**NEW GUIDANCE DOCUMENT**

**ON**

**TRIBAL AMBIENT MONITORING**

*Updates to previous draft reviewed by NTAA;*

*Includes revisions for Sections IV, VII and XII*

*November 2005*

**U. S. Environmental Protection Agency**

**Research Triangle Park, NC**

**Table of Contents**

**New Guidance Document on Tribal Ambient Monitoring**

**(Note: See Appendix B for proposed alternative structure for Table of
Contents)**

**Section I**. Purpose and Audience

Lead: Julie McClintock - EPA/OAQPS 919-541-5339 mcclintock.julie@epa.gov

> Bill Grantham - NTEC 505-242-2175 x116 bgrantham@ntec.org

**Section II.** Guidelines for EPA Support for Tribal Air Monitoring

Lead: Phil Lorang - EPA/OAQPS 919-541-5463 lorang.phil@epa.gov

> Bill Grantham - NTEC 505-242-2175 x116 bgrantham@ntec.org

**Section III**. Background for Planning Tribal Air Monitoring

Lead: Joe Tikvart - EPA/OAQPS/SEE 919-541-7793 tikvart.joe@epa.gov

**Section IV**. Tribal Air Quality Issues, Relevant Ambient Air
Monitoring, and Current and Recent Tribal Air Monitoring Activities
Directed Towards These Issues

Lead: Norm Beloin - EPA/R1 617-918-8387 <beloin.norm@epa.gov>

> Bill Thompson - Penobscot 207-827-7776cleanair@penobscotnation.org

Mike Copeland - EPA/R8 303-312-6010 copeland.michael@epa.gov

Keith Rose - EPA/R10 206-553-1949     rose.keith@epa.gov

**Section V.** Implementation of Monitoring (identify all things that
need to be done, e.g., Q/A, siting requirements, report to AQS, etc.)

Lead: Joy Wiecks - Fond du Lac 218-878-8008 <joywiecks@fdlrez.com>

Leland Grooms --EPA/R7 913-551-7124 grooms.leland@epa.gov

**Section VI.** The Role of Tribal Monitoring in the National Monitoring
Strategy

Lead: Phil Lorang - EPA/OAQPS 919-541-5463 lorang.phil@epa.gov

Stephen Hartsfield - NTAA 505-242-2175 x106 shartsfield@ntec.org

Bill Nally - EPA/R6 214-665-8351     nally.bill@epa.gov

**Section VII**. Understanding Monitoring Data and Its Implications

Lead: Motria Caudill - EPA/R5 312-886-0267 <caudill.motria@epa.gov>

Glenn Gehring - TAMS 702-784-8269 <gehring.glenn@epa.gov>

James Hemby - EPA/OAQPS 919-541-5459   hemby.james@epa.gov

**Section VIII**. Storage and Access to Monitoring Data

Lead: Farshid Farsi - TAMS 702-784-8263 farsi.farshid@epa.gov

Tami Laplante - EPA/OAQPS 919-541-1915 <laplante.tami@epa.gov>

George Dilbeck - EPA/ORIA 702-784-8278     dilbeck.george@epa.gov

**Section IX**. Assessment of Ambient Air Quality in Indian Country in
the Absence of Air Monitoring

Lead: Keith Rose - EPA/R10 206-553-1949     rose.keith@epa.gov

Ryan Callison - ITEC 800-259-5376 x1006 rcallison@cherokee.org

Glenn Gehring - TAMS 702-784-8269 <gehring.glenn@epa.gov>

Stephen Hartsfield - NTAA 505-242-2175 x106 <shartsfield@ntec.org>

Bill Thompson - Penobscot 207-827-7776cleanair@penobscotnation.org

Annabelle Allison - ITEP 919-541-0708 allison.annabelle@epa.gov

**Section X.** How to Request EPA Funding and Other Support

Lead: Stephen Hartsfield - NTAA 505-242-2175 x106 <shartsfield@ntec.org>

Ken Cronin - NTEC 505-242-2175 x115 kcronin@ntec.org

**Section XI.** Other Air Quality Management Program Elements

Lead: ?????

Leroy Williams (Gila River)

**Section XII.** The Tribal Perspective

Coordinator: Lisa Riener - Quinault 360-276-8215 x484
lriener@quinault.org

Joy Wiecks - Fond du Lac 218-878-8008 <joywiecks@fdlrez.com>

**I. Purpose and Audience**

**A. Background on EPA's Tribal Air Monitoring Program**

EPA's tribal air policy emphasizes that as sovereign governments, tribes
set their own air program goals. Therefore, EPA's goal for the tribal
air program is appropriately to help the tribes understand their air
quality problems and to establish and meet their air quality goals,
rather than to set goals or timetables for the tribes.

Tribes are diverse in their air quality problems, challenges, and
capabilities. In addition, tribes often also face non-air risks to the
health of their members \-- as well as other challenges and
disadvantages \-- that are different from those facing non-tribal
communities. Because of the diversity in situations and goals from tribe
to tribe, EPA has taken the approach of delegating to the Regional
Office level the tasks of assisting tribes in identifying their goals
and the task of managing the available resources to help meet those
goals. Because Regions understand individual tribal situations,
effective decisions about funding and in-kind assistance are best made
at the Regional Office level. Regional Offices have taken the initiative
on helping tribes set air quality goals and design ambient monitoring to
support them. Regions have prioritized requests from tribes when they
collectively exceed the tribal air management grant funds available to
the Regional Office. Regional Offices also negotiate, award, and manage
grants to individual tribes. Regional Offices provide in-person,
telephone, and written guidance and assistance to the tribal governments
at all these stages. Technical training on the actual operation of
monitors is available to tribes through the Tribal Air Monitoring
Support (TAMS) Center, which is supported by a grant from EPA
Headquarters. To date, Regional Offices and individual tribes have
entered into grants that have dedicated a portion of the available
tribal air management resources to plan, establish, and operate
approximately \[insert #\] ambient air monitoring stations in Indian
country.

In the course of this deliberately highly decentralized process,
Headquarters and Regional Offices have prepared a limited body of
strategic guidance on tribal air monitoring, i.e., guidance on deciding
whether to monitor, what type of monitoring to do, and how EPA will
prioritize requests for funding assistance. This guidance is rather
general in nature, reflecting the need to accommodate the diversity of
tribal situations.[^1] In addition to this limited body of strategic
guidance, tribes have access to the large body of EPA guidance on
monitoring technologies, quality assurance, and data management. While
originally prepared for use by state and local government agencies, this
technical guidance is equally applicable to monitors in tribal settings.

**B. Purpose of this Guidance Document**

This guidance document is not intended to modify any existing EPA
policies on tribal air quality management. The intended purpose of this
guidance document is to improve the ability of tribes and regional
offices to prioritize monitoring resources and to accomplish the
following:

● (1) ensure that tribal goals for tribal air monitoring projects are
clearly stated and documented in grant agreements (or other suitable
forms) before resources under EPA management are applied, that progress
in meeting those goals is tracked, and that tracking results are used to
make adjustments when appropriate.

*Do we want to imply that regions are not applying standards
consistently?*

● (2) serve as a useful information resource for tribes as they
determine their need for monitoring, work plans and grant applications,
as well as a one stop resource for locating technical information.

● (3) assist tribes to understand monitoring data.

*How do we do this?*

● (4) help integrate and coordinate tribal and state/local/national
monitoring strategies and activities.

*How? What does this mean? Section 4?*

● (5) Recognize the need for flexibility to address the unique needs of
individual tribes.

*Is this a separate point? Put in intro?*

**C. Audience**

The intended audiences for this document are tribal environmental
professionals and EPA Regional Office and Headquarters staff who are
involved in resource allocations, tribal air grant award and management,
program evaluation, strategic planning of monitoring networks, or
technical support to monitoring programs. State monitoring officials may
also benefit from reading this document, as it may improve their
understanding of tribal goals and how EPA strives to help tribes meet
their goals. This should allow them to collaborate more efficiently with
tribes whenever collaboration serves state and tribal objectives.

*This section is OK. If we adopt Bill's proposed new organization then
we need to make sure the new organization addresses different
audiences.*

**D. Relationship to EPA's Strategic Plan, Budget, and Program
Assessment Process**

EPA's Strategic Plan for 2003-2008 contains this statement regarding
EPA's commitment to work with tribes:

EPA is committed to working with tribes on a government-to-government
basis to develop the infrastructure and skills tribes need to assess,
understand, and control air quality on their lands. We will increase air
monitoring in Indian country, and, in consultation with tribes, we will
establish needed federal regulatory authorities and help tribes develop
and manage their own air programs in a manner consistent with EPA Indian
Policy and tribal traditions and culture. We plan to complete a policy
determining when Federal Implementation Plans are appropriate for
bringing Clean Air Act programs to Indian country. We will support
tribal air programs by providing technical support, assistance with data
development, and training and outreach, and we will help tribes
participate in discussions of national policy and operations and in
regional planning and coordination activities. Where tribes choose not
to develop their own programs, we will implement air quality programs
directly.

In developing its annual budget plans, EPA considers whether sufficient
resources are available to support tribal air monitoring that is
necessary and appropriate to protect air quality in Indian country or to
provide important data that helps meets state, local, or national
monitoring data needs. Each year, EPA's budget request to Congress
requests a certain amount of funding for use in giving to grants to
tribes to support air quality management. For the last several years,
Congress has appropriated about \$11 million for this purpose.[^2] It
has become apparent that increasing numbers of tribes are interested in
establishing monitoring stations, and that not all interested tribes
will be able to obtain EPA financial support for ambient air monitoring
if resources for tribal air quality management remain steady. Many if
not all Regional Offices report that already they are not able to meet
all requests to provide grant funds for tribal air monitoring. Other
than reporting this situation, this guidance document is not intended to
examine or make recommendations regarding the overall level of EPA
funding and in-kind support to tribal air quality management. EPA
considers this and other budget issues through other processes. The
experience of working across Headquarters and Regional Office and with
tribal professionals in the course of preparing this guidance document
\[will/has\] better informed EPA staff about the tension between
resources and needs, and will inform EPA budget decision-makers in
future years.

The Office of Management and Budget (OMB) on a regular basis assesses
EPA's Air Program to determine how well each part of the Air Program is
managed in terms of having appropriate, and well defined goals; applying
resources towards those goals; providing guidance to partners who help
meet the goals; having systems in place to observe how well the goals
are met; and making adjustments in the program when necessary to reach
those goals. In addition to meeting OMB expectations, this "goals and
feedback" model is just good common sense because it helps make sure
that limited resources are used in ways that best meet the right goals.
Programs that are found by OMB to have serious weaknesses in management
are asked to make corrections and face the possibility of funding
reduction in future year budget proposals to Congress.

The most recent round of review of the NAAQS air quality program by OMB
has made EPA managers and staff more conscious about the importance of
being able to document that the tribal assistance portion of the Air
Program meets OMB measures and goals, guides participants to meet those
goals, tracks progress, and make adjustments when needed. This guidance
document on tribal air monitoring is a new part of such documentation.

It should be noted that unlike most EPA programs, the goals of the
tribal air monitoring program have been set by the Regional offices and
tribes with general guidance from Headquarters and OAQPS. A result is
that people inside and outside of EPA who are not personally involved in
working with tribes on monitoring projects need the benefit of reporting
systems to be able to be aware of and assess what is being accomplished
with available resources. The preparation of this document represents
one cycle of such assessment and reporting, in that current and recent
tribal air monitoring programs are reviewed in Section IV.

**E. The Tribal Perspective**

EPA received comment from NTAA and tribal professionals in October on
the 11/05 draft. As a result of the comments received, we divided the
Guidance effort into two documents: (1) EPA Guidance to identify and
prioritize resources related to tribal air quality, and (2) Monitoring
Guidance for tribes. The Tribal perspective section will appear in both
documents.

Both documents convey EPA guidance and reflect EPA policies and both
will be developed by a workgroup that include tribal environmental
professionals. EPA has opened the development of this document to all
interested tribal environmental professionals to assist us to make a
document that takes into account tribal input and is meaningful to
tribes, as well as to EPA. To ensure that tribal views are represented,
particularly if they are not the same views as those represented in this
document, we are at various points in the document delineating text
blocks which will offer comment or reaction from the tribal perspective.
These passages are provided by tribal environmental professionals and
NTAA and do not represent EPA policy or guidance, but may be useful to
some or all readers of this document.

