From: Clean Air Fairbanks <cleanairfairbanks@gmail.com>

Sent: Thursday, October 16, 2014 8:53 PM

To: Green, Gregory; Powers, Tom; Stewart, Lori; Wood, Gil; McCabe, Janet

Cc: Atkinson, Emily; Browne, Cynthia

Subject: Problems with monitoring, letter previously sent to Region 10 EPA

Dear Ms. McCabe, Ms. Stewart, Mr. Green, Mr. Powers, and Mr. Wood:

To follow-up on the discussion of monitoring in our meeting Tuesday, I wanted to share with 

you a recent letter I sent to Region 10. The letter raises questions about the apparent shell 

game that has been played with the monitoring network and PM2.5 data collection in 

Fairbanks. 

My point in forwarding this letter to you is to make very clear that a strong NSPS is needed.

Monitoring is not a panacea. NSPS standards designed to protect health and prevent harm are 

needed now, not five years from now.

Thank you,

Sylvia Schultz

--

cleanairfairbanks@gmail.com

http://cleanairfairbanks.wordpress.com

Polluting is a choice. Breathing is not.
October 2, 2014

Dennis McLerran, EPA Regional Administrator (mclerran.dennis@epa.gov)

Kate Kelly, Director, Office of Air Waste and Toxics (kelly.kate@epa.gov)

US EPA Region 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

Re: Request for EPA air monitoring and data reconsideration in the FNSB PM2.5 

nonattainment area

Dear Regional Administrator McLerran and Director Kelly,

The Regional Administrator of the Environmental Protection Agency (EPA) should promptly 

establish and operate air monitoring in the Fairbanks North Star Borough (FNSB) PM2.5 

nonattainment area to meet monitoring objectives, network design criteria, and sampling 

frequency requirements under the Clean Air Act.

The Regional Administrator should also review all available data to determine whether North 

Pole Elementary can be designated State and Local Air Monitoring Stations (SLAMS) from 2011 

to 2013, whether North Pole Fire has already collected sufficient data to be designated SLAMS 

beginning in 2014, and if design values can be recalculated based on these stations and using 

continuous monitor data. Monitoring from the area of expected maximum concentration needs 

to drive State Implementation Plan (SIP) targets and controls.

In addition, full site data records, including from continuous monitors, should be made available 

on EPA AirData http://www.epa.gov/airdata to support required monitoring objectives that 

include informing the public, compliance accountability, and health studies.

State and local agencies are playing an air monitor shell game to hide data and hinder 

requirements to control PM2.5 pollution. In 2012, the FNSB PM2.5 nonattainment area 

recorded the nation’s highest 98th percentile 24-hour PM2.5. Downtown Fairbanks PM2.5 

concentrations are on par with the most air polluted areas in the nation such as San Joaquin 

Valley, CA, Salt Lake City, or Logan, UT. However, 98th percentile 24-hour PM2.5 in local 

neighborhoods in areas of expected maximum concentration have been three times higher

than downtown Fairbanks. Meeting PM2.5 attainment in these most impacted neighborhoods 

requires expanding the focus beyond the downtown Fairbanks monitor. The public has been 

left uninformed about the seriousness of the exceedances and the grave risk to health. Federal 

regulators have been misled to think the problem is less serious and are anticipating a target for 

reduction far smaller than what is actually required.

The most significant monitoring failure has been that state and local agencies have not located 

a State and Local Air Monitoring Stations (SLAMS) in an area representing a neighborhood (or 

higher) scale of expected maximum PM2.5 concentration.
Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 2

Other failures compound the problem. The current SLAMS in downtown Fairbanks fails to meet 

monitoring network objectives, SLAMS design criteria, or operating frequency requirements. In 

2013, a neighborhood station that had operated for six years and reported high concentrations

was shut down immediately after the public and EPA raised inquiries as to why its data were

not considered in nonattainment decisions. Most recently, North Pole Fire, a station that in 

2012 recorded the highest PM2.5 concentrations in the nonattainment area (and the nation),

will be downgraded to represent an area of approximately 100 meters, disqualifying its data 

from nonattainment decisions. The National Core multipollutant monitoring station (NCore) in 

downtown Fairbanks has not met sampling frequency requirements for NCore or SLAMS, but 

has now been proposed to be designated the SLAMS. Sampling frequency has not met 

minimum requirements, and continuous monitor data has not been considered in 

nonattainment decisions or routinely available to the public. The current air monitoring 

program relies on inadequate data collected from the incorrect location, misdirecting every 

element of protection for public health intended under the Clean Air Act.

State and local agencies have shown themselves incapable or unwilling to meet federal air 

monitoring network requirements. Inadequate sampling, improper monitor placement, closure 

of a key monitoring station, and downgrading the monitor in the area of expected maximum

concentration hide the severity of the PM2.5 pollution and prevent essential remedies. A SIP 

based on inadequate data will be insufficient to protect the health of residents in the most 

severely polluted areas. This will be grounds to reject the SIP. A series of state and local agency 

decisions undermining monitor data collection shows probable intent to subvert Clean Air Act 

requirements and responsibilities.

EPA extended the deadline for submittal of the SIP to Dec. 31, 2014. Yet, the Regional 

Administrator should be aware that the State of Alaska has not established statutes or 

regulations to support SIP enforcement or controls. The comment period on draft regulations 

ended Jan. 24, 2014. Over 900 public comments were received by the Alaska Department of 

Environmental Conservation (ADEC). The agency’s website gives this update: “Due to the 

number of comments, the Department does not expect to have the response to comments 

completed until after June 2014.” (Information on ADEC's Proposed Regulations) June has come 

and gone with no sign of the final regulations.

