U.S. Environmental Protection Agency 

Office of Air and Radiation 

Final 

Fiscal Year 2010 

National Program & Grant Guidance 

April 28, 2009
Contents 

Executive Summary 3 

I. Program Office 

II. Introduction/Context 3 

 A. Organization of the Technical Guidance 

 B. Organization of the Grant Guidance 

III. Priorities for the Regions 3 

IV. Implementation Strategies 4 

V. Performance Measures 4 

VI. Tracking Progress 5 

VII. State and Tribal Assistance Grants 5 

VIII. Program Contacts 5 

Healthier Outdoor Air 6 

Clean Air Allowance Trading Programs 8 

Federal Stationary Source Regulations 10 

Federal Vehicle and Fuels Standards and Certifications 11 

Federal Support for Air Quality Management 12 

Federal Support for Air Toxics Programs 19 

State and Local Air Quality Management 23 

Tribal Air Quality Management 28 

Healthier Indoor Air 34

Asthma 

Radon 

Stratospheric Ozone 37 

Domestic Programs 

Multilateral Fund 

Radiation Protection 39 

Radiation Protection 

Radiation Response Preparedness 

Homeland Security Preparedness, Response, and Recovery 

Climate Change 43 

Greenhouse Gas Registry Rule 

Voluntary Climate Protection Programs 

Appendix A Supplemental Information and Guidance for Outdoor and Indoor Air Quality 

Programs Funded with FY 2010 STAG Funds 

Appendix B FY 2010 Performance Measures 

Appendix C State Grant Performance Measures 

Appendix D Key Program Implementation Changes from 2009 

Appendix E OAR ARRA Measures 

Appendix F Responses to Comments 

Final FY 2010 Technical Guidance — April 28, 2009 2
Executive Summary 

I. Program Office – Office of Air and Radiation: This document describes air and radiation 

program implementation priorities and milestones for Fiscal Year (FY) 2010 and provides 

information on the use and prospective allocation of FY 2010 state, local, and tribal assistance 

grants (Appendix A). 

II. Introduction/Context: The information in this document supports achievement of the 

objectives, sub-objectives, and strategic measures in proposed in the 2009–2014 EPA Strategic 

Plan Change Document (http://epa.gov/ocfo/plan/plan.htm) and the performance goals in EPA’s 

FY 2010 Annual Performance Plan and Congressional Justification. 

A. Organization of the Technical Guidance: The main body of the guidance (not the 

appendices) is organized into five chapters B Outdoor Air, Indoor Air, Stratospheric Ozone, 

Radiation Protection, and Climate Change. These chapters correspond to the Objectives in 

the Goal 1—Clean Air and Global Climate Change section of the 2009-2014 EPA Strategic 

Plan Change Document. Each chapter begins with the sub-objectives and strategic Measures 

from the Strategic Plan and discusses the overall strategy for achieving the objective. This 

information informs the reader of the longer-term outcomes and results being pursued, and 

sets the stage for program subsections that present more detailed strategies and specific 

implementation activities. For instance, the Outdoor Air chapter contains subsections that 

reflect the different roles and responsibilities of the partners/co-regulators. One subsection 

speaks to the federal role and another speaks to the roles of state, local, and tribal air quality 

management agencies. In other chapters, the subsections are based on the type of activity 

rather than who performs the activity. The Stratospheric Ozone chapter, for example, is 

subdivided into domestic vs. international activities, whereas the Indoor Air chapter is 

subdivided into environmental contaminants/asthma triggers and radon. 

B. Organization of the Grant Guidance (Appendix A): As noted above the Outdoor Air 

chapter includes a discussion of the key roles and responsibilities of state, tribal, and local 

agencies in implementing ongoing and FY 2010-specific priorities. This activity is largely 

supported by grant assistance from EPA with significant matching resources from the coimplementors. Appendix A provides information and guidance on selected program areas 

supported by grant assistance. It highlights the major changes impacting program grants in 

FY 2010 both programmatically and administratively. Appendix A is divided into six 

sections: an executive summary which highlights major developments affecting FY 2010 

grant assistance, fundamental elements of sound grants management, areas of emphasis and 

change in programs supported with grant assistance, a dedicated section on ambient air 

monitoring programs, a preliminary FY 2010 air grant allocation, and information on the FY 

2010 state indoor radon grant program and grant allocation. 

III. Priorities for Regions: OAR’s top priorities for the Regions in FY 2010 are: 

A. Ozone, PM2.5, and Regional Haze. Act on State Implementation Plan (SIP) submissions 

and redesignation requests including regional haze control strategy plans; assist in 

designating areas for the 2008 8-hr ozone standard and the lead standard; and after 

Final FY 2010 Technical Guidance — April 28, 2009 3
designations are final including the PM2.5 designations in 2009, begin working with states on 

their attainment plans. 

 

B. Clean Air Interstate Rule. Assist states with CAIR emissions monitoring and reporting. 

C. Ambient Monitoring. Work with state and local agencies to: ensure start-up of nearsource lead monitoring stations by January 1, 2010; plan design of required urban non 

source-oriented monitors and include in annual monitoring network plan due by July 1, 2010; 

plan for changes in ozone monitoring season for start in 2010, if required; communicate any 

required changes to each state’s ozone monitoring network for non-urban and lower 

population areas for inclusion in annual monitoring network plans; ensure certification of 

2009 data submitted to AQS database by May 1, 2010; and, ensure readiness of remaining 

required NCore measurements such as PM10-2.5 mass, due to start on January 1, 2011. 

D. Mobile Sources. Implement the National Clean Diesel Campaign, assist with and 

comment on conformity determinations, process conformity-related SIP revisions, and make 

determinations and act on mobile budgets at time of SIP processing. 

E. Air Toxics. Delegate and provide assistance to co-regulators for section 111, section 112, 

and section 129 standards; and, increase emphasis on implementing programs and activities 

that contribute to reducing exposure to air toxics in areas that are experiencing 

disproportionate impacts.

F. Title V Permits. Work on permitting the pollution sources that remain to be permitted, 

and permit renewals. 

G. Indoor Environments. In implementing programs that addresses indoor air quality 

issues, increase emphasis on programs and activities that contribute to reducing asthma 

attacks in areas that are experiencing disproportionate impacts. 

H. State, Local, and Tribal Planning. Support multi-pollutant planning and efforts to 

reduce emissions of all air pollutants, while addressing other considerations such as land use, 

transportation, and energy.

IV. Implementation Strategies: The air and radiation toolbox includes statutory and regulatory 

activities, market-based program activities, partnership and community-based activities, and 

activities related to developing or implementing innovative approaches. Regions choose the mix 

of strategies and activities most appropriate for their circumstances and prevailing environmental 

issues while also addressing base program requirements. These strategies are described in more 

detail in the technical sections of this document. Regions are also encouraged to work closely 

with states to identify opportunities for enhanced work sharing, resource flexibility, and phased 

implementation of program requirements. Performance Partnership Agreements and 

Performance Partnership Grants are two examples of tools available to address workload issues. 

V. Performance Measures: OAR and the Regions collaborated to develop and agree on the 

performance measures listed in Appendix B. These were arrived at through discussions among 

HQ and regional program experts and managers, and further refined though an EPA-wide 

Final FY 2010 Technical Guidance — April 28, 2009 4
measures review process advanced by the Office of the Chief Financial Officer. Goals of the 

EPA-wide review process included: 1) improving measure quality, 2) establishing the fewest 

number of measures needed for program and performance management, and, 3) achieving 

maximum consistency among measures being used by different levels of management. 

VI. Tracking Progress: OAR tracks progress through existing monitoring, data reporting, and 

information systems used by OAR, Regions, and state, tribal, and local agencies, and through 

Measures Central. We also track and discuss program progress via conference calls, face-to-face 

meetings, and the exchange of written information. 

VII. State and Tribal Assistance Grants: Priorities for the use of FY 2010 air grant resources 

are outlined in the State and Local Air Quality Management subsection. Appendix A provides 

more information on specific grant topics including new initiatives, areas of changing emphasis 

such as monitoring, and associated program support. It also contains preliminary, national 

Region-by-Region allocations for state and local air quality programs and for state indoor radon 

grants. A tribal air grant allocation and the distribution of funds for certain competitive grant 

programs will be provided at a later date. 

VIII. Program Contacts:

• Criteria Pollutants, Air Toxics, Multi-pollutant Planning, and Regional Haze: Jeff 

Whitlow, phone 919-541-5523, email whitlow.jeff@epa.gov

• Trading Programs: Doris Price, phone 202-343-9067, email price.doris@epa.gov or 

Larry Kertcher, phone 202-343-9121, email kertcher.larry@epa.gov

• Mobile Sources: Mike Haley, phone 202-564-1708, email haley.mike@epa.gov

• State and Local Air Grants: Bill Houck, phone 202-564-1349, email 

houck.william@epa.gov unless a specific contact is listed in the grant guidance appendix. 

• Tribal: Darrel Harmon, phone 202-564-7416, email harmon.darrel@epa.gov

• Indoor Air: Tom Kelly, phone 202-343-9444, email kelly.tom@epa.gov

• Radiation: Bonnie Gitlin, phone 202-343-9371, email gitlin.bonnie@epa.gov

• Stratospheric Ozone: Ross Brennan, phone 202-343-9226, email brennan.ross@epa.gov

• Climate Change: Michael Zatz, 202-343-9152, email zatz.michael@epa.gov

 

• General Questions: Mike Hadrick, phone 202-564-7414, email 

hadrick.michael@epa.gov

++ End of Section ++ 

Final FY 2010 Technical Guidance — April 28, 2009 5
Healthier Outdoor Air 

Objective 1.1 – Healthier Outdoor Air. Through 2011, working with partners, protect human 

health and the environment by attaining and maintaining health-based air quality standards and 

reducing the risk from toxic air pollutants. 

Sub-objective 1.1.1: Reduce Criteria Pollutants & Regional Haze. 

Strategic Measures:

• By 2015, reduce the population-weighted ambient concentration of ozone in all 

monitored counties by 14 percent from the 2003 baseline, compared to the eight percent 

cumulative reduction expected by 2008. 

• By 2015, reduce the population-weighted ambient concentration of PM2.5 in all 

monitored counties by six percent from the 2003 baseline, compared to the four percent 

cumulative reduction expected by 2008. 

• By 2014, reduce emissions of fine particles from mobile sources by 51,000 tons from the 

2009 level of 417,000 tons. 

• By 2014, reduce emissions of nitrogen oxides (NOX) from mobile sources by 2.1 million 

tons from the 2009 level of 9.3 million tons. 

• By 2014, reduce emissions of volatile organic compounds from mobile sources by 1.1 

million tons from the 2009 level of 5.9 million tons. 

• By 2018, visibility in eastern Class I areas will improve by 15% on the 20% worst 

visibility days, as compared to visibility on the 20% worst days during the 2000-2004 

baseline period. 

• By 2018, visibility in western Class I areas will improve by 5% on the 20% worst 

visibility days, as compared to visibility on the 20% worst days during the 2000-2004 

baseline period. 

• By 2014, with EPA support, 47 additional tribes will have completed air quality emission 

inventories. (FY 2007 baseline: 37 tribal emission inventories.) 

• By 2014,12 additional tribes will possess the expertise and capability to implement the 

Clean Air Act in Indian country (as demonstrated by successful completion of an 

eligibility determination under the Tribal Authority Rule). (FY 2007 baseline: 10 tribes.) 

Final FY 2010 Technical Guidance — April 28, 2009 6
Sub-objective 1.1.2: Reduce Air Toxics.

Strategic Measures:

• By 2014, reduce toxicity-weighted (for cancer risk) emissions of air toxics to a 

cumulative reduction of 34 percent from the 1993 non-weighted baseline of 7.24 million 

tons, maintaining the 34% cumulative reduction expected by 2006. 

• By 2014, reduce toxicity-weighted (for non-cancer risk) emissions of air toxics to a 

cumulative reduction of 59 percent from the 1993 non-weighted baseline of 7.24 million 

tons, compared to the 58% cumulative reduction expected by 2006. 

Sub-objective 1.1.3: Reduce the Adverse Effects of Acid Deposition. 

Strategic Measures:

By 2014, due to progress in reducing acid deposition, the number of chronically-acidic water 

bodies in acid-sensitive regions of the northern and eastern United States should be maintained at 

or below the 2001 baseline of approximately 500 lakes and 5,000 kilometers of stream-length in 

the population covered by the Temporally Integrated Monitoring of Ecosystems/Long-Term 

Monitoring Survey. The long-term target is a 20 percent reduction in the number of chronicallyacidic water bodies in acid-sensitive regions by 2030. 

• Through 2015, maintain the national annual emissions of sulfur dioxide (SO2) from 

utility electric power generation sources at a level below 8.95 million annual tons, 

compared to the 1980 level of 17.4 million tons per year. 

• By 2014, reduce total annual average sulfur deposition by 20 percent from 2001 

monitored levels of up to 15 kilograms per hectare for total sulfur deposition. 

• By 2014, reduce total annual average nitrogen deposition by 30 percent from 2001 

monitored levels of up to 9 kilograms per hectare for total nitrogen deposition. 

 EPA's strategy for achieving the results expressed above combines national and local 

measures, reflecting different federal, state, tribal, and local government roles. States are 

primarily responsible for maintaining and improving air quality and meeting national ambient air 

quality standards (NAAQS) established by EPA. State programs develop emission inventories, 

operate and maintain air monitoring networks, perform air quality modeling, and develop State 

Implementation Plans (SIPs) that lay out control strategies for improving air quality and meeting 

NAAQS. 

 EPA assists states by providing technical guidance and financial assistance, issuing 

regulations, and implementing programs designed to reduce pollution from the most widespread 

and significant sources of air pollution: mobile sources, such as cars, trucks, buses, and 

construction equipment; and stationary sources, such as power plants, oil refineries, chemical 

plants, and dry cleaning operations. Interstate transport of pollutants—a problem no state can 

solve on its own—makes a major contribution to air pollution problems in the eastern U.S. To 

Final FY 2010 Technical Guidance — April 28, 2009 7
address this issue, EPA requires control of upwind sources that contribute to downwind 

problems in other states. 

 EPA has a trust responsibility to protect air quality in Indian country, but authorized tribes 

may choose to develop and implement their own air quality programs. EPA and states are 

working to increase the currently limited information on air quality on tribal lands, build tribal 

capacity to administer air programs in Indian country, and establish EPA and state mechanisms 

to work effectively with tribal governments on regulatory development and regional and national 

policy issues. 

 To further reduce exposure to air toxics, EPA will develop and issue federal standards for 

major stationary sources and area sources which, when implemented through state programs, 

will reduce toxic emissions by 1.7 million tons. In addition, we will conduct national, regional, 

and community-based efforts to reduce risks from hazardous air pollutants. Characterizing 

emissions and the risks they pose on national and local scales, such as in Indian country, will 

require significant effort. We will need to update the science and to keep the public informed 

about these issues. 

 We will develop and refine tools, training, handbooks, and information to assist our partners 

in characterizing risks from air toxics, and we will work with them on strategies for making local 

decisions to reduce those risks. We will work with state, tribal, and local agencies to modestly 

expand the national toxics monitoring network, and will compile and analyze information from 

local assessments to better characterize risk and assess priorities. 

 Our strategies for achieving healthier outdoor air are implemented through the following 

seven programs: 

• Clean Air Allowance Trading Programs 

• Federal Vehicle and Fuels Standards and Certifications 

• Federal Stationary Source Regulations 

• Federal Support for Air Quality Management 

• Federal Support for Air Toxics Management 

• State and Local Air Quality Management 

• Tribal Air Quality Management 

 The first five programs are federally-implemented programs and the latter two are grant 

programs that support state, tribal, and local air program implementation. All these programs and 

their priorities for FY 2010 are described below. 

CLEAN AIR ALLOWANCE TRADING PROGRAMS 

 The program includes development, implementation, and evaluation of federally-administered 

emission reduction programs that include the trading of emissions allowances. Trading programs 

help implement the NAAQS and reduce acid deposition, toxics deposition, and regional haze. 

Pollutants include SO2, NOX, and, as a co-benefit of SO2 emission reductions, mercury. Current 

Final FY 2010 Technical Guidance — April 28, 2009 8
operating programs include the Acid Rain Program authorized under Title IV of the 1990 Clean 

Air Act (CAA) Amendments and the Clean Air Interstate Rule (CAIR) seasonal and annual 

programs for interstate control of ozone and fine particle (PM2.5) pollution. The CAIR seasonal 

NOX control program includes not only the states and sources in the NOX Budget Program 

(NBP), but also over 600 additional sources and six more states in Regions 4, 5, 6, and 7 that 

were not subject to the NBP.

Strategy

 Our strategy for using allowance trading programs to promote more cost-effective pollution 

control and achievement of environmental objectives includes four components: 

• Clean Air Interstate Rule (CAIR): Continue implementation of this rule, promulgated in 

May 2005, which uses the proven cap-and-trade approach to achieve substantial 

reductions in SO2 and NOX. CAIR is a powerful component of EPA’s plan to help over 

450 counties in the eastern U.S. meet the NAAQS for ozone or PM2.5. All affected states 

are achieving the mandated reductions primarily by controlling power plant emissions 

through an EPA-administered interstate cap-and-trade program. By FY 2010, states 

should finalize all CAIR-related rulemakings and ensure that regulated sources are 

monitoring their emissions. The initial compliance year for the CAIR SO2 control 

program begins on January 1, 2010. 

• Existing Programs: Implement, operate, and assess existing allowance trading programs, 

including the new programs and revisions to existing programs established under CAIR. 

 

• New Statutory Authority: If multi-pollutant program legislation is enacted, EPA will 

work to develop implementing regulations. Modern statutory authority that applies 

nationwide could be an efficient long-term mechanism for achieving large-scale multipollutant emission reductions. 

• Program Accountability: Establish an integrated assessment program to include enhanced 

ambient and deposition monitoring, efficiency measures, and indicators to track health 

and environmental benefits, as called for in the recent report by the National Academy of 

Sciences. Operate, maintain, and modernize the Clean Air Status and Trends Network 

(CASTNET) monitoring network consistent with NAS recommendations, and evaluate 

incorporating atmospheric mercury speciation and deposition monitoring capability.

Discussion

 A high priority for FY 2010 is to continue implementation and operation of the CAIR annual 

and seasonal programs, consistent with the decision by the D.C. Circuit Court in December 2008 

to “allow CAIR to remain in effect until it is replaced by a rule consistent with [the Court’s July 

11, 2008] opinion” so as to “at least temporarily preserve the environmental values covered by 

CAIR.”1

 During FY 2010, EPA will be proceeding expeditiously to finalize and publish its 

 

1 U.S. Court of Appeals for the D.C. Circuit, No. 05-1244, page 3 (decided December 23, 2008). 

Final FY 2010 Technical Guidance — April 28, 2009 9
proposed rule for replacement of the original CAIR with a rule that addresses the Court’s 

concerns. Notice and comment rulemaking will proceed throughout the year. 

 In FY 2010, EPA will continue to assist states with CAIR implementation, especially 

activities related to allowance trading, emissions monitoring, and end-of-season reconciliation of 

emissions and allowances for affected sources. Affected units in the 20 former NBP states 

include boilers, turbines, and combined cycle units from a diverse set of industries as well as 

electric utility units. The initial compliance year for the SO2 control program under CAIR-PM is 

2010. Required SO2 emissions monitoring and reporting for CAIR began on January 1, 2009. 

FY 2010 Milestones: CAIR NOX and SO2 Control Programs

• EPA completes implementing software and guidance for CAIR. EPA works with states to 

finalize rulemakings to establish the preferred allowance allocations, operate the trading 

and emissions reporting programs, and certify source emissions monitors. 

• Regions assist states with emissions monitoring and reporting and EPA assists states and 

sources in the initial compliance year for CAIR SO2 control program. 

FY 2010 Milestones: Acid Rain Program

• Working with states, tribes, local agencies, Regional Planning Organizations, and other 

partners in CASTNET, develop and begin implementation of an operations plan that will 

assure supportability over the next five years and will bring this network in-step with 

integrated national monitoring strategies involving regionally-representative core sites. 

• Report progress in reducing sulfur and nitrogen deposition and in reducing the number of 

chronically-acidic water bodies in acid-sensitive regions, and SO2 emissions reduced. 

FEDERAL STATIONARY SOURCE REGULATIONS 

 This program includes activities related to: maximum achievable control technology 

(MACT), combustion, and Area Source Standard development; the Stationary Source Residual 

Risk Program; New Source Performance Standards; and, associated national guidance and 

outreach information. The strategy is to develop generally-available, control technology-based 

standards for the highest priority area source categories. 

FY 2010 Priorities

• Propose and promulgate area source standards and residual risk standards according to 

court ordered schedules. 

• Promulgate NESHAP for Reciprocating Internal Combustion Engines. 

• Promulgate NESHAP for Brick and Structural Clay. 

• Promulgate NESHAP for Plywood and Composite Wood Products. 

• Promulgate NESHAP: Reconsideration for Portland Cement. 

• Promulgate NESHAP for Polyvinyl Chloride and Copolymers. 

Final FY 2010 Technical Guidance — April 28, 2009 10
• Promulgate NESHAP: Defense Land Systems and Miscellaneous Equipment (Military 

MACT). 

• Promulgate additional amendments to prior NESHAP/MACT Standards. 

• Promulgate NESHAP for Industrial Boilers (major and area sources). 

• Promulgate Remand Response and Amendments for Commercial and Industrial Solid 

Waste Incinerators (CISWI). 

• Promulgate Reconsideration of Stationary Combustion Turbines (Subpart KKKK). 

• Promulgate NESHAP for Gold Mining Production Processes. 

• Propose Response to Remand for Large Municipal Waste Combustion Units (MWCs). 

• Propose Response to Remand for Small Municipal Waste Combustion Units (MWCs). 

• Propose revisions to NSPS for residential wood heaters. 

FEDERAL VEHICLE AND FUELS STANDARDS AND CERTIFICATIONS 

 This program includes federal activities that support the development, implementation, and 

evaluation of regulatory, market-based, and voluntary programs to reduce pollutant emissions 

from mobile sources and fuels. Types of mobile sources addressed include: light-duty vehicles 

and engines (cars, light-duty trucks, sport utility vehicles); heavy-duty engines (buses, large 

trucks); nonroad vehicles/engines (construction, farm equipment, locomotives, marine); and 

fuels (diesel, gasoline). The strategy for reducing emissions from mobile sources includes four 

elements. 

• Clean Vehicles: Develop, implement and ensure compliance with stringent emission 

standards for cars, light-duty trucks, sport utility vehicles, buses, large trucks, and 

nonroad vehicles/engines. 

• Clean Fuels: Implement cleaner gasoline and diesel fuel regulations and develop 

reformulated gasoline, diesel fuel, and non-petroleum alternatives. 

• Clean Transportation Alternatives: Develop strategies to encourage transportation 

alternatives that minimize emissions and address continued growth in vehicle miles 

travelled (VMT). 

• Clean Technology: Work with industry to certify low emission vehicles that use new 

engine technologies, such as clean diesel, exhaust gas recirculation for diesel, new 

catalyst technology, fuel cells, and hybrid-electric vehicles. Continue in-house 

assessment and development of clean engine and fuel technologies and conduct 

technology reviews to evaluate progress toward implementation of new vehicle and 

engine standards. 

Final FY 2010 Technical Guidance — April 28, 2009 11
FY 2010 Priorities

• Promulgate final rule for renewable fuel standards requirements (RFS2).

• Promulgate final rule reducing GHG emissions from light-duty and heavy-duty vehicles.

• Complete the EPAct Testing Program (multi-year testing program started in 2007-2008) 

aimed at evaluating the fuel impacts of renewable fuels. 

o Apply the results of the EPAct testing program to update the fuel effects model 

used to support regulations.

o Develop new fuel and/or vehicle regulations to mitigate any adverse impacts on 

air quality resulting from the renewable fuel volumes required under EISA.

• Develop a proposal for a national Low Carbon Fuel Standard. 

• Promulgate final rule reducing emissions from large commercial ships and establish 

standards for US Emissions Control Area (ECA).

• Promulgate final rule establishing OBD requirements for nonroad diesel engines.

• Continue to implement manufacturer-run in-use compliance program for highway heavyduty diesel engines and promulgate in-use compliance program for nonroad diesel 

engines. 

• Propose new harmonized test cycle for highway motorcycles and light duty vehicles in 

accordance with the international Group of Experts on Pollution and Energy (GRPE) 

agreement. 

• Continue to implement the 2007-2010 heavy-duty standards, nonroad diesel standards, 

low sulfur fuel requirements, fuel-related provisions in the mobile source air toxics rule, 

and renewable fuel requirements. 

• Promulgate new jet aircraft engine emission standards that would align federal rules with 

the International Civil Aviation Organization standards and propose other controls and 

program upgrades under CAA authority. 

• Promulgate rule (in response to court remand) justifying or updating the 2012 model year 

standards for snowmobiles. 

• Promulgate rule controlling lead in aviation gasoline and its use in piston engines. 

• Assess the need for stricter off-cycle standards for light-duty vehicles and evaluate if 

similar action is needed for heavy-duty vehicles. 

• Evaluation of in-use fuel economy data; this assessment will ensure that the test methods 

stay current with changes in vehicle technologies, driving behavior, and other factors. 

• Finalize initial on-road component and incorporate nonroad sources into new 

transportation emission model Motor Vehicle Emission Simulator (MOVES). 

• Regions assist nonattainment areas in preparing SIPs and assist with implementation of 

federally-required control strategies such as vehicle inspection/maintenance (I/M) and 

state fuel programs. 

FEDERAL SUPPORT FOR AIR QUALITY MANAGEMENT 

 The federal support program includes Headquarters and Regional Office non-financial 

support to state, tribal, and local air pollution control agencies for developing, implementing, and 

evaluating programs to implement the NAAQS and reduce regional haze. It also includes regular 

reviews of, revisions to, and establishing standards for the criteria pollutants; developing 

Final FY 2010 Technical Guidance — April 28, 2009 12
associated national guidance and outreach information for implementing these standards; and 

developing emission limiting regulations for specific categories of stationary sources. The 

federal support program also includes working with other federal agencies to ensure a 

coordinated approach, and with international governments to address sources of air pollutants 

that lie outside our borders but contribute to air quality degradation within the United States. 

Federal financial support is addressed under "State and Local Air Quality Management" and 

"Tribal Air Quality Management." 