**II. Guidelines for EPA Support for Tribal Air Monitoring**

This section states the guidelines that EPA applies in its air
monitoring work with tribes. The purpose of listing them here is to
promote understanding and observance of the principles by EPA staff, and
to help tribes anticipate and understand the basis for future EPA
actions. Most of these principles flow from the Clean Air Act, the EPA
Indian Policy, the Tribal Air Rule, and other existing law and EPA rules
and policies on budget, quality assurance, ambient monitoring, etc. The
wording of these principles was the subject of the first few conference
calls among the project participants. Individual EPA Regional Offices
may have their own guidelines or grant criteria. In the course of
developing this guidance document, Regional Offices reviewed their
guidelines to ensure they did not conflict with those stated here. The
guidelines include the following:

a.  EPA has a responsibility to relate to each tribe on a
    government-to-government basis, and should act in the tribe's best
    interest. To the extent possible, EPA should also take into account
    the tribe's preferences. EPA is obligated to consult with tribes at
    an appropriate level. Input from tribal environmental professionals
    was obtained starting at an early point in the development of this
    guidance/strategy. However, EPA's consultation responsibilities may
    require continued discussions between tribal leaders and appropriate
    EPA staff or management

b.  Tribes set their own air quality goals. EPA strives to assist them
    in doing so and in determining how monitoring can help clarify
    and/or accomplish those goals.

c.  Monitoring supported by EPA grant funds should always be for the
    identified purpose of characterizing and/or managing specific known
    or suspected short term and/or long term risks to environmental
    values that depend on maintaining or restoring good air quality,
    including:

    i.  Human health risks (including informing exposed persons about
        the level of their exposure)

    ii. Ecological risks

    iii. Cultural resources and values, including those related to
         visibility.

d.  EPA and each tribe receiving funding to conduct monitoring should
    reach a clear understanding, before operations commence, of the
    duration of the funding or the timing and process for future
    decisions regarding continuation of the funding. There needs to be
    periodic re-evaluation of the need for and value of ongoing
    monitoring, for example on a three- to five-year cycle.

e.  EPA should support tribal capacity building, for example, by helping
    to develop the capabilities of tribal staff. Contractor support may
    be necessary and appropriate in some situations, but generally is
    not the preferred approach to carrying out monitoring. In the area
    of ambient monitoring, capability includes development of monitoring
    objectives, development of quality assurance plans, installation and
    operation of the monitors, execution of quality assurance plans,
    data handling, and understanding the implications of the observed
    ambient concentrations. EPA should seek to allow a tribe sufficient
    support and opportunity to progress through these stages.

f.  EPA has limited resources in its enacted budget to help pay for
    tribal air quality management in general. EPA is therefore unable to
    support all monitoring in Indian country that may have value to the
    affected tribes.

g.  There needs to be consistency/fairness across tribes, but also
    flexibility to hear and if appropriate to address unusual or
    unexpected tribe-specific situations.

h.  Decisions affecting specific tribes should be made at a level where
    individual situations can be appreciated.

i.  EPA should encourage all parties to take advantage of all available
    data on ambient air quality where technically relevant. Operating
    monitors may provide useful information on air quality some distance
    from their location and information on transport into and out of
    state and tribal lands.

j.  Tribes should have equal opportunity to participate in programs that
    are not inherently tied to state/tribe distinctions, and to benefit
    from resources used to support those programs, where such access is
    consistent with program goals.[^3]

k.  Grant procedures and grant performance must comply with applicable
    laws and regulations.

l.  EPA will work with tribes to ensure that there is timely EPA and
    public access to data collected with federal funds. EPA will need to
    explain the significance and need for this access to tribes
    generally and to each grant recipient. EPA should help tribes
    understand the significance of their data quickly so tribes are
    never less aware than others of the data and the data's
    implications.

m.  This EPA guidance does not limit any tribe's right to monitor for
    whatever air pollutants it chooses in its own portion of Indian
    country.

    **III. Background for Planning Tribal Air Monitoring**

    **Introduction**

    This section contains background on the Clean Air Act, other
    relevant laws, regulations, and policies, and other information that
    is not specifically about tribal air monitoring. It is intended to
    assist tribal professionals who are not already familiar with this
    material, so that they can participate more easily and effectively
    with EPA staff. To save space and time, this section consists of
    thumbnail sketches and pointers to other documents for fuller
    descriptions. In order to be brief and understandable to tribal
    professionals unfamiliar with the history and complexity of air
    pollution law, policy, history, and technology, the thumbnail
    sketches are simplified and do not convey all provision or nuances.
    They assist tribal staff in understanding the more detailed
    references, and in discussing these topics with EPA specialists and
    more experienced tribal professionals. Additional substantial
    amounts of information concerning (1) the Clean Air Act and
    associated EPA rules, (2) government policies, program planning,
    budgets and grants, (3) technical issues related to monitoring,
    emissions inventories and air data, and (4) health-related topics
    can be found by working through the following Internet addresses:

    Clean Air Act \-- <http://www.epa.gov/air/caa/>

    Chief Financial Officer (EPA) \--
    <http://www.epa.gov/ocfo/index.htm> Tribal Air (EPA/OAR) \--
    <http://www.epa.gov/air/tribal/>

    American Indian Environmental Office
    (EPA)\--<http://www.epa.gov/indian/index.htm>

    Northern Arizona University \-- <http://www4.nau.edu/>

    Technology Transfer Network (EPA/OAR) \-- <http://www.epa.gov/ttn/>

**A. EPA's Planning and Budgeting**

EPA's Strategic Plan serves as the Agency's road map for 5 year periods.
The plan is intended to lay out long-term goals, as well as annual goals
that will need to be met along the way. It helps EPA to measure how far
it has come towards achieving goals and to recognize where approaches or
directions need adjustment to achieve better results. Finally, it
provides a basis from which EPA\'s managers can focus on the highest
priority environmental issues and ensure the best use of resources.
Strategic Plans were released in 1997, 2000 and 2003. A plan for the
period 2006 -- 2011 is in preparation. A significant goal of the new
plan is to build on recent advances in strengthening joint
regional/state/tribal planning.

The Strategic Plan is supplemented by National Program Manager Guidance
and Regional Plans to accomplish goals associated with individual media,
e.g., air, including guidance on grants. The grant guidance specifically
addresses funding for tribes and their monitoring programs. For each
fiscal year (which runs from October through September), EPA also
develops a budget which defines the goals and objectives towards which
the Agency intends to work within the fiscal year and the funding
necessary to accomplish these goals and objectives. The budgeting
process includes a summary of EPA's budget, an annual performance plan,
a Congressional justification, and appropriate links to congressional
funding bills.

Also, under the Government Performance and Results Act (GPRA), an Annual
Report which serves as the Agency's program performance report
highlights the Agency's environmental, programmatic, and financial
performance for each fiscal year. Progress in meeting annual performance
goals for which data are available is documented, including that
contributed by tribal partners. Useful Internet links to all of this
information includes:

> \-- <http://www.epa.gov/ocfopage/plan/plan.htm>
>
> \-- <http://www.epa.gov/ocfo/npmguidance/index.htm>
>
> \--
> <http://www.epa.gov/cfo/npmguidance/oar/2005/oar_finalnpmguide.pdf>
>
> \--
> [http://yosemite.epa.gov/R10/AIRPAGE.NSF/283d45bd5bb068e68825650f0064cdc2/e34950b285534aa988256dfe0063be55/\$FILE/The%20TRIBAL%20AIR%20GRANTS%20FRAMEWORK%20final.pdf](http://yosemite.epa.gov/R10/AIRPAGE.NSF/283d45bd5bb068e68825650f0064cdc2/e34950b285534aa988256dfe0063be55/$FILE/The TRIBAL AIR GRANTS FRAMEWORK final.pdf)

\-- <http://www.epa.gov/ocfopage/budget/index.htm>

\-- <http://www.epa.gov/ocfo/finstatement/apr.htm>

**B. Relevant CAA provisions**

Section 301(d) of the Clean Air Act specifically authorizes EPA to treat
Indian tribes as States under the Act. In turn, the EPA Administrator
must promulgate regulations specifying those provisions of this Act for
which it is appropriate to treat Indian tribes as States. These
regulations establish requirements that Indian tribes must meet if they
choose to seek such treatment, and provides for awards of federal
financial assistance to tribes to address air quality problems. A range
of related policies and initiatives have also evolved over time with
regard to Indian tribes. In particular, the following documents are
relevant: the EPA Indian Policy, the Tribal Air Rule, and the draft
document "Implementing the Clean Air Act in Indian Country". Associated
legislative, regulatory and policy documentation is provided at the
following Internet addresses:

Clean Air Act and Tribes

> \-- <http://www.epa.gov/air/tribal/tar.html>
>
> \-- <http://www.epa.gov/air/caa/caa301.txt>
>
> \--
> <http://www.epa.gov/fedrgstr/EPA-AIR/1998/February/Day-12/a3451.htm>

EPA Indian Policy

> \-- <http://www.epa.gov/indian/policyintitvs.htm>
>
> \-- <http://www.epa.gov/indian/pdfs/indian-policy-leavitt-pr.pdf>

Tribal Air Rule

> \--http://yosemite.epa.gov/r10/airpage.nsf/16388b0c5db97d0088256b58005f8de5/94f65e27af63d505882569530077ae73!OpenDocument

Implementing the Clean Air Act in Indian Country

\-- <http://www.epa.gov/air/tribal/1997Caaimp.pdf>

**C. The January 27, 2005 Holmstead memo on criteria for award of tribal
air grants**

This document set forth criteria for the air program to use when
reviewing and assessing tribal requests for grants under the State and
Tribal Assistance Grants (STAG) appropriation. Two overriding factors
and four additional criteria for reviewing and assessing tribal requests
for FY05 STAG grants are identified, including significant air quality
related health concerns and environmental/cultural resource concerns as
overriding factors, plus programmatic commitment and leadership, prior
grant performance, location relative to essential data, and commitment
to air quality issues. The complete document is available at the
following Internet address:

\-- HolmsteadTAG_012705.doc

**D. Tribal Environmental Agreements**

A template for EPA/Tribal Agreements was prepared to establish
"workplans" between the Regions and Tribes to develop environmental
protection in Indian country. The Agreements should reflect the need for
development by partnership, flexibility, and re-visitation through a
common set of principles and consistent factors. The Agreements should
respect the sovereignty and legal status of tribes. These Agreements are
a critical next step to further developing environmental protection in
Indian country. To effectively evaluate the need for Tribal program
development in a consistent manner as well as provide a benchmark
against which to measure progress over time, the following outline has
been suggested: Preamble/Introduction, Draft EPA/Tribal Agreement
Template, Purpose for Establishing EPA/Tribal Agreements, Guiding
Principles, General Agreement on Region-wide Tribal Issues, Planning and
Budget Cycles, and (Name of Tribe)/EPA Specific Action Plan. Specifics
of tribal agreements can be found at the following Internet address:

\-- <http://www.epa.gov/indian/agree.htm>

**E. The existing state/local/other monitoring networks: types,
purposes, history, funding**

To preserve and improve the quality of the nation's air, it is necessary
to evaluate the status of the atmosphere as compared to clean air
standards and historical information. Ambient air monitoring programs
make such assessments possible. A review of the various air monitoring
networks (e.g., SLAMS, NAMS, PAMS, SPMS, including tribal monitoring) is
provided as part of the National Ambient Air Monitoring Strategy. That
strategy and other relevant information on monitoring networks,
including tribal programs, are provided at the following Internet
addresses:

\--
<http://www.epa.gov/ttn/amtic/files/ambient/monitorstrat/allstrat.pdf>

\-- <http://www.epa.gov/oar/oaqps/qa/monprog.html#Ambient>

\-- <http://www.epa.gov/oar/oaqps/montring.html>

\-- <http://www.epa.gov/ttn/amtic/amlinks.html>

\-- <http://vista.cira.colostate.edu/improve/Default.htm>

\-- <http://www.epa.gov/air/tribal/tribetotribe.html>

**F. The AMTIC Internet website**

The Ambient Monitoring Technology Information Center (AMTIC) Internet
website is operated by EPA\'s Ambient Air Monitoring Group (AAMG). AMTIC
contains information and files on ambient air quality monitoring
programs, details on monitoring methods, relevant documents and
articles, information on air quality trends and nonattainment areas,
federal regulations related to ambient air quality monitoring, as well
as information on monitoring training, contacts and related Internet
sites. The AMTIC Internet address is:

\-- <http://www.epa.gov/ttn/amtic/>

**G. The draft National Ambient Air Monitoring Strategy and related
rulemaking**

The overarching goal of the draft National Ambient Air Monitoring
Strategy is to improve the scientific and technical competency of the
nation's air monitoring networks while increasing our ability to protect
public and environmental welfare; and to accomplish this in flexible
ways that accommodate future needs in an optimized resource constrained
environment. Objectives in achieving this broad based goal include:
manage the Nation's air monitoring networks, establish a new air
monitoring approach, provide a greater degree of timely public air
quality information, improve network efficiencies, foster the
utilization of new measurement method technologies, encourage
multi-pollutant measurements, provide a base air monitoring structure,
develop and implement a major public information and outreach program,
seek input from the scientific community, provide air monitoring
platforms and data bases, and assess funding levels needed to maintain
support for this monitoring strategy. The impact of this strategy on
tribal monitoring is also addressed, including operation of monitoring
sites by Tribes. The draft monitoring strategy document (4/24/04) and
supporting documents that both provide a description of the strategy and
reflect ongoing components of the strategic plan development are
available at the following Internet addresses:

\-- <http://www.epa.gov/ttn/amtic/monstratdoc.html>

\-- <http://www.epa.gov/ttn/amtic/monitor.html>

**H. QA requirements, example QAPPs, resources for developing QAPPs**

EPA uses its Quality System to manage the quality of environmental data
collection, generation, and use; the primary goal is to ensure that data
are of sufficient quantity and quality to support decisions for
protecting the public and the environment. The Ambient Air Monitoring
Quality Assurance program applies these principles to air quality data.
This is accomplished through effective communication and cooperation
with monitoring organizations, which include EPA, State, Local, Tribal
agencies, the academic community and industry. The following QA tools
are routinely provided: [Guidance
Documents](http://www.epa.gov/airprogm/oar/oaqps/qa/index.html#guidance%23guidance),
[The National Performance Evaluation
Program](http://www.epa.gov/airprogm/oar/oaqps/qa/index.html#NPEP%23NPEP),
[Data Quality Assessments and
Reports](http://www.epa.gov/airprogm/oar/oaqps/qa/index.html#datqa%23datqa),
[Ambient Air Quality Assurance
Training](http://www.epa.gov/airprogm/oar/oaqps/qa/index.html#training%23training),
and example QAPP's. Information on QA requirements and examples of
applications are available at the following Internet addresses:

\-- <http://www.epa.gov/quality/index.html>

\-- <http://www.epa.gov/airprogm/oar/oaqps/qa/index.html>

\-- <http://www.epa.gov/ttn/amtic/quality.html>

\-- <http://www.epa.gov/ttnamti1/files/ambient/airtox/nattsqapp.pdf>

**I. Data systems for ambient air measurements (AQS, other)**

The Air Quality System (AQS) is EPA's widely used repository of ambient
air quality data. AQS stores data from over 10,000 monitors, 5000 of
which are currently active. State, Local and Tribal agencies collect the
data and submit it to AQS on a periodic basis. A detailed description of
AQS, supporting manuals and guides, web-based access, information on
training, and links to other sources of air quality information,
including S/L/T agencies in provided at the following Internet address:

\-- <http://www.epa.gov/ttn/airs/airsaqs/>

**J. Availability of ITEP and TAMS support**

The Internet home page for the Institute for Tribal Environmental
Professionals (ITEP) states that "ITEP was established in 1992 to assist
Indian Tribes in the management of their environmental resources through
effective training and educational programs."

The Internet home page for the Tribal Air Monitoring Support Center
states that \"The Tribal Air Monitoring (TAMS) Center was created
through a partnership between Tribes, the Institute for Tribal
Environmental Professionals and the United States Environmental
Protection Agency. It is the first technical training center designed
specifically to meet the needs of tribes involved in air quality
management and offers an array of training and support services to
Tribal air professionals. The TAMS Center mission is to strive to
develop tribal capacity to assess, understand and prevent environmental
impacts that adversely affect health, cultural, and natural resources.\"

Listings of training programs and services are provided respectively at
the following Internet addresses:

\-- <http://www4.nau.edu/itep/>

\-- <http://www4.nau.edu/tams/>

**K. Availability and role of "benchmarks" for health and ecosystem
effects**

Air Quality indicators, concentrations of criteria pollutants relative
to the NAAQS, effects on health due to toxic air pollutants, and other
ambient measures such as visibility and acid deposition, all provide
benchmarks of the nation's air quality. The 2003 Report on the
Environment makes extensive use of indicators in assessing the status of
health and ecosystem effects; preparation of a report that reflects 2006
has begun. The Report on the Environment, and associated information on
criteria and toxic air pollutants, is available at the following
Internet addresses:

\-- <http://www.epa.gov/indicators/index.htm>

\-- <http://www.epa.gov/indicators/roe/html/roeTOC.htm>

\-- <http://www.epa.gov/ttn/naaqs/>

\-- <http://www.epa.gov/iris/index.html>

\-- <http://www.epa.gov/ttnatw01/hlthef/hapindex.html>

\-- <http://www.epa.gov/air/toxicair/index.html>

\-- <http://www.epa.gov/air/visibility/index.html>

\-- <http://www.epa.gov/airmarkets/cmprpt/arp03/summary.html>

**L. National Emissions Inventory**

The National Emissions Inventory (NEI) is a national data base of air
emissions information with input from numerous State and local air
agencies, from tribes, and from industry. This data base contains
information on stationary and mobile sources that emit criteria air
pollutants and their precursors, as well as hazardous air pollutants
(HAPS). The data base includes estimates of annual emissions, by source,
of air pollutants in each area of the country, on an annual basis.
Emissions estimates for individual point or major sources (facilities),
as well as county level estimates for area, mobile and other sources,
are available currently for 1990 and 1996 through 1999 for criteria
pollutants, and for 1999 for HAPs. A final version of the 2002 NEI will
be ready in December 2005.

Four of the six criteria pollutants are included in the NEI data base:
CO, NOx, SO2, and PM10 and PM2.5. The NEI also includes emissions of
VOC, which are ozone precursors, emitted from motor vehicle fuel
distribution and chemical manufacturing, as well as other solvent uses.
VOCs react with NOx in the atmosphere to form ozone. Ammonia (NH3) is an
additional pollutant included in the NEI. The NEI data base defines
three classes of criteria air pollutant sources, e.g., point, area, and
mobile.

Hazardous air pollutants, also known as toxic air pollutants, are those
pollutants that are known or suspected to cause serious health problems.
Section 112 of the Clean Air Act (CAA) currently identifies a list of
188 pollutants as HAPs. The list of HAPs includes relatively common
pollutants such as formaldehyde, chlorine, methanol, and asbestos, as
well as numerous less common substances. The NEI data base includes
emission estimates for the 188 HAPs from stationary major and area
sources and mobile sources, as defined in the Clean Air Act (CAA). The
NEI includes three classes of HAP emission sources: Major, Area and
Other, and Mobile.

More information about the NEI data base and the compilation of criteria
pollutant and HAP emissions inventories, and links to the data base, are
available at the following Internet addresses:

> \-- <http://www.epa.gov/ttn/chief/net/index.html>
>
> \-- <http://www.epa.gov/ttn/chief/eiinformation.html>

**M. National Air Toxics Assessment**

The National Air Toxics Assessment (NATA) is a national-scale assessment
of [33 air pollutants](http://www.epa.gov/ttn/atw/nata/34poll.html) (a
subset of 32 air toxics on the Clean Air Act\'s list of 188 air toxics
plus [diesel particulate matter](javascript:gloss('gloss.html#diesel'))
(diesel PM)). The assessment includes four steps that look at the year
1996:

1.  Compiling a national emissions inventory of air toxics emissions
    from outdoor sources.

2.  Estimating ambient concentrations of air toxics across the
    contiguous United States.

3.  Estimating population exposures across the contiguous United States.

4.  Characterizing potential public health risk due to inhalation of air
    toxics including both cancer and non-cancer effects.

The goal of the national-scale assessment is to identify those air
toxics which are of greatest potential concern, in terms of contribution
to population risk. The results will be used to set priorities for the
collection of additional air toxics data (e.g., emissions data and
ambient monitoring data). Note: As of May 2002, the results posted for
all four steps include revisions based on input from scientific peer
review. Results are available at the following Internet address:

\-- <http://www.epa.gov/ttn/atw/nata/>

**N. Air quality modeling methods and tools, in particular how they may
be able to give insight into air quality in Indian country when ambient
monitoring is not available**

There are three types of air quality models: dispersion, photochemical,
and receptor models used in assessing control strategies and source
impacts. Source code and associated user\'s guides and documentation are
routinely provided for preferred/recommended models, screening models,
and alternative models. In addition, guidance if provided for applying
air quality models for regulatory applications for both State
Implementation Plans (SIP) demonstrations and revisions, as well as
permit applications for new source reviews, including Prevention of
Significant Deterioration (PSD) regulations. These latter applications
are particularly relevant for estimating air quality impacts in Indian
country.  Also available is the Model Clearinghouse which is designed to
help record the interpretation of modeling guidance for specific
regulatory applications.  Modeling contacts within the EPA Regional
Offices and State environmental agencies are available.  Detailed
information on models, codes and guidance in their use is available at
the following Internet addresses:

\-- <http://www.epa.gov/ttn/scram/>

\-- <http://www.epa.gov/scram001/tt22.htm>

\-- <http://www.epa.gov/scram001/tt25.htm>

**O. Indoor air issues including radon and mold**

Radon and mold can both be problems in indoor environments. Radon is
odorless and tasteless, but may exist at ambient air levels that exceed
safe limits in homes. Air containing radon that is breathed indoors is
the second leading cause of lung cancer in the United States today. 
Likewise, molds are part of the natural environment and are produced by
means of tiny spores. Mold may begin growing indoors when mold spores
land on surfaces that are wet. Molds can gradually destroy the things
they grow on, but damage to homes and furnishings can be prevented and
potential health problems avoided by controlling moisture and
eliminating mold growth. Internet addresses with additional information
on radon and mold, associated effects, and mitigation strategies are
available at the following Internet addresses:

\-- <http://www.epa.gov/iaq/index.html>

\-- <http://www.epa.gov/mold/index.html>

\-- <http://www.epa.gov/radon/index.html>

\-- <http://www.epa.gov/iaq/atozindex.html>

**P. The New Source Review and PSD programs and their relationship to
monitoring needs**

The New Source Review (NSR) permitting program applies to new major
stationary sources and major modifications locating in areas designated
as nonattainment for the NAAQS. The Prevention of Significant
Deterioration (PSD) permitting program applies to new major stationary
sources and major modifications locating in areas designated as
attainment or unclassifiable for the NAAQS. These programs generally
require the permit applicant to conduct a source impact analysis, using
monitored data and air quality models. For the NSR program, the impact
analysis must demonstrate that the new or modified source will not cause
or contribute to a violation of state or national air quality standards
or cause an adverse impact to visibility in any federal Class I area.
The PSD program is generally designed to provide a more comprehensive
source impact analysis than the NSR program, including effect on air
quality related values, e.g., visibility, that have been identified for
Class I areas. NSR/PSD and the use of air monitoring data in source
impact analyses to identify existing (representative) conditions and
potential future impacts are addressed at the following Internet
addresses:

\-- <http://www.epa.gov/nsr/>

\--
<http://www.epa.gov/ttn/amtic/files/ambient/criteria/reldocs/4-87-007.pdf>

\-- <http://www.epa.gov/ttnamti1/files/ambient/visible/r-99-003.pdf>

**Q. Clean Air Act section 110(a)(2)(D) -- the interstate transport
provision that also addresses transport between states and tribes.**

Section 110(a)(2)(D) is the provision of the Clean Air Act that requires
EPA to ensure that each state\'s SIP prevents emissions from that state
contributing significantly to nonattainment in another state. So far,
EPA has used this section twice to require states to control their
emissions because of effects on nonattainment in other states, in the
NOx SIP Call rule and the Clean Air Interstate Rule. A section of the
Clean Air Interstate Rule preamble discussed the tribal issues of that
particular action.

Tribes can be treated as if they were states under this provision, both
as upwind contributors and as downwind receptors of air pollution, but
as of the date of this document no such tribe has actually been
officially treated in this way. In concept, this section can apply
between a tribe and the state within which it is located, not just other
states. A downwind tribe would need to be experiencing nonattainment
with a NAAQS for this provision to be used to seek emission reductions
from the upwind state or states; to date, only monitoring data has been
used as evidence of such nonattainment in the two cases in which EPA has
applied this section to states. The details of Section 110 and
applications in national rules are available at the following Internet
address:

\-- <http://www.epa.gov/oar/caa/caa110.txt>

\-- <http://www.epa.gov/ttn/naaqs/ozone/rto/rto.html>

\-- <http://www.epa.gov/CAIR/index.html>

**R. The GAP program**

Under its Indian Policy, Presidential Memorandum and Executive Orders,
EPA works with Tribal governments on a government-to-government basis
and recognizes Tribes as the primary parties for making environmental
policy decisions and carrying out program responsibilities affecting
Indian reservations, their environments, and the health and welfare of
the reservation populace. One tool that EPA has to assist Tribes in
developing Tribal environmental protection programs is the General
Assistance Program (GAP).