On October 1, 2014, ADEC planned to decommission the State Office Building station that 

operated since 1972 and has been the designated SLAMS. ADEC has requested EPA approval to 

close this station in downtown Fairbanks and relocate it to a different site in downtown 

Fairbanks. EPA should use its authority under 40 CFR §58.14(c) to deny this request. Instead, 

the Regional Administrator should designate North Pole Elementary as SLAMS from 2011 to 

2013 and North Pole Fire Station #3 as SLAMS beginning in 2014. Data, including continuous

Federal Equivalent Method (FEM) monitoring, from both sites are eligible for comparison to the 

National Ambient Air Quality Standards (NAAQS) for PM2.5 per 40 CFR §50 Appendix D 3(a) and 

40 CFR §58.11(e). Expanding the combined site data record using FEM as well as Federal 

Reference Method (FRM) monitors will likely meet data completeness requirements under 40 
Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 3

CFR §50 Appendix N 4.1 and 4.2. Further, the Regional Administration should take over 

operation of North Pole Fire to ensure operation going forward meets SLAMS requirements.

The EPA Regional Administrator is authorized under 40 CFR §58.60 to locate and operate an 

ambient air monitoring site if the state or local agency fails to locate, or schedule to be located, 

when necessary in his judgment to meet monitoring network objectives and design criteria

specified in 40 CFR §58 Appendix D. North Pole Fire meets federal requirements for a SLAMS to 

be located in an area of expected maximum concentration. 40 CFR §58 Appendix D 4.7.1(1). 

Operation of a SLAMS site in this neighborhood is necessary to ensure adequate data collection 

to “support compliance with ambient air quality standards and emissions strategy 

development.” 40 CFR §58 Appendix D 1.1(b). It is not reasonable to wait for state and local 

agencies to get it right when the record of improper air monitoring shows intent to get it 

wrong.

The EPA Regional Administrator should immediately establish year-round PM2.5 sampling (at 

least 1-in-3 day) at the North Pole Fire SLAMS to ensure adequate creditable samples from the 

neighborhood of expected maximum concentration for NAAQS comparison.

EPA should also use continuous FEM monitoring in addition to FRM monitors. 1-in-3 day 

sampling cannot meet required monitoring network objectives needed to address extreme air 

pollution. 40 CFR §58 Appendix D 1.1.1. Continuous FEM monitoring eliminates bias caused by 

gaps in sampling, improves public reporting, strengthens reliability of data comparisons against 

the NAAQS, supports development of the attainment plan, and allows more robust air pollution 

research studies. Anchorage and Juneau (neither are PM2.5 nonattainment areas) and many 

areas designated nonattainment under the 2006 PM2.5 standard rely on continuous FEM 

monitoring at their SLAMS:

San Joaquin Valley, CA, Liberty-Clairton, PA, Los Angeles, CA, Harrisburg-LebanonCarlisle-York, PA, Lancaster, PA, Cleveland-Akron-Lorain, OH, Salt Lake City, UT, 

Philadelphia-Wilmington, PA-NJ-DE, Johnstown, PA, Seattle-Tacoma, WA, Allentown, PA, 

San Francisco Bay Area, CA, Logan, UT-ID, New York, NY-NJ-CT, Canton-Massillon, OH, 

Detroit-Ann Arbor, MI, Provo, UT, Pittsburgh-Beaver Valley, PA, Yuba City-Marysville, 

CA, Detroit-Ann Arbor, MI, Steubenville-Weirton, OH-WV, and Birmingham, AL

But not Fairbanks. In 2012 and 2013, the FNSB nonattainment area had higher 98th percentile 

daily values than any of these communities. It is essential to apply the power and timeliness of 

continuous FEM monitoring to meet the serious challenge of PM2.5 in the FNSB nonattainment 

area.

Action by the Regional Administrator is needed urgently to stop the shell game. When a site 

shows high values, FNSB shuts it down or downgrades it to prevent comparison to the NAAQS. 

FNSB and ADEC have not included continuous FEM monitors in NAAQS considerations even 

though no evidence of performance problems has been included in the annual plan. FNSB shut 

down the North Pole Elementary station apparently to keep its high concentrations from being 
Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 4

considered. The state downgraded North Pole Fire Station #3 to apparently disqualify its data 

from full NAAQS comparison. FNSB could shut down North Pole Fire without notice or EPA 

approval just like North Pole Elementary. FNSB removed the RAMS from Watershed School 

without notice in 2013 even though it served an essential objective of alerting the school, 

parents, and residents of repeated hot zone episodes in that neighborhood. Watershed School 

Update. In the last several days, FNSB put a Relocatable Air Monitoring System (RAMS) trailer 

called “North Pole Water” on the Old Richardson Highway near Tanana Drive. Will this be the 

station used to “replace” North Pole Fire?

EPA needs to do more than stop shutdowns and downgrades of essential monitors. EPA needs 

to take over to ensure sampling frequency protocols are followed this coming winter. 

Inadequate sampling limits data analysis needed to protect health and meet attainment. EPA 

also needs to recalculate daily and annual nonattainment design values using continuous FEM 

monitor data and to make continuous FEM data available on Air Data. It is time to designate 

monitors from the neighborhood of expected maximum concentration as SLAMS and use these

data, not that from downtown Fairbanks, to drive SIP targets and controls and protect health.