 Over the next several years, we will continue to focus on implementing the current PM and 

ozone NAAQS, including the 1997 PM2.5 NAAQS, the 2006 revised 24-hour PM2.5 NAAQS, the 

1-hour ozone NAAQS (through anti-backsliding requirements) and the 1997 and 2008 8-hour 

ozone NAAQS. EPA plans to place greater emphasis on integrating across OAR programs, 

specifically as it relates to energy issues and air quality planning. EPA will provide opportunities 

for greater collaboration with states, tribes and other federal agencies in addressing these air 

quality problems and continued emphasis on innovative strategies to improve air quality, such as 

the Sustainable Skylines Initiative which integrates air quality planning with energy, 

transportation and land use. Through this process EPA will provide technical assistance to states 

on emission reduction measures for PM2.5 and ozone nonattainment areas. We will also be 

focusing on implementing the lead (Pb) NAAQS, which is of particular importance to areas with 

potential environmental justice concerns. 

 EPA will undertake rulemaking to address the DC Circuit Court’s concerns with CAIR. 

During the rulemaking process, EPA will continue to implement the current CAIR. Through the 

implementation process, EPA will ensure that CAIR is integrated with other NAAQS programs 

and the regional haze program and will determine the degree those programs may still rely on the 

emissions reductions from CAIR. 

 We will continue to work with states and local air quality and transportation agencies to 

implement transportation conformity regulations and to ensure the technical integrity of mobile 

source controls in SIPs. We will also assist states, tribes, and local governments in crafting 

strategies that accommodate growth and economic development while minimizing adverse 

effects on air quality and other quality-of-life factors. This may include strategies to integrate air 

quality management into land use, transportation, energy use, and community development 

plans. 

 We will continue to work with states, tribes, and local agencies to implement an integrated 

ambient monitoring strategy to refocus the existing air monitoring resources toward current data 

collection needs for ozone, PM, lead, regional haze, and air toxics. 

 We will continue to redesign our current emissions factor program for both criteria and air 

toxics pollutants to: (1) make the development of emissions factors more self supporting and 

open to fuller participation by external organizations; (2) increase the use of electronic means to 

standardize the development process, quantify the quality components, and streamline all aspects 

of emissions factors development and use; (3) make the emissions factors uncertainties and 

emissions quantification methodologies more transparent to users; and, (4) provide direction on 

the proper application of emissions factors consistent with non-inventory program goals 

Final FY 2010 Technical Guidance — April 28, 2009 13
including clearer guidance and direction on use of more direct quantification tools (e.g., 

emissions monitoring) in lieu of emissions factors. 

NAAQS – Priorities for FY 2010

Headquarters

• Provide annual air quality reports to Regions by June 1, 2009 and work with Regions to 

develop appropriate actions to bring new violating attainment areas into compliance with 

the NAAQS. 

• Work with Regions to determine if their 1997 PM2.5 nonattainment areas and the 1997 

moderate 8-hour ozone nonattainment areas have attained by their April 5, 2010 and June 

15, 2010 attainment dates respectively, and work with the Regions on a consistent 

approach for making determinations that areas attained by their attainment date, for 

making clean air determinations based on the Clean Data Policy, and for taking action to 

approve attainment date extensions and making findings of failure to attain as necessary. 

• Work with Regions to encourage and support innovative and voluntary projects (e.g., 

wood stove changeouts) to protect the public from the harmful effects of air pollution. 

• Continue to encourage and implement voluntary and partnership programs for the 

manufacture and labeling of cleaner and more efficient biomass fueled appliances, e.g., 

hydronic heaters and manufactured fireplaces. 

• Continue outreach to and education of public on ways to burn biomass more cleanly and 

efficiently. 

• Continue to work with financial experts to identify and develop tools, resources and 

programs for state, tribal, and regional authorities to implement innovative financial 

programs (e.g., low interest loans and supplemental environmental projects) to deliver 

financing options for wood stoves, wood hydronic heaters and other air emission sources. 

• Provide guidance, assistance and consultation throughout the designation process for the 

revised lead and 2008 8-hr ozone NAAQS. 

• Continue to coordinate and provide technical and policy guidance to the Regions on the 

ozone and PM2.5 implementation programs for the 1997 NAAQS and begin working with 

Regions on implementation of 2006 PM2.5 NAAQS. 

• Work with federal and state partners to address fire emissions impact on attainment of the 

NAAQS and the regional haze progress goals. 

• Expand air quality monitoring to additional areas with potential environmental justice 

concerns. 

• Improve analytical tools to assess environmental justice impacts of rulemakings. 

• Provide technical and policy guidance to Regions on implementing the lead NAAQS. 

• Begin work on 1997 8-hr ozone §110 (a)(2) infrastructure FIPs required by March 17, 

2010. 

• Begin work with regions to determine §110(a)(2) infrastructure SIP submittals for the 

2008 8-hour ozone, 2006 24-hour PM2.5 and lead NAAQS. 

• Work with Regions to determine if the extreme 1-hour ozone nonattainment areas have 

attained by their November 15, 2010 attainment date and work with them on a consistent 

approach for making determinations that areas attained by their attainment date, or 

making findings of failure to attain as necessary. 

• Review quarterly data, and monitor progress of CAFO monitoring study. 

Final FY 2010 Technical Guidance — April 28, 2009 14
• Review monitoring data and begin development of CAFO emission estimation 

methodologies. 

• Coordinate best management practice (BMP) studies with USDA for CAFO minimizing 

emissions. 

• Continue outreach and education of public and animal industry on CAFO air emission 

issues. 

• Explore/evaluate potential tools to develop the CAFO process-based model for emission 

estimates. 

• Provide technical direction to industry/academic groups conducting their own CAFO 

studies so their quality assurance and monitoring protocols will be consistent with the 

NAEMS. 

• Develop baselines for measuring air quality in areas with potential environmental justice 

concerns. 

• Improve analytical tools to assess environmental justice impacts of rulemakings. 

• Provide support on integrated and multi-pollutant air pollution planning activities. 

• Begin work on the regional haze FIPs required by January 2011. 

• Work with Regions on development and review of §185 fee programs. 

• Finalize required reviews of NO2 and SO2 primary NAAQS for health effects 

• Issue Notice of Proposed Rulemaking for NO2 /SO2 secondary NAAQS for welfare 

effects. 

Regions

• Review air quality reports and work with states to develop appropriate actions to bring 

new violating attainment areas into compliance with the NAAQS. 

• Take final rulemaking action within 18 months of receipt of any redesignation request. 

• Work with states and tribes to encourage and support innovative and voluntary emission 

reduction projects (e.g., wood stove changeout programs). 

• Track allowable and actual processing times for SIPs processed during the fiscal year and 

submit midyear and end-of-year reports to the National SIP Processing Workgroup. 

• Manage the processing of SIP revisions to ensure final rulemaking actions on all ozone 

and PM2.5 SIPs are completed consistent with the annual SIP processing goal. 

• Process voluntary and mandatory reclassifications for 8-hour ozone areas. 

• Coordinate with states, tribes, and local governments on designating initial nonattainment 

areas for revised 2008 8-hr ozone NAAQS and lead NAAQS. 

• Take final rulemaking actions on remaining 1997 PM2.5 and 1997 8-hr ozone NAAQS 

SIP submittals (e.g., RFP, attainment demonstrations). 

• Make attainment determinations for 1997 PM2.5 nonattainment areas with an April 5, 

2010 attainment date and 1997 8-hr ozone areas with a June 15, 2010 attainment date. 

• Issue clean air determination actions and grant one-year extensions, as appropriate, for 

1997 PM2.5 nonattainment areas with an April 5, 2010 attainment date. 

• Issue attainment determination actions for 1997 8-hour ozone nonattainment areas with a 

June 15, 2010 attainment date including mandatory reclassifications, clean air data 

findings, or one-year attainment extension date. 

• Coordinate with states and tribes on areas designated nonattainment for the 2006 PM2.5

NAAQS and begin assisting them to develop plans to attain the 2006 PM2.5 NAAQS. 

Final FY 2010 Technical Guidance — April 28, 2009 15
• Support state monitoring network and tribal implementation of lead and rural ozone 

monitors. 

• Assist states to develop and submit SIPs due for the 1997 8-hr ozone Subpart 1 

nonattainment areas that were reclassified to Subpart 2 

• Assist states to develop and submit 1997 8-hr ozone 110 (a)(2) infrastructure SIPs for 

regions to take final approval action before March 17, 2010 or begin work on required 

FIP. 

• Assist states to develop timely §110(a)(2) infrastructure SIP submittals for the 2008 8-

hour ozone, 2006 24-hour PM2.5, and 2008 lead NAAQS for submission in 2011. 

• Work with states to determine if the extreme 1-hour ozone nonattainment areas have 

attained by their November 15, 2010 attainment date. 

• Encourage voluntary and partnership programs for manufacture and labeling of cleaner 

and more efficient biomass fueled appliances. 

• Work with financial experts to identify and develop tools, resources and programs for 

state, tribal, and regional authorities to implement innovative financing programs (e.g., 

low interest loans and supplemental environmental projects (SEPs)) to deliver financing 

options for wood stoves, wood hydronic heaters and other air emission sources 

• Coordinate with states, tribes, and local governments on developing air quality 

forecasting for ozone and PM2.5 and public reporting (Enviroflash.info). 

Regional Haze – Priorities for FY 2010

Headquarters

• Continue to coordinate with Federal Land Managers and Regional Planning 

Organizations on regional haze issues. 

• Continue to coordinate with regions and provide technical and policy assistance on 

regional haze SIPs. 

Regions

• Manage the processing of SIP revisions to ensure final rulemaking actions on all regional 

haze SIPs are completed consistent with the annual SIP processing goal. 

Ambient Monitoring – Priorities for FY 2010 (NAAQS)

Headquarters

• Provide ambient air monitoring input to NO2 NAAQS final rulemaking, scheduled to be 

completed by January 22, 2010. 

• Provide ambient air monitoring input for the SO2 primary NAAQS review. EPA is 

planning a proposal by November 16, 2009, and a final by June 2, 2010. 

• Provide ambient air monitoring input to the NO2 and SO2 secondary standards NAAQS 

reviews. An ANPR for the SO2/NO2 secondary NAAQS is expected by August 2009, 

with a proposal by February 12, 2010, and a final by October 19, 2010. 

• Provide ambient air monitoring input to the carbon monoxide NAAQS review. EPA is 

planning for an ANPR by June 2010 and a proposal by October 28, 2010. 

• Provide ambient air monitoring input for the PM NAAQS review. EPA is planning for an 

ANPR by August 2010. 

• Provide implementation support for lead NAAQS monitoring. 

Final FY 2010 Technical Guidance — April 28, 2009 16
• Manage the national contracts for filter purchases. 

• Monitor timeliness and completeness on the national scale for EPA-supported monitoring 

and flag still-unresolved issues for regional office resolution. 

• Review data certification documentation and set certification flags on AQS data where 

certification/QA requirements have been met. 

• Complete Management System Reviews of at least two regional monitoring programs. 

• Publish/Prepare National report on precision and bias performance by 9/30/2010. 

• Coordinate with regions to ensure the independent QA of NAAQS monitoring sites. 

• Publish/prepare National report on 2009 and 2010 Performance Evaluation Program 

(PEP) and National Performance Audit Program (NPAP) findings within two months of 

each audit and overall by July 1, 2010. 

• Review and approve NCore monitoring stations. 

• Manage the national contract for laboratory analysis of filters for speciation including 

providing data to review by states and submitting data to AQS. 

• Complete Phase III of the carbon sampler changeover. This includes providing equipment 

and installation/training support at any remaining PM2.5 chemical speciation network 

(CSN) stations, via national contractor/vendor. 

• Award/manage interagency agreement with National Park Service for operation of 

IMPROVE monitors for regional visibility. Allow states and tribes to use this mechanism 

for IMPROVE-protocol sampling at other locations. 

• Review and approve/ disapprove requests for Federal Equivalent Methods (FEM) for 

continuous PM2.5 methods within 120 days of completed application, and similarly act on 

each first request for each Approved Regional Method (ARM). 

• Encourage, review and approve/disapprove requests for Federal Equivalent Methods for 

PM10-2.5 within 120 days of completed application. 

• Develop ambient monitoring portion of the FY2011 national program and grant guidance 

consistent with the national strategy, in collaboration with state, tribal, and local 

leadership and Regions, by April 2010. 

• Provide training support for NCore-needed precursor gas monitoring through workshops 

held at HQ in RTP and/or national conferences. 

• Propose and finalize (as appropriate) monitoring rule changes needed to support potential 

revisions to the NAAQS according to the 5-year review timeline. 

• Host next national ambient monitoring conference in partnership with the National 

Association of Clean Air Agencies. The conference expected to be held early in FY 2010 

(i.e., late calendar year 2009). 

Regions

• Identify and resolve completeness and timeliness issues with regard to quarterly data 

submission by monitoring agencies. 

• Evaluate submitters’ annual data certification requests and documentation and forward to 

HQ when adequate. 

• Review the evidence that state/local monitoring programs meet 40 CFR Part 58 

appendices A, C, D, and E as applicable (evidence is a required element in annual 

monitoring plans due July 1) and seek corrective action by monitoring agencies where 

needed. 

• Review requests for changes in state monitoring plans and act on them within 120 days. 

Final FY 2010 Technical Guidance — April 28, 2009 17
• Manage contracts for independent performance audits of state/local monitor networks 

(PEP and NPAP), for those states choosing that approach to independent audits (some 

regions only). 

• Perform Technical Systems Audits on 1/3 of reporting organizations, or as required to 

achieve an audit of each agency within a 3-year period. 

• Transfer State and Tribal Air Grant (STAG) funds to OAQPS for any additional 

state/tribal IMPROVE-protocol sites requested by state, tribal, or local agencies by May 

2010 for monitoring to begin/continue in July 2010. 

Title V and NSR – Priorities for FY 2010

Headquarters

• Continue to address Title V Task Force recommendations. 

• Support Regions in issuing permits and evaluating Title V and NSR permit programs. 

• Support and maintain Title V permit activity database (TOPS). 

• Support tribal efforts in developing Title V and NSR permitting programs and delegation 

requests. 

• Continue to assist Regions on NSR regulatory revisions and proposed regulations. 

• Continue to assist Regions in implementing the final regulations for permitting new and 

modified sources in Indian country. 

• Continue to modify existing NSR permit regulations, as necessary, to be consistent with 

the Agency’s “Clean Air” initiatives, and the ozone and PM NAAQS. 

• Prepare and issue final orders on citizen petitions based on drafts from Regions. 

• Provide training and technical guidance to Regions on final new regulations, as 

necessary. 

Regions

• Review proposed initial, significant modifications and renewal operating permits, as 

necessary, to ensure consistent implementation of the Title V program. 

• Report active Title V permits via TOPS and update all applicable TOPS data. 

• For purposes of updating TOPs, report outstanding renewals of Title V permits (permits 

older than 5 years that have not been renewed). 

• Issue Title V permits to respond to objections when permitting authority refuses to act. 

• Continue working on completing, per agreed upon schedules, remaining first-round Title 

V program evaluations pursuant to March 2002 OIG report. 

• Prepare draft orders to citizen (public) petitions based upon OAQPS’ petition handling 

process. 

• Perform 1/4 of follow-up Title V program evaluations for programs with at least 20 

permits pursuant to February 2005 OIG report and set target to issue evaluation report 

within the fiscal year. 

• Issue PSD and Part 71 permits in Indian country. 

• Continue to assist permitting authorities on NSR regulatory revisions and proposed 

regulations. 

• Evaluate NSR permit programs, as warranted and set target to issue reports within 120 

days of evaluation. 

Final FY 2010 Technical Guidance — April 28, 2009 18
• Provide training and technical guidance and support to permitting authorities and the 

public, as necessary. 

• Take action on all NSR SIPs/TIPs submitted in FY 2007 and FY 2008. 

• Continue issuance of Title V permits on tribal and other federal lands, as necessary. 

• Review major NSR/PSD permits for new and modified sources, as necessary, to ensure 

consistent implementation of the NSR program. 

• Provide End of Year Regional Progress Report for status of EPA review of NSR permits. 

Mobile Sources – Priorities for FY 2010

Headquarters

• Work with Regions to assist states in developing, implementing, and transitioning I/M, 

OBD, and fuel programs. 

• As necessary, assist Regions in processing conformity determinations made by 

metropolitan planning organizations or state agencies. As necessary, assist Regions in 

making adequacy determinations for identified mobile source budgets in control strategy 

SIPs and maintenance plans submitted by states. 

Regions

• Assist states in developing, implementing, and transitioning mobile source control 

strategies such as I/M, OBD, and state fuel programs. 

• Assist state and local agencies in evaluating and promoting public comprehension of the 

need to maintain vehicles when OBD light is illuminated. 

• Assist states and local air quality and transportation agencies in future conformity 

determinations as needed. 

• Review and comment on transportation conformity determinations made by metropolitan 

planning organizations or state agencies. 

• Complete processing of transportation conformity SIPs submitted by states in FY 2009 as 

necessary. 

• Make adequacy/inadequacy determinations, as necessary, for identified mobile source 

budgets included in control strategy SIPs and maintenance plans submitted by states 

and/or approve/disapprove such budgets at the time of SIP processing. 

• Work with OTAQ to provide training in the use of the Motor Vehicle Emission Simulator 

(MOVES) model, and review modeling results for state and local agencies. 

• Work with states to develop creditable mobile source programs.

FEDERAL SUPPORT FOR AIR TOXICS PROGRAMS 

 The federal support program includes Headquarters and Regional Office non-financial 

support to state, tribal, and local air pollution control agencies for: modeling, inventories, 

monitoring, assessments, strategy and program development; community-based toxics programs; 

voluntary programs including those that reduce inhalation risk and those that reduce deposition 

to water bodies and ecosystems; voluntary efforts to address emissions from the 11 million 

existing diesel engines that are not subject to the new, more stringent emission standards that 

took effect in 2007 and later; international cooperation to reduce transboundary and 

Final FY 2010 Technical Guidance — April 28, 2009 19
intercontinental air toxic pollution; National Emissions Inventory (NEI) development and 

updates; and, Persistent Bioaccumulative Toxics (PBT) activities. It also includes training for air 

pollution professionals. In addition, it includes activities for implementation of MACT, Residual 

Risk, and Area Source standards and the National Air Toxics Assessment (NATA) and the 

National Air Pollutant Assessment (NAPA). Our strategy has five components: 

• Work with partners to improve the technical specifications and procedures for the 

National Air Toxics Trends Stations (NATTS) ambient monitoring network, to support 

short-duration local-scale (also known as community-scale) monitoring studies, and to 

develop improved emission factors. (Federal funding support for the NATTS network 

and local-scale monitoring studies is addressed under the State and Local Air Quality 

Management section below.) 

• Implement a residual risk program and support community assessment and risk reduction 

projects, and compile and analyze the information collected from them to better 

characterize risk and assess priorities for further action. 

• Provide technical expertise and support to state, tribal, and local air toxics programs in 

assessing and reducing major stationary source, area source, and mobile source air toxics. 

• Continue to develop and improve risk assessments and management methodologies. 

• Innovative approaches in addition to regulatory efforts that will achieve emission 

reductions. These approaches include, but are not limited to, wood smoke education and 

woodstove changeout programs that reduce indoor and ambient exposure to air toxics, 

emission reductions from the existing diesel fleet not subject to new emission standards, 

a collision repair campaign to reduce air toxics emissions from the auto body repair 

industry, the Sustainable Skylines Initiative, and partnership programs for the 

manufacture and labeling of cleaner biomass-fueled appliances. 

• Work with communities through EPA’s Communities for a Renewed Environment 

(CARE) program and other local efforts to address environmental justice issues that are 

associated with disproportionate exposure to air toxics. 

 EPA activities that assist in the toxics reduction strategy include the NEI, NATA, NAPA, air 

quality modeling, the National Clean Diesel Campaign (NCDC), and data analysis programs. In 

addition, the Air Toxics Monitoring Program indirectly and in some cases directly supports all 

the technical tools as well as the programs noted above. 

Air Toxics Implementation – Priorities for FY 2010

Headquarters

• Finalize development of new NEI process and Emission Inventory System (EIS) in 

preparation for 2008 NEI. 

• Collaborate with Regions, states, tribes, and local governments on the development of the 

new NEI process and the EIS. 

Final FY 2010 Technical Guidance — April 28, 2009 20
• Work with Regions to determine the focus for community air toxics programs in support 

of the Urban Air Toxics Strategy (UATS) and CARE. 

• Continue development of tools and guidance for communities. 

• Work with Regions to assist states, tribes, and local governments to develop and 

implement voluntary air toxics programs that address outdoor, indoor, and mobile 

sources, including areas near schools and areas with potential environmental justice 

concerns. 

• Work with Regions to encourage and support innovative and voluntary projects to assess 

and address sources of air toxics, including areas near schools and areas with potential 

environmental justice concerns. 

• Develop baselines for measuring air quality in areas with potential environmental justice 

concerns. 

• Undertake biannual assessments of the environmental benefits being achieved in 

environmental justice areas as a result of diesel emission reduction programs. 

• Continue to oversee and approve qualification of Phase 2 for OWHH. 

• Continue to implement the Sustainable Skylines Initiative by working with existing cities 

as well as adding additional cities to the initiative. 

• Continue to implement partnership programs for biomass fueled appliances, e.g., 

hydronic heaters, low-mass fireplaces. 

• Continue to work with financial experts to identify and develop tools, resources and 

programs for states, tribal, and regional authorities to implement innovative financing 

programs (e.g., low interest loans and SEPs) to deliver financing options for wood stoves, 

wood hydronic heaters and other air emission sources. 

• Continue to redesign our emission factors program as described under “Federal Support 

for Air Quality Management.” 

Regions

• Review new NEI process and EIS components and assist states, tribes, and local 

governments with similar reviews. 

• Provide feedback to headquarters on new NEI process and EIS components. 

• As appropriate, work with headquarters in developing flexible and risk-based programs. 

• Assist states, tribes, and local governments where appropriate in conducting data analysis 

and assessment for air quality management implications in general. (Applicable to states 

conducting air toxics monitoring regardless of funding source.) 

• Work with states and local and tribal governments to develop and implement area source 

programs. 

• Delegate and provide implementation assistance to states, tribes, and local governments 

for section 111, 112, and 129 standards, as needed. 

• Implement section 111, 112 and 129 standards, including Federal 111(d)/129 plans, in 

areas where states do not. 

• As appropriate, provide assistance, data, and information to HQ in order to help facilitate 

revisions/amendments to section 111, 111(d), 112 and 129 rules and associated Federal 

Plans. 

• As appropriate, assist HQ in development of area source standards. 

• Assist HQ in determining the focus for community air toxics programs in support of the 

UATS and CARE, where appropriate. 

Final FY 2010 Technical Guidance — April 28, 2009 21
• As appropriate, participate in residual risk analyses for MACT and/or GACT standard 

source categories, and standard setting process. 

• Work with states, tribes, and local governments on establishing infrastructure to 

implement a risk based air toxics program that focuses on sensitive populations (e.g., 

near schools and areas with potential environmental justice concerns). 

• Work with communities (e.g., CARE communities/projects) to assess and address 

sources of air toxics, including the use of voluntary air toxic reduction programs in their 

communities, particularly those areas with potential environmental justice concerns. 

• Provide training to states, tribes, and local governments on air toxics program 

requirements. 

• Work with states, tribes, and local governments to implement their risk-based air toxics 

program. Specifically, assist states, tribes, and local governments to: 1) implement a 

residual risk program, and 2) assess and address the combined impact of multiple sources 

of air toxics, encouraging voluntary reductions of air toxics from indoor and outdoor 

sources, as appropriate.

• Continue to oversee the state effort to adopt state rules for hydronic heaters and support 

voluntary programs for biomass appliances.

• Work with financial experts to identify and develop tools, resources and programs for 

states, tribes, and regional authorities to implement innovative financing programs (e.g., 

low interest loans and SEPs) to deliver financing options for wood stoves, wood hydronic 

heaters and other air emission sources. 

• Work with HQ to implement the Sustainable Skylines Initiative by providing support to 

cities under the initiative.

Air Toxic Monitoring – FY 2010 Priorities

Headquarters

• Transfer 103 funds for NATTS grants to affected regional offices. 

• Manage national contract for NATTS lab analysis. 

• Conduct Proficiency Testing and Technical System Audits for national contract lab and 

state/local labs servicing NATTS, and report results within 60 days of audit after 

opportunity for state/local lab review of draft audit report. 

• Provide national/regional-scale analysis of currently available air toxics data by 

September 2010, with conclusions relevant to air quality management and to establishing 

future goals for the NATTS program and other monitoring initiatives. 

• Hold National Air Toxics Data Analysis Workshop by end of 2010. 

• Monitor NATTS data submissions for completeness and timeliness. 

• Conduct a grant competition for community scale air toxics ambient monitoring projects; 

upon completion, transfer the STAG 103 funds for selected projects to affected regions. 

• Provide guidance to Regions for negotiation of individual grants to ensure that data meets 

risk screening, risk characterization, and/or risk assessment requirements where 

appropriate given study objectives that were material in selecting the project for funding. 

• Provide mechanism for optional participation in Proficiency Testing and Technical 

System Audits by labs which are not direct NATTS participants. (Cost would be borne by 

the state/local lab.) 

Final FY 2010 Technical Guidance — April 28, 2009 22
• Provide tools and guidance for analyzing local air toxics data for air quality management 

implications. 

• Review Technical Assistance Document and update if appropriate. 

Regions

• Ensure NATTS work plans are consistent with program office template guidance. 

• Ensure NATTS QAPP is adequate to provide quality data for submission to AQS. 

• Participate in at least 50% of NATTS TSA lab and field site audits. 

• Track status and coordinate needed follow-up actions between the program office and 

states, tribes, and local agencies in support of the NATTS QA program (e.g., TSA and PT 

activities). 

• Identify and resolve completeness and timeliness issues with regard to quarterly data 

submission by monitoring agencies. 

• Award the community scale air toxics ambient monitoring grants, as applicable. 

• Assist states, tribes, and local governments in siting, installing, and operating new and 

upgraded toxic monitoring equipment for community scale grant projects. 

• Review QA programs and ensure compatibility of community scale air toxics 

measurements across projects and with NATTS, where appropriate. 

• Ensure community scale QAPP is adequate to provide quality data for submission to 

AQS and/or ensure that the project results meet the requirements of the approved QAPP. 

• Assess and review existing air toxics networks, and assist states, tribes, and local 

agencies in siting, installing, and operating new and upgraded toxic monitoring 

equipment. 

• Ensure QAPP is adequate to provide quality data for submission to AQS. 

STATE AND LOCAL AIR QUALITY MANAGEMENT 

 The state and local air quality management program includes funding to assist state and local 

air pollution control agencies in developing and implementing programs to attain and maintain 

the national ambient air quality standards (NAAQS) and to assess, prevent and control air 

pollution such as hazardous air pollutants. The program also provides funding to interstate 

transport commissions, and other multi-jurisdictional organizations (composed of state and local 

representation) to help coordinate air quality improvement efforts. Funding is also provided on a 

competitive basis to reduce diesel emissions from the existing diesel fleet and from school buses 

through the National Clean Diesel Campaign through a separate appropriation under the Energy 

Policy Act of 2005. State and local agencies also maintain Title V operating permit programs for 

major stationary and other sources, but Title V activities are funded through permit fees and are 

not grant-eligible. Conversely, Title V permit fees should not be used to fund grant-eligible 

activities. 