"Guidelines on the Award and Management of General Assistance Agreements
for Indian Tribes" provide the national policy guidelines and criteria
for the award and administration of GAP grants. They reflect statutory
and regulatory requirements and, in some instances, establish new
binding requirements that have not been announced previously. The EPA
Regions may provide supplemental guidelines and establish Regional
priorities and criteria that are consistent with relevant statutes,
regulations and this document. The complete document is available at the
following Internet address:

\-- <http://www.epa.gov/indian/pdfs/gap2000.pdf>

**S. Visibility provisions of the Clean Air Act, mandatory and
non-mandatory Class I areas**

Section 162 of the Clean Air Act designates international parks,
national wilderness areas, national memorial parks, and national parks
greater than a certain size to be Class I areas. Sections 169A and 169B
declare as a national goal the prevention of any future, and the
remedying of any existing, impairment of visibility in such areas where
impairment results from manmade air pollution. A study and report to
Congress on available methods for implementing this national goal is
authorized and is to be accompanied by recommendations for monitoring,
modeling and preventing/remedying manmade pollution and resulting
visibility impairment. Regulations are to be promulgated to assure
reasonable progress toward meeting the national goal and compliance with
the requirements of these sections. An assessment and evaluation that
identifies, to the extent possible, sources and source regions of
visibility impairment including natural sources as well as source
regions of clear air for class I areas is to be made within 3 years
after enactment of the Clean Air Act Amendments of 1990. Establishment
of Visibility Transport Regions and Commissions is authorized for
assessing the scientific and technical data, pertaining to adverse
impacts on visibility from potential or projected growth in emissions
from sources located in the Visibility Transport Region and recommend
measures that should be taken under the Clean Air Act to remedy such
adverse impacts. Relevant sections of the CAA, reports on visibility,
and information on the regional haze program and on Regional Planning
Organizations can be found at the following Internet addresses:

\-- <http://www.epa.gov/air/caa/caa162.txt>

\-- <http://www.epa.gov/air/caa/caa169A.txt>

\-- <http://www.epa.gov/air/caa/caa169B.txt>

\-- <http://www.epa.gov/air/visibility/index.html>

**Number range CHAPTERIV. Tribal Air Quality Issues, Relevant Air
Monitoring Air Monitoring and Tribal Air Monitoring Activities**

This section will examine the reasons for tribal air quality monitoring
and provide examples of current tribal air monitoring.

Section 301 (d) of the 1990 Clean Air Act Amendments provides federally
recognized tribal governments the authority to implement Clean Air Act
programs for their reservations and other land that they can demonstrate
jurisdiction. The Tribal Authority Rule (TAR) promulgated on February
12, 1998, further delineates the authority of tribes to implement air
quality programs under the Act.

Tribes may need to conduct ambient air monitoring for a variety of
reasons which include the following: (1) attainment with health and
welfare based National Ambient Air Quality Standards (NAAQS); (2)
impairment of visibility and biological diversity for vistas within or
near reservations; (3) measurement of toxic air pollutants for health
and ecological effects; (4) collection of near-real time data for
reporting Air Quality Index (AQI) to the tribal community and to EPA's
AIRNOW real-time mapping program, (5) monitoring air quality related to
tribal environmental and cultural resource concerns, (6) being part of a
Regional/State monitoring network (7) for determining air quality
background levels and establishing air quality baselines and (8) to
increase awareness that indoor environments play a large, if not the
largest, role in causing the increase in asthma and respiratory disease.

.

Tribes have a need to understand the short and long term effects of long
distance transport on tribal lands and the effects of atmospheric
deposition on the ecology of their lands. Tribes also need air
monitoring data to identify the role of off-reservation sources and /or
to build a case or partnership for controlling those sources. Examples
of these programs include long term IMPROVE, NADP, MDN, ozone, PM2.5,
precursor gas and toxic air quality monitoring.

The following is a review with examples of how the tribes have conducted
air quality monitoring to provide data: (see appendix?? for more
detailed examples of specific air monitoring)

> **1. Air monitoring for compliance with health based NAAQSs**
>
> Tribes are currently monitoring to demonstrate compliance with
> national standards, primarily for ozone and particulate matter, in
> areas of the country that are not in compliance with the NAAQSs for
> these pollutants. The data from these sites may be used to demonstrate
> the need to develop a tribal implementation plan, to show the
> inadequacies of state or federal implementation plans (or monitoring
> networks) or to warn tribal members of unhealthy air quality. Tribes
> may also be well located to perform air monitoring that broadens the
> coverage of state SIP monitoring networks. For example, several tribes
> in Regions 1 operate ozone and PM2.5 air monitoring sites in areas
> that the states are unable to monitor, such as the island of Martha's
> Vineyard, MA or far eastern ME.
>
> An example of this type of air monitoring is the ozone air quality
> monitoring being performed is the Wampanoag Tribe of Gay Head at
> Aquinnah, MA (Martha's Vineyard). The tribe is currently operating an
> air monitoring program consisting of an ozone monitor, an IMPROVE
> sampler, and a meteorological station. The station is located in the
> Massachusetts non-attainment area in an area where there is no state
> air monitoring. In 2005 the station recorded four days above the 8-hr.
> ozone NAAQS and provided the tribe with health related air quality
> data to inform tribal members. Data from this station will also
> provide the tribe with the ability to ensure that ozone air quality
> standards will be met in the future.
>
> PM10 monitoring has been on-going in non-attainment areas on Tribal
> lands in Montana for many years. The Confederated Salish and Kootenai
> Tribes and the Northern Cheyenne Tribes were designated non-attainment
> for PM10 in 1989. Ongoing monitoring for PM10 will be required to
> satisfy compliance with their respective Tribal Implementation Plans.
> PM2.5 monitoring was also initiated in these two areas as a screening
> tool to ensure compliance with the PM2.5 standard.

2.  **Impairment of visibility for vistas within or near reservations**

> Visibility measurements are another important measurement objective
> for tribal reservations designated as Federal mandatory Class 1 areas.
> The CAA amendments of 1990 set a target of improving visibility in
> mandatory Class 1 Areas to natural visibility conditions by 2064. Data
> from these sites will provide tribes important information to
> determine the impacts from regional haze on visual impairment on
> tribal lands. Examples of visibility measurements on tribal lands
> include the operation of IMPROVE monitors by a number of tribes and
> the operation of haze-cameras on tribal lands. The Aroostook Band of
> Micmac Indians operate both an IMPROVE monitor and a haze camera at
> their air monitoring site in Presque Isle Maine. Data from this site
> is included in the National IMPROVE web page and the haze camera is
> included as part of the NESCAUM haze-cam network. The Assiniboine and
> Sioux Tribes of the Fort Peck Indian Reservation in northern Montana
> also operate an IMPROVE monitor which they use to monitor the status
> of their voluntary Class 1 air shed. They, the Confederated Salish and
> Kootenai Tribes, and the Northern Cheyenne Tribes operate IMPROVE
> samplers that supplement the core IMPROVE network and provide valuable
> information on areas that would otherwise lack monitoring resolution.

3.  **Toxic air pollutants for health and ecological effects**

> Tribes are also monitoring for hazardous air pollutants and/or air
> toxics. Air monitoring for these pollutants can either be for short
> term exposures when there is a chemical release or for long term
> community and ecological impacts. Sources of these pollutants include
> nearby stationary sources, area sources, mobile sources, and long
> distance transport from urban areas. Data from these sites provide the
> tribes critical information on hazardous pollutant exposures and
> impacts of air toxics on communities and tribal lands through risk
> analyses conducted using this monitoring data. Examples of this type
> of monitoring include mercury deposition monitoring or the impact of a
> nearby power plant or pulp mill. The Nez Perce Tribe of Idaho is
> currently conducting air toxics monitoring in the town of Lewiston and
> on their reservation for toxic emissions from the Potlatch pulp mill
> in Lewiston.

4.  **Monitoring to Support AQI and AIRNow**

> Some Tribes are operating continuous monitoring for ozone and PM2.5
> and convert these data to the appropriate AQI, based on EPA's AQI
> concept. This AQI relates concentration of pollutants to their
> potential health effects and can be used to alert a community to
> unhealthy air quality conditions. Another critical role for tribal
> monitoring is being part of the national AIRNOW mapping program. These
> sites provide near real-time data quality information and valuable
> information to better understand the fate and transport of air
> pollution.

5.  **Significant air quality related environmental and cultural
    resource concerns**

> One of the most important reasons that tribes are conducting air
> quality monitoring is to gather information on the long term air
> quality effects on the tribal community and on tribal lands. In many
> cases tribes use their ancestral []{.mark}lands for subsistence
> hunting and fishing, traditional rites, and harvesting native plants.
> Tribes are concerned that long term exposures to air pollutants, acid
> rain, and heavy metal deposition will adversely affect these
> resources. It should be noted that this type of air monitoring
> requires a long term commitment both in term of funding and in
> resources (for operation of equipment and analyses/assessments of the
> data). Examples of this type of monitoring include operating trace
> level SO2, CO and NOy monitors, sulfate, nitrate, metals, and NADP &
> MDN samplers and IMPROVE samplers~~.~~

6.  **Regional Monitoring**

> Another critical role for tribal monitoring is being part of a
> Regional/State monitoring network. Tribes may be well located to
> perform air monitoring that broadens the coverage of state SIP
> monitoring networks and supports the national AIRNOW mapping program.
> Several tribes in Regions 1 operate ozone and PM2.5 air monitoring
> sites in areas that the states are unable to monitor, such as the
> island of Martha's Vineyard, MA or far eastern ME. Not only do these
> sites provide extended coverage for the regional air monitoring
> program, but also they provide improved coverage for EPA's AIRNOW
> real-time air quality mapping program. These sites provide valuable
> information to better understand the fate and transport of air
> pollution.

7.  **Determining Air Quality Background Levels and Establishing Air
    Quality Baselines for PSD**

> In some cases tribes will need to conduct air quality monitoring to
> determine air quality background levels or to establish a baseline.
> This information is important for the protection of areas with
> pristine air quality and to provide quantitative data before new
> stationary sources are located in or near Indian Country.

8.  **Indoor Air Quality**

> The increase in asthma and respiratory disease, and the attempt to
> discover their causes has led to an increased awareness that indoor
> environments play a large, if not the largest, role in causing this
> issue. Molds, tobacco smoke, Radon, improper ventilation, insect
> infestations, and cooking/heating fires all play a role in increasing
> the effects of respiratory distress on effected populations and to a
> disproportionate extent, Tribal members. Funding for monitoring
> projects such as the Radon monitoring program, Tools for Schools, and
> others, can be used to assist in identifying problems and suggest
> solutions. This information can be used to act or can influence other
> mechanisms to assist in remediation of Indoor Air Quality issues.
>
> **9. Source Monitoring**
>
> Tribes may need to conduct emission monitoring on their major point
> sources for compliance purposes. This may be in the form of stack
> tests or by conducting continuous emission monitoring. Normally tribes
> monitors for particulate, sulfur dioxide, nitrogen oxides, volatile
> organic compounds and/or carbon monoxide. Generally this monitoring is
> required by a PSD or operating permit.

# V. Implementation of Monitoring

There is a growing movement in the United States of Tribal organizations
taking an increased interest in ambient air quality issues on Tribal
lands.

Tribes wishing to examine ambient air quality issues on their
reservations or tribal lands should have a good working strategy in
place as they decide what their interests and concerns are in the
development of their work plan and program strategy. Tribal entities
often decide that the best way to assess the current air quality
situation is through the use of ambient air quality monitors. A
strategic approach to monitoring should incorporate specific planning
stages.

Initially, a tribe will need to work with their EPA regional contacts to
begin development of a work plan which will be required for EPA
operational grant funds and used to organize the direction of the
program. This is especially important in the planning phase as many of
the air monitoring development steps can be incorporated into the work
plan objectives and thus funded by EPA. This also obligates EPA to
provide guidance and technical assistance throughout the whole process.

The tribe should then research a complete list of sources on local,
regional and even national levels depending on the pollutant of interest
and type of monitoring incorporated. A tribe can identify which
pollutants are of the greatest concern through existing methods and
tools such as:

-   EPA Air Quality System (AQS): A national database that tracks air
    monitoring data from state, local, and other entities

-   Data from existing programs such as IMPROVE, CASTNET, etc.

-   State Emission inventories

-   Private industry monitoring data

-   Climatology data

In correlation with the data, the type and need of monitoring should
also focus on the category of source. The category of source will
determine a great deal of what method of monitoring should be utilized
and if it is worth pursuing. Categories can be broken down as follows:

-   Stationary

    -   Fixed facilities such as:

    -   Factories

    -   Power Plants

    -   Chemical Process Industries

    -   Petroleum Refineries

-   Area

    -   Dry Cleaners

    -   Bakeries

    -   Surface Coating Operations

    -   Home Furnaces

    -   Crop Burning

-   Mobile

    -   On-Road

        -   Trucks

        -   Buses

        -   Cars

    -   Off-Road

        -   Farm vehicles

        -   Construction Equipment

        -   Trains

A tribe should take all of this information in to account before
deciding to start sampling. Many tribes often perform their own emission
inventory prior to designing a sampling program which can be
incorporated into the EPA grant work plan. Two important questions
should be asked and answered by the tribe about air monitoring before it
begins:

1)  Why are we sampling?

2)  What is our response or plan if our sampling data indicates
    unhealthy conditions?

