainment pollutant(s).
17) Q: How does the Tribal Implementation Plan differ from the State Implementation Plan?
A: The CAA requires each state to adopt a State Implementation Plan (SIP). Unlike states,
tribes are not required to adopt an implementation plan. In the Tribal Authority Rule, the
EPA recognized that not all tribes will have the need or the desire for an air pollution
control program. Where the tribes elect not to develop a Tribal Implementation Plan
(TIP) the EPA will adopt, without unreasonable delay, such Federal Implementation Plan
provisions as are necessary or appropriate to protect air quality. However, where the
tribes elect to adopt rules to regulate sources of criteria air pollutants under their
jurisdiction, these rules will form the core of a TIP. Compared to SIPs, TIPs are optional,
modular, have flexible submission schedules, and allow for joint tribal and the EPA
management.
18) Q: Is hydraulic fracturing (i.e., oil and gas well activities) categorized as area source?
A: Generally hydraulic fracturing can be categorized as an area source of emissions because
the individual activity emissions do not qualify them as point sources. Emissions from
mobile drilling rig engines can be categorized as nonroad mobile emissions. For specific
emissions inventory questions the EPA has Clearinghouse for Inventories and Emissions
Factors (Chief) Help Desk at (919) 541-1000 or info.chief@epa.gov
19) Q: What is the EPA Regional Priorities with respect to air quality this year?
A: The EPA Region 6 priorities for air quality are:
Page 22 - December, 2015
-------
• Implementing programs for regional haze and the ozone and sulfur dioxide air quality
standards.
20) Q:
A:
21) Q:
A:
22) Q:
A:
23) Q:
A:
Page 23 - December, 2015
If a tribe is proposing to begin air monitoring activities, will they be given a reasonable
amount of time {after start of grant period} before they are expected to begin collecting
air quality data?
Yes. A reasonable amount of time will be given to start collecting data, however, the
time period expected for the monitor to be operational and data commenced to be
collected should be within the first 2-3 months of the project period.
Are there different levels of delegation to permit issuance?
Yes. Delegation can be customized to each specific situation and need/qualification of
the tribe. This can occur in several stages like issuance of minor NSR permits or issuance
of PSD /nonattainment permits, or the full preconstruction permitting program. We could
delegate the state to do the review and propose issuance of the permit but the EPA can
still retain signature of the permit. All delegated programs for issuance of a permit must
meet the requirements in 40 CFR 124 for public notice, and other cross cutting program
issues such as Endangered Species Act. Title V program cannot be delegated.
What is the minimum for CAA 105 match?
CAA Section 105 requires all applicants to provide a 40% cost share (match).
Please note - the tribes who have obtained approval for treatment as a state (TAS) under
Section 105 of the CAA may apply for a reduced match of 5%.
What is the process if a tribes needs to amend a grant workplan?
It requires the tribe to send a request to the project officer in writing with an explanation
and a revised workplan to show the revised activities project timeline.
------- |