 State, tribal, and local grant assistance is appropriated by Congress under the Agency’s State 

and Tribal Assistance Grants (STAG) appropriation. State and local air programs are funded 

under §105 of the Clean Air Act (CAA) with recipient agencies providing matching resources at 

no less than 40% of the total approved §105 program costs. Section 103 of the Act provides 

100% federal funding to state, multi-jurisdictional, and local entities, including universities and 

Final FY 2010 Technical Guidance — April 28, 2009 23
other non-profits, to conduct studies, investigations, experiments, demonstrations, surveys, 

training, and certain forms of research, on the nature, prevention, causes and effects of air 

pollution. Eligibility for some grants awarded under §103 authority may be limited to certain 

types of applicants pursuant to specific conditions outlined in EPA’s enacted budget and/or as 

directed by Congressional appropriation. Interstate air pollution control agencies, including 

interstate transport commissions, receive funds under §106 which also requires a recipient 

match. Additional information on the use of STAG resources is contained in Appendix A. 

Strategy

 EPA’s strategy for achieving clean outdoor air includes a comprehensive, multi-pollutant 

approach that combines national, regional, and local measures with responsibilities for 

implementation carried out by the most appropriate and effective level of government. Problems 

with broad national or global impact are best handled at the federal level. State, tribal, and local 

agencies can best address regional and local problems that remain after federal measures are 

applied. In implementing the state and local air quality management component of this strategy 

EPA will: 

• Work with state, local, and other governmental partners to target available STAG 

resources to those air pollution problems which pose the greatest risk to public health 

(e.g., fine particles, ozone, and hazardous air pollutants); 

• Allocate resources to address not only the attainment of PM2.5 and 8-hour ozone 

NAAQS, but also support ongoing state and local air program operations and delegated 

programs which help maintain healthy air quality; 

• Encourage support for regional and community-scale strategies that complement the 

impacts of federal measures (e.g., action day programs, air quality reporting, early ozone 

reductions, wood smoke reduction programs, diesel retrofits and other mobile source 

initiatives, integrated air toxics risk assessment and reduction projects); 

• Provide support to assist states, tribes, and local agencies to develop air quality 

forecasting programs, especially the addition of forecasting particle pollution. 

• Encourage the use of Enviroflash to communicate air quality alerts to the public; 

• Target significant resources to recipients to develop, refine, and maintain monitoring 

systems and emission inventories which help provide a clear picture of the nature and 

sources of air pollution and help gauge the impacts of preventive and mitigative measures 

employed; 

• Support the efforts of states and multi-jurisdictional organizations (MJOs) to develop 

information and strategies for use by states and tribes in reducing haze and improving 

visibility across the country, including formerly pristine areas; 

• Provide resources that focus on transboundary or binational, geographically-specific 

environmental issues involving a multi-pollutant, multi-state, and sometimes a multimedia approach; 

• Provide support for training and other associated program support to assist state, local, 

multi-state, and other agencies in addressing their air pollution problems; 

• Provide training and technical support to assist states, tribes, and local agencies in 

developing and conducting wood boiler and wood stove changeout programs to reduce 

particle pollution; to implement a clean burning education campaign; and, 

Final FY 2010 Technical Guidance — April 28, 2009 24
• Provide resources to eligible entities to support diesel engine retrofits, rebuilds and 

replacements, and idling reduction technologies that target reductions from the existing 

diesel fleet. 

 Inherent in these efforts is EPA’s policy to ensure that collaborative and timely consultation 

occurs with its partners in the areas of planning, priority-setting, and budgeting. It is the policy 

of OAR and the Regions to seek prior consultation with partners on the allocation and use of 

grant resources. EPA will continue to work with the Environmental Council of States (ECOS), 

the National Tribal Operations Committee (NTOC), the National Tribal Air Association 

(NTAA), and the National Association of Clean Air Agencies (NACAA) to identify and resolve 

issues associated with the purposes, distribution and use of grant resources. 

 EPA continues to place high priority on effective grants management including proper use of 

authorities for award, effective use of competition where appropriate, articulation and reporting 

of programmatic and environmental results, and effective oversight of agreements including 

compliance with programmatic terms and conditions. More information on specific grant 

priorities and critical grant management topics is contained in Appendix A. 

NAAQS – Priorities for FY 2010

States should: 

• Review air quality reports and take appropriate actions to eliminate future violations in 

attainment areas that violate any of the NAAQS. 

• As appropriate, submit redesignation requests including maintenance plans for areas with 

clean air quality data. 

• Work with local area stakeholders to support innovative, voluntary, early action 

initiatives such wood smoke reduction programs. 

• All state/local primary quality assurance organizations submit NAAQS pollutant data, 

PAMS, and QA data to AQS directly or indirectly through another organization 

according to schedule in 40 CFR Part 58. 

• Continue to implement SIPs for 1997 PM2.5 and ozone NAAQS. 

• Submit any outstanding PM2.5 and ozone SIP elements. 

• Consult with EPA as necessary to finalize area designations on revised 2008 ozone and 

lead NAAQS. 

• Implement NOX and SO2 Requirements under CAIR. 

• Begin planning for 2006 PM2.5 NAAQS SIPs due no later than 2013. 

• Work with local agencies to implement woodstove changeout/hydronic heater programs 

and wood smoke education campaigns in areas where changeouts could significantly 

reduce ambient particle concentrations. 

• Explore feasibility of changing out existing outdoor wood-fired boilers to significantly 

reduce PM2.5 concentrations. 

• Begin to integrate nontraditional planning (e.g. land use, transportation, and energy) into 

air quality management. 

Final FY 2010 Technical Guidance — April 28, 2009 25
Regional Haze – Priorities for FY 2010

States should:

• Continue to work with Regions on issues related to submitted regional haze SIPs. 

• Implement BART requirements. 

• Submit any outstanding regional haze SIP elements. 

NAAQS Ambient Monitoring – Priorities for FY 2010

 Regions should work with states to ensure that state monitoring networks for NAAQS, 

PM2.5speciation and PAMS meet applicable regulatory and guidance requirements. This includes 

the following specific actions: 

• Implement lead monitoring at near-source locations, where required by January 1, 2010. 

• Plan to implement lead monitoring at non near-source locations as part of each state’s 

annual monitoring network plan due to EPA by July 1, 2010. 

• Revise the ozone monitoring season in each state’s network, if required, in time for the 

start of the 2010 ozone monitoring season. 

• Submit 2011 annual network plan required by 40 CFR § 58.10, by July 1, 2010 unless 

another schedule has been approved (state/local only, unless tribal work plan 

requirement). The plan should provide for the movement or start-up of additional ozone 

monitoring stations associated with smaller urban areas and non-urban areas, if required. 

• Operate monitors for other NAAQS pollutants, PM2.5 speciation, and PAMS according to 

40 CFR Part 58, approved monitoring plans, and/or grant agreements including QMPs 

and QAPPs. 

• Submit NAAQS pollutant data, PAMS, NCore and QA data to AQS according to 

schedule in 40 CFR Part 58. 

• Certify 2009 NAAQS pollutant data in AQS and provide supporting documentation by 

July 1, 2010 (state/local only, unless tribal work plan requirement). 

• Ensure adequate, independent QA audits of NAAQS monitors, including PEP and NPAP 

or equivalent (state/local only, unless tribal work plan requirement). 

• Conduct monthly QA checks for flow rates of PM2.5 speciation monitors and submit data 

quarterly to AQS. Target is for 75% completeness. (state/local only, unless tribal work 

plan requirement). 

• Complete the changeover to IMPROVE-style carbon samplers at PM2.5 speciation trends 

and supplemental site (state/local only). 

• Report real time ozone and PM2.5 data to AirNOW for cities required to report the AQI 

(state/local only). 

• Complete the first 5-year-cycle network assessment required by July 1, 2010 (state/local 

only, unless tribal work plan requirement). 

• Implement remaining measurements associated with NCore so that each station is ready 

for full operation by January 1, 2011. 

Final FY 2010 Technical Guidance — April 28, 2009 26
Toxics Ambient Monitoring – Priorities for FY 2010

 Regions should work with states to ensure NATTS sites are operated according to EPA's 

technical guidance and the QAPP and QMP. This includes the following specific actions: 

• Operate NATTS sites according to national technical guidance and the QAPP and QMP. 

• Participate in inter-laboratory Proficiency Testing and Technical System Audit programs 

according to national guidance and the approved QAPP and QMP (state/local only). 

• Submit NATTS data to AQS quarterly, within 120 days of end of each quarter. The data 

objective for completeness rate is 85% of the potential concentration values for each 

quarter (state/local only). 

• Conduct federally-funded community assessment projects consistent with grant terms 

(including schedule), technical guidance, and QAPP and QMP (state/local/tribal). 

• Submit data from federally-funded community monitoring projects to AQS quarterly, 

within 120 days of end of each quarter. The data objective for completeness rate is 85% 

of the potential concentration values for the study period (state/local/tribal). 

• Perform and publish/post local-scale monitoring data analyses in federally-funded 

community scale project plans (state/local/tribal). 

• Recipients of the Community Scale Air Toxic Ambient Monitoring grants shall present 

their findings at the National Air Toxics Data Analysis Workshop (state/local/tribal). 

• Operate study sites based on the terms of QAPP and QMP (state/local/tribal). 

• Submit data to AQS quarterly. The target data completeness rate is 85% of the potential 

concentration values submitted within 120 days of end of each quarter (state/local/tribal). 

Title V and NSR – Priorities for FY 2010

• Ensure sources submit Title V applications for renewal. 

• Provide timeliness data on new title V permits and significant permit modifications to 

EPA Regional Offices for entry into TOPS. 

• Continue to issue initial permits, significant modifications, and renewal Title V permits 

and reduce backlog of renewal permits. 

• Cooperate with EPA in Title V permit program evaluations, set target to respond within 

90 days to EPA’s evaluation report and implement recommendations as warranted. 

• Issue new Title V permits and significant permit modifications within 18 months of 

application completeness determined by permitting authority. 

• Issue 78 % of major NSR permits within one year of receiving a complete permit 

application. 

• Issue NSR permits consistent with CAA requirements and enter BACT/LAER 

determinations in the RBLC. 

• Provide timeliness data on NSR permits issued for new major sources and major 

modifications by entering data including “the application accepted date” and “the permit 

issuance date” in to the RBLC national database. 

Final FY 2010 Technical Guidance — April 28, 2009 27
Air Toxics – Priorities for FY 2010

• Quality assure, validate, and revise NEI facility data using EIS components. 

• Collect data for the integrated 2008 HAP emissions inventory. 

• Implement delegated or approved section 112, 111(d) and 129 standards, as appropriate, 

for major sources and area sources. 

• Implement delegated residual risk standards. 

• Work with communities to develop and implement voluntary air toxics programs that 

address outdoor, indoor, and mobile sources with emphasis on areas with potential 

environmental justice concerns. 

TRIBAL AIR QUALITY MANAGEMENT 

 The national Tribal Air Quality Management Program includes funding for Indian tribes and 

Tribal Air Pollution Control Agencies, as well as providing training and support for tribes with 

typically small staffs and limited resources. Through CAA §103 grants, tribal air pollution 

control agencies, among others, may conduct and promote research, investigations, experiments, 

demonstrations, surveys, studies and training related to air pollution. Tribes typically use this 

funding source to research and investigate the air quality within, and emissions sources affecting, 

lands within their jurisdiction. Through CAA §105 grants, tribes may develop and implement 

programs for the prevention and control of air pollution or for the implementation of national 

primary and secondary ambient air quality standards, permit programs, and delegated federal 

programs like Part 71 and MACT standards. Tribes have the authority to set standards and 

develop additional programs to meet their unique needs. This authority is grounded in the CAA 

and the Tribal Authority Rule, as well as their inherent sovereign authority. For detailed grant 

guidance see Appendix A. 

Strategy

 EPA is committed to work with the tribes, our regulatory partners, to assist them in 

understanding their air quality, completing air quality assessments setting appropriate air quality 

goals, and developing air quality management programs where appropriate to meet those goals. 

The completion of air quality assessments in Indian country is achieved through a combination 

of training and technical support of tribal staff in areas such as conducting assessments, source 

characterizations, emission inventories, monitoring programs, modeling, and other analyses, as 

appropriate. At the same time, work continues to improve and facilitate tribal participation in the 

policy and programmatic aspects of the national air quality management program. As tribes gain 

experience, they are then better able to address their air quality concerns, and enhance their 

overall program development and participation. EPA is committed to supporting the National 

Tribal Air Association (NTAA) as a leadership and coordination organization, working to 

promote relationships between and amongst tribes and EPA. NTAA serves an important role in 

facilitating tribal involvement in EPA policy and regulatory development. 

 EPA is also committed to building tribal capacity, where appropriate, to implement—either 

directly through tribal regulations and Tribal Implementation Plans (TIPs), Title V programs, or 

as partners in implementation of applicable Federal Implementation Plans (FIPs)—CAA 

Final FY 2010 Technical Guidance — April 28, 2009 28
protections for human health and the environment for federally-recognized tribes. A primary 

mechanism for this priority is to fund the Institute for Tribal Environmental Professionals (ITEP) 

in its role as a leader in tribal air quality training and technical support. The ITEP program 

provides an internationally-recognized curriculum, developed especially for the unique needs of 

Indian country. This program has been instrumental in assisting tribes in developing the 

necessary skills to start and implement air quality management programs for their reservations. 

ITEP and EPA together implement the Tribal Air Monitoring Support (TAMS) Center. 

 Tribal STAG funds are allocated to tribes through each regional office (except Region 3 

which has no federally-recognized tribes) based on a formula that includes a number of factors 

such as tribal population, number of tribes, nonattainment areas, and number of Title V sources. 

Regional offices then allocate funds to tribes based on additional factors related to risk, 

environmental goals, and tribal capacity. EPA STAG funding in recent years has been unable to 

provide grants to every tribe requesting support, so this methodology allows funding decisions to 

be made in a nationally-consistent manner while seeking to maximize the local environmental 

benefit. 

 OAR supports many tribal efforts to understand and address air quality, and many tribes 

include monitoring and emission inventory programs in their activities. OAR provides funding to 

approximately 80 tribes to monitor a variety of pollutants of concern to them, and many tribes 

have provided an exemplary level of reliability and data capture in operating monitors of every 

type. In addition, 36 tribes have completed emissions inventories to help determine potential air 

quality and programmatic concerns for their tribe. To continue the effectiveness and relevancy of 

these tribal programs, OAR expects the regional offices and tribes to jointly determine where 

and why monitoring or emissions inventory development is necessary, while OAR provides 

technical assistance through the Tribal Air Monitoring Support (TAMS) Center. 

 EPA’s strategy is to provide flexibility for tribes and regional offices to address the many 

different air quality situations on tribal lands on a case-by-case basis, rather than setting goals for 

tribes at the national level. Ambient air monitoring often, but not always, will be an appropriate 

one-time or continuing element of a tribal air quality assessment and management program. 

Section II of Appendix A of this document provides revised interim guidance to help tribal and 

regional office staff achieve clarity on the objectives of monitoring efforts. 

 Many (but not all) tribes regularly upload their monitoring data to AQS, where the data can 

be used by EPA to verify accomplishment of grant work plans and by interested parties to 

understand the air quality situation of the particular tribe. While recognizing the sensitivity of 

tribes to the use of their data, OAR expects tribal grants awarded in FY 2009 to include a 

commitment for quality-assured monitoring data to be submitted (directly by the tribe or other 

agreed arrangement) on a timely basis to AQS or other national database (e.g., AQS is not able 

to directly receive the data from the CASTNET or IMPROVE networks at this time). OAQPS is 

available to join the regional offices in pre-award consultations with any tribes where issues of 

data ownership and submission of data are of concern. EPA also encourages tribal participation 

in AirNow, but this should not be a condition required in the grants. 

 In FY 2010, attention should continue to be paid to the quality aspects of tribal air monitoring 

programs. Every new or renewed grant supporting ambient monitoring on tribal lands should 

Final FY 2010 Technical Guidance — April 28, 2009 29
require preparation and regional office approval of Quality Management Plans (QMPs) and 

Quality Assurance Project Plans (QAPPs) that clearly identify the purposes to be served by the 

monitoring. OAR has worked with the regions and monitoring organizations to develop a graded 

approach for the development of these documents. The QAPP should provide that tribal 

monitoring include regular precision and accuracy checks, using Appendix A of 40 CFR Part 58 

as general guidance, unless other quality assurance procedures are justified as more appropriate 

to the monitoring objectives. Data reporting to AQS should include reporting of the precision 

and accuracy check results. The TAMS Center provides training on these QA aspects of 

monitoring programs and has developed Turbo-QAPP software approved for use by OAQPS. 

Tribal QAPPs developed using this software should be generally approvable. 

Many tribes are very concerned about climate change and its impact on federally-recognized 

tribes. Tribes often are the first to experience the impact of climate change and are generally less 

able to address it than state, local agencies or the private sector, which have more resources. In 

FY 2010, attention should be given to help tribes participate in the development of climate 

change legislation, policy, or regulation. Attention should be paid, not only to mitigation issues, 

but also the special needs of tribes in adaptation. EPA will provide pilot project grants called 

Sustainability for the Seventh Generation to help tribes address air quality, climate change, and 

sustainability by encouraging the integration of land use, energy, transportation, and air quality 

planning activities. 

 Our strategy includes specific funding to support tribal interest in air toxics. Tribes have 

started to increase their participation in air toxics issues, but are limited by availability of 

funding and resources to assess the level of impact and risk. However, tribes continue to be 

concerned about toxics, and often have disproportional impacts due to subsistence activities and 

lifestyles. This is particularly true where local problems may be caused by local and regional 

sources such as residential wood smoke, industrial facilities, and mobile sources. This also 

applies to toxic deposition and bioaccumulation of persistent bioaccumulative toxins, such as 

mercury, dioxin and PCBs. The 229 Alaska Native Villages, many of whom rely on traditional 

subsistence lifestyles, have expressed particular concern over local and international toxics, and 

Arctic peoples are known to suffer disproportionately high exposures to these toxic and 

persistent compounds. 

 Finally, to enhance the visibility of the OAR Tribal Program and to further integrate tribal 

issues and concerns into EPA’s daily programmatic activities, regions should, where appropriate, 

provide the tribes with the funding assistance necessary for reasonable participation in national 

level conferences, meetings, and planning activities. For example, there are several national 

conferences on topics such as monitoring, emission inventories, quality assurance, and data 

analysis. There are also a number of strategic planning efforts underway under the auspices of 

the Clean Air Act Advisory Committee that could benefit from consistent and meaningful tribal 

participation. Such provisions should be added, as appropriate, to the tribal grant workplans. 

FY 2010 Priorities

Headquarters

• Provide support to tribes and Regions for completion of emissions inventories and their 

submission to the Emissions Inventory database. 

Final FY 2010 Technical Guidance — April 28, 2009 30
• Provide training and technical support to tribes for air quality assessment and monitoring, 

including submission of quality assured data into the AQS system. 

• Work with Regions to provide air quality outreach and training events to tribal staff, as 

appropriate. 

• Provide grant and staff support to national tribal organizations to support effective tribal 

participation in policy development. 

• Provide grant and staff support for training on national CAA policy issues. 

• Invite tribes to participate in policy development and implementation workgroups. 

• Support training for tribes on the SIP process. 

• Provide meaningful notice and access to tribes for participation in rule or program 

development. 

• Support training for tribes on the TAS and TIP processes. 

• Support Regional Office FIP efforts. 

• Promulgate the tribal NSR rule. 

• Provide support for toxics training and outreach events to tribes and other opportunities 

for tribes to participate in air toxics reduction efforts. 

• Provide support for training to tribes on voluntary programs. 

• Provide support for tribal efforts to understand, assess, and respond to indoor air 

concerns on reservations. 

• Work with Regions to assist interested tribes in implementing voluntary emission control 

retrofit programs for existing heavy-duty diesel engines/school buses and wood 

stove/hydronic heater changeout programs. 

• Continue to support tribes and Regions with information and training to address wood 

smoke emissions, both indoors and out. 

• Continue to maintain and support the tribal database. 

• Continue to provide guidance to tribes on planning and implementing air monitoring 

programs. 

• Continue to support tribal participation in assessment and monitoring activities related to 

the atmospheric deposition of mercury on tribal lands. 

• Continue to facilitate distribution of information to tribes by maintaining the EPA Tribal 

website and the Tribal Newsletter. 

• Support and encourage early and frequent consultation with tribal governments on OAR 

actions that may affect them. 

• Support tribal efforts to understand, mitigate and adapt to climate change. 

• Work with Regions to implement voluntary programs to integrate nontraditional planning 

(e.g. land use, transportation, and energy) into air quality management. 

Regions

• Provide grant and technical support to interested federally-recognized tribes for the 

purpose of conducting air quality management activities. 

• Provide support to tribal air quality assessment activities such as emissions inventories, 

monitoring, and submission of monitoring data into national databases as appropriate. 

• Work with HQ to provide air quality outreach and training events to tribal staff, as 

appropriate. 

Final FY 2010 Technical Guidance — April 28, 2009 31
• Provide grant resources and staff support for tribes to participate in regional and national 

level activities. 

• Provide support for tribes on the SIP process. 

• Provide grant resources and support to tribes for participation in rule or program 

development. 

• Provide support for tribes on the TAS and TIP processes and act on TAS and TIP 

submittals. 

• Use Direct Implementation Tribal Cooperative Agreement (DITCA) authority to directly 

implement federal responsibilities as appropriate. 

• If necessary, identify areas requiring FIP and implement FIP development and 

implementation process. 

• Issue Part 71 and pre-construction (PSD) permits. 

• Implement and enforce federal standards (NSPS NESHAP, etc.). 

• Work with tribes to implement tribal, CAA, and voluntary emission control programs. 

• Support RPO-related funding and technical activities. 

• Support tribal capacity building with regard to understanding and addressing air toxics 

issues impacting reservations, as needed or appropriate. 

• Provide support for outreach events to tribes and other opportunities for tribes to 

participate in air toxics reduction efforts. 

• Make outreach and training on voluntary programs available to tribes. 

• Provide support and technical assistance to reservation and tribal communities to 

understand and address indoor air quality concerns. 

• Work with HQ and interested tribes in implementing voluntary emission control retrofit 

programs for existing heavy-duty diesel engines impacting reservation and tribal 

communities. 

• Work with HQ to conduct formal consultations with tribal leaders when appropriate. 

• Support OTS Tribal Database by regularly inputting appropriate data and ensuring tribal 

accomplishments and activities are accurately described. 

• Provide support and technical assistance to tribes to address residential wood and coal 

burning. 

Tribes

• Attend air quality outreach events; participate in ozone or PM policy development, 

and/or regulatory response, as appropriate. 

• Provide air quality monitoring or assessment data to EPA and/or AQS. 

• Complete and submit emissions inventories to the EIS. 

• Participate in regional and national level meetings, conferences, and teleconferences on 

CAA policy development and seek training and support to build capability for effective 

participation. 

• Participate in CAA rules and policy development that impact federally-recognized tribes. 

• Submit eligibility determinations under the TAR. 

• Submit TIPs to address air quality conditions for lands within the tribes’ jurisdiction. 

• Assist in FIP development and implementation process, as appropriate. 

• Review and test new Emissions Inventory process and EIS components. Provide 

feedback to regions. 

Final FY 2010 Technical Guidance — April 28, 2009 32
• Provide outreach to tribal communities on both indoor and outdoor air toxics issues. 

• Participate in training on voluntary programs to address air quality concerns. 

• Attend indoor air quality training. 

• Participate in indoor air quality assessment and outreach to reservation and tribal 

communities. 

• Implement voluntary emission control retrofit programs for existing heavy-duty diesel 

engines and wood stove and hydronic heather changeout campaigns. 

• Participate in and develop climate change activities. 

• Participate and develop multi-pollutant air quality planning activities such as the 

Sustainability for the Seventh Generation Initiative. 

++ End of Section ++

Final FY 2010 Technical Guidance — April 28, 2009 33
Indoor Air

Objective 1.2 - Healthier Indoor Air. Through 2014, working with partners, reduce human 

health risks by reducing exposure to indoor air contaminants through the promotion of voluntary 

actions by the public. 

 

Sub-objective 1.2.1: Reduce Radon Risk. By 2014, the number of future premature lung cancer 

deaths prevented annually through lowered radon exposure will increase to 1,267 from the 2006 

baseline of 644 future premature lung cancer deaths prevented. 

Sub-objective 1.2.2: Reduce Exposure to Asthma Triggers. By 2014, the number of people 

taking all essential actions to reduce exposure to indoor environmental asthma triggers will 

increase to 7.2 million from the 2003 baseline of 3 million. EPA will place special emphasis on 

children and other disproportionately impacted populations. 

Sub-objective 1.2.3: Reduce Exposure to Indoor Air Contaminants in Schools. By 2014, the 

number of schools implementing an effective indoor air quality management plan will increase 

to 48,000 from the 2002 baseline of 25,000. 

 EPA addresses indoor air quality issues by developing and implementing voluntary outreach 

and partnership programs that inform and educate the public about indoor air quality and actions 

that can reduce potential risks in homes, schools, and workplaces. EPA also supports states and 

communities in developing and implementing comprehensive multi-stakeholder air toxics 

reduction efforts. 

 Through these voluntary programs, EPA disseminates information and works with national, 

international, state, tribal, and local governments; industry and professional groups; and the 

public to promote actions to reduce exposures to potentially harmful levels of indoor air 

pollutants including radon, asthma triggers including environmental tobacco smoke (ETS), and 

mold contamination in homes. EPA also transfers technology by providing detailed guidance on 

indoor air-related building design, operation, and maintenance practices to building owners, 

building managers, and school facility managers and easy-to-use tools to educators and school 

facility managers. A key focus area is on the environmental management of asthma triggers 

through outreach to schools, child care centers, health care providers, and the general public. 

 EPA also provides tribes with appropriate tools and assistance to address mold contamination 

as well indoor air toxics, such as radon, ETS, and particulate matter. EPA works with other 

federal agencies to provide guidance and assistance on how to reduce the exposure levels of 

these contaminants in all tribal communities. 

 Through the State Indoor Radon Grant (SIRG) Program, EPA helps states that have not yet 

established the basic elements of an effective radon assessment and mitigation program, and will 

support innovation and expansion in states that already have programs. 

Final FY 2010 Technical Guidance — April 28, 2009 34
 Our strategies for improving indoor air quality and increasing the number of people breathing 

healthier indoor air are implemented through two priority areas: 1) indoor environmental 

pollutants and triggers which cause or exacerbate respiratory-related illnesses, and 2) radon. 