Once the pollutant parameter has been identified the sampling
methodology should be decided on. The final decision on what type of
monitors to used will also focus on many factors such as cost, accuracy,
level of quality assurance, weather conditions, and conditions at
monitoring site (electricity and phone line availability). Ambient air
monitors can be broken down in following two general groups, manual and
continuous:

-   Manual Samplers

    -   Time averaged data

    -   Sampling Media

        -   Filter samples

        -   Cartridges

        -   Canisters

    -   Analyzed in separate step

-   Continuous Samplers

    -   Instrumental methods

    -   On-line data

The type of air monitoring sampler to be used should weigh heavily on
the monitoring objectives the tribe has developed concentrating on what
they want the data to provide. Such reasons might be:

-   To determine highest concentrations expected to occur in the area
    covered by a monitoring network

-   To determine representative concentrations in areas of high
    population density

-   To determine impact on ambient pollution levels of significant
    source categories

-   To determine background concentration levels

This step is a difficult and important one. For example, many tribes are
involved in particulate sampling. They may choose to deploy a couple
manual PM2.5 samplers to an area of their tribal land. This will require
a daily operator (or whenver the sampler runs) to collect the filters to
process. This monitor will require electricity. The tribe may choose a
continuous PM2.5 monitor, this will involve using a data logger to
record readings and can be downloaded from a modem to a remote site if
phone connections are available. The tribe may want to become vested in
existing national programs for particulate, such as the IMPROVE and
CASTNET, which offer assistance in all areas of operation, or the tribe
may choose to use mini-volume samplers which are more portable and can
be used in a mobile status.

An air monitoring site should be chosen based on what information the
tribe wishes to capture. Monitoring can be performed to capture
emissions from a specific source, for background information, or to
gather information on concentrations found near schools and
neighborhoods. Some Reservations are large enough that monitors are
needed in multiple locations.

Once a tribe has identified pollutants of concern and a potential
site(s), grant money must be obtained. A work plan is drafted explaining
the need for a monitor and submitted to the Regional EPA office. Cost
information must be collected, both for the monitor and for ancillary
costs. Ancillary costs vary widely with the type of monitor needed and
where it is to be located. These may cover: construction of a monitoring
shed or purchase of a monitoring trailer; installation of electricity
and phone service; purchase of a data logger and chart recorder; lab
costs; purchase of calibration devices; spare parts for monitor; tools
for working on the monitor; and shipping costs to the lab. Some monitors
are very complex and must be shipped back to the vendor for servicing,
these costs should be considered. For a complex monitor, vendors often
offer to come out and place the monitor themselves and give a training
session, these costs must also be considered. A dedicated computer or
laptop may be purchased for gathering data, analyzing it, and uploading
it to national databases.

A tribe must also consider how audits are to be performed. These
services must be performed by an outside party using separate equipment
and may be contracted out. Costs for these services may be large. A
tribe may even consider contracting out the entire operation of a
monitor, although these costs may be prohibitive.

Once a work plan has been approved and grant money is in hand, the tribe
must order the monitor and ancillary equipment and arrange for its
placement. All this activity must be coordinated, along with laboratory
analysis. Tribes must also learn how to use the monitor and write a
quality assurance project plan (QAPP) and Standard Operating Procedures
for its operation. This can be a months-long process. Once the tribe has
finished the QAPP, it is submitted to the Regional Office for approval.
Although QAPPs are supposed to be written and approved before a tribe
actually starts collecting data, this may be unrealistic. It is hard to
write a QAPP for a monitor one has never seen, let alone operated.
Although QAPPs may be copied from another tribal or state agency's QAPP,
the operation of the monitor still needs to be understood by the tribal
operators. ITEP courses are available for some types of monitors but not
for all, and courses are offered infrequently. Tribes are also strongly
encouraged to collect meteorological data at the monitoring site. This
involves pricing, ordering, installing and operating additional pieces
of equipment.

After data is collected, tribes need to be able to understand what to do
with it. ITEP offers Data Analysis courses where tribes can learn basic
statistical techniques used for demonstrating compliance with National
Ambient Air Quality Standards. Data also needs to be uploaded to the
EPA's AQS database. Some tribes put their data on a website so tribal
members can access it on a day-to-day basis.

All of the above considerations need to be addressed if a tribe is to
have a successful monitoring program.

**VI. The Role of Tribal Monitoring In the National Monitoring
Strategy**

\[This section will explain the history, status, and content of the
National Ambient Air Monitoring Strategy and the relationship between it
and tribal monitoring programs.\]

(to be completed)

**VII. Understanding Monitoring Data and Its Implications**

1.  **Background**

There are many approaches to data interpretation ranging from a simple
data summary to complex statistical procedures. The range of
possibilities can be overwhelming, but is easily narrowed by asking a
simple question: "Why was monitoring conducted in the first place?" The
appropriate use of monitoring data is intimately linked with the
monitoring objective. Assuming that the monitoring agency has followed
the procedures outlined in Section ??, the existing or proposed
monitoring plan has a purpose in mind and steps have been taken to
ensure that the final data product is adequate for its intended purpose.

For example, an agency located in a potential high ozone area may set up
an ozone monitor to gauge attainment of the National Ambient Air Quality
Standard (NAAQS). Quality assurance measures must be put in place to
collect reliable data for a 3-year period. If the dataset is found to
meet data quality objectives then it may be used as the basis for NAAQS
attainment designation for the county. If the data are incomplete or
otherwise compromised, then an attainment determination will not be
possible.

Similarly, there are data quality requirements for hazardous air
pollutant (HAP) monitoring which is intended for use in exposure
assessment and health risk interpretation. It is not uncommon for an
agency to collect ambient HAP data only to discover later that the wrong
target compounds were reported or that detection limits were too high to
allow comparing the data against cancer risk benchmarks. These problems
can be minimized by effective planning which identifies the intended use
of monitoring data and delineates specific monitoring quality
objectives.

2.  **Purpose**

The main goal of this section is to help Tribal staff achieve their
monitoring program objectives through an effective use of monitoring
data. We will give an overview of potential data uses and provide links
to relevant guidance documents and examples. Possible data uses include:
determining attainment of NAAQS for criteria pollutants; characterizing
population exposure to HAPs, also known as "air toxics"; assessing air
pollutant trends over time; and attributing source contribution to air
pollution.

Basic data summary and statistical techniques allow the monitoring
agency to effectively communicate project results. These methods are
important for a variety of purposes: to inform Tribal members and others
about local air quality; to summarize monitoring results in grant
documentation and the final project report; and to describe prior air
quality findings as justification for new or renewed funding in a grant
application.

This section will be useful to an agency that has already collected a
dataset and needs help understanding it. However it may be even more
valuable to a program manager who is in the stages of planning an air
quality study as it will provide a clear understanding of what an
ambient monitoring program can do for them and what questions it can
answer.

3.  **Recommendations for specific data uses**

    1.  **Criteria pollutants**

Tribal agencies that conduct ambient air quality monitoring most
frequently collect data for the six common pollutants (also referred to
as \"criteria\" pollutants): carbon monoxide (CO), lead (Pb), nitrogen
dioxide (NO~x~), ozone (O~3~), particulate matter (PM), and sulfur
dioxide (SO~2~). PM falls into two categories: particles smaller than 10
microns in diameter (PM~10~) and particles smaller than 2.5 microns
(PM~2.5~). This section will describe how criteria pollutant monitoring
data may be interpreted and used as part of an air quality management
program.

For more information on sources of criteria pollutants, health and
environmental effects, efforts underway to help reduce the pollutant,
and other helpful resources, visit:
[www.epa.gov/air/urbanair/6poll.html](http://www.epa.gov/air/urbanair/6poll.html)

1.  **NAAQS attainment**

EPA has set NAAQS standards for the six criteria pollutants. The NAAQS
include both primary and secondary standards. Primary standards set
limits to protect public health, including the health of \"sensitive\"
populations such as asthmatics, children, and the elderly. Secondary
standards set limits to protect public welfare, including protection
against decreased visibility, damage to animals, crops, vegetation, and
buildings. The table below lists the current NAAQS for criteria
pollutants. Units of measure for the standards are parts per million
(ppm) by volume, milligrams per cubic meter of air (mg/m^3^), and
micrograms per cubic meter of air (µg/m^3^).

**Table 1. National Ambient Air Quality Standards**

  ------------------ --------------- ------------------- -----------------
  **Pollutant**      **Primary       **Averaging Times** **Secondary
                     Standards**                         Standards**

  Carbon Monoxide    9 ppm (10       8-hour^1^           None
                     mg/m^3^)                            

                     35 ppm\         1-hour^1^           None
                     (40 mg/m^3^)                        

  Lead               1.5 µg/m^3^     Quarterly Average   Same as Primary

  Nitrogen Dioxide   0.053 ppm\      Annual (Arithmetic  Same as Primary
                     (100 µg/m^3^)   Mean)               

  Particulate Matter 50 µg/m^3^      Annual^2^ (Arith.   Same as Primary
  (PM~10~)                           Mean)               

                     150 ug/m^3^     24-hour^1^           

  Particulate Matter 15.0 µg/m^3^    Annual^3^ (Arith.   Same as Primary
  (PM~2.5~)                          Mean)               

                     65 ug/m^3^      24-hour^4^           

  Ozone              0.08 ppm        8-hour^5^           Same as Primary

  Sulfur Oxides      0.03 ppm        Annual (Arith.      \-\-\-\-\-\--
                                     Mean)               

                     0.14 ppm        24-hour^1^          \-\-\-\-\-\--

                     \-\-\-\-\-\--   3-hour^1^           0.5 ppm\
                                                         (1300 ug/m^3^)
  ------------------ --------------- ------------------- -----------------

^1^ Not to be exceeded more than once per year.

^2^ To attain this standard, the 3-year average of the weighted annual
mean PM~10~ concentration at each monitor within an area must not exceed
50 ug/m^3^.

^3^ To attain this standard, the 3-year average of the weighted annual
mean PM~2.5~ concentrations from single or multiple community-oriented
monitors must not exceed 15.0 ug/m^3^.

^4^ To attain this standard, the 3-year average of the 98th percentile
of 24-hour concentrations at each population-oriented monitor within an
area must not exceed 65 ug/m^3^.

^5^ To attain this standard, the 3-year average of the fourth-highest
daily maximum 8-hour average ozone concentrations measured at each
monitor within an area over each year must not exceed 0.08 ppm.

"Designation" is the term EPA use to describe the air quality in a given
area for any of the criteria pollutants. Geographic areas are designated
as "attainment" or "nonattainment" based on ambient air monitoring data
collected in that area and reported to the Air Quality System (AQS)
national database. Tribes and States submit recommendations to the EPA
as to whether or not an area is attaining the NAAQS for a criteria
pollutant. After working with the Tribal or State agencies and
considering the air quality data, EPA officially designates an area as
attainment or nonattainment. If an area is designated as nonattainment
EPA informs the public that the air in the area is unhealthy to breathe,
and states, local and tribal governments must develop and implement
control plans to reduce pollution. A Tribal Implementation Plan (TIP) is
a set of regulatory

programs that a tribe can develop and adopt to help attain or maintain
national air quality standards. Once a nonattainment area meets the
standards and additional redesignation requirements in the CAA \[Section
107(d)(3)(E)\], EPA will designate the area to attainment as a
\"maintenance area.\"

The website listed below provides an unofficial list of Tribes in 8-hour
ozone nonattainment areas as of April 15, 2004. Official nonattainment
boundaries are specified in 40 CFR Part 81.
[www.epa.gov/ozonedesignations/tribaldesig.htm](http://www.epa.gov/ozonedesignations/tribaldesig.htm)

Detailed instructions on how to determine attainment status based on
ambient monitoring data may be found in the Code of Federal Regulations
(CFR) Title 40 Part 50. The relevant passages for each criteria
pollutant is included as Attachment 1 and may also be accessed on the
web at:

<http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=e18bc4907fc6d399c035b0bd125e238b&tpl=/ecfrbrowse/Title40/40cfr50_main_02.tpl>

2.  **Understanding the Air Quality Index (AQI) and AIRNow**

##### 

The AQI is an index for reporting daily air quality. It tells how clean
or polluted the air is, and what associated health effects might be a
concern for the public. The AQI focuses on health effects that may be
experienced within a few hours or days after breathing polluted air. EPA
calculates the AQI for five of the criteria pollutants: O~3~, PM, CO,
SO~2~, and NO~x~. The AQI scale runs from 0 to 500. The higher the AQI
value, the greater the level of air pollution and the greater the health
concern. For example, an AQI value of 50 represents good air quality
with little potential to affect public health, while an AQI value over
300 represents hazardous air quality.

An AQI value of 100 generally corresponds to the national air quality
standard for the pollutant, which is the level EPA has set to protect
public health. AQI values below 100 are generally thought of as
satisfactory. When AQI values are above 100, air quality is considered
to be unhealthy-at first for certain sensitive groups of people, then
for everyone as AQI values get higher.

Raw ambient air monitoring data is converted into AQI values using
standard formulas developed by EPA. An AQI value is calculated for each
pollutant in an area. The highest AQI value for the individual
pollutants is the AQI value for that day. For example, if a certain date
had AQI values of 90 for ozone and 88 for sulfur dioxide, the AQI value
would be 90 for the pollutant ozone on that day.

#####  

The purpose of the AQI is to help the public understand what local air
quality means to their health. To make it easier to understand, the AQI
is divided into six categories, each of which corresponds to a different
level of health concern. The six levels of health concern and what they
mean are:

-   **\"Good\"** The AQI value for your community is between 0 and 50.
    Air quality is considered satisfactory, and air pollution poses
    little or no risk.

-   **\"Moderate\"** The AQI for your community is between 51 and 100.
    Air quality is acceptable; however, for some pollutants there may be
    a moderate health concern for a very small number of people. For
    example, people who are unusually sensitive to ozone may experience
    respiratory symptoms.