EPA has the responsibility and authority to stop the game.

We have attached a report to substantiate the errors and violations. Thank you for your 

attention to the problem of air quality monitoring in the FNSB PM2.5 nonattainment area. A 

solution depends on your prompt intervention.

Sincerely,

Sylvia Schultz

PM2.5 Program Director

cleanairfairbanks@gmail.com

Attachment

CC: 

Governor Sean Parnell (governor@alaska.gov)

Mayor Luke Hopkins (mayor@fnsb.us)

Commissioner Larry Hartig, ADEC (larry.hartig@alaska.gov)

Director Alice Edwards, ADEC Div of Air Quality (alice.edwards@alaska.gov)

Lucy Edmondson, EPA Region 10 (edmondson.lucy@epa.gov)

EPA Inspector General Hotline (OIG_Hotline@epa.gov)

Eric Jorgensen, Esq, Earthjustice (ericj@earthjustice.org)

Colin O’Brien, Esq, Earthjustice (cobrien@earthjustice.org)

Vicki Clark, Esq, Trustees for Alaska (vclark@trustees.org)

Jonathan Evans, Esq, Center for Biological Diversity (jevans@biologicaldiversity.org)

Jeremy Nichols, WildEarth Guardians (jnichols@wildearthguardians.org)
Request for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 5

Tomás Carbonell, Esq, Environmental Defense Fund (tcarbonell@edf.org)

Joe Minott, Esq, Clean Air Council (joe_minott@cleanair.org)

Brian Moench, MD, Utah Physicians for a Healthy Environment (drmoench@yahoo.com)

C. Arden Pope III, PhD, Brigham Young University (cap3@byu.edu)

Pam Miller, Alaska Community Action on Toxics (pamela@akaction.org)

Patrice Lee, Citizens for Clean Air (patricelee3294@gmail.com)
Errors and Violations Supporting EPA Operation of Air Monitoring and

Reassessment of Existing SLAMS Data and Locations in the

FNSB PM2.5 Nonattainment Area

Sylvia Schultz, Clean Air Fairbanks

cleanairfairbanks@gmail.com

http://cleanairfairbanks.wordpress.com

October 1, 2014

Request 1: The Regional Administrator of the Environmental Protection Agency (EPA) should 

promptly establish and operate air monitoring in the Fairbanks North Star Borough (FNSB) 

PM2.5 nonattainment area to meet monitoring objectives, network design criteria, and 

sampling frequency requirements of the Clean Air Act.

Request 2: EPA should review all available data to determine whether North Pole Elementary 

can be designated State and Local Air Monitoring Stations (SLAMS) from 2011 to 2013, whether 

North Pole Fire has already collected sufficient data to be designated SLAMS beginning in 2014, 

and if design values can be recalculated based on these stations and using continuous monitor 

data.

Request 3: Full site data records, including from continuous monitors, should be made available 

on AirData http://www.epa.gov/airdata to support required monitoring objectives that include 

informing the public, compliance accountability, and health studies.

Evidence of errors and violations supporting these requests:

1. North Pole Fire Station #3 has shown the highest concentrations in the nonattainment area

(and the nation). At least one SLAMS is required to be located in the “expected maximum 

concentration.”

2. Current and proposed SLAMS in downtown Fairbanks do not meet “expected maximum 

concentration” requirement. ADEC represented it met this requirement when it has not.

3. Locating the only SLAMS in downtown Fairbanks, not an area of expected maximum 

concentration, does not meet required Clean Air Act monitoring network objectives and 

PM2.5 design criteria.

4. In 2013, FNSB permanently shut down North Pole Elementary station, operated since 2008,

without warning or explanation just one day after a resident questioned why it was not the 

SLAMS.

5. Solely due to an unidentified obstacle, ADEC’s proposed 2014-2015 monitoring network 

plan disqualified North Pole Fire as a neighborhood scale site.

6. Contrary to air monitoring data, ADEC is downgrading North Pole Fire from “Neighborhood” 

to “Micro-scale” to avoid comparison to NAAQS.
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 2

7. FNSB will operate the North Pole Fire FRM from October through March only, limiting 

comparison to NAAQS.

8. ADEC misidentified the location and other identifiers for North Pole Fire.

9. FNSB has not operated the FNSB Administration Building station to meet sampling 

frequency requirements for SLAMS or NCore stations. ADEC has improperly proposed this 

site as a SLAMS.

10. In the annual monitoring network plan, ADEC did not include a performance assessment of 

monitors that should not be compared to the NAAQS. Thus, continuous FEM monitor data 

may not be excluded from NAAQS consideration.

11. If EPA does not step in to operate North Pole Fire as the SLAMS, nothing prevents North 

Pole Fire from being shut down without notice or ensures data completeness criteria will 

meet standards for NAAQS comparisons for PM2.5 attainment evaluations.

Documentation:

1. North Pole Fire Station #3 has shown the highest concentrations in the nonattainment area 

(and the nation). Federal regulation requires at least one SLAMS to be located in the area of 

“expected maximum concentration.”

State and Local Air Monitoring Stations (SLAMS) make up the ambient air quality monitoring 

sites that are primarily needed for National Ambient Air Quality Standards (NAAQS) 

comparisons for nonattainment decisions. At least one SLAMS in a nonattainment area must

meet the “expected maximum concentration” monitoring objective:

“At least one monitoring station is to be sited at neighborhood or larger scale in an area 

of expected maximum concentration.” 40 CFR §58 Appendix D 4.7.1(1).