REDUCE RISKS FROM INDOOR ENVIRONMENTAL POLLUTANTS AND ASTHMA 

TRIGGERS 

 This program area takes both a pollutant-focused and a place-based approach to reduce the 

risk at the locations where people are exposed to indoor contaminants. As its top priorities, EPA 

and its partners design and implement voluntary guidance, education, outreach, training, and 

incentive programs and activities to reduce exposure to environmental triggers of asthma (i.e., 

ETS, dust mites, pests, molds, nitrogen dioxide, and pet dander), help communities deliver 

effective comprehensive asthma care, and effectively manage indoor air quality in homes, 

schools and office buildings. 

 Our strategy includes: implementing a national, multi-faceted asthma education and outreach 

program to improve and expand the delivery of comprehensive asthma care; an ETS program 

primarily focused on protecting young children from ETS exposure by collaborating with 

federal, state, and local organizations on promoting smoke-free homes and cars; and a national 

education and outreach program to inform the public, schools, school districts, educators, and 

building professionals about the importance of creating and maintaining healthy indoor 

environments in homes, schools, and workplaces. EPA has identified the reduction of asthma 

attacks as a National Environmental Justice Priority. Our strategy is targeted to improve the 

environmental health outcomes of people including segments of the population that are socioeconomically disadvantaged or disproportionately impacted such as children and low-income 

individuals. 

Our program relies on several key implementation/educational tools: 

• National public awareness and media campaigns; 

• Community-based outreach and education. (e.g., educating caregivers of children on 

environmental triggers of asthma and exposure to ETS); 

• Sound, user-friendly guidance tailored to the program’s varied constituencies; 

• Enhancement and application of programmatic support data; and 

• Knowledge and technology transfer.

FY 2010 Priorities for the Regions

• Continue to serve as the local, community-based point of contact to disseminate 

information and foster implementation of the indoor air programs; 

• Work with national partner state/field affiliates, state. tribal, and local partners, and 

coalitions to reduce risks from indoor pollutants and asthma triggers; 

• Oversee grants to reduce risks from indoor pollutants and asthma triggers, particularly in 

homes, schools and day care centers; 

Final FY 2010 Technical Guidance — April 28, 2009 35
• Work with school districts and other school organizations to promote adoption of 

effective indoor air quality management programs in schools; and 

• Work with state, tribal, and local community partners to reduce exposure to indoor 

asthma triggers including through state, tribal, and local asthma plans. 

RADON 

 The voluntary radon program aims to significantly reduce the number of radon-induced lung 

cancer deaths in the U.S. The national goal is to approximately double number of lives saved 

through radon risk reduction within the next five years. 

The program’s primary focus is on radon risk reduction in homes. EPA uses information 

dissemination, social marketing techniques, and partnerships with influential public health and 

environmental organizations to drive action at the national level. The SIRG program is a primary 

vehicle to drive action at the state, tribal and local level. 

The two primary methods to achieve our risk reduction goals are: 

• Building healthier green homes with radon-resistant new construction; and 

• Reducing radon in existing homes. 

A third method is to reduce the risk to children and adults in schools: 

• Reducing radon in schools and building new schools with radon-reducing features. 

The principal mechanisms to achieve these results are: 

• Builders voluntarily building radon-resistant new homes; 

• State and local governments adopting building codes that include radon reduction; 

• Homeowners voluntarily fixing their homes with high radon levels; 

• Sellers/buyers fixing homes within real estate transactions; and 

• Schools reducing radon through “IAQ Tools for Schools” or other program. 

FY 2010 Priorities for the Regions

• Use the SIRG results measures template and approve work plans that reflect EPA’s radon 

priorities; 

• Administer/monitor programmatic and SIRG grant recipient performance for results and 

encourage the timely expenditure of grant funds (older funds first); 

• Participate in national and regional radon meetings; 

• Support the Radon Leaders Saving Lives campaign; and 

• Use Radon Action Month as a way to drive action throughout the year. 

++ End of Section ++ 

Final FY 2010 Technical Guidance — April 28, 2009 36
Stratospheric Ozone 

Objective 1.3 - Protect the Ozone Layer. Through 2014, continue efforts to restore the earth's 

stratospheric ozone layer and protect the public from the harmful effects of UV radiation. 

 

Strategic Measures:

• Heal the Ozone Layer: By 2014, total effective equivalent stratospheric chlorine will 

have reached its peak and begun its gradual decline to a value less than 3.4 parts per 

billion of air by volume. 

• Reduce Emissions of Ozone-Depleting Substances: By 2015, reduce U.S. consumption of 

Class II ozone-depleting substances to less than 1,520 tons per year of ozone depleting 

potential from the 2009 baseline of 9,900 tons per year. 

• Reduce Exposure to Excess UV Radiation: By 2165, reduce the incidence of melanoma 

skin cancer to 14 new skin cancer cases per 100,000 people from the 2005 baseline of 

21.5 cases per 100,000 people. 

 As a signatory to the Montreal Protocol on Substances That Deplete the Ozone Layer 

(Montreal Protocol), the U.S. is obligated to regulate and enforce its terms domestically. In 

accordance with this international treaty and related Clean Air Act (CAA) requirements, EPA 

will continue to implement the domestic rulemaking agenda for the reduction and control of 

ozone-depleting substances (ODS), such as chlorofluorocarbons (CFCs), 

hydrochlorofluorocarbons (HCFCs) and methyl bromide, and enforce rules controlling their 

production, import, and emission. Implementation involves a combination of market-based 

regulatory approaches and development and commercialization of alternatives to ozonedepleting substances. We will strengthen outreach efforts to ensure efficient and effective 

compliance, and continue to identify and promote safer alternatives to curtail stratospheric ozone 

depletion. To help reduce international emissions, particularly in light of the more aggressive 

phasedown requirements adopted by Montreal Protocol signatories in September 2007, we will 

assist developing countries through transfer of technology and U.S. expertise in the development 

and implementation of cap-and-trade licensing systems. 

 Because the ozone layer is not expected to recover until the middle of this century at the 

earliest, the public will continue to be exposed to higher levels of UV radiation than existed prior 

to the use and emission of ODS. Recognizing this fact and the public’s current sun-exposure 

practices, EPA will continue education and outreach efforts to encourage behavioral changes as 

the primary means of reducing UV-related health risks. 

DOMESTIC PROGRAMS 

 EPA leads regulatory and voluntary programs to restore the ozone layer and reduce public 

health risk. For 2010, EPA’s domestic strategy for stratospheric ozone protection will focus on: 

Final FY 2010 Technical Guidance — April 28, 2009 37
• Undertaking measures to ensure successful transition of industries to non-ozone depleting 

alternatives to class II substances (HCFCs), which beginning in 2010 are subject to 

further consumption, production, and use controls under the Montreal Protocol and CAA. 

• Limiting production of class I substances such as CFC-11, CFC-12, and methyl bromide 

to uses identified as critical or essential under the Montreal Protocol. 

FY 2010 Milestones and Priorities

• EPA administers the critical use exemption for production of methyl bromide as allowed 

under the Montreal Protocol. 

• EPA allocates production and consumption allowances for HCFCs to ensure U.S. 

compliance with caps under the Montreal Protocol. 

• EPA expands and refines its electronic reporting and tracking capabilities to improve the 

efficiency, accuracy, and timeliness of reporting by regulated entities and improve the 

protection of confidential information. 

• EPA continues the combination of regulatory and voluntary activities to ensure safe 

handling, recovery, and disposal of ozone-depleting refrigerants, including 

implementation of the GreenChill and Responsible Appliance Disposal voluntary 

programs. 

• EPA continues implementing the Significant New Alternatives Program (SNAP) to foster 

the transition to ozone-safe alternatives. 

• Regions carry out enforcement actions related to programs under Title VI of the CAA, 

including servicing of motor vehicle air conditioners, recycling of ODS, and emissions of 

phased-out substances. For additional information see the National Program Guidance 

issued by the Office of Enforcement and Compliance Assurance. 

MULTILATERAL FUND 

 This program includes the Multilateral Fund, which promotes international compliance with 

the Montreal Protocol by financing the incremental cost of converting existing industries in 

developing countries to cost-effective, ozone-friendly technology. Our strategy is to continue to 

support the Ozone Secretariat’s Multilateral Fund, which provides resources to developing 

nations to facilitate their transition to ozone-safe alternatives. In 2010 we will focus on: 

• Maximizing developing country reductions in ODS production by moving aggressively 

from a project-by-project approach to a national phase-out strategy approach. 

• Accelerating the shift to CFC alternatives by accelerating the closure of CFC 

manufacturers in developing countries. 

• Increasing support to developing country institutions to enable effective implementation 

of policy measures. 

++ End of Section ++

Final FY 2010 Technical Guidance — April 28, 2009 38
Radiation Protection 

Objective 1.4 - Radiation. Through 2014, working with partners, minimize unnecessary 

releases of radiation and be prepared to minimize impacts to human health and the environment 

should unwanted releases occur. 

Strategic Measures:

• Monitor the Environment for Radiation: By 2014, 51 percent of the U.S. population will 

be in proximity to an ambient radiation monitoring system that provides scientifically 

sound data for assessing public exposure resulting from radiological emergencies. (2001 

baseline is 22 percent of U.S. population.) 

• Prepare for and Respond to Radiological Emergencies: By 2014, the radiation program 

will maintain a 90 percent level of readiness of radiation program personnel and assets to 

support federal radiological emergency response and recovery operations. (2007 baseline 

is an 83 percent level of readiness.) 

 EPA works with federal, state, tribal, and local agencies to prevent public exposure to 

harmful levels of radiation in the environment. The Agency assesses exposure risks, manages 

radioactive releases and exposures, ensures proper management of radioactive materials, and 

provides the public with information about radiation and its hazards. EPA also maintains a high 

level of preparedness to respond to radiological emergencies and potential acts of terrorism. 

EPA’s strategies for radiation include: 

• Radiation Protection; 

• Radiation Emergency Response Preparedness; and 

• Homeland Security and Emergency Response and Recovery 

 EPA continues to improve radioactive waste management through guidance, technical tools, 

assessment, and regulatory amendments as necessary and radiation-specific analytical and 

technical support. EPA also is increasing its commitment to Emergency Response/Homeland 

Security. 

 EPA’s Radiation Program continues to integrate radiation data into the Agency’s information 

systems and make radiation information more accessible to the public. The program is enhancing 

the national environmental radiation monitoring system (RadNet) to better respond to radiation 

emergencies and prepare for potential terrorist threats and continues programs to provide 

guidance and tools to other federal agencies, as well as state, tribal, and local governments, our 

stakeholders, and partners. We also are continuing efforts to create and enhance voluntary 

programs to better track radioactive materials, find alternatives to radiation sources in industry, 

and improve disposal options for radioactive sources in commerce. 

Final FY 2010 Technical Guidance — April 28, 2009 39
RADIATION PROTECTION 

 This program includes activities for radiation clean up, federal guidance, risk modeling, Clean 

Materials, Waste Isolation Pilot Plant (WIPP), radiation air toxics, or National Emissions for 

Hazardous Air Pollutants (NESHAPs), technologically-enhanced naturally-occurring radioactive 

material (TENORM), radiation waste management, radioactive and mixed-waste operations, and 

laboratory analyses. 

 

 Using a collaborative strategy, EPA works with the public, industry, states, tribes, and other 

governmental agencies to inform and educate people about radiation risks and promote actions 

that reduce human exposure. EPA also provides radiation guidance and tools and develops 

regulations as appropriate, to control radiation releases. Key programmatic activities include: 

• Promoting the safety of the U.S. and international metal supply by preventing future 

losses of radioactive materials including sealed sources; 

• Ensuring continued compliance with EPA regulations and EPA oversight for DOE waste 

disposal activities at the WIPP; 

• Promoting the reduction and management of radiation risks in a consistent and safe 

manner at Superfund, DOE, DOD, state, local, and other federal sites; 

• Maintaining appropriate methods to manage radioactive releases and exposures including 

evaluating remediation technologies for radioactively contaminated sites; 

• Assessing exposure risks and providing information about radiation and its hazards; 

• Evaluating the human health and environmental risks from radiation exposure and 

mitigating impacts to the public; 

• Providing national-level guidance on the risks posed by radioactive materials in the 

environment; 

• Enhancing voluntary programs to track radioactive materials more effectively, find 

alternatives to radiation sources in industry, and improve disposal options for radioactive 

sources in commerce; 

• Providing a national monitoring program for environmental radioactivity; 

• Improving EPA, state, and commercial radioanalytical capacity and capabilities; 

o Providing analytical capability to evaluate radioactive and mixed waste 

concentrations in all environmental media; 

o Providing improved methods and practices for sampling and assessing radioactive 

material in the environment; and 

o Providing reference laboratory support to review new methods and confirm other 

laboratory analyses. 

FY 2010 Priorities

• Additional quantities of radioactive waste certified by EPA as properly disposed will be 

deposited at the WIPP in 2010; 

• EPA radiation laboratories will improve analytical capacity through updated technology 

and methods; 

Final FY 2010 Technical Guidance — April 28, 2009 40
• EPA will improve state radiation laboratory capabilities and capacity through training 

and evaluation; 

• EPA will respond to issues related to the resurgence of nuclear power, including the 

development of new nuclear power plants; 

• Laboratories will support regional remediation projects; 

• Regions will continue to serve as the local, community-based point of contact to 

disseminate information on EPA’s radiation protection program; 

• Regions will continue to coordinate regional radiation issues among regional offices; 

• Regions will continue to implement regulatory programs (e.g., radiological NESHAPs); 

• Regions will continue as requested, to provide technical support to state radiation, solid 

waste, environmental and health programs and headquarters radiation regulatory, policy 

and technical workgroups; 

• Regions will work with states on issues involving TENORM that include issues 

associated with mining legacy waste disposal and water treatment residuals. 

RADIATION EMERGENCY RESPONSE PREPAREDNESS 

 This program includes federal preparedness activities, ORIA programmatic readiness, 

Radiological Emergency Response Team (RERT) personnel and equipment readiness, 

development and participation in exercises, training and outreach, radiological emergency 

response guidance, extensive laboratory capability for radioactive and mixed waste analyses, and 

RadNet, EPA’s national environmental radiation monitoring system. 

 Using a collaborative strategy, EPA works with tribes, federal, state and local agencies to 

ensure that the appropriate parties are fully informed and prepared to respond should an incident 

involving radiation occur. EPA’s key activities supporting radiation response preparedness 

include: 

• Preparing to respond to incidents involving radioactive materials through training, 

infrastructure development, regular exercises, and field experience; 

• Issuing Protective Action Guides; 

• Coordinating with other organizations to ensure thorough response and preparedness 

planning; 

• Providing radioanalytical laboratory capabilities to assess radioactive contamination 

during all phases of an incident; 

• Providing national, near-real time data on airborne radioactive material concentrations; 

• Supporting nationwide development of increased laboratory capacity and capability; and 

• Providing waste disposal options for wastes resulting from a radioactive dispersal device 

(RDD).

FY 2010 Priorities

• The (RERT) will maintain its high level of team readiness; 

• Laboratories will support urgent regional removal operations; 

• RERT staff will support regions with training and at exercises; 

Final FY 2010 Technical Guidance — April 28, 2009 41
• Regions will continue to serve as the local, community-based point of contact to 

disseminate information on EPA’s radiation response and preparedness program, 

activities, and capabilities. As appropriate, regions should: 

o Provide technical support to state radiation control programs; 

o Support EPA’s radiation emergency response operations, including the 

assignment of personnel to serve as Regional radiation advisor and an RERT 

liaison; 

o Participate in radiological response exercises; and 

o Support radiological response training, including the Radiation Task Force Leader 

course, to increase the capacity of the Agency’s Response Support Corps. 

HOMELAND SECURITY AND EMERGENCY PREPAREDNESS, RESPONSE, AND 

RECOVERY 

 EPA will coordinate homeland security activities across the Agency, with the Department of 

Homeland Security and other federal agencies to ensure consistency with the National Response 

Framework. 

Strategy

 EPA’s strategy for Homeland Security Preparedness, Response, and Recovery builds upon 

the efforts discussed under Radiation Response Preparedness. In addition to overall coordination 

activities, EPA is significantly upgrading its environmental monitoring network for radiation 

(RadNet) by expanding its ambient radiation monitoring capabilities. RadNet provides EPA data 

on ambient levels of radiation in the environment, with data for radiological emergency response 

assessments, and data for public officials and the general public. 

FY 2010 Milestones and Priorities

• EPA will purchase and deploy additional state-of-the-art radiation monitoring units; 

• Regions will provide leadership in coordinating the installation of RadNet monitors, 

specifically assist with identifying station operators and sites, and serve as the local, 

community-based point of contact to disseminate information on EPA’s national 

radiation monitoring system. 

++ End of Section ++

Final FY 2010 Technical Guidance — April 28, 2009 42
Climate Change 

Objective 1.5 - Reduce Greenhouse Gas Emissions. By 2012, 160 million metric tons of 

carbon equivalent (MMTCE) of emissions will be reduced through EPA’s voluntary climate 

protection programs. 

Strategic Measures:

• By 2014, 53 MMTCE will be reduced in the buildings sector (compared to 30 MMTCE 

reduced in 2006) through EPA’s voluntary climate protection programs. 

• By 2014, 112 MMTCE will be reduced in the industry sector (compared to 69 MMTCE 

reduced in 2006) through EPA’s voluntary climate protection programs. 

• By 2014, 20 MMTCE will be reduced in the transportation sector (compared to 0.6 

MMTCE reduced in 2006) through EPA’s voluntary climate protection programs. 

GREENHOUSE GAS REPORTING RULE 

 On March 10, 2009, EPA issued a proposed rule for mandatory greenhouse gas (GHG) 

reporting from large GHG emissions sources. The proposed rule can be found at 

www.epa.gov/climatechange/emissions/ghgrulemaking.html. In developing the reporting 

requirements, EPA considered the substantial amount of work already completed and underway 

in many states, regions and voluntary programs. The new reporting requirements would apply to 

suppliers of fossil fuel and industrial chemicals, manufacturers of motor vehicles and engines, as 

well as large direct emitters of GHGs. The first annual report would be submitted to EPA in 

2011 for the calendar year 2010, except for vehicle and engine manufacturers, which would 

begin reporting for model year 2011. 

RENEWABLE FUEL STANDARDS 

 In response to the congressional mandate in the Energy Policy Act of 2005 (EPAct), EPA 

completed the RFS1 regulations in May 2007 and implemented them beginning September 1, 

2007. The Energy Independence and Security Act (EISA), passed in December 2007, required 

EPA to revise RFS1 and implement new RFS2 standards. For FY 2010, EPA expects to increase 

implementation activities related to Section 1501 of EPAct for annual state-by-state surveys of 

renewable fuel use. The initial survey effort is being piloted—full survey implementation is 

planned in FY 2010 and will continue annually as Congress directed. 

 Full implementation of the RFS2 program is scheduled to begin on January 1, 2010. 

Priorities related to RFS2 include: establishing annual standards for four renewable fuel 

categories, processing and responding to expected waiver requests, and developing regulations to 

mitigate any adverse impacts on air quality resulting for the renewable fuel volumes required. 

Final FY 2010 Technical Guidance — April 28, 2009 43
EPA will also be developing a reporting system, and providing technical assistance and 

registration and reporting guidance to impacted parties on the new provisions of RFS program. 

 

VOLUNTARY CLIMATE PROTECTION PROGRAMS 

 This program includes voluntary domestic and international programs that address GHG and 

climate change issues. Efforts are aimed at reducing emissions of GHGs and mitigating the 

effects of global climate change on the environment and human health while growing the 

economy. EPA’s strategy is to: 

• Continue the successful Energy Star partnerships in the residential and commercial 

buildings sector by adding new products to the Energy Star family; 

• Raise awareness of the Energy Star label for products, buildings, and homes, and 

promoting superior energy management to public and private sector organizations of all 

sizes in all regions of the country. 

• Continue building on the success of voluntary programs in the industrial sector by: 

o enhancing the rate of energy and resource efficiency improvements through the 

Energy Star and WasteWise programs; 

o promoting the Energy Star label for industrial plants and expanding opportunities 

to provide energy benchmarking tools to industry; 

o cost-effectively keeping emissions of methane at 1990 levels or below through 

2010; and, 

o cost-effectively limiting emissions of the more potent greenhouse gases (HFCs, 

PFCs, SF6); and facilitating the use of clean energy technologies and purchases of 

renewable energy. 

• Reduce international GHGs through the Methane to Markets Partnership by promoting 

and deploying cost-effective methane recovery technologies among other countries and 

the U.S. private sector. 

• Increase the use of renewable energy throughout the public and private sector by 

promoting membership in the Green Power Partnership, in particular for larger 

organizations. 

• Ensure that climate change issues are considered in the business operations of major 

American corporations through participation in Climate Leaders. 

• Promote energy efficiency and the generation of increased amounts of renewable energy 

through a variety of utility-focused programs. 

• Continue the SmartWay Transport Partnership to increase energy efficiency and lower 

emissions of freight transportation by: increasing the market penetration of advanced 

Final FY 2010 Technical Guidance — April 28, 2009 44
heavy-duty diesel tractor and trailer technologies; implementing innovative financing 

strategies; developing a supply chain system to allow freight companies to select, 

measure, and certify their environmental performance; and, by enhancing existing 

SmartWay GHG measurement tools so they can be used to certify emission reductions 

from fleet-level projects. 

• Help consumers and businesses more easily identify light and heavy duty vehicles that 

deliver superior fuel economy and emissions by identifying vehicles that meet the 

SmartWay criteria for superior environmental performance. 

• Work with financial experts to identify and develop tools, resources, and programs for 

states and regional authorities to implement innovative financing programs to deliver 

lower cost financing to diesel truck and nonroad equipment buyers (many of who are 

low-income and minority owner operations and businesses) for the purpose of upgrading 

the environmental performance of their diesel trucks or equipment. 

• Continue to develop and demonstrate innovative fuel-efficient and clean vehicle and 

engine technologies, including ongoing work with auto industry partners to transfer 

EPA’s engineering expertise and advanced technologies to commercial application. 

FY 2010 Priorities for Regions: Lead by example in the area of energy efficiency and clean 

energy and promote making the cleaner energy choice to stakeholders. This includes: 

• Make commitments to procure Energy Star-qualified products and encourage other 

organizations to do the same. 

• Encourage tribal governments and communities to be partners in GHG activities and 

participate in and benefit from ongoing coordinated efforts and outreach programs. 

• Ensure that the power management feature of Energy Star-qualified computer monitors is 

enabled and encourage other organizations to do the same. 

• Rate the energy performance of buildings using EPA’s national energy performance 

rating system, apply for the Energy Star label for the qualifying buildings, and determine 

improvement plans for those that do not currently qualify; and encourage other 

organizations to do the same. 

• Join the Energy Star Buildings Challenge and promote a 10% or more reduction in 

energy use in buildings, encourage local governments to do the same, and assist local 

governments in their implementation of the Challenge. 

• Ensure that new building designs are “Designed to Earn the Energy Star” where 

applicable, and encourage others to do the same. 

Final FY 2010 Technical Guidance — April 28, 2009 45
• Promote the use of the ENERGY STAR@Home, ENERGY STAR Yard Stick, and Home 

Energy Advisor web-tools to help homeowners make informed decisions about energy 

efficiency for their homes. 

• Educate trucking companies and shippers about the SmartWay Partnership program and 

encourage them to join the program. 

• Encourage major companies and organizations headquartered in the Region to join 

Climate Leaders and the Green Power Partnership. 

• Make or encourage energy efficiency improvements and clean energy choices by 

promoting a range of innovative financial and policy mechanisms, including: 

o purchasing green power, integrating energy efficiency and clean energy into air 

quality plans (i.e., SIPs), and state supplemental environmental projects (SEPs); 

o promoting the recovery and use of methane as a clean energy source through EPA’s 

methane partnership programs (e.g., landfills, agricultural waste, coal mines, and 

oil/gas operations); 

o creating pilot programs to use commercially-available advanced technology in fleets 

(such as state/municipal vehicles, school buses, or refuse vehicles) to produce costeffective emissions and fuel consumption reductions; and, 

o working with HQ on RFPs for the Diesel Emissions Reduction Program which may 

include requests for projects that include working with financial experts to implement 

innovative financing programs to deliver lower cost financing to diesel truck and 

nonroad equipment buyers, many of whom are low-income and minority-owner 

operations and businesses operating in environmental justice areas. 

++ End of Section ++ 

Final FY 2010 Technical Guidance — April 28, 2009 46
Appendix A – Grant Guidance 

ORGANIZATION 

 This grant appendix is divided into six sections: an executive summary that highlights 

significant developments, a summary key administrative and programmatic requirements and 

discussions of specific air program areas. Preliminary allocations of grants for state and local air 

pollution control agencies and for state indoor radon grants have been reserved in this draft. 

TABLE OF CONTENTS 

Section Page

Organization A-1 

Executive Summary A-1 

Effective Grant Management and Results A-3 

Information on Specific Program Areas A-5 

Ambient Monitoring A-13 

Preliminary State/Local Air Grant Allocation (Reserved) A-47 

State Indoor Radon Grant Program and Allocation (Reserved) A-47 

Section I. EXECUTIVE SUMMARY 

Highlights 

● Announcement of FY 2010 budget details 

were still pending at press time. 

● Guidance assumes prior enacted year 

funding level with a modest increase for 

planning purposes. 

● Implementation of the DERA program 

including the ARRA stimulus provisions 

continues in FY 2010. 

● Continued monitoring resources for Pb and 

Air Toxics hotspots proposed. 

● Continued importance of measuring and 

expressing grant performance and results.

 The technical portion of the national program 

guidance describes the FY 2010 implementation 

priorities, activities and milestones that are necessary to 

make progress towards the Clean Air goal and achieve 

the annual performance goals in the Agency’s Annual 

Performance Plan and Congressional Budget 

Justification. State, local and Tribal governments (and 

key multi-state organizations) as co-implementors, are 

essential to this effort. 

 The roles and responsibilities of co-implementors 

are described in the State/ Local Air Quality 

Management, the Tribal Air Quality Management, and the Radon sections of the technical 

program guidance. Related measures of performance are contained in the appendices covering 

the annual program commitments (appendix B) and the related subset of state grant performance 

measures (appendix C). 

 This grant appendix complements the technical guidance by providing additional 

information on selected program areas supported by grant assistance to co-implementor entities. 