-   **\"Unhealthy for Sensitive Groups\"** When AQI values are between
    101 and 150, members of sensitive groups may experience health
    effects. This means they are likely to be affected at lower levels
    than the general public. For example, people with lung disease are
    at greater risk from exposure to ozone, while people with either
    lung disease or heart disease are at greater risk from exposure to
    particle pollution. The general public is not likely to be affected
    when the AQI is in this range.

-   **\"Unhealthy\"** Everyone may begin to experience health effects
    when AQI values are between 151 and 200. Members of sensitive groups
    may experience more serious health effects.

-   **\"Very Unhealthy\"** AQI values between 201 and 300 trigger a
    health alert, meaning everyone may experience more serious health
    effects.

-   **\"Hazardous\"** AQI values over 300 trigger health warnings of
    emergency conditions. The entire population is more likely to be
    affected.

#### The AIRNow Web site delivers daily AQI forecasts as well as real-time AQI conditions for over 300 cities across the United States. The EPA developed the AIRNow program together with the National Oceanic and Atmospheric Administration (NOAA), National Park Service (NPS), Tribal, State, and Local agencies to provide the public with easy access to national air quality information. AQI data are presented in maps which were generated based on "real-time" ambient monitoring data using either federal reference or equivalent monitoring techniques or techniques approved by the state, local or tribal monitoring agencies. Although some preliminary data quality assessments are performed, the data as such are not fully verified and validated through the quality assurance procedures monitoring organizations use to officially submit and certify data in AQS. Therefore, data are used on the AIRNow Web site only for the purpose of reporting the AQI. Information on the AIRNow web site is not used to formulate or support regulation, guidance or any other Agency decision or position.

In 2005 there were 13 Tribal monitoring agencies that participated in
AIRNow. Tribes interested in joining the AIRNow network should contact
Richard Wayland (OAQPS) at 919-541-4603 or email:
<wayland.richard@epa.gov>.

 

Air quality forecasts and more information about AQI and AIRNow is
available at: [www.airnow.gov](http://www.airnow.gov/)

1.  **Putting data into context**

In addition to determining NAAQS attainment and AQI values, Tribal
monitoring agencies may benefit from putting their monitoring data into
a broader context. There are a few ways to do this. The Tribe may look
up data for the same pollutant at other monitoring sites located in the
same State or region to see how the values compare. It may also be
helpful to look at a nation-wide summary of data or a list of
nonattainment areas. A broader context may also be obtained by learning
about national trends in air quality data.

EPA's AirData website provides access to air pollution data for the
entire US. AirData produces reports and maps of air pollution data based
on user-specified queries. For example a Tribal agency located in
Arizona may wish to look up last year's ozone data for all monitoring
sites in the State. The link below is the interface where the user
selects the geographic area for the data search. Subsequent web pages
narrow the search to the desired pollutant, year, and report format.

<http://www.epa.gov/air/data/geosel.html>

EPA's "Green Book" lists all nonattainment areas in the US. The user can
access a variety of maps and reports for each criteria pollutant at this
web site:

<http://www.epa.gov/air/oaqps/greenbk/>

EPA tracks air pollution trends using two main indicators: ambient air
monitoring data and pollutant emissions. EPA estimates nationwide
emissions of criteria pollutants and air toxics based on many factors,
including actual measurements, levels of industrial activity, fuel
consumption, vehicles miles traveled, and other estimates of activities
that cause pollution.

For EPA\'s most recent evaluation of air pollution trends, click on the
following:

<http://www.epa.gov/airtrends/>

1.  **Air quality characterization for ambient, deposition, and
    visibility data**

The previous section was focused specifically on criteria pollutants and
interpreting data in terms of the NAAQS rules. Beyond the six criteria
pollutants, however, there are hundreds of other pollutants and indices
that a monitoring agency may wish to address. These non-criteria
pollutants and measures include ambient air toxics, wet/dry deposition,
visibility data, and even biomonitoring of ozone injury to sensitive
plants. These types of data do not have corresponding national air
quality standards that help to guide data summary and interpretation.
Instead, monitoring results should be described using basic summary
statistics. The data may also be visualized using simple graphic
techniques.

1.  **Basic summary statistics**

The first step in summarizing air quality data is to take inventory of
the number of samples collected, the range of measurements, and to
provide related information about the monitoring schedule. It is
important to specify the measurement units of the pollutant. If any of
the samples are below detection limits then it becomes necessary to
state the minimum detection limit (MDL) and the number of samples below
the MDL. An example in table form is shown below.

Table 2. Example of monitoring data summary

  --------------- ------------ ------------ ----------- ---------- --------- --------- --------- ----------
  **Pollutant**   **Sampling   **Sampling   **Total     **Unit**   **MDL**   **Min.    **Max.    **Number
                  schedule**   period**     samples**                        value**   value**   samples
                                                                                                 \<MDL**

  Benzene         1-in-6 days  Jan. 2003 -- 107         ppbC       0.01      0.02      1.3       0
                               Dec. 2004                                                         

  1,3-butadiene   1-in-6 days  Jan. 2003 -- 107         ppbC       0.01      Below MDL 0.8       84
                               Dec. 2004                                                         

  Arsenic         Monthly      Jan. 2003 -- 18          ug/m^3^    0.002     Below MDL 0.012     10
  (PM~10~)                     June. 2004                                                        

  Cadmium         Monthly      Jan. 2003 -- 18          ug/m^3^    0.01      Below MDL 0.02      4
  (PM~10~)                     June. 2004                                                        

  Lead (PM~10~)   Monthly      Jan. 2003 -- 18          ug/m^3^    0.005     0.008     0.31      0
                               June. 2004                                                        
  --------------- ------------ ------------ ----------- ---------- --------- --------- --------- ----------

The next step is to summarize some basic characteristics of the data set
using common statistical measures. Some useful examples include:
measures of central tendency, such as the mean or median; measures of
relative standing, such as percentiles; measures of dispersion, such as
range, variance, standard deviation, coefficient of variation, or
interquartile range; measures of distribution symmetry or shape; and
measures of association between two or more variables, such as
correlation. These measures can then be used for description and
communication about the dataset.

The definitions and procedures outlined in parts 3.2.1 and 3.2.2. are
primarily taken from the EPA document "Guidance for Data Quality
Assessment -- Practical Methods for Data Analysis"

> (EPA/600/R-96/084) which is available in full at this website:

<http://www.epa.gov/quality/qs-docs/g9-final.pdf>

This section provides mathematical formulas that allow the user to
calculate descriptive statistics using a simple calculator. These
procedures can be carried out more easily by using the formula functions
in any computer spreadsheet program. Data analysts that are interested
in continuing on to do advanced statistical procedures may consider
investing in a statistical software package and attending training
sessions to practice using them. The end of this section provides
resources for those interested in learning more.

[Central tendency]{.underline}

The most common estimates for central tendency in environmental data are
the mean and median. The ***mean*** may be considered to be the "center
of gravity" of the dataset. It is calculated as a basic arithmetic
average. The ***median*** is the value which falls directly in the
middle of the data when the measurements are ranked in order from
smallest to largest. Thus ½ of the data are smaller than the sample
median and ½ of the data are larger than the sample median. Unlike the
mean, the median is not influenced by a small number of extreme values.

Formulas for measuring central tendency:

![](media/image1.wmf){width="4.997916666666667in"
height="2.345833333333333in"}

[Relative Standing (Percentiles)]{.underline}

It may be useful to know the relative position of one or several
observations in relation to all of the observations. Percentiles are one
such measure of relative standing that may also be useful for
summarizing data. A percentile is the data value that is greater than or
equal to a given percentage of the data values. For example the data
point which is the 25^th^ percentile is greater than or equal to 25% of
the data values and is less than or equal to 75%. Important percentiles
usually reviewed are the quartiles of the data: the 25^th^, 50th, and
75^th^ percentiles. The 50^th^ percentile is also called the sample
median (previously described), and the 25^th^ and 75^th^ percentiles are
used to estimate the dispersion of a data set (next section).

Formula for calculating percentiles with example:

![](media/image2.wmf){width="5.000694444444444in"
height="2.004166666666667in"}

[Measures of Dispersion]{.underline}

Measures of central tendency are more meaningful if accompanied by
information on how the data spread out from the center. Measures of
dispersion in a data set include the range, variance, sample standard
deviation, coefficient of variation, and the interquartile range. These
measures are all described below and formulas provided.

The easiest measure of dispersion to compute is the sample ***range***.
For small samples, the range is easy to interpret and may adequately
represent the dispersion of the data. For large samples, the range is
not very informative because it only considers (and therefore is greatly
influenced) by extreme values.

The sample ***variance*** measures the dispersion from the mean of a
data set. A large sample variance implies that there is a large spread
among the data so that the data are not clustered around the mean. A
small sample variance implies that there is little spread among the data
so that most of the data are near the mean. The sample variance is
affected by extreme values and by a large number of nondetects. The
sample standard deviation is the square root of the sample variance and
has the same unit of measure as the data.

The ***coefficient of variation (CV)*** is a unitless measure that
allows the comparison of dispersion across several sets of data. The CV
is often used in environmental applications because variability
(expressed as a standard deviation) is often proportional to the mean.

When extreme values are present, the ***interquartile range*** may be
more representative of the dispersion of the data than the standard
deviation. This statistical quantity does not depend on extreme values
and is therefore useful when the data include a large number of
nondetects.

Formulas for calculating measures of dispersion:

![](media/image3.wmf){width="5.372916666666667in"
height="3.079861111111111in"}

2.  **Trends analysis**

> To be written

3.  **Data visualization**

Simple graphing techniques are useful to describe the dataset and
communicate monitoring results. Graphs can be used to identify patterns
and trends in the data. Graphical representations include displays of
individual data points, statistical quantities, temporal data, spatial
data, and two or more variables.

Detailed instructions on how to produce these graphics are provided in
Section 2 of the previously mentioned "Guidance for Data Quality
Assessment -- Practical Methods for Data Analysis", available at:
<http://www.epa.gov/quality/qs-docs/g9-final.pdf>

[Histogram/Frequency Plots]{.underline}

Two of the oldest methods for summarizing data distributions are the
frequency plot and the histogram. Both the histogram and the frequency
plot use the same basic principles to display the data: dividing the
data range into units, counting the number of points within the units,
and displaying the data as the height or area within a bar graph.

Figure 1. Example of a frequency plot

![](media/image4.wmf){width="2.498611111111111in"
height="1.7798611111111111in"}

[Box and Whisker Plot]{.underline}

A box and whisker plot or box plot is a schematic diagram useful for
visualizing important statistical quantities of the data. A box and
whiskers plot is composed of a central box divided by a line and two
lines extending out from the box called whiskers. The length of the
central box indicates the spread of the bulk of the data (the central
50%) while the length of the whiskers show how stretched the tails of
the distribution are. The sample median is displayed as a line through
the box and the sample mean is displayed using a '+' sign. Any unusually
small or large data points are displayed by a '\*' on the plot.

Figure 2. Example of a box and whisker plot

![](media/image5.wmf){width="0.7951388888888888in"
height="1.511111111111111in"}

[Scatter Plot]{.underline}

For data sets consisting of paired observations where two or more
variables are measured for each sampling point, a scatter plot is one of
the most powerful tools for analyzing the relationship between two or
more variables. A scatter plot clearly shows the relationship between
two variables. Both potential outliers from a single variable and
potential outliers from the paired variables may be identified on this
plot. A scatter plot also displays the correlation between the two
variables. Scatter plots of highly linearly correlated variables cluster
compactly around a straight line.

Figure 3. Example of a scatter plot

![](media/image6.wmf){width="3.376388888888889in"
height="2.196527777777778in"}

[Time Plot]{.underline}

One of the simplest plots to generate that provides a large amount of
information is a time plot. A time plot is a plot of the data over time.
This plot makes it easy to identify large-scale and small-scale trends
over time. Small-scale trends show up on a time plot as fluctuations in
smaller time periods. For example, ozone levels over the course of one
day typically rise until the afternoon, then decrease, and this process
is repeated every day. An example of a large-scale trend is a multi-year
decrease in air pollution resulting from effective air quality control
programs. For example, the annual average concentration of NO~x~ at a
particular monitoring site may decline over the course of several years
as a result of emissions controls at local industries and the
introduction of cleaner cars.

Figure 4. Example of a time plot

![](media/image7.wmf){width="4.248611111111111in"
height="2.134027777777778in"}

4.  **References, tools, and resources**

## There are additional resources for air monitoring staff and data analysts who would like to learn more about statistical techniques and data analysis. 

## 

## [EPA courses]{.underline}

EPA\'s Air Pollution Training Institute (APTI) primarily provides
technical air pollution training to state, tribal, and local air
pollution professionals, although others may benefit from this training.
The curriculum is available in classroom, telecourse, self-instruction,
and web-based formats. A few potentially useful courses are described
below.