In 2012, North Pole Fire recorded the highest PM2.5 98th percentile daily average concentration 

in the FNSB PM2.5 nonattainment area: 158.4 μg/m3. (Table 1.) North Pole Elementary, a

station with the area’s second highest 98th percentile daily average, recorded: 68.1. By contrast, 

the higher of the two downtown Fairbanks sites recorded a 98th percentile daily value of 50 in 

2012. North Pole Fire was more than three times higher than downtown Fairbanks in 2012

and higher than any nonattainment area in the nation.

The annual average reported from North Pole Fire in 2012 was 16.8, also highest in the 

nonattainment area. (Table 1.)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 3

Table 1. FNSB FRM Monitors, 2012

PM2.5 Fairbanks State 

Office Building

FNSB Admin 

Building

North Pole Elem 

School

North Pole Fire 

Station #3

Site ID 02-090-0010 02-090-0034 02-090-0033 02-090-0035

Annual Average 10.7 11.3 10.2 16.8

24-hr Ave (98th

Percentile) 49.6 50 68.1 158.4

EPA Air Trends, PM2.5 Detailed Information 2011-2013, accessed 10/1/2014.

North Pole Fire has regularly recorded the highest daily PM2.5 concentrations since it began 

operation in 2012. (Figure 1.) No other station in the nonattainment area has shown as 

consistently elevated PM2.5 concentrations as North Pole Fire. This trend is not limited to 2012; 

it persists across seasons and across years. Due to this persistent trend, North Pole Fire meets 

the SLAMS monitoring network objective for expected highest concentration.

Figure 1. FNSB Maximum Daily PM2.5 2010-2014 (EPA AirData www.epa.gov/airdata Local Conditions-88101, 10/1/2014)

In addition, North Pole Fire best meets the monitoring objective to locate monitor sites “to 

determine the highest concentrations expected to occur in the area covered by the network.” 

40 CFR §58 Appendix D 1.1.1. No other current site comes close to meeting this objective.

Clearly, to capture the area of “expected maximum concentration,” the SLAMS site must be at 

North Pole Fire.

2. Current and proposed SLAMS in downtown Fairbanks do not meet “expected maximum 

concentration” requirement. ADEC represented it met this requirement when it has not.

Because the downtown stations are not located in an area of PM2.5 expected maximum 

concentration, neither is qualified to be the only SLAMS station.

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

180.0

μg/m3 PM2.5

FNSB Maximum Daily PM2.5 2010-2014

02-090-0010

02-090-0033

02-090-0034

02-090-0035

EPA AirData

www.epa.gov/airdata

Local Conditions88101, 10/1/2014
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 4

The state misrepresented on its Appendix D Network Evaluation Form that at least one SLAMS 

for each area was sited in an area of expected maximum concentration. ADEC Air Quality 

Monitoring Network Plan 2014-2015, p 50. North Pole Fire is in the area of expected maximum 

concentration but is not a SLAMS, so this criterion was not met.

ADEC proposed the SLAMS to represent downtown Fairbanks. “DEC recognizes that the SOB 

PM2.5 monitor is the violating monitor in the Fairbanks PM2.5 non-attainment area, but 

believes that the NCore site can be used as a representative site for the Fairbanks downtown 

area.” ADEC Air Quality Monitoring Network Plan 2014-2015, p 36. A SLAMS must meet 

monitoring network objectives and PM2.5 network design criteria including the expected 

highest concentration; sites in downtown Fairbanks do not meet these objectives or criteria.

A State Implementation Plan (SIP) targeting reductions to meet attainment in downtown 

Fairbanks will not be adequate to protect health in the neighborhood of expected maximum 

concentration.

3. Locating the only SLAMS in downtown Fairbanks, not an area of expected maximum 

concentration, does not meet required Clean Air Act monitoring network objectives and 

PM2.5 design criteria.

Required monitoring network objectives include determining the neighborhood of expected 

highest concentration and locating stations to represent the proper scale for the pollutant and 

expected sources. 40 CFR §58 Appendix D 1. PM2.5 design criteria require at least one SLAMS 

be located in a neighborhood area of expected maximum concentration. 40 CFR §58 Appendix 

D 4.7.1(1).

4. In 2013, FNSB permanently shut down the North Pole Elementary station just one day after

a resident questioned why it was not the SLAMS. In operation since 2008, the closure came 

with no warning or explanation.

On March 28, 2013, a Fairbanks resident called Lucy Edmondson, EPA Region 10, to ask why 

EPA did not count data from North Pole Elementary although it had been in operation since 

2008. Ms. Edmondson then consulted EPA’s data team and “in house data” then contacted the 

Borough by phone. Ms. Edmondson followed-up with the Fairbanks resident that the Borough’s 

response was that North Pole Elementary was a “winter-only site,” but they had actually been 

running it year-round. Ms. Edmondson relayed to the resident that the Borough was now 

working to get the year around data into the EPA system and that might make North Pole 

Elementary qualify to be counted.

The next day, March 29, 2013, was the last day North Pole Elementary recorded a sample.

There was no notice or explanation given for the shutdown. The annual monitoring network 

plan must include “any proposals to remove or move a monitoring station within a period of 18 
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 5

months following plan submittal.” 40 CFR §58.10(b). However, state monitoring network plans

did not mention removal of the North Pole Elementary station. 