Major programmatic and administrative considerations impacting program grants in FY 2010 are 

highlighted. The draft guidance typically includes a preliminary distribution1

 of state/local air 

 

1 A preliminary allocation has not been included in the draft guidance pending further definition on FY 2009 and FY 2010 

funding. Once this definition is received OAR will release a preliminary allocation and consult with stakeholders before issuing 

A-1
Appendix A – Grant Guidance 

grants. However, at the time of release of this guidance, a final detailed FY 2010 budget 

submission for the Agency had not yet been released. EPA will issue supplemental 

documentation that will include a more detailed, proposed FY 2010 grant allocation as soon as 

the President’s detailed budget has been submitted to Congress. Placeholder information is 

shown in table A-1. This table will be updated when more definitive information on funding 

becomes available. 

Table A-1. Comparison of STAG Assistance: FY 2008 through the FY 2010 Request 

(in $ Millions) 

Program FY 2008 

Enacted Level 

FY 2009 

Estimated Level 

FY 2010 

President’s Budget 

Continuing Air Program * $165.7 $174.7 

PM 2.5 Air Monitoring (§103) $41.8 $41.9 

Air Toxics Monitoring (including 

schools) $6.8 $7.5 

Regional Haze Planning (§103) $2.5 

Diesel Emission Reduction Program ** $49.1 $60.0 

Tribal Air Program $10.8 $13.3 

State Indoor Radon $7.9 $8.1 

Total $284.6 $305.4 

Reserved 

* Includes continuing §105 program and NE OTC under §106. 

** Funds for California Emission Reduction projects are not included in FY 2008 and FY 2009 levels. Funds for State 

and Local Climate Change Initiatives are not included in the FY 2009 total. Also note that the President signed a FY 

2009 economic stimulus bill that provided an additional $300 million for DERA implementation, approximately $88 

million of which was targeted by formula for state and local air quality agencies. 

 Notwithstanding questions on funding, there are several significant developments that 

will impact state and local operations in FY 2010: continued refinements in air monitoring 

programs including a continued focus of air toxics monitoring funds on potential high risk areas 

near schools, supporting monitoring to identify and assess risks from elevated lead (Pb) levels; 

and increases in associated program support for monitoring. Associated program support for 

multi-state trading programs to reduce the impacts of criteria pollutants will continue but EPA 

will be working with state, local and tribal partners to reassess the cost and focus of this 

program.. The region-by-region allocation formula and distribution of state indoor air grant 

resources will also be updated in CY 2009 and any revisions will impact the final distribution of 

FY 2010 grant resources. Minor refinements in performance and accountability measures have 

also been included in the FY 2010 guidance. Note that while the Agency will no longer be 

expressing selected aspects of state grant performance via a state grant template approach, 

performance measures for state and local air and radon grants will not be changing. 

 The guidance does not purport to cover provisions applicable to the full range of air and 

radiation grants such as OAR project or discretionary grants that may be available during FY 

2010. This appendix focuses on continuing program grants to state and local air agencies. Also, 

additional, separate guidance pertaining to Tribal and Indoor Radon grants 2 is available from 

 its final allocation. Please note that the allocation may still be subject to change because: (a) revisions may be necessary based 

upon a final appropriation and enacted operating plan, and (b) funds targeted to certain categories such as associated program 

support are subject to revision based on updated information from the affected state/local agencies. 

2 Additional administrative guidance for the State Indoor Radon program may be found at: 

http://www.epa.gov/radon/sirgprogram.html . Additional information for Tribal air programs can be found at: 

A-2
Appendix A – Grant Guidance 

OAR’s Tribal Coordinator and additional information and details on implementation of grant 

programs under the Diesel Emission Reduction Act is available from the Office of 

Transportation and Air Quality.3 More detailed guidance on competitive and discretionary grants 

is provided via their respective solicitations or applicable information documents.4 Agencies 

should contact the EPA program contact listed for those programs for more information. 

Section II. EFFECTIVE GRANTS MANAGEMENT and RESULTS

 Administrative and programmatic provisions that help govern the effective oversight and 

utilization of continuing program and project-specific grants awarded to state, local, tribal and 

multi-jurisdictional entities are highlighted in this section. The list of provisions is not 

exhaustive but key areas covered are: proper use of authorities for award of assistance, adherence 

to specific grant program requirements, effective post-award oversight, identification of 

performance measures and results, the funding of co-regulator organizations, and the promotion 

of competition. Links to Agency internet and intranet sites where additional information, 

including the full text of available guidance, are provided. 

Using Proper Authorities for Award 

 OAR has issued updated guidance for use by Program and Regional Offices that clarifies 

who is eligible for grant assistance given the purpose, appropriation and grant authority 

associated with the funds. The guidance applies to FY 2009 but OAR plans to periodically 

update the guidance - typically within six weeks of the enactment of a new appropriations bill. 

EPA staff can access the guidance at: http://intranet.epa.gov/ogd/state/Guid_Office_of_OAR.pdf. 

The program contact is Courtney Hyde (202-564-1227). 

Administrative Guidance for OAR Grant Programs 

 OAR has developed a consolidated reference document covering the various statutory, 

regulatory and policy provisions that govern the overall administration of the Section 105 

outdoor air grant program. This guidance is intended as a resource for HQ and regional staff. 

The program contact, William Houck, can be reached at 202-564-1349. The guidance may be 

accessed at: http://intranet.epa.gov/ogd/state/Consolidated_Guid_Adm_S_105_Air_Grant_Program.pdf . OAR 

plans to soon make this and other key grant guidance documents, such as the Assistance 

Authorities document, available via an internet link 

 For the tribal air program, additional guidance and links to Tribal air program 

information may be found at: http://www.epa.gov/oar/tribal/pdfs/menuofoptions.pdf . The 

program contact, Darrel Harmon, may be reached at: 202-564-7416. See Section 3 of this 

guidance for information on Diesel Emissions Reduction Assistance grants. Contact Jennifer 

Keller at 202-343-9121. Additional information and links to guidance on the State Indoor Radon 

Grant program may be found in Section 6 of this appendix. Contract Phil Jalbert at 202-343-

9431. 

 http://www.epa.gov/oar/tribal/pdfs/menuofoptions.pdf . The program contact, Darrel Harmon, may be reached at: 202-564-7416. 

3 Updated information will be provided at: www.epa.gov/cleandiesel (and see also www.recovery.gov) as it becomes available. 

4 More information on OAR and other Agency discretionary grant opportunities, as it becomes available, can be found at: 

http://epa.gov/air/grants_funding.html and http://www.epa.gov/ogd/grants/funding_opportunities.htm .

A-3
Appendix A – Grant Guidance 

Ensuring Effective Oversight of Assistance Agreements 

 Updated EPA Order 5700.2A2 streamlines the post-award management of grants and 

cooperative agreements. It became effective 1/1/08. The Order requires EPA offices to monitor 

recipient compliance with programmatic terms and conditions, the correlation of the work plan 

and application with actual grant progress, equipment use, and compliance with all statutory and 

regulatory requirements. Offices must submit oversight plans and document their execution. 

The Order may be found at: http://intranet.epa.gov/ogd/policy/4.0-PostAward-Topics.htm . 

Improving Performance Measures for State/Local Grants 

 States seeking single media categorical and Performance Partnership grant awards should 

submit work plans that enable EPA to identify clear linkages to EPA’s Strategic Plan. There 

should be consistent and regular performance reporting that enables meaningful comparison of a 

state’s past and planned activities and performance. OAR issues complementary guidance for 

Regions on state grant performance measures as part of the NPM guidance process. Information 

on FY 2010 measures and commitments contained in the annual NPM guidance is contained in 

appendices B and C). Additional information may be found at: 

http://intranet.epa.gov/ogd/state/Final%20FY09%20State%20Grant%20Template%20Guidance

%20%20July%202008.pdf (See also - http://www.epa.gov/ocfo/npmguidance/index.htm) . 

 OAR and the Regional Offices are also working with recipients and the rest of the 

Agency in a continuing process to assess, reduce, refine or affirm existing reporting 

requirements. OAR is always open to comment from state, local and tribal agencies on ways to 

reduce reporting burdens as well as ways to improve performance reporting and performance 

measures. This includes discussion of improved short-term environmental indicators and 

performance measures and their incorporation in annual and multi-year assistance agreements. 

Achieving Programmatic and Environmental Results 

 Sound measures of performance should yield insightful and useful results data. EPA 

Order 5700.7 applies to all Agency grants not just grants to States and covers all phases of the 

grants process from solicitation to application to reporting to evaluation. The Order requires EPA 

project officers to assure that each grant: (a) can be linked to the Agency’s strategic architecture, 

(b) articulates measurable outputs and outcomes, and (c) reports the programmatic and, where 

possible, environmental results achieved. For more information see: 

http://intranet.epa.gov/ogd/policy/order/5700.7.pdf , and 

http://www.epa.gov/ocfo/npmguidance/oar/2007/oar_2007_environ_results.pdf . 

Approval Process for STAG Awards to Co-Regulator Organizations 

 A co-regulator organization is defined by EPA as a national or regional (i.e., multijurisdictional) organization that represents the interests of co-regulators/co-implementors (state, 

tribal or local governments) in the execution of national or regional environmental programs.5

 

 

5 The definition of co-regulator/co-implementor may be found in the Agency’s Order (5700.5A1) - Revised Competition Policy. 

http://intranet.epa.gov/ogd/policy/order/5700_5.pdf . In various regions of the country state and local agencies have formed 

multi-jurisdictional organizations (MJO) to help coordinate their geographically-specific air quality interests. These agencies 

have directed their Regional Offices to target portion of their grant allotment to their MJO. For OAR, the only co-regulator grant 

A-4
Appendix A – Grant Guidance 

EPA issued a policy on December 1, 2006 that clarified that the head of the affected State agency 

or department (e.g., the State environmental commissioner or head of the State public health or 

agricultural agency) be involved in the funding process and that EPA request and obtain the prior 

consent of this official before taking funds off the top of a state grant allotment for direct award 

to a state/local co-regulator organization. The policy can be accessed at: 

http://intranet.epa.gov/ogd/competition/piexemptions/approval_process_for_STAG_awards.htm. 

Promotion of Competition 

 Agency policy is to promote competition in the award of grants and cooperative 

agreements where practical. EPA Order 5700.5A1 presents the Agency’s competition policy. 

The Order exempts grants for continuing environmental programs, such as those funded under 

§105 as well as §103 grants for fine particulate monitoring, §103 national air toxics monitoring 

trends network grants, regional haze planning organization grants, federally-recognized tribes 

and inter-tribal consortia under OAR’s tribal grant program; and TSCA §306 grants for state 

indoor radon programs. Radon grants to tribes and intertribal consortia under TSCA §10 grants 

must be competed. EPA is not precluded from allocating grant funds for a portion of these 

programs through competition, if the Agency determines it is in the best interest of the public. 

Program contact is Courtney Hyde at 202-564-1227.

 Also, effective October 1, 2007, the Agency’s Competition Policy states that co-regulator 

status is no longer available as an exception to compete for a grant for a multi-jurisdictional 

organization. However, other exceptions to competition under the policy - including the ‘public 

interest’ exception - remain available to a co-regulator organization. The Order may be found at: 

http://www.epa.gov/ogd/competition/5700_5A1.pdf . 

Efficient Exchange of Environmental Information 

 States, tribes and territories exchanging both regulatory and non-regulatory environmental 

data with one another, or with EPA, should make the Exchange Network and EPA's connection 

to it, the Central Data Exchange (CDX), where available, the standard way to exchange data. 

Other legacy methods should be phased out. More information can be obtained at: 

http://www.exchangenetwork.net/index.htm. 

Section III. ADDITIONAL INFORMATION on SPECIFIC AIR PROGRAM AREAS

Diesel Emission Reduction Program 

 Program Purpose: The budget request for FY 2010 includes funds to support the Diesel 

Emission Reduction provisions of the Energy Policy Act of 2005. This includes funding for 

competitive federal grants to reduce diesel emissions from the existing fleet. Sections 791-797 

of the Energy policy Act authorize these grant funds which will support implementation of the 

National Clean Diesel Campaign. 

 awarded at the national level with STAG resources has been to the National Association of Clean Air Agencies (formerly 

STAPPA-ALAPCO). 

A-5
Appendix A – Grant Guidance 

 In FY 2008, the Agency began implementation of Sections 791-797 of the Energy Policy Act 

of 2005 after appropriation of nearly $50 million for those provisions. Both the National Grant 

and Loan program and the State Grant and Loan program were funded. OTAQ expects to fund 

at least 100 new grants deploying technology in various sectors using diesel engines through 

these two programs. In addition, OTAQ expects to fund approximately 200 more DERA grants 

through the ‘America’s Recovery and Reinvestment Act of 2009 (ARRA).’ 

 Through the Diesel Emission Reduction Program (DERA), OAR will continue its focus on 

reducing particulate matter by up to 95 percent from existing diesel engines, including both onhighway and non-road equipment. Existing diesel engines are not subject to the new, more 

stringent emission standards that took effect in 2007 and later. These engines often remain in 

service for 20 or more years, and this program will help provide immediate reductions by 

retrofitting these engines with emission control technologies sooner than would otherwise occur 

through normal turnover of the fleet. Implementation of the program also will produce criteria 

air pollutant and air toxics benefits. 

 Program Design: In FY 2010, the Office of Transportation and Air Quality (OTAQ) 

expects to fund at least 125 new grants deploying technology in various sectors using diesel 

engines. This program will support grants and loans for diesel engine retrofits, rebuilds, 

replacements, cleaner fuels, idling reduction measures and low-cost revolving loans. Up to 30 

percent of the funds for diesel emissions reduction grants may again be appropriated to provide 

formula grants to states to establish and support state clean diesel grant or loan programs. 

 

 The Agency’s strategy to implement this program and disseminate its associated clean diesel 

funding is dependent on the actual appropriation levels and any accompanying language 

regarding implementation. In addition, the timing of the actual appropriation will dictate when 

EPA will publish its national announcement of funding availability. DERA, as authorized, 

contains the following key provisions: 

- At least 70% of the funding is dedicated to provide grants and low-cost revolving loans to 

support the National Clean Diesel Initiative charged with achieving significant reductions in 

diesel emissions. This will include the Clean School Bus USA program. Note that at least 50% 

of these funds are directed to benefit public fleets. 

- If the state program provision is funded, as it was in 2008 and 2009, no more than 30% of the 

total funding will be distributed directly to state programs which are designed to achieve 

significant reductions in diesel emissions. The Agency will provide guidance to states for 

applying for these funds if this provision is funded. This would include information on the costeffectiveness of various emission reduction technologies, and permissible uses of the grant funds 

as directed by the 2005 Energy Policy Act’s Diesel Emissions Reduction provisions. 

- In regard to the first 70% of the funding, the Agency will request proposals from eligible 

entities for projects that will reduce emissions from the existing fleet of diesel engines. EPA will 

give priority to projects that: 

o maximize public health benefits, 

o are in areas with poor air quality and/or with air toxic concerns, 

o pursue the most cost effective strategies, 

A-6
Appendix A – Grant Guidance 

 including certified engine configurations, verified technologies, emerging 

technologies, early use of ULSD, 

 promoting alternative fuels where appropriate, 

o serve highest population centers, 

o serve communities with environmental justice concerns, 

 those that receive disproportionate air pollution from diesel fleets. 

- EPA will publish Requests for Proposals (RFPs) and notify Congress, states, and other 

interested or eligible entities, of both this funding competition and of the direct state allocations 

through their respective associations (e.g., NACAA, AAPA, EMA, DTF), announcements on 

EPA’s website, announcements on EPA’s ten regional websites, press advisories, and other 

means for any FY 09 appropriation that is not ARRA of 2009 funding. For 2009–related ARRA 

funds, RFPs will be posted for 30 days with funds awarded in 90 days 

- The regular DERA RFAs will provide a 60 to 90-day window for eligible entities to apply to 

EPA for this funding assistance. Once that window expires and within the subsequent 120-day 

period, EPA will: 

o Review every proposal received to ensure each one meets the required funding 

eligibility and other criteria set forth in the RFA. 

o Disregard proposals that do not meet the criteria. 

o Rank each remaining proposal on its merits according to the criteria set forth in 

the RFP (see “priorities” above.). 

o Notify Congress of the grantee selections. 

o Award the highest ranked proposals. 

 For more information, please contact Jennifer Keller in OTAQ at 202-343-9541. 

Information, including award information, will also be updated at the following website: 

www.epa.gov/cleandiesel . 

National Geographic Priorities: U.S.-Mexico Border Air Program 

 

 The proximity of states and localities in EPA’s Regions 6 and 9 to the U.S-Mexico border 

presents a number of trans-boundary air quality challenges. Many border area residents, 

especially those in heavily urbanized areas, are exposed to health-threatening levels of air 

pollutants such as ozone, PM, CO SO2, and air toxics. Visibility impairment exists in most of 

the Class I areas along and near the border. Accurate evaluation of air quality in the border will 

allow both countries to successfully target controls and reduce air pollutants. Capacity-building 

via such evaluation, training, and pilot projects that can be expanded by Mexico will further 

reduce air emissions along the border. 

 The Border 2012: U.S. - Mexico Environmental Program agreement, signed by both 

countries on April 3, 2003, was created to promote regional as well as border-wide strategies to 

improve air quality through coordinated air quality planning and management activities, such as 

the development of emissions inventories; the deployment, operation, and maintenance of air 

monitoring networks; the development of alternative fuels and energy sources; the development 

of innovative and progressive air quality management approaches; the design of air quality plans 

for the reduction and control of air pollution; pilot emissions reductions projects; and training 

A-7
Appendix A – Grant Guidance 

and workshops aimed at building capacity and the development of public awareness and 

participation. 

 Milestones for demonstrating progress towards clean air in the border region are outlined 

by the Border 2012 Program and in EPA’s long and short term strategies goals and objectives. 

Grant assistance plays a key role in helping achieve them. Early efforts focused on developing 

an organizational infrastructure, raising awareness, gathering information and establishing 

baseline information. Recent assistance has increasingly been focusing on critical analysis and 

mitigation measures such as retrofitting diesel engines aimed at attaining clean air goals and 

building capacity for Mexico to take over management of these and similar programs. In 

FY2008 the Border 2012 Program Objectives for the Air Program were refined to include 

building border greenhouse gas (GHG) information capacity and expanding existing voluntary 

cost-effective programs for reducing GHGs in the border region. 

 

 In addition to supporting the efforts of affected state, local and multi-jurisdictional 

agencies, the Border 2012 Program uses regional workgroups, task forces, and policy forums to 

develop and implement air pollution emission reduction strategies. Many of these rely heavily 

on grass-roots input and actions. For example, OAR and its Mexican counterpart lead the Border 

2012 Air Policy Forum, established to employ a bottom-up collaborative approach to develop 

strategies for cooperative emissions reduction efforts along the border. EPA’s activities are 

designed to encourage, develop and implement cooperative projects with various levels of 

federal, state, and local government, tribes, academics, non-governmental organizations and 

others, so that sustained, comprehensive pollution abatement can occur in the common air sheds 

of border sister cities, as well as in remote areas where trans-border air pollution occurs. Air 

Policy Forum members additionally advise EPA and Mexico’s SEMARNAT on potential 

strategic funding needs and opportunities. 

 EPA Region 6 and 9 use a combination of direct grants and competitive solicitation to 

support state, local, and tribal initiatives. In encouraging local and grass-roots strategies, the 

Agency is committed to full and open competition for many grants and contracts. This 

empowers a larger number of state, local, tribal entities (also working with academics and 

NGOs) to become active participants in border air quality improvements. The combination of 

these grant funds with directed, specific projects facilitated by contracts has yielded very positive 

results. For example, Mexico has assumed increased ambient monitoring responsibility along 

portions of the border region. In FY 2009, approximately $2.7 million was available for Border 

work in Regions 6 and 9. The funding level for FY 2010 is still pending but funded activity will 

likely focus on three major areas: public outreach and involvement, the enhancement of 

scientific knowledge, and the support of projects that deliver tangible emission reductions. The 

Regions will work with OAR to assure that the activities funded are appropriate to the entities 

eligible and the appropriate authority for award. For more information on the program please 

contact: Ruben Casso in Region 6 (214-665-6763); and in Region 9, Christine Vineyard (415-

947-4125) or Andrew Steckel (415-947-4115). 

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Appendix A – Grant Guidance 

Multi-State Programs 

Regional Haze Planning Organizations 

 Dedicated funding for Regional Haze Planning Organizations (RPOs) was provided as 

part of EPA’s FY 2009 budget. Regional Haze State Implementation Plans (SIPs) were due to 

EPA by December 17, 2007. The RPOs were instrumental in providing the States with the 

needed materials to complete final preparation of their Regional Haze SIPs. EPA believes that if 

States choose to fund RPOs to assist with late SIP submittals or with developing their 

Reasonable Progress Plans, that decision is best made by the individual States and funds can be 

withheld from the State’s STAG allotment in consultation with the EPA regional offices. For 

additional information contact Jeff Whitlow at 919-541-5523. 

Northeast Ozone Transport Commission (OTC) 

 

 The OTC was created pursuant to sections 176A and 184 of the CAA. The OTC 

represents Northeastern and Mid-Atlantic states in the Ozone Transport Region (OTR) in: (a) 

assessing interstate transport of ozone and its precursors; and (b) determining the need for, and 

appropriateness of, additional control measures within the OTR, or areas affecting the OTR. The 

OTC is supported by a small executive staff that functions largely to coordinate OTC activities, 

facilitate communication among members, and serve as the point of contact for organizations 

external to the OTC, including EPA. The OTC Executive Director also serves on the CAAAC, a 

senior-level Federal Advisory Committee established in 1990 to advise EPA on issues related to 

implementing the Clean Air Act Amendments of 1990. The OTC also serves as the regional 

haze planning organization for the OTR, in concert with the Northeast States for Coordinated Air 

Use Management and the Mid-Atlantic Regional Air Management Association. 

 For FY 2010, the OTC’s work continues to focus on six areas: general analytical support to 

member states; analysis of mobile, stationary, and area source measures, particularly new clean 

air technologies; member communications; solicitation of non-governmental stakeholder input; 

coordination with other organizations; and consensus building. The focus areas are supported by 

OTC committees that develop and recommend specific action items for the Commission and the 

member states. The OTC implements its policy recommendations through consensus resolutions 

and draft model rules that provide guidance to member states. For more information contact Pat 

Childers in OPMO at 202-564-1082. 

National Association of Clean Air Agencies 

 The National Association of Clean Air Agencies or NACAA is the national association of 

state, territorial, and local air pollution control agencies in the United States. NACAA is 

supported with a small staff located in Washington, D.C. The objective of NACAA is to 

coordinate the air quality activities of state and local air pollution control officials at the national 

level and to engage in activities that enhance the effectiveness of their agencies. NACAA 

disseminates information through a variety of means (e.g., electronic newsletter, website, email, 

technical committees), plans and sponsors conferences and technical workshops (e.g., mobile 

source air quality, air pollution awareness, membership meetings) serves as a state/local liaison 

to EPA, coordinates member participation on EPA and joint State-EPA technical committees, 

produces technical assistance for members such as model rules and implementation strategies, 

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Appendix A – Grant Guidance 

and addresses air pollution control issues in concert with other public and private interests. 

 Funding for NACAA has been identified as part of the national allocation at the 

request of the member state and local air pollution control agencies for numerous years. A 

jurisdiction not participating in NACAA does not provide any of its allotted funds for support 

of the Secretariat. Traditionally, the NACAA executive board (comprised of state and local 

air pollution control officials) acts on a staff request for a two-year period and requests that 

EPA set aside funds from the participating state and local agencies= grant funds on a 

proportional (i.e., population) basis. 

 Since NACAA is forward-funded, fiscal year funds go to support operations for the 

ensuing fiscal year. Following state and local membership approval, EPA did approve a 

two-year request for NACAA for the period of FY 2008-2009. NACAA is currently 

receiving just over $1.58 million in FY 2008 STAG funds respectively for its FY 2009 grant 

year. These funds were requested by member state and local agencies to be set-aside by EPA 

from what would have been their grant allotment. Six states alternatively request that 

NACAA direct bill them for their contributions as their preferred payment approach. Since 

NACAA has not yet prepared a FY 2010 budget, the amount of federal FY 2009 funds to be 

requested has not been finalized. 

 As noted earlier, the Deputy Administrator has determined that before EPA can take 

funds off the top of a continuing state program allotment funded under 40 CFR 35 Subpart A 

to fund an eligible co-regulator organization like NACAA, EPA must first receive an 

assurance of prior concurrence from the head of any State environmental agency or 

department affected. While EPA is not prescribing an approach for doing this, OAR is 

advising that this assurance be obtained as part of the annual grant negotiation process for 

both state and direct-funded local air pollution control agencies.6 The concurrence should be 

documented by EPA in the recipient’s grant file. Actual award is still dependent on EPA’s 

review and formal approval of the application package. 

 EPA will provide a state-by-state breakout of share contributions once the all 

concurrences are received. For more information, contact William Houck at 202-564-1349 

or via email at B houck.william@epa.gov. 

 

6 Since NACAA membership is composed of both state and local direct-funded grant recipients, direct funded local 

agencies are also affected and should assure this prior concurrence. Pass-through local agencies do not have a direct grant 

relationship with EPA and would need to consult with their state. 

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Appendix A – Grant Guidance 

Program Support for States/Locals 

CAIR Seasonal NOx Trading Program 

 

 NOx emissions from electric power generation and 

other major stationary sources contribute significantly to the 

formation of ground-level ozone, a serious public health and 

environmental problem. Long-range transport of ozone and 

precursor pollutants means that problem analysis and 

mitigation must involve all of the jurisdictions with sources 

contributing to, and populations affected by, these pollutants. 

Experience has demonstrated that one of the most effective 

ways to achieve this is through a multi-jurisdictional, marketbased approach using a well-designed, centrally-administered 

NOx emissions budget and trading system. States affected by 

Highlights 

● NOx Budget program (NBP) 

phased out. 

 

● All NBP states plus 6 new nonNBP states participating in CAIR 

seasonal NOx trading program. 

● Initial compliance season for 

CAIR seasonal NOx program (May 

1 – Sep 30, 2009). 

the NOx SIP Call adopted this approach as part of their NOx State Implementation Plans. 

 For FY 2008 and FY 2009 respectively, support of the NOx Budget Program (NBP) 

for states affected under the NOx SIP Call and for transition of these states and additional 

non-NBP states into the CAIR seasonal NOx program has been provided in part from Sec 105 

grant funds of the affected states. (Jurisdictions not affected or not participating in the trading 

programs have not had to contribute their grant resources to support them.) There were 

2,594 affected, non-exempt units under the NBP in 2007. Through a wide range of pollution 

control strategies and an active NOx allowance trading market in 2007, emissions from 

affected sources continued to decrease in 2007. Emissions during the ozone season were 

60% percent below 2000 levels and 74% below 1990 levels. The volume of emissions data 

processed by EPA has increased almost 300% over the program in 2000, as has the number 

of end-of-season reconciliations of unit emissions against allowances held. In FY 2009, units 

in six additional states, which were not subject to NBP, participated in the EPA-administered 

regional allowance trading program and reported emissions data for the CAIR seasonal NOx

program. The initial compliance season for the CAIR seasonal NOx program is May 1 – 

September 30, 2009. 