## 

***Introduction to Environmental Statistics***

This series of online lectures was developed for USEPA by the University
of Illinois at Chicago School of Public Health, Environmental and
Occupational Health Sciences Division. No registration is required to
access the archived lectures. The lectures are available at this
website:

<http://www.epa.gov/air/oaqps/eog/envirostats/index.html>

Module 1: Interpreting Your Monitoring Data\
Mudule 2: Sampling and Analytical Limitations & Sample Detection Limits\
Module 3: Quality Assurance Quality Control

Module 4: Analysis of Trends

Module 5: Language of Data Graphing

Module 6: Censored Values and Extreme Values

Module 7: Fundamentals of Trajectory Analysis

## 

## Introduction to Environmental Statistics - SI:473B

This course introduces the student to the basic concepts of statistical
analysis. The course was designed for students with little formal
education in statistics who must apply statistical techniques to analyze
environmental data. The package has seven modules, a workbook, and a VHS
format video tape. The workbook and video tape are mailed to the student
by EPA, but it is necessary to acquire one of the recommended companion
texts.

## Course information is available at: 

## [**http://www.epa.gov/air/oaqps/eog/catalog/si473b.html**](http://www.epa.gov/air/oaqps/eog/catalog/si473b.html)

Major Topics

-   Descriptive statistics

-   Hypothesis testing

-   One- and two-sample t-tests of significant differences

-   Analysis of variance

-   Chi-square techniques for tests of homogeneity of data sets

-   Decision flow chart

-   Quality control charts

-   Guide to statistical problem solving

# *Training Courses on Quality Assurance and Quality Control Activities*

EPA Quality Staff develops a variety of traditional training courses on
quality assurance (QA) and quality control (QC) activities and the EPA
quality system. For each course, there is a facilitator guide with
slides and speaker notes, suggested activities, and supplementary
materials for student handouts. Instructors should have an applied
knowledge in quality system management, as well as quality assurance and
quality control activities.

One subject area of particular interest is "Interpreting monitoring
data". This half day course teaches participants how to deal with
monitoring data using statistics. Participants learn about the need to
incorporate systematic planning into monitoring activities, realize the
importance of representativeness, be able to graphically view the data,
and gain an insight into the complexities of statistical analyses of
monitoring data. "Introduction to Data Quality Assessment" is another
useful subject area. This one-day course demonstrates how to perform a
data quality assessment (DQA) to evaluate data and provides detailed
information on graphical and statistical tools. This course will
familiarize participants with the process for performing a data quality
assessment. It does not involve detailed instructions on the statistics
involved in the process. The course is intended for managers or analysts
that either use (analyze) data themselves or review the use of data by
others. Materials are available at:
<http://www.epa.gov/quality/trcourse.html>

[Other tools and resources]{.underline}

EPA has a website for Quality-Related Resources which contains links to
other sources of information on quality systems available on the web:

<http://www.epa.gov/quality/qa_links.html>

> *Examples of tools and resources available through the EPA quality
> resources page:*
>
> DataPlot - National Institutes of Science and Technology\
> DataPlot is a free, public-domain, multi-platform software system for
> scientific visualization, statistical analysis, and non-linear
> modeling.\
> [www.itl.nist.gov/div898/software/dataplot.html/](http://www.itl.nist.gov/div898/software/dataplot.html/)
>
> StatPages.Net - John C. Pezzullo\
> Contains links to online calculators, free statistical software,
> online statistics books, tutorials, and related resources.\
> [members.aol.com/johnp71/javastat.html](http://members.aol.com/johnp71/javastat.html)
>
> Statistics Calculators - UCLA Department of Statistics\
> Calculators include statistical graphs, power calculations, sample
> size calculations, etc.\
> [calculators.stat.ucla.edu/](http://calculators.stat.ucla.edu/)
>
> George Mason University - Guide to Statistical Software\
> A comparison of commercially available statistical software.\
> [www.galaxy.gmu.edu/papers/astr1.html](http://www.galaxy.gmu.edu/papers/astr1.html)

1.  **Source apportionment: using tools such as emissions inventories,
    wind direction data, and receptor models to determine pollution
    sources**

> To be written

2.  **Exposure assessment for hazardous air pollutants**

> To be written

3.  **Multi-media exposure assessment using deposition monitoring**

> To be written

3.  **Conclusions**

> To be written

4.  **Attachment 1. Excerpts from CFR on NAAQS monitoring**

**O~3~ (8-Hour)**

§ 50.10 National 8-hour primary and secondary ambient air quality
standards for ozone.

\(a\) The level of the national 8-hour primary and secondary ambient air
quality standards for ozone, measured by a reference method based on
appendix D to this part and designated in accordance with part 53 of
this chapter, is 0.08 parts per million (ppm), daily maximum 8-hour
average.

\(b\) The 8-hour primary and secondary ozone ambient air quality
standards are met at an ambient air quality monitoring site when the
average of the annual fourth-highest daily maximum 8-hour average ozone
concentration is less than or equal to 0.08 ppm, as determined in
accordance with appendix I to this part.

**PM~10~**

§ 50.6 National primary and secondary ambient air quality standards for
PM~10~.

\(a\) The level of the national primary and secondary 24-hour ambient
air quality standards for particulate matter is 150 micrograms per cubic
meter (µg/m 3 ), 24-hour average concentration. The standards are
attained when the expected number of days per calendar year with a
24-hour average concentration above 150 µg/m 3 , as determined in
accordance with appendix K to this part, is equal to or less than one.

\(b\) The level of the national primary and secondary annual standards
for particulate matter is 50 micrograms per cubic meter (µg/m 3 ),
annual arithmetic mean. The standards are attained when the expected
annual arithmetic mean concentration, as determined in accordance with
appendix K to this part, is less than or equal to 50 µg/m 3 .

\(c\) For the purpose of determining attainment of the primary and
secondary standards, particulate matter shall be measured in the ambient
air as PM10 (particles with an aerodynamic diameter less than or equal
to a nominal 10 micrometers) by:

\(1\) A reference method based on appendix J and designated in
accordance with part 53 of this chapter, or

\(2\) An equivalent method designated in accordance with part 53 of this
chapter.

**PM~2.5~**

§ 50.7 National primary and secondary ambient air quality standards for
PM2.5.

\(a\) The national primary and secondary ambient air quality standards
for particulate matter are 15.0 micrograms per cubic meter (µg/m3)
annual arithmetic mean concentration, and 65 µg/m3 24-hour average
concentration measured in the ambient air as PM2.5 (particles with an
aerodynamic diameter less than or equal to a nominal 2.5 micrometers) by
either:

\(1\) A reference method based on appendix L of this part and designated
in accordance with part 53 of this chapter; or

\(2\) An equivalent method designated in accordance with part 53 of this
chapter.

\(b\) The annual primary and secondary PM2.5 standards are met when the
annual arithmetic mean concentration, as determined in accordance with
appendix N of this part, is less than or equal to 15.0 micrograms per
cubic meter.

> \(c\) The 24-hour primary and secondary PM2.5 standards are met when
> the 98th percentile 24-hour concentration, as determined in accordance
> with appendix N of this part, is less than or equal to 65 micrograms
> per cubic meter.

**Pb**

§ 50.12 National primary and secondary ambient air quality standards for
lead.

> National primary and secondary ambient air quality standards for lead
> and its compounds, measured as elemental lead by a reference method
> based on appendix G to this part, or by an equivalent method, are: 1.5
> micrograms per cubic meter, maximum arithmetic mean averaged over a
> calendar quarter.

**NO~2~**

40 CFR § 50.11 National primary and secondary ambient air quality
standards for nitrogen dioxide.

\(a\) The level of the national primary ambient air quality standard for
nitrogen dioxide is 0.053 parts per million (100 micrograms per cubic
meter), annual arithmetic mean concentration.

\(b\) The level of national secondary ambient air quality standard for
nitrogen dioxide is 0.053 parts per million (100 micrograms per cubic
meter), annual arithmetic mean concentration.

\(c\) The levels of the standards shall be measured by:

\(1\) A reference method based on appendix F and designated in
accordance with part 53 of this chapter, or

\(2\) An equivalent method designated in accordance with part 53 of this
chapter.

> \(d\) The standards are attained when the annual arithmetic mean
> concentration in a calendar year is less than or equal to 0.053 ppm,
> rounded to three decimal places (fractional parts equal to or greater
> than 0.0005 ppm must be rounded up). To demonstrate attainment, an
> annual mean must be based upon hourly data that are at least 75
> percent complete or upon data derived from manual methods that are at
> least 75 percent complete for the scheduled sampling days in each
> calendar quarter.

**SO~2~**

40 CFR § 50.4 National primary ambient air quality standards for sulfur
oxides (sulfur dioxide).

\(a\) The level of the annual standard is 0.030 parts per million (ppm),
not to be exceeded in a calendar year. The annual arithmetic mean shall
be rounded to three decimal places (fractional parts equal to or greater
than 0.0005 ppm shall be rounded up).

\(b\) The level of the 24-hour standard is 0.14 parts per million (ppm),
not to be exceeded more than once per calendar year. The 24-hour
averages shall be determined from successive nonoverlapping 24-hour
blocks starting at midnight each calendar day and shall be rounded to
two decimal places (fractional parts equal to or greater than 0.005 ppm
shall be rounded up).

\(c\) Sulfur oxides shall be measured in the ambient air as sulfur
dioxide by the reference method described in appendix A to this part or
by an equivalent method designated in accordance with part 53 of this
chapter.

\(d\) To demonstrate attainment, the annual arithmetic mean and the
second-highest 24-hour averages must be based upon hourly data that are
at least 75 percent complete in each calendar quarter. A 24-hour block
average shall be considered valid if at least 75 percent of the hourly
averages for the 24-hour period are available. In the event that only
18, 19, 20, 21, 22, or 23 hourly averages are available, the 24-hour
block average shall be computed as the sum of the available hourly
averages using 18, 19, etc. as the divisor. If fewer than 18 hourly
averages are available, but the 24-hour average would exceed the level
of the standard when zeros are substituted for the missing values,
subject to the rounding rule of paragraph (b) of this section, then this
shall be considered a valid 24-hour average. In this case, the 24-hour
block average shall be computed as the sum of the available hourly
averages divided by 24.

**CO**

40 CFR § 50.8 National primary ambient air quality standards for carbon
monoxide.

\(a\) The national primary ambient air quality standards for carbon
monoxide are:

\(1\) 9 parts per million (10 milligrams per cubic meter) for an 8-hour
average concentration not to be exceeded more than once per year and

\(2\) 35 parts per million (40 milligrams per cubic meter) for a 1-hour
average concentration not to be exceeded more than once per year.

\(b\) The levels of carbon monoxide in the ambient air shall be measured
by:

\(1\) A reference method based on appendix C and designated in
accordance with part 53 of this chapter, or

\(2\) An equivalent method designated in accordance with part 53 of this
chapter.

\(c\) An 8-hour average shall be considered valid if at least 75 percent
of the hourly average for the 8-hour period are available. In the event
that only six (or seven) hourly averages are available, the 8-hour
average shall be computed on the basis of the hours available using six
(or seven) as the divisor.

\(d\) When summarizing data for comparision with the standards, averages
shall be stated to one decimal place. Comparison of the data with the
levels of the standards in parts per million shall be made in terms of
integers with fractional parts of 0.5 or greater rounding up.

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 submittal 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 U.S. public environmental
policy. Both tribal and non-tribal U.S. 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 U.S.
whose sole job is to assist tribes with AQS entry.

**A. Description of AQS for Tribal Needs**

(to be completed)

**B. Getting data into EPA's AQS System**

(to be completed)

**C. What Data and When Should It Be Entered into AQS**

(to be completed)

**D. Who Has Access to Data Once Submitted to AQS**

(to be completed)

**E. How AQS Can Be Used to Retrieve Tribal Monitoring Data in Useful
Forms**

(to be completed)

**IX. Assessment of Ambient Air Quality in Indian country in the Absence
of Air Monitoring**

Prior to conducting air monitoring, Tribes may want to assess air
quality in Indian Country to determine if monitoring is warranted. This
section will identify and briefly discuss web-based and computer models
that are available to Tribes to assess air quality in Indian Country.
The methods addressed in this section include:

1.  Web-Based Air Quality Data Resources

2.  Data Interpolation Methods

3.  Local-Scale Plume Models

4.  Large-Scale Grid Models

5.  Smoke Models

6.  High-split Model to identify sources on worst days

X.. **How to Request EPA Funding and Other Support**

\[This section is intended to give the first steps in applying for
funding and tips for things to be careful about. In the early conference
calls on this document-writing project, the point was made that this
section may emphasize that it is appropriate for each tribe to request
the resources actually needed to accomplish its monitoring goals, to
create a more complete record regarding the sufficiency of resources
made available.\]

(to be completed)

**XI. Other Air Quality Management Program Elements**

\[This section is intended to give first steps and other information
regarding development of emissions inventories and source reporting,
adoption of source emissions standards, adoption and operation of
permitting programs, etc. for the benefit of tribes that are considering
or are in the early stages of involvement in such programs.\]

(to be completed)

**XII. The Tribal Perspective**

In 2004, the Environmental Protection Agency produced a final draft
document on their National Ambient Air Monitoring Strategy (NAAMS).
(This document should be reviewed and commented upon by this group). The
EPA says interesting and positive things about the integration of tribes
in the national air monitoring strategy document.  EPA had decided
originally to do a separate air monitoring strategy for tribes so that
tribes would not get "lost" in the national strategy. This is an
important issue.

