**VIII: Storage and Access to Monitoring Data**

**Problem Statement**

Tribes collect environmental data principally for internal use so tribal
leaders can make informed decisions to accomplish their environmental
policy objectives. Historically, EPA has required tribes in some Regions
to submit data to the Air Quality System (AQS) as a deliverable for
their Clean Air Act related grants. Not all EPA Regions have required
tribal data to be submitted to AQS. Recently, there has been a push by
EPA for all tribes to submit their data to AQS in all EPA Regions.

Many tribes have argued that forcing them to submit data to AQS is an
infringement on their inherent tribal sovereignty. Others have argued
that it isn't stated in the Tribal Authority Rule that tribal data must
be submitted to a national database, and the new requirement is policy,
not law. There is a link between tribal sovereignty and data collected
on tribal lands, and some tribal governments are expressing significant
reluctance to being forced to submit data to national databases, such as
AQS. Policy relating to tribal AQS data submittal should carefully
consider tribal concerns and include dialog with tribal leaders at the
highest levels of government.

There is also a "right to know" aspect in US public environmental
policy. Both tribal and non-tribal US citizens live within the tribal
environmental jurisdictions as defined by the Tribal Authority Rule of
the Clean Air Act, and policies developed and implemented within Indian
country can also impact neighboring jurisdictions. This complicates the
issue of tribal sovereignty as it relates to public access to
environmental information. This is especially true for environmental
data gathered through federal funding. These are also things that need
to be considered.

As previously stated, several tribes currently submit their data to AQS.
There are other tribes that are very open to submitting data to AQS in
principal, yet the resources to accomplish the task are limited.
Technical staff within tribal nations are frequently tasked with
multiple duties. This sometimes requires one person to develop and
utilize technical expertise in virtually every aspect of implementing
the Clean Air Act within their jurisdictions. The time they can spend
submitting data to AQS is limited. Since this is an infrequent task,
usually only required on a quarterly basis, it can also be a difficult
task to master. New resources to assist with AQS data submittal may be
necessary. Presently there isn't a single person anywhere in the US
whose sole job is to assist tribes with AQS entry.

Historically, some tribes relied heavily on various consultants to enter
air monitoring data into AQS on their behalf. However, since there is
currently less funding available from EPA to the tribes, the
responsibility has now been shifted back to the tribes to submit their
air monitoring data into AQS themselves. While it is true that some
regional EPA offices have been entering tribal raw data into AQS for a
few tribes, there is a push to limit regional assistance by training
tribal air quality staff so they may resume responsibility of entering
their own data into AQS.

**Description of AQS for Tribal Needs**

The Air Quality System (AQS) contains ambient air pollution data
collected by EPA, state, local, and tribal air pollution control
agencies from thousands of monitoring stations.  AQS also contains
meteorological data, descriptive information about each monitoring
station (including its geographic location and its operator), and data
quality assurance/quality control information.  So far, 27 tribes submit
their own data into AQS, while 14 tribes have others such as EPA
Regional offices, states or contractors submitting their data into AQS.
Currently there are 7 tribes submitting data using the new tribal code.

**Getting Data into AQS**

EPA regulations require state/local/tribal environmental agencies to
report air monitoring data at least quarterly. Data for one calendar
quarter are due to EPA by the end of the following quarter. However,
some values may be absent due to incomplete reporting, and some values
subsequently may be changed due to quality assurance activities. Today,
States, Local and Tribal agencies submit their data directly to AQS via
a web application. Users will need access to the internet in order to
access AQS. Registered users may also retrieve data through the AQS
application and through the use of third party software such as the
Discoverer tool from Oracle Corporation.  In the future, data from AQS
will be available via the AQS Data Mart that will be in production late
spring 2006.

**Who has Access to Data Once Submitted to AQS**

The Office of Air Quality Planning and Standards (OAQPS) and other AQS
users rely upon the system data to assess air quality, assist in
Attainment/Non-Attainment designations, evaluate State Implementation
Plans for Non-Attainment Areas, perform modeling for permit review
analysis, and other air quality management functions.  AQS information
is also used to prepare reports for Congress as mandated by the Clean
Air Act.

**How AQS can be used to Retrieve Tribal Monitoring Data in Useful
Forms**

OAQPS modified AQS to allow the use of tribal codes in the place of
state/county codes for data loading and retrieval. This change allows
tribal users to submit and retrieve tribal data without using a
reference to geo-political FIPS State and County codes, and thus
reinforce EPA's commitment to recognizing tribal sovereignty. Should any
tribe (or any user for that matter) need assistance or help loading or
retrieving data, AQS has user support which is provided through the EPA
Call Center. There is a toll free number (866-411-4372), and e-mail
(epacallcenter@epa.gov) that users may use to get help with the AQS
application. This helpline covers all aspects of AQS, i.e., simple
questions such as changing passwords to modifying reports to retrieve
specific data or change/correct monitoring data. Also EPA's ten regional
offices each have an AQS representative that can assist tribes in using
AQS. There is also training available at the annual AQS conference that
tribes can take advantage of during the conference.