State plans from 2010 to 2013 did not describe North Pole Elementary as winter-only. The plans

described summer and winter monitoring objectives and plans to evaluate pollutant 

characteristics. (If speciation data was recorded at North Pole Elementary as noted in state 

network plans from 2010 to 2013, EPA AirData shows no record of it.) According to the last plan 

before the shutdown:

“The source contribution to winter time PM2.5 is still being studied. Wood smoke from 

home heating is currently considered one of the major sources. During the summer 

months, the main source is wildland fire smoke. The goals of the FNSB Winter 

Monitoring Project conducted during the winters of 2008-09, 2009-10, and 2010-11 are 

to evaluate wintertime pollutant characteristics and develop a strategy to reduce the 

concentration in North Pole.” ADEC, Alaska’s 2013 Air Monitoring Network Plan, 

Chapter 3, p 14.

The Borough’s decision to shut down the monitor took one day. It takes months for data to be 

entered into EPA’s AirData system where it is available to the public. It took more than a year

for us to put together that North Pole Elementary ceased operation just one day after a 

member of the public asked why the station was not considered by EPA.

Was the timing of the North Pole Elementary shutdown just a remarkable coincidence? Or did 

the resident’s phone call trigger a decision on the part of the local agency to prevent EPA from 

considering North Pole Elementary in nonattainment decisions? The absence of any mention in 

the annual monitoring network plan as required prior to decommissioning a site speaks to the 

decision trigger being the phone call.

What then would have been the impact of comparing North Pole Elementary with NAAQS? 

North Pole Elementary consistently had the highest three-year design value of the 98th

percentile daily averages from 2008-2010 to 2011-2013. A nonattainment determination based 

on North Pole Elementary rather than the cleaner site in downtown Fairbanks would support

substantially different control plans to meet a larger increment of improvement. (However, 

North Pole Fire had the highest daily design values from Jan. 1, 2012 to June 28, 2014.)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 6

Table 2. FNSB Daily PM2.5 Design Values from FRM monitors, 2008-2014

Daily PM2.5

Design Values (all 

FRM)

Fbks State Office 

Bldg (SLAMS)

FNSB Admin 

Bldg (NCore)

North Pole 

Elem School

North Pole 

Fire Station #3

Site ID 02-090-0010 02-090-0034 02-090-0033 02-090-0035

2008-2010 50 47 63

2009-2011 47 45 63

2010-2012 46 42 47

2011-2013 42 45 45

2012 to 6/28/2014 43 46 128

EPA Air Trends Design Values 2011-2013 and Archives 2008-2012, accessed 10/1/2014.

Regarding annual averages, North Pole Elementary was not considered in the state’s Dec. 10, 

2013 letter to EPA regarding designations of PM2.5 nonattainment areas violating the annual 

standard. The state submitted the FNSB 2010-2012 annual PM2.5 design value of 11.5, highest 

in the state, based on data from the State Office Building in downtown Fairbanks. The FNSB 

annual design value of 11.5 is within 5 percent of the annual standard of 12. If all the data from 

North Pole Elementary were considered, would the FNSB nonattainment area exceed the 

annual PM2.5 standard?

5. Solely due to an unidentified obstacle, ADEC’s proposed 2014-2015 monitoring network 

plan disqualified North Pole Fire as a neighborhood scale site.

According to the Part 58 Appendix E evaluation form in the draft plan, the North Pole Fire 

monitor inlet does not meet the criterion for distance from sampler to obstacle: “must be at 

least twice the height that the obstacle protrudes above the probe inlet.“ ADEC Air Quality 

Monitoring Network Plan 2014-2015, p 66. 

This failure to meet the spacing from obstructions appears to explain the site’s downgrade to 

micro-scale. Neighborhood sites are not allowed to violate the spacing from obstructions

criterion. 40 CFR §58 Appendix E 4(a). Micro-scale sites may violate the criterion if structures 

are unavoidable. Further, micro-scale sites are “not eligible for comparison to the annual PM2.5 

NAAQS.” 40 CFR §58.30.

However, the evaluation form does not specify how North Pole Fire does not meet Appendix E. 

Under “Other Comments” the form states: “Trees to the North are just outside the limits.” On 

page 29 of the draft plan, “Spacing from Obstructions (meters)” is “none;” “Height (meters)” is 

“4;” and “Trees” is “> 30.”

Information provided by the state for Appendix E is contradictory and unclear. What is the 

obstacle that causes North Pole Fire to fail spacing from obstructions criterion? Could it be the 

building? The building is approximately 16 meters away from the monitor inlet. The inlet is 4 

meter high, so the building would have to be 12 meters (40 feet) tall—it is not that tall. Could 

the group of trees be the obstacle? Four small deciduous trees are at least 20 meters away and 
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 7

would have to be 14 meters (46 feet) tall to violate the criterion—they are not. (Dimensions 

estimated using Google Earth.) If these are obstructions, they are avoidable: raise the monitor 

inlet, move the monitor a few meters farther from the building, or top or remove the trees. 

Photographs of North Pole Fire do not show an obstacle. ADEC Alaska’s 2013 Air Monitoring 

Network Plan, Chapter 3, p 18. The monitor inlet appears taller than the closest side of the fire 

station.

The state’s Appendix E evaluation form in the 2014-2015 draft plan disqualifies North Pole Fire 

from neighborhood scale and NAAQS comparison purely on the basis of avoidable yet 

unidentified obstacles.