 

 In FY 2009, EPA continued development and testing of the Emissions Collection and 

Monitoring Plan System (ECMPS) which will provide users with a single client tool for 

checking and submitting data, direct access to EPA’s database via this tool, and the ability to 

quality assure data prior to submission in FY 2010 and beyond. Several software 

development activities to contain or lower program operating costs are nearing completion 

and, as a result, the processing costs per source are lower than they would have been 

otherwise. EPA administers the allowance trading program; quality assures and processes 

reported emissions data, monitor certifications, and unit operating data; performs end-ofseason reconciliation of unit emissions with allowances held; and performs other 

administrative functions on behalf of the states through a national contract and associated 

program support. Support for operating the CAIR seasonal NOx trading program comes from 

the grant funds of participating states. As shown Table A-2, state shares are based on the 

A-11
Appendix A – Grant Guidance 

Table A-2. Contribution to CAIR Seasonal NOx Trading Program by Region and State 

 

Region I 173 $115,045

Connecticut 62 $41,230

Massachusetts 90 $59,850

New Hampshire 10 $6,650

Rhode Island 11 $7,315

Region 2 541 $359,765

New Jersey 178 $118,370

New York 363 $241,395

Region 3 523 $347,795

Delaware 40 $26,600

District of Columbia 5 $3,325

Maryland 50 $33,250

Pennsylvania 211 $140,315

Virginia 137 $91,105

West Virginia 80 $53,200

Region 4 1,001 $665,665

Alabama 126 $83,790

Florida 299 $198,835

Kentucky 109 $72,485

Mississippi 103 $68,495

North Carolina 159 $105,735

South Carolina 100 $66,500

Tennessee 105 $69,825

Region 5 924 $609,856

Illinois 280 $181,596

Indiana 187 $124,355

Michigan 158 $105,070

Ohio 193 $128,345

Wisconsin 106 $70,490

Region 6 156 $103,740

Arkansas 49 $32,585

Louisana 107 $71,155

Region 7 189 $125,685

Iowa 68 $45,220

Missouri 121 $80,465

Total Annual $ 3,507 $2,327,551

Region/ State

CAIR Seasonal 

Program Cost* 

FY2008 - FY2010

Units in CAIR 

Seasonal Program 

(as of FY2007)

* Processing cost per source calculated as $665 by OAP/CAMD. 

number of affected sources per state times a unit cost per source. Jurisdictions not affected 

or not participating in this EPA-administered centralized allowance trading program are not 

required to contribute grant resources. 

 EPA issues a yearly report on program compliance and environmental results (see 

http://www.epa.gov/airmarkets/progress/nbp07.html and US EPA, 2007 NOx Budget 

A-12
Appendix A – Grant Guidance 

Trading Program: Compliance and Environmental Results, EPA-430-R-08-008, December 

2008). For more information contact Larry Kertcher at 202-343-9121 or Doris Price at 202-

343-9067 in the Clean Air Markets Division of OAP. 

Clean Air Act Training 

 Section 103(b) of the Clean Air Act authorizes EPA to provide training for air 

pollution control personnel and agencies and to make training grants to air pollution control 

agencies and other qualified entities related to the causes, effects, extent, prevention and 

control of air pollution. In addition to the Agency resources that EPA targets, EPA is 

targeting approximately $2 million in STAG funds for the support of Clean Air Act training 

provided by multi-jurisdictional organizations and other state training programs in FY 2010. 

These funds are subject to consultation and concurrence with participating state and local air 

pollution control agencies. For more information contact Debbie Stackhouse in the Office of 

Air Quality Planning and Standards at 919-541-5281. 

 Section IV. AMBIENT MONITORING

Monitoring Highlights

● Ambient Air Monitoring implications for revised NAAQS 

3⁄4 Lead (Pb) NAAQS strengthened, includes new network requirements 

– published on November 12, 2008. 

3⁄4 Ozone (O3) NAAQS strengthened. Planned proposal for revised 

ozone monitoring network requirements in 2009 or early 2010. 

3⁄4 NO2 NAAQS proposal by June 2009 with a final completed by 

January 2010; 

3⁄4 SO2 and CO NAAQS reviews with final rules completed by May of 

2011. 

● Continued improvement of the ambient air monitoring program: 

3⁄4 Annual monitoring network plans for 2010 to include candidate 

NCore stations (plan due by July 1, 2009). 

3⁄4 The first 5-year assessment of each States Air Quality Monitoring 

Network is due to EPA by July 1, 2010. 

3⁄4 Date of data certification for ambient air monitoring data submitted 

to EPA moves up to May 1 starting in 2010. 

3⁄4 Further work on PAMS assessment 

3⁄4 Daily speciation through a combination of filter-based and 

continuous methods in a small number of cities to support multiple 

objectives including accelerating the pace of health studies 

3⁄4 Emphasis on air toxics “hot-spots” such as schools as part of next 

community-scale monitoring projects 

3⁄4 Characterization of Hazardous Air Pollutant (HAP) metals in the 

coarse particle fraction as part of air toxics method development. 

● Budget transition issues 

3⁄4 Reassessment plans for section 105 funds and monitoring input 

3⁄4 Transition of PM2.5 monitoring funds to section 105 

3⁄4 Comment sought on (a) utilizing 1⁄2 the available community-scale 

funds for implementation of the lead network; (b) transition of 

community-scale funds to section 105 authority; and (c) use of 

PAMS funds for National and Regional scale data analysis and 

equipment replacement

 EPA and its partners at 

state, local, and tribal agencies, 

manage and operate ambient air 

monitoring networks across the 

country with three primary 

objectives: to ensure the public has 

access to clean air by comparing 

data and implementation of the 

National Ambient Air Quality 

Standards (NAAQS), to provide 

the public with reports and 

forecasts of the Air Quality Index, 

and to provide information to 

health and atmospheric scientists 

to better inform future reviews of 

the NAAQS. 

 EPA works with state, 

local, and tribal air monitoring 

agencies to continuously improve 

the ambient air monitoring 

networks for current and future 

needs. This work includes 

milestones that have resulted from 

planning the ambient air 

monitoring network though a 

stakeholder driven process known 

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Appendix A – Grant Guidance 

as the Ambient Air Monitoring Strategy7 (monitoring strategy) as well as through NAAQS 

reviews that include both public and scientific input. 

 The major purpose of the monitoring strategy is to optimize the networks to be more 

responsive to current and future needs (e.g., assess air quality trends, better characterize the 

multi-pollutant nature of air pollution, provide for more timely information through 

continuous monitoring, better support development of improved air quality simulation 

models, etc.). EPA finalized revisions to the ambient air monitoring regulations in 20068 to 

align the ambient air monitoring requirements with the themes and objectives of the 

monitoring strategy. The new monitoring regulations: remove network minimums for some 

pollutants, lower minimum requirements for others, eliminate the National Air Monitoring 

Station (NAMS) designation, and reduce the requirements for photochemical assessment 

monitoring stations (PAMS). The new regulations also add some new monitoring 

requirements with implementation dates ranging from January 1, 2007 to January 1, 2011. 

 As part of its commitment to review each NAAQS within five years, EPA has recently 

reviewed and revised NAAQS for particulate matter (PM), ozone, and lead (Pb). The final 

rule for PM was published on October 17, 2006, for ozone on March 27, 2008, and for lead 

on November 12, 2008. EPA has begun the process of reviewing the NAAQS for NO2, CO, 

and SO2 with final rules expected in 2010 (NO2, and SO2) and 2011 (CO). Also, EPA has 

begun the process of the next reviews for PM and ozone so that they are completed within 

five years from the previous review. All of these reviews have either resulted in necessary 

changes to the monitoring networks to better support the NAAQS, or in the case of ozone, a 

commitment by EPA to propose changes to the monitoring requirements in the coming 

months. EPA is working closely with its partners through forums such as the Ambient Air 

Monitoring Committee of the National Association of Clean Air Agencies (NACAA) and the 

Ambient Air Monitoring Steering Committee (co-chaired by the NACAA State and local 

Monitoring Co-chairs and the Director of EPA’s Air Quality Assessment Division within the 

Office of Air and Radiation’s Office of Air Quality Planning and Standards) to ensure 

monitoring agencies and EPA are working together to improve the ambient air monitoring 

networks for current and future needs. 

 This document provides guidance for the use of PM, other criteria pollutants, PAMS, and 

air toxics monitoring resources, and reflects the emerging direction provided for in the 

Ambient Air Monitoring Strategy for State, Local, and Tribal Air Agencies while also 

considering the need for changes to the network in support of revised NAAQS. The 

guidance has been prepared consistent with the revisions to the ambient air monitoring 

regulations for applicable monitoring of PM, PM speciation, ozone, lead (Pb), PAMS, and 

NCore multi-pollutant stations. Guidance associated with NAAQS pollutants that have not 

had a recent review (i.e., nitrogen dioxide, carbon monoxide, and sulfur dioxide) is limited 

since the existing regulations only require retaining these monitors for a small number of 

areas; however, EPA is now encouraging retaining existing monitoring stations until network 

assessments are complete - due July 1, 2010 - and the NAAQS reviews are completed over 

the next three years. 

 

7

 Available at http://www.epa.gov/ttn/amtic/monstratdoc.html 8 40 CFR Part 53 and Part 58, October 17, 2006. 

A-14
Appendix A – Grant Guidance 

 

Highlights of Changes in Monitoring Funding for FY 2009 and 2010 

 At the time of release of this guidance, the President’s detailed FY 2010 funding 

request covering state and tribal grant programs had not yet been made public. In FY 2010, 

EPA expects to provide support for PM2.5 and air toxics monitoring funding through §103 

authority. Federal funding for PAMS is expected to be provided at the same level as 

previous years ($14M) within §105 to those regions with PAMS areas. All other monitoring 

operations are funded with §105 funds and state or local funding as part of the minimally 

required match to §105 funding. Specific details of EPA’s plans for monitoring funding in 

2009 and 2010 follow. 

● In this guidance, for planning purposes, OAR is operating under a budget scenario 

reflecting the most recently enacted budget year – FY 2009. In negotiating grants using FY 

2010 funds, EPA’s priority will be that essential monitoring for protection of public health 

from PM exposure above the NAAQS will not be compromised. It is EPA’s intention to 

negotiate grant work plans and accountability measures that ensure that PM2.5 monitoring 

activities required by regulation, needed for the development of SIPs, or needed for 

informing the public of days with unhealthy air quality are continued. 

● In developing the FY 2010 PM2.5 monitoring allocation, OAR will employ the same 

region-by-region funding approach used in prior years – e.g., determination of per month 

costs of operating the existing network. This cost per month is based on examining prior 

year grants in detail and determining a cost per month for each grantee. For FY 2009, all 

PM2.5 monitoring grants are to be scheduled to end on March 31, 2010. Therefore, funding 

for FY 2010 will be for a 12 month period beginning April 1, 2010. Nominal replacement of 

existing PM2.5 monitoring equipment (e.g., FRMs) is to be funded out of each agencies 

regular PM2.5 monitoring grant. 

● For the PM2.5 network, EPA considers the overall size of the existing Federal Reference 

Method (FRM)/Federal Equivalent Method (FEM) network adequate for implementing the 

revised NAAQS. Regional offices and the states should consider: (a) whether the current 

network of FRM/FEM and supplemental PM2.5 speciation sites is optimal for supporting 

implementation of the revised PM2.5 NAAQS, and (b) how samplers among stations and even 

funds among states would need to be shifted to provide equitable access to the speciation 

data needed to understand the causes of 24-hour NAAQS nonattainment for each prospective 

nonattainment area. Also, changes in population exposure and emissions patterns may mean 

that a small number of sites each year may need to be re-located. Any possible changes to 

the PM2.5 network are to be identified in the respective agencies annual monitoring network 

plan due to the applicable EPA Region by July 1 of each year according to §58.10 – Annual 

Monitoring Network Plan and Periodic Network Assessment.

A-15
Appendix A – Grant Guidance 

● There will be changes in the unit cost of PM2.5 filters and speciation laboratory services 

provided as associated program support due to pre-negotiated contract increases in unit 

prices. As a placeholder until monitoring agencies inform EPA of their planned use of filters 

and laboratory services in 2010, EPA will initially reserve funds as associated program 

support based on an assumption that the number of filters and the number of monitoring sites 

requiring laboratory services will be the same in 2010 as in 2009. 

● EPA recently issued a new five-year contract for chemical analysis and reporting of the 

Speciation Trends Network (STN) and supplemental stations that make up a large portion of 

the Chemical Speciation Network (CSN). The other major component of the CSN is the 

IMPROVE protocol stations run by state, local, and tribal agencies; however, laboratory and 

reporting services for IMPROVE protocol stations are provided as part of an interagency 

agreement with the National Park Service. The Speciation Trends Network (STN) operates 

every third day and the supplemental stations nominally operate every sixth day. Under the 

new contract, all STN and supplemental stations are now supported with Teflon and nylon 

filter modules for the Met One SASS or Met One SuperSASS samplers. 

● EPA is continuing to work with the National Park Service and state, local, and tribal 

agencies on a new carbon sampling platform for the STN and supplemental chemical 

speciation network stations. On April 1, 2009, monitoring stations at 63 locations were 

scheduled to begin sampling using the URG 3000N sampling platform. This sampler is 

being implemented to align carbon sampling and analysis methods with the IMPROVE 

program. The April 1, 2009 start date represented the second of three phases of the carbon 

sampler conversion. The first phase included implementation of 56 stations utilizing a 

combination of single and collocated samplers (3 stations are collocated); while the third 

phase is expected to include 77 stations, with implementation expected in late 2009. The 

costs associated with implementation of the carbon sampler conversion have been paid for 

with §103 PM2.5 monitoring funds from FY 2008 and earlier. No FY 2009 or FY 2010 funds 

are expected to be needed to complete the remainder of this project. Details on the carbon 

sampler conversion can be found at: http://www.epa.gov/ttn/amtic/specurg3000.html . 

● Funding for the portion of the IMPROVE program that addresses progress in improving 

visibility in Class I areas will remain the same as in previous years. This includes funding 

for the 110 IMPROVE stations needed to meet the regional haze rule requirements of states 

monitoring Class I areas for long-term trends through and beyond the 10-year SIP period 

(2008 to 2018), as well as being useful in the required periodic assessments of progress 

towards the national visibility goal. 

● The level of funds for the nationally administered, independent Performance Evaluation 

Program (PEP) provided as associated program support for PM2.5 monitoring is expected to 

be approximately $1.5 million. Monitoring agencies with an adequate level of independence 

between quality assurance and monitoring groups may conduct the PEP themselves. In these 

cases monitoring agencies that conduct the PEP will receive the refundable portion of the 

EPA program costs that would otherwise have been used to pay for EPA regional lab 

contract staff. 

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Appendix A – Grant Guidance 

● EPA is developing a lead (Pb) Performance Evaluation Program (Pb-PEP). This 

program will operate similar to the PM2.5 PEP with a call letter for participation to be sent at 

the same time as the call for participation in other federally implemented performance 

evaluation programs. Where federally implemented, EPA Regional ESAT contract staff are 

expected to leverage audits for multiple programs when visiting an area. The cost of 

participation in this program is being developed and will depend on the number of 

participating agencies, the number of stations to audit each year, and the number of audits 

that can be leveraged with other activities during a visit to an area. 

● The level of funds for the nationally administered, independent National Performance 

Audit Program (NPAP) is expected to be approximately $454,000. Similar to the PEP, in the 

NPAP, monitoring agencies with an adequate level of independence between quality 

assurance and monitoring groups may conduct the NPAP themselves and receive the §105 

funds that otherwise would have supported their participation in the national program. 

● The 24-hour PM10 standard protects the public from effects of short-term exposure to 

inhalable coarse particles, and PM10 monitoring should continue in areas at risk of violating 

that standard. In other areas, reductions in PM10 monitoring may be appropriate. Agencies 

are encouraged to migrate to low-volume PM10 sampling as aged PM10 samplers are 

replaced, especially at stations with existing PM2.5 FRMs, to allow for measurement of PM10-

2.5. 

 

● As one of the NCore multi-pollutant monitoring requirements, EPA is requiring PM10-2.5 

mass (using the new federal reference method or a future equivalent method) and PM10-2.5 

speciation (no method yet specified) at between 62 and 71 locations. Since NCore is not 

required to be operational until January 1, 2011, the FY 2010 allocation does not specifically 

target funds for the creation of PM10-2.5 mass or speciation measurements. However, PM10-2.5 

mass measurements can be easily obtained using co-located low-volume PM10 and PM2.5 

samplers and many agencies are already performing or planning to perform these 

measurements soon. For PM10-2.5 speciation, EPA will be engaging the Clean Air Scientific 

Advisory Committee’s Ambient Air Monitoring and Methods Subcommittee this year. Since 

PM10-2.5 speciation is not fully developed, EPA is only encouraging this measurement as part 

of special projects and studies designed to address specific issues and not part of any routine 

monitoring operation. For 2010, EPA encourages the mass measurement of PM10-2.5 at 

NCore and other important sites as determined within monitoring agencies. 

● In FY 2011, EPA also anticipates that there may be shifts in PM2.5 monitoring funds 

among regions to reflect further transition to continuous PM2.5 instruments, addition of 

precursor gas monitoring capability at NCore multi-pollutant sites, and discontinuation of 

additional PM2.5 speciation sites. 

● For FY 2010, EPA is still seeking comment on utilizing $150,000 each year, prorated 

from each PAMS recipient, to perform regional and national scale assessments of the data. 

This is planned to be follow-up to the existing assessments to enhance the usefulness and 

utility of the PAMS data. Assessments will be performed to address a number of questions 

A-17
Appendix A – Grant Guidance 

on the wealth of data collected by agencies operating PAMS. As in the past, EPA will solicit 

input among PAMS data users, including State and local agencies, on priorities for national 

and regional assessments. 

● For FY 2010, EPA is still seeking comment on a reserve of 5% of the PAMS funds 

($700K) for the expressed purpose of purchasing new capital equipment (e.g., gas 

chromatographs and upper air meteorology equipment) for participating agencies. The 

proposal has been made since several PAMS agencies have reported they are unable to 

purchase new equipment and much of their existing inventory of PAMS monitoring 

equipment is outdated. 

● In FY 2010, EPA anticipates funding air toxics monitoring at the existing 27 National 

Air Toxics Trends Stations (NATTS). 

● For the 2010 community-scale air toxics funds, EPA plans to continue support for 

monitoring projects involving “hot-spots” such as locations where schools may be impacted 

from a local source or sources with elevated levels of air toxics emissions. EPA is planning 

to continue the development of the lead (Pb) monitoring network over the two-year period 

from 2010 and 2011. The need and requirement for the network was identified as part of the 

recent NAAQS review. Lead is unique among all air pollutants in that it is both a criteria 

pollutant and a hazardous air pollutant (HAP). 

Fine Particulate (PM2.5) Monitoring Network 

 On October 17, 2006 EPA revised the PM2.5 NAAQS by lowering the 24-hour (or 

daily) standard from 65μg/m3

 to 35μg/m3. EPA also retained the existing annual fine particle 

standard at 15 μg/m3. In the monitoring rules supporting the PM2.5 NAAQS, EPA requires 

monitoring agencies to locate at least one PM2.5 monitoring site for each Metropolitan 

Statistical Area (MSA) in a population-oriented area of expected maximum concentration. 

Under the 1997 PM2.5 NAAQS, the design values for almost all non-attainment areas were 

driven by the annual NAAQS. With the new lower PM2.5 daily NAAQS, a majority of areas 

will be driven by the daily NAAQS. However, in most cases the area of expected maximum 

concentration will be the same. 

 In planning a PM2.5 monitoring network for 2010, agencies will need to consider how 

their networks are addressing the network design requirements as part of their annual 

network reviews due each summer. Agencies are to review their PM2.5 design values for 

2006-2008 and determine if they are required to continue or start operating daily sampling 

according to §58.12 – Operating Schedules. For a small number of cases, a new monitoring 

site may need to start up; in other cases, sites may need to move. EPA envisions that 

state/local agencies will continue to maintain a large robust network of PM2.5 monitors to 

support several monitoring objectives including protection of public health through the 

NAAQS. 

 The PM2.5 monitoring network includes three well-established components: the 

network of filter-based FRM/FEMs used for comparison to the NAAQS; continuous mass 

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Appendix A – Grant Guidance 

monitors used in public reporting of the Air Quality Index; and speciation program samplers 

and monitors including the Speciation Trends Network, supplemental speciation sites, and 

the IMPROVE program used to characterize the chemical composition that makes up fine 

particulate matter. Smaller dynamic components of the PM2.5 monitoring program include a 

small network of continuous speciation monitors and the measurement of precursors to PM2.5 

at NCore multi-pollutant stations. Areas of interest to enhance PM monitoring include 

reinvesting monitoring resources into high sensitivity monitoring of CO, SO2, and NO2/NOy

to better characterize precursor gases that lead to particle formation, expanding the network 

of PM2.5 continuous monitors, and planning for daily speciation sampling in a small number 

of the most populated cites in the country where this information can support data needs in a 

state and for use in helping expedite health studies. 

Overall Direction 

 FY 2010 continues a multi-year transition of the ambient air monitoring conducted by 

state and local air monitoring agencies along the path set by the Monitoring Strategy. For 

PM2.5 this means continued operation of high value federal reference method (FRM) and 

speciation sites; PM2.5 continuous monitoring and associated data management systems for 

timely reporting of high quality data; and precursor gas analyzers, data analyses and quality 

assurance activities that will support better understanding of particle formation. 

 The restructured networks will continue operation of high value sites, with 

investments and divestments. To provide a clearer understanding of the expected outcomes 

of the ambient air monitoring objectives, the following goals for the fine particulate 

monitoring network have been developed: 

• Appropriate spatial characterization of PM2.5 NAAQS; 

• Public Reporting of PM2.5 in the AQI; 

• Characterization of PM2.5 chemical speciation data for long term trends, 

development and accountability of emission control programs, tracking of 

regional haze, and for use in health studies; 

• Implementation of NCore trace-level CO, SO2, NO2/NOy and NH3 monitoring to 

support characterization of PM precursors; 

• Assessment of PM2.5 data quality; 

• Procurement and testing of PM2.5 filters. 

Divestments 

 In the revisions to the ambient air monitoring regulations, EPA finalized reductions to 

the required number of FRM/FEM in larger cities and eliminated FRM/FEM requirements 

for some rural areas. For some areas, especially large cities well below the revised NAAQS, 

this may provide an opportunity to divest of one or more redundant monitoring sites. For 

other areas it may provide an opportunity to move one or more sites, which are not the design 

value sites, to get a better spatial characterization of PM2.5 or seek locations that are a 

concern with the more protective daily PM2.5 NAAQS. 

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Appendix A – Grant Guidance 

 Chemical speciation data from the Speciation Trends Network, IMPROVE, and the 

remaining supplemental speciation sites will continue to be utilized to track progress over 

time as the national and local control programs are implemented. There are some areas that 

are expected to be in residual nonattainment for PM2.5 even after the national control 

strategies are implemented that may have attainment deadlines beyond 2009, or that may be 

designated nonattainment with the revised 24-hour PM2.5 NAAQS. In these cases the 

regional office and the state, and where appropriate, local agencies, should work out an 

appropriate network design for the chemical speciation component of their PM2.5 monitoring 

network within the available allocation, as part of their annual network review. States and 

local agencies may consider divesting of low-value supplemental speciation stations in areas 

that are not expected to be in violation of the PM2.5 NAAQS. 

 In the revisions to the ambient air monitoring regulations, EPA finalized new 

requirements for the number of required Performance Evaluation Program (PEP) audits that 

result in an overall national reduction in the required number of site audit days. For FY 2010 

the cost of the PEP will be about $1.5 million. Costs for the PEP to a monitoring 

organization are determined by the number of sites within a monitoring organization. States 

with multiple monitoring agencies not already organized under one Primary Quality 

Assurance Organization should consider doing so to save minimize the number of required 

audits.

 As in 2009, monitoring organizations will again be asked to determine whether they 

plan on implementing the PM2.5 Performance Evaluation Program (PEP) or allow for 

continued Federal implementation of this program. Monitoring organizations must meet the 

minimum requirements of adequate and independent in order to implement the PEP. OAQPS 

has provided guidance to regional offices on how to assess adequacy and independence of 

proposed audit programs.9 Information on this decision process will be provided in a 

memorandum from the EPA regional office to the monitoring organizations each year in 

order to make decisions that will affect the next calendar year audit activities. OAQPS 

anticipates that a FY 2010 guidance memorandum covering details on participation in the 

PM2.5 PEP will be issued to the EPA regional offices in June 2009. 

Investments 

 The revisions to the Ambient Air Monitoring Regulations published in the Federal 

Register on October 17, 2006 include new performance based criteria for approval of 

continuous PM2.5 methods as equivalent to the filter-based FRM. On March 12th, 2008, 

EPA’s Office of Research and Development approved the first continuous PM2.5 FEM10. 

This method is now available and its data can be compared to the NAAQS as well as for 

public reporting of the Air Quality Index (AQI). However, at the time of this writing no 

other instruments have been approved. With just one approved continuous PM2.5 FEM, but 

possibly more on the way, it may make sense to modify the start date for any newly required 

 

 9 January 8, 2007 memorandum from Phil Lorang (Ambient Air Monitoring Group Leader) to Regional Office 

ambient monitoring managers. 

10 Met-One BAM1020 – PM2.5 configuration, Automated Equivalent Method – EQPM – 0308 - 170 

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Appendix A – Grant Guidance 

continuous monitor stations11 until multiple vendors are offering continuous instruments that 

have been approved as federal equivalent methods (FEM) or monitoring organizations 

themselves have applied for and received approval for continuous approved regional methods 

(ARM). Monitoring agencies that are comfortable with the approved method could benefit 

by discontinuing operation of some or all (with the exception of required FRMs for QA 

purposes) of their FRMs, which tend to be costly to operate due to pre- and post- sampling 

laboratory analysis. These savings could be used to pay for some of the cost of the new 

monitors; however, capital acquisition funds would need to be provided up-front for the new 

monitors. Therefore, EPA regions will work closely with state and local agencies within the 

existing funding allocations on whether new monitors should be purchased. Technical 

direction on implementing and reporting data from continuous PM2.5 FEM and ARM 

monitors is available on EPA’s AMTIC web site12. 

Gas monitoring with high sensitivity measurements of CO, SO2, and NO/NOy will 

continue as part of the PM2.5 monitoring network to support characterization of PM 

precursors in FY 2009 and FY 2010. Planning over the last few years has resulted in funding 

being available for all required NCore multi-pollutant sites for these pollutants using 

carryover funds from prior years and planned funds from fiscal years 2005 through 2007. 