One of the motivations for tribes to want to monitor the air quality are
human health issues; it is not a scientific interest in this subject.
This motivation is not addressed in the NAAMS. But the NAAMS document
must be examined for it has many useful details that address tribal air
monitoring.

It is useful to refer to this document: the National Ambient Air
Monitoring Strategy.  Some important points in it are:

EPA's entire air monitoring structure has clearly moved to the Ncore
strategy. This document states that there is a role for tribal
participation in several Levels of this strategy. These Levels are
clearly framed in this NAAMS document. And the role of tribes is clearly
stated.

Ambient monitoring systems are a critical part of America's air program
infrastructure. Air data from these monitoring systems are used to do
several things, such as: characterize "air quality" and associated
health and ecosystem impacts, to develop emission strategies to reduce
adverse impacts, and to account for air quality progress over time.

The United States spends well over \$200 million annually on routine

ambient air monitoring programs, a figure dwarfed by the billions
associated with emission reduction strategies. The ambient air data
provide a basis for an accounting of an air programs progress. Therefore
you can determine the value of those investments.

The Ncore strategy , mentioned in the NAAMS, talks about:

> Comprehensive monitors, (55 in rural areas) and Level 3 monitors
> (1,000 monitors specifically for local concerns, hotspots, etc).  The
> 2004 EPA Draft Monitoring Strategy also states that tribes have the
> right to participate in this Ncore strategy. Clearly the tribes have a
> purpose and a right to be involved with this strategy.

In this NAAMS there is fairly clear statement of tribal needs:

> "The prevailing air monitoring issues for Tribes include a severe
> shortage of resources for equipment, maintenance, operations,
> personnel and training".

This Tribal Perspective supports the NAAMS statement of need. The tribes
care about monitoring for human health reasons, not necessarily
scientific reasons. And the tribes need resources for air monitoring on
tribal lands.

The NAAMS highlights the fact that the Ncore strategy could benefit from
including tribes because the tribes can provide additional monitoring
sites, fill data gaps, and identify background conditions. These are the
reasons how tribal air monitoring could help the entire strategy. Tribal
monitoring can help this air quality infrastructure.

Many tribes are in isolated areas, but are subject to poor downwind air
quality. The tribes want to know the air quality data, and the effects
on human health. This is the reason that many tribes want their own air
monitors. Human health issues are of the utmost importance to tribes
(you cannot take care of "Mother Earth" without your own health being
good).

The NAAMS document also acknowledges that the priority for tribes is not
just trying to be useful for the national strategy, but that:

> "Monitoring priorities must be based on [Tribal
> decisions]{.underline}, which in many cases involve developing a
> better characterization of local exposure to air pollutants."

The NAAMS mentions the benefits of the TAMS center in Las Vegas, NV.
This center for tribal air work is an important tool for the tribes. It
helps the tribes in many ways to deal with their ambient air monitoring.

The NAAMS mentions the RPO's in integrating tribes into larger air
monitoring strategies. The RPO's help tribes and states work on air
issues, it brings them together for work on air monitoring. There must
be team work on all levels to preserve air quality.

The NAAMS document recognizes that tribes will benefit by being able to
identify threats to health. Tribes must be able to deal with air
monitoring on tribal lands. Tribes do not trust the states or the
Federal government to do this for them because of past historical
experience. But the basic fact is that the Federal government and the
Environmental Protection Agency have written into its basis, the
protection of the tribes.

The original Tribal Monitoring Strategy paper spoke of the Ncore
strategy. As outlined in the Ncore strategy, finding a meaningful way to
participate in that strategy is important. A tribal affiliated group,
such as the Institute for Tribal Environmental Professionals (ITEP),
should be identified to do the "representativeness" analysis for all
tribes, in certain regions of the US. Identifying those tribes that is
not currently represented by the Ncore network should be made. These
tribes should have access to the regional air monitoring data to see the
status of their air quality.  This project should also be aimed at
locating tribes that would serve to fill data gaps, and those that have
air pristine enough to provide background conditions. A perfect example
of how this could be performed is when ITEP worked with the Western
Regional Air Partnership (WRAP). Below is a template for this process.
It discusses how ITEP worked with tribes in the West to uncover these
tribal issues. Perhaps this template could be used over the entire US:

> In 1996, the Grand Canyon Visibility Transport Commission (GCVTC, the
> predecessor to WRAP) identified a need for emissions inventories and
> air monitoring on and near tribal lands in the Western USA. We need to
> do this Nation wide for all tribes. This western US project, funded by
> the Western Regional Air Partnership's (WRAP) Tribal Data Development
> Working Group (TDDWG), served as a first step in gathering existing
> information on tribal air quality in the WRAP region. This is an
> important template for all of the US. The purpose of this project was
> to assess the current state of tribal air quality data and programs in
> the WRAP region and to clarify future needs in tribal air quality data
> development. The information collected and summarized is meant to
> inform the committees on the magnitude of the gap in air quality data
> over tribal lands, in the West. It is also meant to provide a starting
> point for planning future data development efforts in Indian Country,
> all over the USA.

Several critical issues were identified through this project, they
include:

-   A serious limitation on environmental program resources among the
    WRAP tribes.

-   A high demand for new and continuing tribal air quality programs in
    the WRAP region.

-   A shortage of tribal staff to deal with air quality issues.

The following will describe how these issues were identified and could
be a template for how this could be accomplished all over the USA.

ITEP was contracted to gather information on tribal air programs in the
WRAP region for this project. ITEP compiled a list of the 237 federally
recognized tribes in the WRAP region, along with environmental and/or
air program contacts for each of the tribes. ITEP attempted to contact
220 of these tribes and 156 tribes completed the assessment instrument.
ITEP staff persons were assigned to make all of the contacts.

One of the critical findings of ITEP's inquiries was a serious
limitation on environmental program resources among the WRAP tribes.
This is true all over the US. Information gathered in 2001, for the
western states indicated that only 22% of the 156 tribes it contacted
are currently involved in the WRAP. Of those not currently involved in
the WRAP, 41% indicated that they were not involved due to lack of staff
and/or resources. Twenty-five percent (25%) said that they were not
aware of the WRAP prior to the ITEP phone call. This data suggests a
need for a more active outreach program for tribes. This is true all
over the US.

The shortage of tribal staff to deal with air quality issues was
apparent in every phase of the WRAP project. It was difficult to
schedule meetings due to tribal staff's full schedules. Additional staff
in tribal air programs would increase the quality and quantity of tribal
air programs, as well as provide tribal staff with time for informed and
meaningful participation in air monitoring work.

Research also revealed a high demand for new and continuing tribal air
quality programs in the WRAP region, and across the USA. When asked if
the tribe had an air program, 38% (60 tribes) said that they did. The
other 96 tribes indicated that they did not have an air program.
Planning to meet the demands for tribal air programs should be underway,
not only for these new tribes but for the tribes that have been found to
be seriously understaffed**.** As more tribes endeavor to assess,
monitor and protect their air quality, additional resources must be
identified to support quality tribal air programs.

Many tribes in the WRAP region effect air quality through prescribed
burning programs. One hundred fifty-six (156) tribes were asked if
prescribed burning occurred on their reservation. Approximately half
(76) of the tribes responding said that prescribed burning did occur on
their reservation. An additional 14 tribes, who do not currently use
prescribed burns, indicated that they plan to use them in the future.
This information indicates that tribes should play an integral part in
regional planning of fire emissions. Air monitoring is important where
use of fire occurs often. This happens on tribal lands, and monitoring
of the air is an important issue for tribes concerned with human health.

This project identified several challenges and opportunities for tribal
air quality programs

in the Western USA, and could be used as a template all over the USA.

\[The coordinator/authors for this section may choose to convey the
tribal perspective by the use of delineated text blocks within other
individual sections as well as including this section.\]

> **Appendix A**
>
> **Examples of Tribal Air Monitoring**

Name of Monitoring Project

Tribe

Project Objectives

Pollutants Monitored

Description of the Project (include budget information)

Quality Assurance

Data Analysis/Assessment

Results/Conclusions/Outcomes

**Appendix B**

Number range CHAPTER**Tribal Air Monitoring Guidance Document**

**Proposed Revision to Table of Contents**

**[Old § No.]{.underline}**

**I. Background**

A.. Purpose and Audience I

B. ~~Guidelines~~ Principles for EPA Support for Tribal Air Monitoring
II

C. Background for Planning Tribal Air Monitoring III

**II EPA Policy and Strategies regarding tribal air monitoring**

A. Tribal Air Quality Issues, Relevant Ambient Air Monitoring, and
Current and Recent Tribal Air Monitoring Activities Directed Towards
These Issues IV

B. The Role of Tribal Monitoring in the National Monitoring Strategy VI

**III Guidance for Tribes on air monitoring issues**

A. Implementation of Monitoring (identify all things that need to be
done, e.g., Q/A, siting requirements, report to AQS, etc.) V

B. How to Request EPA Funding and Other Support X

C. Storage and Access to Monitoring Data VIII

D. Understanding Monitoring Data and Its Implications VII

E. Assessment of Ambient Air Quality in Indian Country

> in the Absence of Air Monitoring IX

F. Other Air Quality Management Program Elements XI

**IV Tribal Perspective** XII

> **Appendix C**
>
> **Examples of Tribal Air Monitoring**
>
> **Examples of Tribal Air Monitoring Projects**

  --------------- ----------- --------------- -------------- ------------------ ------------ ------------ ----------------------- ----------------------------------
  **Name of       **Tribe**   **Project       **Pollutants   **Description of   **QA Plan?   **Location   **Data                  **Results/Conclusions/Outcomes**
  Project**                   Objectives**    Monitored**    Project/Budget**   (yes/no)**   of Data**    Analysis/Assessment**   

  Sioux           Spirit Lake Measure ambient VOCs and                          Yes                       EPA reviewed data that  Monitored HAPs were far below RfCs
  Manufacturing   Tribe, Fort air toxics in   Carbonyls                                                   was supplied by         for inhalation. Tribe wishes to
  Air Toxics      Totten, ND  proximity of    using UATMP                                                 monitoring completed by conduct follow-up short-term
  Monitoring                  manufacturing   canisters and                                               Tribe and analyzed by   project after installation of
  Project                     plant and       Puf sampler,                                                EPA contractor,         controls at source.
                              community       met monitor                                                 compared values to IRIS 
                                                                                                          RfC                     

                                                                                                                                  

                                                                                                                                  

                                                                                                                                  

                                                                                                                                  

                                                                                                                                  
  --------------- ----------- --------------- -------------- ------------------ ------------ ------------ ----------------------- ----------------------------------

[^1]: The available strategic guidance (excluding technical guidance on
    monitor operations and maintenance) includes the following
    documents, and perhaps others at the individual Regional Office
    level:

    4-page section titled "Tribal Air Quality Management" in the *Final
    National Program and Grant Guidance for Fiscal Years 2006-2008*,
    April 27, 2005.

    Memo from Jeffrey R. Holmstead, "Criteria for Providing Funds to
    Tribes from the State and Tribal Grant Assistance Appropriation for
    103 and 105 Grants," January 27, 2005.

    ***"***[Menu Item***:***]{.smallcaps} Air Quality Monitoring
    Activities***,"*** in *The Tribal Air Grant Framework - A Menu of
    Options For Developing Tribal Air Grant Work Plans and Managing
    Grants for Environmental Results*, September 2004.
    http://yosemite.epa.gov/R10/AIRPAGE.NSF/283d45bd5bb068e68825650f0064cdc2/e34950b285534aa988256dfe0063be55/\$FILE/The%20TRIBAL%20AIR%20GRANTS%20FRAMEWORK%20final.pdf

    Guidance for Conducting: TRIBAL AIR QUALITY ASSESSMENTS, U.S. EPA
    Region 10, April 15 2005.

[^2]: In FY2005, EPA proposed to Congress that there be separate amounts
    of air grant funding for states and tribes. EPA observes these two
    separate ceilings in its operating plan under the enacted FY2005
    budget. EPA has proposed the same separation for FY2006, and EPA has
    issued grant and technical guidance for FY2006 based on this
    separation. In FY2005, \$ 11.1 million is available for tribal air
    management, see http://www.epa.gov/ocfo/budget/2005/2005bib.pdf. The
    proposed FY2006 budget provides \$ 11 million, see
    http://www.epa.gov/ocfo/budget/2006/2006bib.pdf.

[^3]: For example, EPA's CASTNet monitoring program is intended to
    monitor acid deposition across broad areas for the purposes of broad
    national objectives. Operation of CASTNet is funded separately from
    the state and tribal air grant (STAG) funds. Some CASTNet sites are
    currently located in Indian country. As new sites are contemplated,
    tribal lands in the right areas of the country to support the
    monitoring goals should be considered equally with state and federal
    lands.