6. Contrary to air monitoring data, ADEC has downgraded North Pole Fire from 

“Neighborhood” to “Micro-scale” to avoid comparison to NAAQS.

In the current proposed monitoring network plan, ADEC downgrades North Pole Fire to “microscale” ADEC Air Quality Monitoring Network Plan 2014-2015, p 29. (EPA approval is not needed 

to finalize this downgrade unless the station is a SLAMS.) Regulations prohibit micro-scale 

stations from being compared against the annual NAAQS standard. 40 CFR §58.30. North Pole 

Fire has been operated as a “neighborhood” scale station since beginning operation in 2012. 

The downgrade takes effect while FNSB collects additional data:

“The FNSB is also planning to use their mobile monitoring system (sniffer technology) to 

further evaluate the North Pole Fire #3 site to determine if the site is a hot spot or truly 

representative of a larger neighborhood scale.” p 1.

Plans to gather more data cannot explain downgrading the station.

PM2.5 design criteria specify the dimensions for neighborhood and micro-scale:

Neighborhood scale is used for a “reasonably homogeneous urban sub-region” with 

dimensions of “a few kilometers.” 40 CFR §58 Appendix D 4.7.1(c)(3).

Micro-scale monitoring of stationary sources is used for “large industrial processes” 

impacting an area of “with dimensions extending up to approximately 100 meters.” 40 

CFR §58 Appendix D 4.7.1(c)(1).

Existing data demonstrate North Pole Fire meets spatial requirements for neighborhood scale, 

not micro-scale. Mobile monitoring during the winter of 2013/2014 found North Pole Fire 

centered in an area of highest PM2.5 concentrations with a 4-km diameter. (Figure 2.)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 8

Figure 2. FNSB combined average PM2.5 2013/2014 winter season with spatial scales of 2 kilometers and 100 meters 

overlay.

FNSB mobile monitoring was used to identify the location for North Pole Fire in 2012. Data from 

last winter confirms that North Pole Fire represents PM2.5 concentrations in an area of more 

than several kilometers (neighborhood scale). To downgrade it to represent just 100 meters 

(micro-scale) disregards FNSB’s years of mobile data. 

The state’s downgrade of North Pole Fire comes after the 2013 plan that referenced North Pole 

Fire as potentially more representative. “Preliminary studies suggest that this new site might be 

more representative of the North Pole neighborhood scale pollutant levels.” ADEC Alaska’s 

2013 Air Monitoring Network Plan, Chapter 3, p 16. (Representing North Pole neighborhoods 

may sound good but is not required.)

PM2.5 design criteria explicitly require at least one SLAMS be located in the area of expected 

maximum concentration.

North Pole Fire correctly matches neighborhood scale PM2.5 monitoring network objectives for

representing areas of maximum PM2.5 concentration:

“To determine PM2.5 concentrations which are typical over a geographic area having 

relatively high PM2.5 concentrations, a neighborhood scale site is more appropriate. 
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 9

Such a site would likely be located in a residential or commercial area having a high 

overall PM2.5 emission density but not in the immediate vicinity of any single dominant 

source.” 40 CFR §58 Appendix D 1.2(d).

“The most important spatial scale to effectively characterize the emissions of particulate 

matter from both mobile and stationary sources is the neighborhood scale for PM2.5.” 

40 CFR §58 Appendix D 4.7.1(b)(4)(c).

Figure 3 further illustrates the appropriateness of neighborhood scale for this “reasonably 

homogeneous urban sub-region” with dimensions of “a few kilometers.” 40 CFR §58 Appendix 

D 4.7.1(c)(3).

Figure 3. Map of North Pole Fire showing homogeneous urban sub-region, note 200 m scale. (Bing Bird’s Eye 2012)

Why would the state downgrade North Pole Fire to micro-scale? The most likely explanation is 

to prevent the data from being compared to the NAAQS annual standard.

“PM2.5 measurement data from monitors that are not representative of area-wide air 

quality but rather of relatively unique micro-scale, or localized hot spot, or unique 

middle-scale impact sites are not eligible for comparison to the annual PM2.5 NAAQS. 

PM2.5 measurement data from these monitors are eligible for comparison to the 24-

hour PM2.5 NAAQS. For example, if a micro- or middle-scale PM2.5 monitoring site is 

adjacent to a unique dominating local PM2.5 source, then the PM2.5 measurement data 

from such a site would only be eligible for comparison to the 24-hour PM2.5 NAAQS.” 40 

CFR §58.30. (bold added)

To ignore evidence that fully qualifies North Pole Fire as a neighborhood scale seems to show a 

calculated intent to prevent the data from being used in nonattainment considerations.
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 10

7. FNSB will operate the North Pole Fire FRM from October through March only, limiting 

comparison to NAAQS.

With no explanation, the FRM at North Pole Fire will be operated October through March only. 

ADEC Air Quality Monitoring Network Plan 2014-2015, p 33. (EPA approval is not needed to 

finalize this sampling schedule unless the station is a SLAMS.)

In the 2013 plan, ADEC reported that the North Pole Fire FRM would be operated on a 1-in-3 

day schedule throughout the year. ADEC, Alaska’s 2013 Air Monitoring Network Plan, Chapter 

3, p 17. Now, without explanation, it will be operated only in the winter.

Reducing sampling frequency undermined the relevance of data collected at North Pole 

Elementary before it was shut down without notice. Inadequate sampling frequency prevents 

comparison with the NAAQS, especially for the annual standard, reducing the modeled target 

and efficacy of controls in the SIP.