 EPA will also be working with state and local agencies to pilot a small number of PM2.5

continuous mass monitors and ammonia samplers where funds are available. For daily 

speciation EPA expects to work with a small number of monitoring agencies to pilot daily 

characterization of fine particle chemical speciation using a combination of continuous and 

filter-based technologies. One solution might include post-sampling laboratory analysis of 

elements on Teflon filters with semi-continuous operation of sulfate and carbon monitors. 

 Monitoring agencies may also find it useful to use a portion of their direct awards to 

implement additional meteorology equipment that supports forecasting of the AQI. Of 

specific interest may be recently commercialized, high quality, and lower priced instruments 

that characterize the vertical thermal structure of the boundary layer. 

 For FY 2009 and FY 2010, PM2.5 monitoring grant funds allocated to states can be 

directed towards improvements in data management systems to support timely reporting of 

high quality data from PM continuous mass monitors, PM continuous speciation monitors, 

and precursor gas monitors. Resources dedicated to this area will support processing, 

validating, and reporting or data that supports the PM monitoring program. 

 In late 2009, EPA expects to host a comprehensive National Ambient Air Monitoring 

Conference. This conference was last held in November of 2006 shortly after the Revisions 

to the Ambient Air monitoring Regulations were published. EPA and state and local 

agencies will both benefit by strong participation in this conference to manage and enhance 

 

11 The October 17, 2006 Revisions to the Ambient Air Monitoring Rule provide that for every required 

FRM/FEM in a MSA at least 1⁄2 that many stations must operate a PM2.5 continuous method. These required 

PM2.5 continuous methods were to be operational by January 1, 2008. 12 http://www.epa.gov/ttn/amtic/datamang.html 

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Appendix A – Grant Guidance 

the ambient air monitoring program. EPA regions are encouraged to make participation in 

the conference a condition of each agencies PM2.5 monitoring grant. 

Distribution of Funds13

 The draft FY 2010 guidance does not yet include an allocation of PM2.5 monitoring 

funds among regional offices for use in direct awards.14 EPA must still consult with 

stakeholders about how to allocate PM2.5 monitoring funding in light remaining 

implementation issues associated with NCore. A final allocation will include tables that will 

provide more detailed information on the region-by-region allocation including cost 

estimates for associated program support. Cost estimates will be based on an assumption that 

monitoring organizations will not reduce their networks (and the services/ materials needed 

to support them) in 2010 compared to previous years. The estimates should help inform how 

the program costs may change this coming year and are subject to change based on 

monitoring organizations’ actual plans for the numbers of sites that will need these services 

in FY 2010.15 These numbers may decline if states choose not to maintain their existing 

PM2.5 monitoring networks. 

For more information on PM2.5 monitoring, contact Tim Hanley at 919-541-4417 or via 

mail at hanley.tim@epa.gov. 

Monitoring Networks for Other NAAQS Pollutants (and PM10-2.5) 

Support of Established NAAQS Networks 

 This section covers monitoring networks for the other pollutants covered by a NAAQS -- 

ozone, lead (Pb), CO, SO2, NO2, PM10, -- and PM10-2.5.

16 Of these pollutants ozone has the 

 

13 In FY 2006 and earlier years, EPA’s national guidance set aside PM2.5 monitoring funds for use in funding several 

categories of associated program support, allocated the remaining funds among the regional offices for use in direct grants, 

and provided targets or suggestions for how the regions might negotiate funding levels for specific categories of state/local 

monitoring activities; for example operation of filter-based monitors versus continuous monitors. For FY 2007, EPA 

restructured the targeted categories of program support and state/local monitoring operations to focus more on activities that 

are of current special interest, for example new monitoring sites required as a result of the revised 24-hour PM2.5 NAAQS. 

In FY 2007, EPA worked with grant recipients to develop work plans that were intended to utilize available FY 2007 and 

earlier funding by a common date of March 31, 2008, at which time FY 2008 funding would begin. For some recipients, 

this meant a grant period different than 12 months. The savings in shorter grant periods for these recipients have been 

reapplied to meet the listed types of new monitoring needs wherever they exist. In FY 2008 PM2.5 monitoring grants were 

negotiated between EPA regional offices and state and local agencies for the period April 1, 2008 thru March 31, 2009. 

These grants utilized §103 authority as directed in EPA’s appropriation. 

16 Once the president’s detailed budget has been announced, a final allocation will be provided. 

15 State and local agencies have costs associated with many activities within each monitoring program area. Not all types 

of operating expenses may be accounted for. Some of these costs are fairly well understood such as capital infrastructure, 

salaries of staff and management working on the program, and costs of expendable items used in the program. Less 

obvious, but important to include in planning operation of a network, are costs of participating in conferences and 

workshops that support training and building further expertise in agencies operating the network. 

16 On October 17, 2006 EPA revoked the annual PM10 NAAQS everywhere. 71 FR 61144. The 24-hour PM10 NAAQS was 

retained everywhere. No NAAQS was established for PM10-2.5. On the same day, EPA also promulgated a Federal 

Reference Method for PM10-2.5 and certain monitoring requirements for PM10-2.5 as part of the new NCore network with an 

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Appendix A – Grant Guidance 

most robust network with over 1200 stations across the country. Networks for CO, SO2, 

NO2, and PM10 are still maintained in most agencies with minor divestments over the last 

several years (see figure below); however, for lead there has been a substantially larger 

divestment due to almost all monitoring stations being substantially below the previous lead 

(Pb) NAAQS. Additional information on each network is summarized below. 

 In March of 2008, EPA strengthened the ozone NAAQS by revising the 8-hour 

standard to a level of 0.075 ppm. Despite having a large and robust ozone monitoring 

network already operating in most urban areas across the country, EPA stated its intention17

to propose a separate rule to address changes to the ozone monitoring requirements. Changes 

to the ozone monitoring requirements are necessary to implement the revised ozone NAAQS. 

These changes may affect the required ozone season, requirements for minimum monitors in 

smaller urban areas – where monitoring are not currently required, and requirements for 

Table A-2 

non-urban areas such as sensitive ecosystems. The proposed rule may occur in 2009 or early 

2010 and finalized in time for implementation of some or more requirements in 2010. 

Funding needs associated with any changes to the ozone monitoring requirements are not 

established at this point since the proposal has not yet been published. 

 In October of 2008, EPA significantly strengthened the lead NAAQS from 1.5 μg/m3 to 

0.15 μg/m3 as measured by total suspended particulate. For lead, the existing lead 

monitoring network was considered inadequate to implement the revised lead NAAQS and 

therefore, changes to the lead monitoring requirements were included along with the revised 

lead NAAQS. With a substantially stronger NAAQS, regional offices and state and local 

monitoring agencies should work closely together to ensure that any sources of lead exposure 

 implementation date of January 1, 2011. 71 FR 61236. A plan for PM10-2.5 monitoring at NCore is due by July 1, 2009. FY 

2009 grant funds should be used to begin development of this plan. EPA is not requiring that any FY 2009 or FY 2010 

grant funds be used to implement PM10-2.5 monitoring, although that is an eligible use of grant funds where negotiated 

between a Regional Office and a recipient. 

17 http://www.epa.gov/air/ozonepollution/pdfs/2008_03_factsheet.pdf 

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Appendix A – Grant Guidance 

have been identified and appropriate steps are taken (ensuring the adequacy of the emission 

inventory and modeling impacts) to determine if ambient air monitoring is warranted. EPA 

is requiring near-source monitoring to begin operation by January 1, 2010 and non-source 

monitoring by January 1, 2011. Annual monitoring network plans corresponding to the nearsource and non-source monitoring are due by July 1, 2009 and July 1, 2010. EPA has 

proposed the a total of $2.5 million in FY 2009 funding under §105 authority for this 

monitoring and this effort will continue under the President’s FY 2010 budget request. EPA 

will work with state and local agencies to begin planning their lead network starting during 

CY 2009. 

 Over the next three years, EPA expects to complete reviews of the remaining NAAQS 

that have not had a recent review (i.e., NO2, SO2, and CO). The NO2 review is scheduled to 

be completed by January 22, 2010; the SO2 primary standard review by June 2, 2010; the 

NO2 and SO2 secondary standards are being reviewed together and are to be completed by 

October 19, 2010; and the CO standard - both primary and secondary – is to be completed by 

May 13, 2011. Each of these reviews may result in necessary changes to the monitoring 

requirements to implement each NAAQS. 

With possible changes to each of the NAAQS that have not had a recent review and 

the requirement for each state - and where delegated - applicable local agencies to perform a 

comprehensive assessment of their ambient air monitoring network every five years18, EPA 

is now asking agencies to hold off on substantial changes to their ambient air monitoring 

network until each of these activities are complete. EPA acknowledges that ambient air 

monitoring agencies will not have the benefit of all NAAQS having recent reviews prior to 

submitting their comprehensive assessments by July 1, of 2010; however, to the extent that 

existing monitoring stations can be maintained, especially when multiple measurements are 

leveraged and data are being utilized, agencies may find that existing stations are useful for 

one or more of the revised NAAQS. EPA is developing network assessment tools and will 

be sharing these tools on upcoming conference calls and workshops that state and local 

agencies attend. Ultimately, these tools will be available on EPA’s web site; likely on the 

Air Quality Analyses web site19. 

 FY 2010 STAG grant funds for the aforementioned ambient monitoring programs 

should be utilized to provide: 

• National and local spatial characterization of ozone (O3) relative to the NAAQS; 

• National and local public reporting of O3 in the AQI; 

• Local public reporting of CO, SO2, NO2, and PM10 in the AQI for areas where 

these pollutants are of concern; 

• Local characterization of the CO, SO2, NO2, and PM10 NAAQS in the few areas 

with NAAQS non-attainment and maintenance issues; 

• Implementing newly required near-source lead (Pb) monitoring stations by 

January 1, 2010, where required or there is the potential to exceed the Pb 

 

18 40 CFR §58.10 

19 http://www.epa.gov/ttn/analysis/ 

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Appendix A – Grant Guidance 

NAAQS; 

• Planning non-source Pb monitoring stations in MSAs over 500,000 people that 

are to begin operation by January 1, 2011; 

• In addition to the monitoring provided for above, limited characterization of O3, 

CO, SO2, NO2, Pb, and PM10 data in all other areas for long term trends, support 

for long-term health and scientific assessments, and development and 

accountability of emission control programs as part of a multi-pollutant approach 

to air quality management; 

• Assessment of O3, CO, SO2, NO2, Pb, and PM10 data quality; 

• Analysis and interpretation of the O3, PAMS, CO, SO2, NO2, Pb, and PM10

monitoring data and development of data assessment tools; 

• Procurement and testing of PM10 filters, including 46.2 mm Teflon filters used in 

low-volume PM10 samplers; 

• Independent and adequate assessment of these pollutants’ data quality, which is 

required in 40 CFR Part 58. This assessment is based on audit data generated 

under the National Performance Audit Program (NPAP). State and local agencies 

will choose either to obtain audit services through EPA-managed contracts funded 

with STAG funds, or may operate equivalent state-managed programs using 

independent staff, equipment, and standards. In some regions, EPA staff may 

perform or assist in audits with no charge to STAG funds, depending on staff and 

travel funds availability. 

• Reporting and certification of ambient air monitoring data required20 to be 

submitted to the Air Quality System (AQS) database. In 2010 the date of 

certification moves up from July 1 to May 1. 

Ambient Air Performance Evaluation Programs 

 A performance evaluation is a type of audit where quantitative data is collected 

independently in order to evaluate the proficiency of an analyst, laboratory, or some or all of 

the component parts of a data collection activity. EPA implements a number of performance 

evaluation programs on behalf of the monitoring agencies. Two major federally implemented 

performance evaluation efforts include the National Performance Audit Program (NPAP) for 

the gaseous pollutants and the Pb-Performance Evaluation Program

National Performance Audit Program (NPAP) 

The NPAP is a cooperative effort among OAQPS, the EPA regional offices, the 

monitoring organizations that operate EPA-funded air pollution monitors, and the other 

organizations that operate air monitors for example at PSD sites. The implementation goals 

of the NPAP are to audit approximately 20 percent of the monitoring sites in the Ambient Air 

Quality Monitoring Network each year. 

 Although it is a goal to visit every monitoring site generating data that has 

significance to the air quality program within a 5-year period, among these sites there is an 

 

20 §58.15 – Annual air monitoring data certification, and §58.16 – Data submittal and archiving requirements. 

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Appendix A – Grant Guidance 

emphasis on auditing higher priority monitors (e.g., sites prioritized for health risk reasons) 

more frequently. In 2008, the requirement for adequate independent audits applies to sites 

with monitoring types not designated as “non-regulatory. The NPAP program uses a throughthe-probe (TTP) audit system, where appropriate for the monitoring situation given a site’s 

physical layout. This system has the advantage of testing the performance of the entire 

monitoring sampling train including inlets and manifolds, and provides station operators 

immediate feedback on the audit results. 

Each year, monitoring organizations are asked whether they plan on implementing the 

NPAP or would prefer continued Federal implementation of this program using STAG funds. 

Any non-EPA audits arranged by monitoring organizations must meet the minimum 

requirements of being adequate and independent. Additional guidance on demonstrating that 

a state-implemented program meets these minimums will be provided in a memorandum 

early in the calendar year. Under this approach EPA reserves a portion of appropriated 

STAG funds to cover potential Federal implementation of the NPAP, based on the number of 

geographically separate monitoring sites (not the number of distinct monitors) within each 

EPA Region. 

 The initial reserve of FY 2010 funds is estimated to be approximately $454,000. This 

is based on EPA’s current understanding of monitoring organizations’ intentions for how 

NPAP audits will be implemented in 2010. If the number of sites in a Region to be audited 

by EPA staff or EPA-managed contractors is reduced because more monitoring organizations 

plan on implementing a program of adequate and independent NPAP audits without reliance 

on EPA contractors, and those organizations are assessed by the EPA regions as capable to 

perform the NPAP by September 2009, a corresponding amount of STAG funds will be 

made available to the regional office for allocation as direct awards. The amount of funds 

held by EPA to perform the NPAP includes both a fixed cost associated with programs tools 

and equipment such as standard operating procedures and hardware and variable costs such 

as the operator time and travel costs associated with the number of audits conducted. The 

September 2009 cutoff date gives EPA time to make necessary contracting and other 

arrangements for the audits it will manage in 2010. 

Lead Performance Evaluation Program (Pb-PEP) 

The implementation of a Pb-PEP is a new requirement starting in calendar year 2010 

and it provides an assessment of overall bias at the primary quality assurance organization 

(PQAO) level. PQAO is defined in 40 CFR Part 58 Appendix A. The program will be a mix 

of one or two PM2.5 PEP like audits with additional collocated sampling. The program will 

require the same number of audit samples as required for PM2.5 meaning: 

o PQAOs with < 5 sites require 5 audits (1 PEP, 4 collocated) 

o PQAOs with > 5 sites require 8 audits (2 PEP, 6 collocated) 

 The Pb-PEP audits consist of the implementation of a separate portable TSP Pb 

audit sampler that is placed within 2-4 meters of the routine Pb sampler, is operated by an 

independent auditor and the sample is shipped to an independent Pb-PEP laboratory for 

analysis. For the collocated samples, each quarter the monitoring organization field operator 

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Appendix A – Grant Guidance 

will take one additional collocated sample and send this sample to the independent Pb-PEP 

laboratory for analysis. 

Similar to the PM2.5 PEP and the NPAP, implementation decisions for Pb-PEP are 

made by the monitoring organizations on an annual basis. EPA will draft a memo to the 

monitoring organizations to determine whether they plan to self implement the Pb-PEP or 

utilize the federally implemented program using STAG funds. Any non-EPA audits arranged 

by monitoring organizations must meet the minimum requirements of being adequate and 

independent. The definition for adequate and independent for Pb-PEP will be very similar to 

PM2.5 PEP and the actual requirements will be developed by June, 2009. The decision memo 

will be distributed in July 2009 and take the form of previous PM2.5 PEP decision memos. It 

is very likely that the Pb-PEP information will be incorporated into PM2.5 memo so all 

decisions are made at the same time. An example of one of these decision memos can be 

found at: http://www.epa.gov/ttn/amtic/npepqa.html. The EPA regions will collect this 

information from the monitoring organizations and provide the information to OAQPS in 

time to redirect the appropriate STAG funds for the federally implemented program. 

Under this approach EPA reserves a portion of appropriated STAG funds to cover 

potential Federal implementation of the Pb-PEP, based on the number of monitoring sites 

(not the number of distinct monitors) within each PQAO within a Region. 

Another QA activity being developed as part of supporting the revised lead (Pb) 

monitoring network is making available Pb quality control strips for laboratories that provide 

analytical support. EPA envisions a program where a third party laboratory develops lead 

strips with known concentrations that are sent to participating Pb analytical laboratories. 

Data from participating laboratories would be reported similar to current lead strip reporting 

requirements, and assessments would be available for determining laboratory bias. Funds to 

support the third party contractor are still being determined and are proposed to be reserved 

from §105 funds. 

The amount of funds held by EPA to perform the Pb-PEP includes both a fixed cost 

associated with programs tools and equipment such as standard operating procedures and 

hardware and consumables and variable costs such as the operator time and travel costs 

associated with the number of audits conducted. 

 

Photochemical Assessment Monitoring System (PAMS) 

Required by section 182(c)(1) of the Clean Air Act, the PAMS program collects 

ambient air measurements in areas classified as serious, severe, or extreme ozone 

nonattainment. Each PAMS area collects data for a target list of volatile organic compounds 

(VOCs), NOx, NOy, and ozone, as well as surface and upper air meteorological 

measurements. 

Monitoring rule amendments published on October 17, 2006 greatly reduced the 

minimum PAMS requirements. The revisions were intended to require the retention of the 

minimum common PAMS network elements necessary to meet the objectives of every 

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Appendix A – Grant Guidance 

PAMS program, while freeing up resources for states to tailor other features of their own 

PAMS networks to suit their specific data needs. Overall, the changes significantly reduced 

the costs of the minimum PAMS monitoring requirements, but it was not EPA’s intention to 

require or encourage a reduction in the overall level of PAMS monitoring. The following 

summarizes the changes to the PAMS requirements: 

• The number of required PAMS sites has been reduced. Only one Type 2 site is 

required per area regardless of population, and Type 4 sites are no longer required. 

Only one Type 1 or one Type 3 site is required per area. 

• The requirements for speciated VOC measurements have been reduced. Speciated 

VOC measurements are only required at Type 2 sites and one other site (either Type 1 

or Type 3) per PAMS area. 

• Carbonyl sampling is no longer required. 

• NO2/NOx monitors are required only at Type 2 sites. 

• Trace level NO2/NOy are required at one site per PAMS area (either Type 1 or Type 

3). 

• Trace level CO is required only at Type 2 sites. 

Consistent with recent years, FY 2010 STAG funds will support four types of PAMS 

activities: monitoring system implementation and operation including replacement of aging 

equipment, data reporting to AQS, data analysis, and quality assurance. Also, regions are to 

plan and as appropriate approve the use of some of these funds to replace or upgrade aging or 

obsolete equipment. For FY 2010, about $14 million is targeted for operation of the PAMS 

network. Of this, $10.5 million has nominally been allocated for program implementation 

and operation, data reporting, and QA. $3.5 million has been nominally allocated for data 

analysis by state and local agencies. However, Regional Offices have had the flexibility to 

allow states to adjust this split and even to use a portion of their designated PAMS funds for 

other purposes. Table A-3 shows the FY 2009 allocation of PAMS funds within the regional 

allotments.. These PAMS funds are included in the ozone category of the national region-byregion allocation. 

The §105 reallocation study process now underway also provides EPA and its state 

and local partners an opportunity to critically re-examine the purposes, funding level, and 

basis for distribution of funds targeted for PAMS support. A variety of considerations could 

be involved including accounting for those areas subject to the changing PAMS rule 

requirements, relative ozone air quality, the robustness of the networks, dollar needs over 

time, etc. EPA would like to discuss the future of PAMS with the state and local agencies as 

part of the analysis process. 

In addition to the reallocation study, EPA is also working with its state and local 

partners that are involved in PAMS in an assessment of the program. This PAMS assessment 

includes a workgroup of representatives from EPA, state, local, and multi-state. The 

assessment is scheduled to be completed during FY 2009. Outcomes of the assessment have 

identified many insightful interpretations of the data, but also the need for additional followup work. EPA seeks comment on follow-up assessment work by utilizing a prorated amount 

from each PAMS Region in the amount of $150,000 during both FY 2009 and FY 2010. 

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Appendix A – Grant Guidance 

 The PAMS program has been operational since the mid 1990’s and as such for a 

number of agencies the monitoring equipment is becoming significantly aged. Some 

agencies have been able to upgrade or buy new equipment from within their exiting, 

allocation; however, due to the high initial capital cost, many other agencies have reported 

they are not able to set aside enough funds from within one year to purchase these large 

capital cost items. For FY 2010, EPA solicits comment on a hold-back of 5% of the PAMS 

Table A-3. Distribution of FY 2009 Funds for PAMS Support 

Region 

Number 

of 

PAMS 

Areas 

Local 

Data 

Analysis 

Implementation 

and Operation Total 

Total with proposed 

$150K set aside for 

national data analysis 

and $700K set aside 

for equipment 

replacement 

1 5 $726,297 $2,125,815 $2,852,112 $2,678,979 

2 1 $232,415 $571,060 $803,475 $754,701 

3 3 $348,623 $1,087,907 $1,436,530 $1,349,328 

4 1 $145,259 $366,848 $512,107 $481,020 

5 21 $290,519 $959,749 $1,250,268 $1,174,372 

6 5 $617,603 $2,061,029 $2,678,632 $2,516,030 

7 0 $0 $0 $0 $0 

8 0 $0 $0 $0 $0 

9 82 $1,162,075 $3,307,303 $4,469,378 $4,198,071 

10 0 $0 $0 $0 $0 

National Data 

Analysis $150,000 

Equipment 

Replacement $700,000 

Totals 24 $3,522,791 $10,479,711 $14,002,502 $14,002,502 

1 Chicago and Milwaukee have a combined network. 2 So. Coast & Mojave Desert AQMDs have a combined network 

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Appendix A – Grant Guidance 

funds ($700K) for the expressed purpose of purchasing new capital equipment (e.g., gas 

chromatographs and upper air meteorology equipment) for participating PAMS agencies. If 

successful, EPA would work with all PAMS agencies to set up a equipment replacement plan 

over a multi-year period. 

 Notwithstanding a re-allocation, and in light of the recent changes in PAMS 

requirements, regional offices should still re-examine the current split between data analysis 

and implementation and operations with their recipients rather than strictly adhere to the 

splits shown in Table A-3. Regional offices may also consider other departures from 

historical funding practices, for example providing more funds to a particular state in FY 

2010 to support a needed one-time intensive study, with temporarily reduced funding for 

routine PAMS monitoring in other states. In CY 2009 or 2010, resources permitting, EPA 

will issue a new technical guidance document to assist regional offices and states in 

evaluating the utility of the data collected by current PAMS networks and in identifying new 

types of PAMS monitoring that can provide useful missing data for ozone attainment 

planning. 

 EPA recognizes that the PAMS sites are a major source of data on air toxics including 

some of the toxics that contribute significantly to the total risk from air toxics in some of the 

largest cities. The regions, state and local monitoring agencies should keep this dual purpose 

in mind as the plan network changes in FY 2010 and beyond. For example, as speciated 

VOC sampling is reduced at type 4 sites, consideration should be given to moving to autoGC sampling at the remaining PAMS sites. 

FY 2010 PAMS Activities for State and Local Agencies

 The allocated PAMS funds should be used to meet the following objectives: 

(1) Continue System Implementation 

• Reduce number of monitoring sites and monitoring at remaining sites, while 

remaining in compliance with revised PAMS regulations or approved alternative 

plans developed as part of reconfiguration efforts. 

• Operate remaining existing sites, including replacement of aging equipment. 

• Continue to improve NOx monitoring, replacing NOx instruments with NOy/NO 

instrumentation and/or more sensitive NO2/NOx monitors at select PAMS sites. 

• Install and operate trace level CO monitors at Type II sites. 

• Develop and conduct area specific ozone precursor studies based on area specific 

needs. 

• Continue making surface measurements of wind direction, wind speed, temperature, 

and humidity at all PAMS sites and additional measurements of solar radiation, 

ultraviolet radiation, pressure, and precipitation at one site in each PAMS area. 

Continue making upper-air measurements of wind direction, wind speed, and 

temperature at a representative location in each PAMS area. The upper-air monitoring 

program will depend upon region-specific factors such that the optimum design for a 

given PAMS region is expected to be some combination of remote sensing and 

A-30
Appendix A – Grant Guidance 

conventional atmospheric soundings. 

• For PAMS sites collocated with NCore multi-pollutant precursor gas sites, the 

meteorological monitoring data for ambient temperature, wind speed, wind direction, 

relative humidity, barometric pressure, and solar radiation are to be submitted to the 

AirNow program. 

(2) Data Analysis 

• Continue to develop and implement PAMS data analysis plans at the state and local 

levels that demonstrate use of data, provide analyses demonstrating data analysis 

products and results commensurate with allocated resources targeted for data analysis 

in grant work plans and the minimum set of PAMS data analyses specified in EPA 

guidance. 

• Use PAMS data to develop and optimize control strategies in State Implementation 

Plan for ozone. 

• Develop trends in ozone precursors, based on PAMS data that may serve to 

corroborate “rate-of-progress” and accountability demonstrations. 

• Use PAMS data to corroborate ozone precursor emissions inventories and to address 

transport concerns. 

(3) Data Reporting 

• All PAMS data, including meteorological data, shall be submitted into AQS 

consistent with 40 CFR Part 58. 

• All PAMS data shall be identified in EPA’s Air Quality System (AQS) as monitor 

type ‘PAMS’ or ‘Unofficial PAMS’. 

• Adequate procedures must be developed and followed to ensure proper validation of 

data prior to submission to AQS. 

(4) Quality Assurance 

• All sites must have and operate according to a Quality Assurance Project Plan 

(QAPP) approved by an EPA regional office. 

• Ensure that adequate and independent audits are conducted for FRM and FEM 

SLAMS monitors at PAMS sites. These audits are discussed above under ‘National 

Performance Audit Program (NPAP).’ 

Air Toxics Monitoring 

 For FY 2010, the President’s request includes resources for the support of national air 

toxics monitoring and characterization activities. Funds are awarded under §105 authority to 

continue support for ongoing air toxics monitoring activities initiated and conducted by state 

and local air quality agencies. In addition, the Agency is proposing dedicated funds under 

CAA §103 for the support of : (1) operation and maintenance of the multi-year National Air 

Toxics Trends Stations (NATTS), and (2) local air toxics monitoring projects (see Table A4). Funding for NATTS and local projects is being planned with §103 authority which 

enables 100% federal funding. 