8. ADEC misidentified the location and other required information for North Pole Fire.

The state included significant factual errors regarding North Pole Fire’s location and other 

information in the most recent air quality monitoring network plan draft. ADEC Air Quality 

Monitoring Network Plan 2014-2015 6/30/2014. Annual monitoring network plans are required 

to include information including the address, geographical coordinates, and AQS identification 

number. 40 CFR §58.10(b). Other than the site name, the entire row of Table 3-1 (page 9) in

ADEC’s draft plan is wrong. (Table 3.)

Table 3. Comparison of ADEC draft plan with correct identifiers for North Pole Fire Station #3

Site Name Address Latitude/ 

Longitude

AQS 

Identification

Draft Plan, p 9 North Pole Fire 

Station #3

388 Hurst Rd, 

North Pole

64.762973N

-147.310297W

02-090-0036

Correct North Pole Fire 

Station #3

3288 Hurst Rd, 

North Pole

64.762740N

-147.310233W

02-090-0035

These factual errors make it difficult for federal regulators or the public to review the station 

location or evaluate the monitoring objective and spatial scale of representativeness. EPA 

AirData uses the coordinates for the North Pole Fire monitor that incorrectly place the monitor 

in a small group of trees. (Figure 4.)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 11

Figure 4. Green pin on image of North Pole Fire monitor (64.762740, -147.310233). Red pin on four small deciduous trees

misidentified as monitor location (64.762973, -147.310297). (Google earth 6/19/2012, EPA Download Site Data PM2.5)

Figure 5. North Pole Fire at 3288 Hurst Rd, North Pole, AK prior to monitor installation. (Google Street View Sept 2011)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 12

Figure 6. North Pole Fire at 3288 Hurst Rd, North Pole, AK prior to monitor installation. (Bing Bird’s Eye 2012)

In addition, ADEC’s map on page 18 of the draft plan (Figure 7) incorrectly locates the station on 

the northeast corner of the Dawson and Hurst intersection. North Pole Fire is actually closer to 

the northwest corner.

Figure 7. Map on page 18 of ADEC draft plan incorrectly locates North Pole Fire in NE corner of intersection. (Google earth)
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 13

9. FNSB has not operated the FNSB Administration Building station to meet sampling 

frequency requirements for SLAMS or NCore stations. ADEC has improperly proposed this site 

as a SLAMS.

The FNSB Administration Building has been operated as the National Core multipollutant 

monitoring station (NCore) for Alaska since 2011. The state has requested EPA approval to 

designate the NCore as the SLAMS. Both NCore and SLAMS must operate on at least a 1-in-3 

day schedule. 

NCore: “Manual PM2.5 samplers at NCore stations... must operate on at least a 1-in-3 

day sampling frequency.” 40 CFR §58.12(d)(2). “Continuous monitoring methods are to 

be used at the NCore sites when available for a pollutant to be measured, as it is 

important to have data collected over common time periods for integrated analyses.” 

40 CFR §58 Appendix D 2(c).

SLAMS: “Required SLAMS stations whose measurements determine the design value for 

their area and that are within plus or minus 10 percent of the NAAQS; and all required 

sites where one or more 24-hour values have exceeded the NAAQS each year for a 

consecutive period of at least 3 years are required to maintain at least a 1-in-3 day 

sampling frequency.” 40 CFR §58.12(d)(1)(ii).

Neither the FNSB Administration Building NCore nor the Fairbanks State Office Building SLAMS 

met 1-in-3 day sample frequency requirements from 2009 to 2013. (Table 4.)

Table 4. FNSB NCore and SLAMS sampling frequency, 2009-2013

Sampling Frequency, Year/# 

Days in Year

Minimum 

Sampling Req.

FNSB Admin 

Building

Fairbanks State 

Office Building

Site ID 02-090-0034 02-090-0010

NCore POC 1 & 2 SLAMS POC 1 & 2

2009/365 121 17 118

2010/365 121 115 119

2011/365 121 112 116

2012/366 122 121 119

2013/365 121 113 112

EPA AirTrends PM2.5 Design Values 2011-2013 and PM2.5 Design Values Archives and EPA 

AirData http://www.epa.gov/airdata/ad_viz_plotval.html, all accessed 10/1/2014.

ADEC improperly submitted the request to move the downtown SLAMS. EPA may approve 

requests to move a SLAMS monitor to a nearby location only if the requirements of Appendix D 

to part 58 “continue to be met.” 40 CFR §58.14(c). State and local agency failures to meet 

Appendix D include those raised previously:
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 14

40 CFR §58 Appendix D

1.1 Monitoring Network Objectives – improper SLAMS location and sampling frequency 

interfere with all three monitoring objectives.

1.2 Spatial Scales – not met: goal to locate monitors to correctly match “most appropriate” 

spatial scale for monitoring site type, air pollutant, and monitoring objective.

4.7.1(b)(1) expected maximum concentration – not met: at least one required monitoring 

station must be sited at neighborhood or larger scale “in an area of expected maximum 

concentration.”

4.7.1(c)(1) and 4.7.1(c)(3) Micro-scale and Neighborhood scale – North Pole Fire does not 

meet micro-scale dimensions of approximately 100 meters. This site fits neighborhood scale 

for “the reasonably homogeneous urban sub-region with dimensions of a few kilometers.”

In addition, designating the FNSB Administration Building as both NCore and SLAMS does not 

complement data collection.

“NCore sites are expected to complement the PM2.5 data collection that takes place at 

non-NCore SLAMS sites, and both types of sites can be used to meet the minimum PM2.5

network requirements.” 40 CFR §58 Appendix D 4.7.1.

Consolidating SLAMS and NCore into one station minimizes PM2.5 data collection in this 

severely affected PM2.5 nonattainment area, further diminishing already inadequate PM2.5 

sampling and interfering with requirements necessary to protect public health.

Regulations do not support EPA approval of ADEC’s request to move the SLAMS to a site in 

downtown Fairbanks.

10. In the annual monitoring network plan, ADEC did not include a performance assessment 

of monitors that should not be compared to the NAAQS. Thus, continuous FEM monitor data 

may not be excluded from NAAQS consideration.

State and local governments may request that Federal Equivalent Method (FEM) monitors 

should not be used in comparison to the NAAQS but must accompany this request with a 

performance assessment in the annual monitoring network. 40 CFR §58.11(e).

Lacking this request or assessment, EPA has no basis to exclude North Pole Elementary and 

North Pole Fire continuous FEM data from NAAQS consideration. For that matter, continuous 

FEM data from the downtown stations also cannot be excluded.

It is unclear exactly why FNSB does not use continuous FEM monitors. According to the state’s 

5-year plan, continuous monitors “cannot be trusted” in Fairbanks, and “several of our FEM 

PM2.5 samplers operated in Fairbanks are biased high.” State of Alaska 2010 Ambient Air 

Quality Network Assessment, p 61. However, no data were provided to substantiate this claim. 

Without a formal assessment as provided in 40 CFR §58.11(e), continuous FEM monitor data 

can be compared with the NAAQS.
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 15

For SLAMS, where a monitoring agency has identified that the continuous monitor does not 

produce data of adequate quality, the agency “must ensure” that FRM sample frequency 

requirements are met. 40 CFR §58.10(b)(13). For this nonattainment area, FNSB has done the

opposite and ensured sample frequency requirements were not met.

We conducted a spot comparison of collocated North Pole Fire FRM and FEM monitors from 

Sept. to Dec. 2012. We found a slope of 0.9933. This is within 1 ± 0.10 guidance provided by 

Table C-4 test specifications for PM2.5 FEMs. 40 CFR §53 Subpart C. The data from the two 

monitors correlated very well, with a correlation coefficient of 0.9768.

Even if continuous FEM data does not meet the correlation criteria, this does not exclude the 

data from consideration. 

“Correlation is required to be reported in the assessment, but failure to meet the 

correlation criteria, by itself, is not cause to exclude data from a continuous FEM 

monitor.” 40 CFR §58.11(e)(6).

After the first 24 months of operation, data not certified by the reporting agency can be used 

by EPA if judged “complete and accurate” by EPA. 40 CFR §50 Appendix N (3)(a). EPA should not 

allow state and local efforts to prevent comparison of North Pole Fire to NAAQS to circumvent 

imperatives of the Clean Air Act and public health. 

EPA should collect and review all data to determine whether North Pole Elementary can be 

designated SLAMS from 2011 to 2013, its continuous monitors accepted as FEM, and the 

combined site data record reported to EPA Air Quality System (AQS) for comparison with 

NAAQS. 

Similarly, North Pole Fire began operations March 1, 2012. On March 1, 2014, 24 months later, 

it is eligible for comparison to NAAQS. EPA should determine whether North Pole Fire can be 

designated SLAMS beginning in 2014, its continuous monitors accepted as FEM, and the 

combined site record made available on AQS for comparison with NAAQS.

Even without the continuous FEM monitors, North Pole Fire appears to have adequate 

creditable FRM samples for comparison against the PM2.5 daily standard per 40 CFR §50 

Appendix N 4.2. Data substitution may help fill out requirements for comparison to the PM2.5 

annual standard and may be considered valid by Administrator initiative considering “factors 

such as monitoring site closures/moves, monitoring diligence, the consistency and levels of the 

daily values.” 40 CFR §50 Appendix N 4.1. 

EPA should recalculate design values based on SLAMS monitors properly sited in the area of the 

expected maximum concentration using the combined site data record of the collocated FRM 

and continuous FEM monitors.
Support for EPA Monitoring and Data Reconsideration for FNSB PM2.5, 10/2/2014, page 16

11. If EPA does not step in to operate North Pole Fire as the SLAMS, nothing prevents North 

Pole Fire from being shut down without notice or ensures data completeness criteria will 

meet standards for NAAQS comparisons for PM2.5 attainment evaluations.

North Pole Fire is qualified for NAAQS comparison and SLAMS designation yet may be shut 

down without notice or accountability just like North Pole Elementary. 

Under FNSB control, North Pole Fire will be operated as a micro-scale site and only every third 

day from October through March, weakening or defeating the relevance of its data in 

nonattainment decisions. Meanwhile, with EPA approval, a monitor in downtown Fairbanks will 

continue to be the only SLAMS, and all nonattainment decisions will be based on this location 

even though the site does not meet requirements for expected maximum concentration. Only 

FRM data from the downtown station will count even if sampling frequency is less than one out 

of three days each year. FEM continuous data will continued to be labeled “cannot be trusted”

and ignored without any assessment of actual performance.

State and local agencies are experienced players in the game of hiding PM2.5 monitoring data 

even when it prolongs nonattainment and continues to expose the public to very unhealthy air.