A-31
Appendix A – Grant Guidance 

Included in the NATTS program total are three supplemental program components: 

quality assurance, methods development, and an analysis initiative using all available 

ambient air quality data for toxics with special emphasis on observations from the NATTS 

and community-scale monitoring programs. These three components are associated program 

support for all grants that support air toxics monitoring or management activities. FY 2010 

will be the eight overall year of NATTS data collection, the sixth complete year of NATTS 

data collection, and the fourth local-scale grant cycle in seven years. The desired program 

objectives are: 

• Establish trends and evaluate the effectiveness of air toxics emissions reduction 

strategies. 

• Characterize the local-scale ambient concentrations that result when air toxics 

originating from local sources concentrate in relatively small geographical areas, 

producing the greatest risks to human health. 

• Provide data to support, evaluate, and improve emission inventories and air quality 

models used to develop emission control strategies, perform exposure assessments, 

and assess program effectiveness. 

• Provide data to support scientific studies to better understand the relationship between 

ambient air toxics concentrations, human exposure, and health effects from these 

exposures. 

 In FY 2009, EPA expects approximately $4.1 million in §103 STAG funds will be used 

to fund operation of the National Air Toxics Trends Station (NATTS) Network during the 

period July 1, 2009 – June 30, 2010. About $0.8 million is proposed to be used for quality 

assurance, data analysis, and methods and instrumentation associated with the NATTS 

program. 

 The NATTS program component will continue to build on the established quality 

assurance and methods protocols. Laboratory and field staff continue to work with EPA to 

ascertain the optimum methods for capturing and analyzing core pollutants associated with 

risk, develop performance based quality indicators to prove valid data results that will 

contribute to our understanding of risks, and stabilize the measurements for all NATTS sites 

so that comparisons across the nation can be made. Efforts to further improve methods for 

hexavalent chromium and acrolein are anticipated to continue through at least 2010, and 

additional methods development work may include how to best measure coarse particles 

(PM10-2.5) for HAP metals and other speciation components to complement the existing 

measurement of metals in PM10 at NATTS. The analytical community will continue to 

assess trends in air toxics concentration levels, relate those data to associated risk levels, and 

explore relationships between these ambient and risk levels to emission sources and changes 

in these levels to emission reduction efforts. 

 The community-scale projects are intended to better characterize air toxics problems 

at the local level and to address those problems through local actions which complement 

national regulatory requirements. Such monitoring has the potential to elucidate the scope of 

local air toxic problems, measure what reductions have been achieved through actions taken, 

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Appendix A – Grant Guidance 

and provide information needed for local policy development on reducing emissions from 

particular sources. 

While aimed at meeting local data needs, EPA expects that data, results, and findings 

from all community-scale projects will also be valuable to other areas and to the national air 

toxics programs. Hence, a portion of the air toxics STAG funds are used to organize, 

summarize, and analyze the air toxics data from the community-scale studies and the NATTS 

sites (and data from other monitoring efforts) and to communicate the findings to all states 

involved in air toxics management. This includes a data analysis workshop. 

 While EPA anticipates that monitoring of air toxics hotspots at the community level, 

particularly around schools, will continue into FY 2010, EPA intends to further consult with 

stakeholders on the nature and approach for local scale air toxics monitoring for FY 2010. 

The Agency will produce supplementary information and guidance for FY 2010. For further 

information regarding prior year community-scale air toxics monitoring projects, including 

previous solicitations, successful project proposals and final reports, may be found at: 

http://www.epa.gov/ttn/amtic/local.html. For more information contact Michael Jones in 

OAQPS’ Ambient Air Monitoring Group at 1-919-541-0528, or jones.mike@epa.gov. 

 The FY 2010 allocation categories and amounts are provided in Table A-4. The 

funding allocation for operation of NATTS sites will be sub-allocated to the regions with 

state and local agencies hosting those sites. The split of funding among the other listed line 

items may be adjusted prior to the start of FY 2010 based on consultations with state and 

local air agency representatives. Funds for other line items listed are anticipated to be used 

in nationally administered support contracts or competitively awarded to eligible recipients 

for specific activities. 

Table A-4 

Proposed FY 2010 Funding for Lead, National Air Toxics Trends 

and Community-Scale Monitoring 

$4,195,000 Operation and maintenance of existing and new NATTS sites.

 $320,000 NATTS Quality Assurance: includes periodic Proficiency Testing, targeted Technical 

Systems Audits, and annual data quality assessment via centrally (OAQPS) managed 

contracts. 

$300,000 Data Analysis: delineate and assess trends, data and network assessment to include 

exploration / demonstration of monitoring data utility in providing local scale findings that 

are useful in S/L/T air quality program management, and Annual Data Analysis Workshop 

for EPA and S/L/T’s to share results; synthesize into annual report. 

$180,000 Methods and Instrumentation: support for improved air toxics monitoring methodology, 

especially for priority HAPs for which methods either do not exist, or existing methods have 

been deemed insufficient to meet end user needs; acquire new, upgrade, or replacement 

sampling or analytical equipment on a limited, case-by-case, as needed basis in direct 

support of NATTS.

Pending Community-scale monitoring projects: EPA is seeking comment on supporting monitoring 

projects involving “hot-spots” such as locations where schools may be impacted from a 

local source or sources with elevated levels of air toxics emissions. .

TBD Total Funding 

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Appendix A – Grant Guidance 

 

IMPROVE Visibility Monitoring Network 

The IMPROVE monitoring program supports the national goal of reducing haze to 

near natural levels in National Parks and wilderness areas. IMPROVE monitoring sites 

collect data on visibility, including optical, photographic, and speciated particulate data, 

though EPA resources are only used for the particle speciation monitoring. EPA works with 

the Regional Planning Organizations (RPOs) to help states prepare their SIPs for regional 

haze rule (these were due 12/07). Data from IMPROVE sites are needed to meet the regional 

haze rule requirements of states for monitoring Class I area long-term trends through and 

beyond the 10-year SIP period (2008 to 2018), as well as being useful in the required 

periodic assessments of progress towards the national visibility goal. States also use data 

from the IMPROVE network to characterize upwind and background PM10 and PM2.5

conditions and to assess source attribution for the PM2.5 and PM10 NAAQS in nonattainment 

areas. 

The IMPROVE network was started in 1987 as part of a federally-promulgated 

visibility plan and operated by the Department of the Interior (DOI) under the direction of a 

multi-agency federal/state steering committee. EPA expanded the original network in FY 

1999 and FY 2000 from approximately 30 sites to 110 sites. The expanded network covers 

all of the Clean Air Act Class I areas where visibility is important (except the Bering Sea 

area which is impractical to monitor). EPA provides state/local air quality management 

STAG funds to the DOI to help maintain the IMPROVE network because of the importance 

of IMPROVE data to development of SIPs for both regional visibility and PM NAAQS 

attainment. The DOI and the other participant organizations contribute in excess of $3 

million of their own funds or in-kind resources per year to support field operations and other 

monitoring at IMPROVE sites. 

For reasons of convenience and/or consistency of data, a number of state, local, and 

tribal monitoring organizations have historically chosen to ask the IMPROVE program to 

provide field technical support and laboratory services for additional sampling stations at 

locations under their control, using the IMPROVE protocols for sampler design, sampler 

operation, and laboratory analysis. Data from these additional “state/local IMPROVE 

protocol sites” (currently about 60) are managed and made public along with the data from 

the 110 sites in protected class I areas. These additional sites are provided as associated 

program support. This arrangement will continue in FY2010. In addition, some federal 

agencies provide full funding for additional IMPROVE protocol sites to meet various 

program or research objectives. 

Tribal, state, local, and federal monitoring organizations may continue, discontinue, 

or add sites for the monitoring period which runs from July 1, 2010 through June 30, 2011. 

Once a monitoring organization has identified its source of funds for such sites, it may 

contact Marc Pitchford (see below) to request monitoring support services and to begin 

arranging for the necessary funds transfer. Requests should be made as early in calendar year 

2010 as possible, but no later than April 30, 2010. Tables A-3 and A-4 are based on a 

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Appendix A – Grant Guidance 

placeholder assumption that monitoring organizations will retain all current state/local 

IMPROVE protocol sites in 2010. 

After extensive testing to ensure data comparability, the IMPROVE steering 

committee approved a change in carbon analysis methodology (both analyzer and protocol) 

to replace their 18-year old analyzer systems with new system for all samples collected 

starting in 2005. The IMPROVE steering committee also mandated the development and 

approved for use a revised algorithm for estimating light extinction from IMPROVE PM 

speciation data, that is expected to be used by most (perhaps all) states in their Regional Haze 

Rule SIPs. A revised (incorporating the latest data flags and edits) IMPROVE dataset 

required by the Regional Haze Rule for the 5-year baseline period (2000 to 2004) was 

disseminated through the IMPROVE and VIEWS (http://vista.cira.colostate.edu/views/). The 

Visibility Information Exchange Web System (VIEWS) is a database system and set of 

online tools originally designed to support the Regional Haze Rule. VIEWS provides easy 

online access to a wide variety of air quality data and provides online tools for exploring and 

analyzing these data. It also is used to facilitate the research and understanding of global air 

quality issues. 

 For FY 2009, about $2.6 million of PM2.5 monitoring funds appropriated under §103 

authority and about $1.2 million of state/local STAG funds appropriated under §105 

authority were proposed to be targeted to support visibility monitoring at 110 IMPROVE 

sites and 7 sites collocated with CASTNET. For more information on the IMPROVE 

program, contact Tim Hanley (919-541-4417) or Lew Weinstock (919-541-3661) in OAQPS. 

Planning Information for Ambient Monitoring on Tribal Lands

 

EPA respects each tribe’s sovereign ability to identify its air quality goals and to 

make monitoring decisions it deems appropriate for its needs. This section addresses issues 

for consideration when conducting ambient air quality monitoring in the particular context of 

an EPA grant work plan. There are no Clean Air Act requirements for ambient monitoring 

on tribal lands, so tribes have flexibility in customizing ambient monitoring to address the 

many different situations they face in terms of air quality and other environmental concerns. 

Whatever the local situation, the purpose of any ambient monitoring should be to inform the 

public living in Indian country about the quality of the air where that quality is in doubt, to 

assist the tribe in managing its air quality, to help the tribe make the case that other 

governments or private parties need to control emissions due to their effect on air quality on 

tribal land, and/or to help track the effects of control actions to verify that they have 

addressed a problem. 

 For some tribes ambient monitoring may or may not be a priority for funding 

compared to other air quality program or environmental program activities. If monitoring is 

conducted, a tribe’s interests can be best served when the type of monitoring is appropriate 

for the specific situation. For a given tribe, some types of monitoring may be useful, while 

others may not be relevant. With limited resources available, strategic planning based on 

A-35
Appendix A – Grant Guidance 

thoughtful priorities is needed. The EPA regional offices will be the principal EPA partners 

with tribes in this case-by-case planning. 

 Over the last few years, EPA has emphasized that data from EPA-funded monitors on 

tribal lands should be available to both EPA and the general public through the AQS or other 

relevant national data system, once start-up issues are worked out and the data are reliable. 

EPA will continue to work with tribes on workable alternatives for data preparation and 

submission. In awarding grants to tribes with FY 2010 funds, regional offices are expected 

to make sure that tribes will have a way to get data submitted, including QA-related data. 

 EPA has developed an Ambient Air Monitoring Strategy for State, Tribal and local 

Air Agencies that re-examines how the national ambient monitoring programs can be more 

thoughtfully directed towards their multiple purposes 

(http://www.epa.gov/ttn/amtic/monstratdoc.html)

21. For the most part, this strategy addresses 

situations and considerations relevant to states, rather than the special situations and 

considerations relevant to tribes. In FY 2008, EPA developed a document titled: Technical 

Guidance for the Development of Tribal Air Monitoring Programs

(http://www.epa.gov/ttn/oarpg/t1/memoranda/techguidancetribalattch.pdf ) with the intent of 

providing tribes a better understanding of the ambient air monitoring process and to provide 

information on resources and tools to help build and sustain and air quality monitoring 

program. For 2009 and beyond, EPA may provide additional guidance specifically related to 

tribal air monitoring. Any new guidance will continue to provide flexibility for tribes and 

regional offices to address the many different air quality situations on tribal lands on a caseby-case prioritized basis. See: http://www.epa.gov/oar/tribal/tam.html for information on 

the progress in developing new guidance for tribal monitoring. 

 Technical assistance in conducting ambient monitoring is provided to tribes through 

the Tribal Air Monitoring Support (TAMS) Center (http://www4.nau.edu/tams/ ). TAMS 

staff can provide more specific information on any of the types of monitoring described here.

 The remainder of this section provides general information that may assist tribes in 

clarifying their objectives for ambient monitoring and getting started on planning monitoring 

to meet those objectives. 

Air Toxics Monitoring: This may be the type of ambient monitoring of most interest to 

many tribes, because local sources potentially subject to tribal management can dominate 

exposures and because public perceptions of air toxic risks can be strong. As with all 

monitoring, the purpose of monitoring air toxics is to identify problems that merit action, 

plan what action will be effective, and track the effects of the action to verify it has addressed 

the problem. Of the 187 officially listed air toxic compounds under the Clean Air Act, a 

subset of 18 have historically been monitored at EPA-funded non-tribal sites.22 In 2008, 

 

21 The Ambient Air Monitoring Strategy was last updated in December of 2008. 

22These monitored compounds are: benzene, carbon tetrachloride, chloroform, 1,3-butadiene, 

1,2-dichloropropane, methylene chloride, tetrachloroethylene, trichloroethylene, vinyl chloride, arsenic and 

compounds, beryllium and compounds, cadmium and compounds, Hexavalent chromium, lead and compounds, 

manganese and compounds, nickel and compounds, acetaldehyde, formaldehyde, and acrolein. 

A-36
Appendix A – Grant Guidance 

EPA expanded the list to cover a number of Polycyclic Aromatic Hydrocarbons (PAHs). 

Tribal monitoring likely should not aim beyond this list or its revision without specific local 

reasons, and should not necessarily attempt to measure all of these. While many other 

compounds will be collected on the same filter or cartridge, or in the same canister, there is 

extra cost at the laboratory for each compound that is measured and reported. Some of the 

compounds on this list, for example carbon tetrachloride, are not emitted (or not supposed to 

be emitted) from any current source and/or have about the same concentration everywhere in 

the U.S. so there is little to be gained from measuring them on any particular reservation. 

For many air toxics (except some gases), samples need to be collected in the field (or 

indoors) and shipped to specialized laboratories for analysis. EPA has contracts with 

qualified labs which make it relatively easy to have this done. 

Interpreting air toxics monitoring data is not a simple task, since there are no bright legal 

lines between “acceptable” and “unacceptable” air quality, as there are for NAAQS 

pollutants. Interpretation can be more difficult or impossible if the monitoring location or the 

monitoring schedule is not appropriate for estimating risk to residents. Each regional office 

has specialists in risk assessment that can assist tribes in planning air toxics monitoring so 

that it is useful. 

 See http://www.epa.gov/air/tribal/airtoxics.htm for more information on air toxics from a 

tribal perspective. See http://www.epa.gov/ttn/amtic/airtoxpg.html for information on 

monitoring of air toxics. See http://www.epa.gov/ttn/atw/nata for the 1999 National Scale 

National Air Toxics Assessment website23; the information and links on this website may be 

useful background when considering whether and what air toxics to monitor on a reservation, 

even if no 1999 assessment was possible for that reservation due to lack of an emissions 

inventory. 

Monitoring for NAAQS Pollutants using Federal Reference Methods (FRM) or Federal 

Equivalent Methods (FEM): This type of monitoring is primarily useful for determining on 

a formal basis whether air quality in a given location meets or does not meet a national 

ambient air quality standard (NAAQS), for example ozone, PM2.5, PM10, CO, SO2, NO2 or 

lead. It takes three years of data collection to make this determination for most NAAQS of 

interest. Establishing attainment status via FRM/FEM monitoring data can be important as it 

can affect the legal requirements that apply to sources at and around that location. It can also 

affect whether a tribe can pursue action to seek emission reductions from upwind sources 

beyond the tribal boundary. 

 Monitoring for certain NAAQS pollutants may indicate a need to reduce emissions within 

the tribal boundary in order to protect public health of the residents, but in many cases it will 

be obvious from an understanding of emission-generating activities that local sources do not 

cause or contribute to concentrations near or above the NAAQS. Judging from experiences 

 

23 The 1999 NATA is the latest available as of January 2009. 

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Appendix A – Grant Guidance 

in many non-tribal situations around the country, CO nonattainment is very unlikely on 

reservations, even where traffic is attracted by entertainment centers. 

 On October 17, 2006, EPA promulgated a rule which lowered the 24-hour PM2.5 NAAQS 

from 65 to 35 micrograms per cubic meter. This change should be considered when planning 

tribal monitoring, because the more stringent standard is more likely to be violated as a result 

of local sources such as seasonal wood burning, wild fires, and prescribed burning than is the 

annual PM2.5 NAAQS. EPA also revoked the annual PM10 NAAQS everywhere (not the 24 

hour PM10 NAAQS). This change is expected to have no impact on tribes, as the annual 

standard was rarely violated anyway. PM10 and PM2.5 sources on reservations (wood 

burning, fires, road and agricultural dust, etc.) could be a problem by themselves or on top of 

concentrations coming from upwind areas. 

 In March 2008, EPA strengthened the ozone NAAQS by revising the 8-hour standard to a 

level of 0.075 ppm. At the time of finalizing the ozone NAAQS, EPA stated its intention to 

propose a separate rule to address changes to the ozone monitoring requirements that would 

be necessary to implement the revised ozone NAAQS. These may include proposed changes 

to the required ozone season, requirements for minimum monitors in smaller urban areas – 

where monitoring are not currently required, and requirements for non-urban areas such as 

sensitive ecosystems. The proposed rule may occur in 2009 and finalized in time for 

implementation of some or more requirements in 2010. However, as explained earlier no 

such requirements would exist for tribal nations. Despite monitoring regulations not being 

required of tribal nations, the potential for these changes are mentioned here so that they can 

be considered for implementation in tribal monitoring programs in 2010, if available at that 

time. The potential for ozone nonattainment, if it exists, is most likely due to upwind offreservation sources. Tribal monitoring programs may have an interest in characterizing both 

ozone exposure of their population as well as characterizing sensitive ecosystems on their 

lands. 

 In October 2008, EPA significantly strengthened the lead NAAQS from 1.5 μg/m3 to 

0.15 μg/m3

 as measured by total suspended particulate. With a substantially stronger 

NAAQS, regional offices and tribal monitoring agencies should work closely together to 

ensure that any sources of lead exposure on or immediately impacting tribal lands have been 

identified and appropriate steps are taken (ensuring the adequacy of the emission inventory 

and modeling impacts) to determine if ambient air monitoring is warranted. 

 Before beginning any NAAQS monitoring, the regional office and tribe should consider: 

(1) whether attainment status can be determined with reasonable confidence in other ways 

(including passive monitors and other methods that do not qualify as Federal Reference 

methods but can be sufficient for unofficially showing that concentrations are well below the 

NAAQS), (2) how information on the attainment/nonattainment status once available could 

affect management of the tribal air program, and (3) how long the monitoring should 

continue if it does or does not show a NAAQS violation. 

 The EPA regional offices should work with the tribes to review the status and continued 

utility of any FRM monitors which have been operating long enough to have to have 

A-38
Appendix A – Grant Guidance 

reasonably complete data for at least 3 to 5 years. If attainment with a comfortable margin 

has been found and if there is no on-reservation or nearby development that is likely to 

change the situation substantially, it may be good to discontinue this type of monitoring in 

favor of other environmental management efforts. 

Continuous PM2.5 Monitoring – There are several types and brands of monitors that 

provide estimates of PM2.5 concentrations on a continuous basis, without need for filters to be 

sent to a laboratory for weighing. These are both less expensive to operate than a filter-based 

monitor and can give information on air quality that tribal officials and the public can use in 

real time to manage emission sources and personal activities. The first continuous PM2.5

Federal Equivalent Method (FEM) was approved by EPA’s Office of Research and 

Development on March 12, 2008 and others may be approved in the coming year. For a 

complete list of approved methods, see: http://www.epa.gov/ttn/amtic/criteria.html. 

Continuous PM2.5 monitors with official status as a Federal Equivalent Method (FEM) can be 

used for purposes of comparing to the NAAQS. 

Passive Monitoring and Other Types of Screening Monitoring: A passive monitor is one 

which “soaks up” pollution rather than actively collecting it on a filter or pumping it through 

an on-site measurement device. This means they can be used where there is no electricity 

supply. Also, the monitoring unit is usually inexpensive, so it is possible to place them more 

closely together or over a much larger area than conventional powered monitors could 

possibly be placed. Passive monitors are not suitable for formal designation of an area as 

attainment or nonattainment but they can help a tribe understand the air quality situation on 

its reservation, for example, what part of a reservation has the worst air quality and whether 

any part has concentrations that approach health benchmarks. There are passive monitors 

available for a number of pollutants including several volatile organic air toxics including 

benzene, ozone, CO, and SO2. Time periods for exposing the monitor to the ambient (or 

indoor) air vary. The monitors must be collected each sampling period and sent to a 

laboratory for chemical analysis, so costs are not insignificant. Passive monitoring programs 

are usually of short duration because of the field labor and laboratory costs, compared to 

automated continuous analyzers. They have the advantage of requiring little up-front 

investment, however. EPA Region 6 has been in the forefront of applying passive 

monitoring to a variety of situations on and off reservations. See 

http://www.epa.gov/ttn/amtic/passive.html for more information. 

Photochemical Assessment Monitoring: This is a very specialized type of monitoring 

related to the ozone NAAQS, in which air samples collected in the morning are taken to a 

laboratory for measurement of the concentrations of many individual hydrocarbon species 

including some toxic gases. This monitoring is only done during the ozone season. The 

purpose is to help identify the chemicals and sources contributing to ozone and the most 

efficient controls for reducing ozone concentrations. It is unlikely that this type of 

monitoring meets any distinct tribal need. See http://www.epa.gov/ttn/amtic/pamsmain.html

for more information. 

PM2.5 Speciation Monitoring: This is a very specialized and expensive type of monitoring 

related to the PM2.5 NAAQS, in which filters collected over a 24-hour period are shipped by 

A-39
Appendix A – Grant Guidance 

overnight express to a laboratory for measurement of various components of PM2.5 such as 

sulfate, nitrate, elemental carbon, organic carbon, and individual metals. This type of 

monitoring is done every third or every sixth day, year round. The purpose is to help identify 

the direct and precursor pollutants and sources contributing to PM2.5 and the most efficient 

controls for reducing PM2.5 concentrations. Most STN sites are in urban areas. This type of 

monitoring may meet a tribal need, if a PM2.5 nonattainment (or near nonattainment) situation 

is confirmed through simpler monitoring and its causes are not apparent, if high numbers of 

diesel engines operate in or upwind of the reservation, or if sources of toxics metals in PM2.5

form are known or suspected to be a health risk. However, if metals are a concern, it may be 

more appropriate to sample for metals in PM10 form in order to capture all the PM that enters 

the human thorax and may affect health. Most air toxics monitoring programs sampling for 

toxic metals do so in PM10 form. See http://www.epa.gov/ttn/amtic/speciepg.html for more 

information. 

IMPROVE Protocol Monitoring: IMPROVE stands for Interagency Monitoring of 

Protected Visual Environments. The IMPROVE program is described elsewhere in this 

Appendix. See http://vista.cira.colostate.edu/improve/ for more information. Each site has 

several monitors, all aimed at collecting information to understand what pollutants and 

sources contribute to haze and to track changes in visibility over many years. Among these 

monitors are a PM10 sampler and samplers to provide speciation details for PM2.5. These data 

allow calculation of an index of visibility. The IMPROVE program can be convenient for 

the monitoring organization providing the site, because the IMPROVE program contractors 

provide equipment installation, training, periodic field support, laboratory analysis, and data 

management and publication. 

 Over the last several years, about 10 tribes have applied for and received grant assistance 

from their EPA regional office to allow them to request the IMPROVE program to establish 

and provide technical services for an IMPROVE protocol sampling station on tribal land. 

Some tribal sites have operated for a period and then been discontinued. The grant funds 

needed to pay for this are awarded to the tribe by the EPA regional office, but transferred to 

the IMPROVE program through OAQPS. Tribal monitoring organizations may ask for FY 

2009 funding from their EPA regional office to continue, discontinue, or add sites for the 

monitoring period which runs from July 1, 2009 through June 30, 2010. FY 2010 funding 

would be used for the July 1, 2010 through June 30, 2011 period. Once a tribal monitoring 

organization has been awarded funds for such sites, the tribe and/or the regional office may 

contact EPA to request monitoring support services and to begin arranging for the necessary 

funds transfer. Requests should be made as early in calendar year 2010 as possible, but no 

later than March 31 in order to start or continue monitoring on July 1. 

 In some cases in the past, a Regional Planning Organization or other multi-state 

organization has funded a tribe’s operation of an IMPROVE protocol site because of its 

advantageous location. In the future, EPA plans on streamlining this process by talking to 

the regions and Tribes at the early stages of the planning process so IMPROVE funds for 

tribal sites (that decide to operate for the next fiscal year) can be forwarded directly to 

OAQPS without being distributed to the regions and then being transferred to OAQPS. This 

should save time and provide for greater efficiencies. 

A-40
Appendix A – Grant Guidance 

 IMPROVE protocol monitoring is the generally accepted approach to quantifying 

visibility, and is the right approach if a tribe has a need for such quantification. EPA regional 

office staff can assist a tribe in understanding how such data could be used for official and 

unofficial purposes. Because the protocol quantifies carbonaceous material in PM2.5, 

IMPROVE protocol sampling may also be of interest if high numbers of diesel engines 

operate in or upwind of the reservation. IMPROVE monitors are not Federal 

Reference/Equivalent monitors, however, and cannot be used for designation purposes or to 

officially trigger a requirement for off-reservation sources to reduce their adverse impact on 

attainment within a reservation or other tribal land area. 

CASTNET Monitoring: CASTNET is a long-term monitoring network of more than 80 

sites located primarily in rural areas. This network is designed to measure status and trends 

in deposition of particles, ozone, and other pollution emitted from facilities with tall stacks 

(generally power plants), mixed in the atmosphere, and transported over long distances. 

Ambient monitoring at CASTNET sites is supposed to reflect the overall effect of emissions 

from many sources, rather than any individual plant. While there is likely to be no direct use 

of such monitoring data in a tribe’s own air quality program, a tribe may wish to host a 

CASTNET site in order to help advance the national air quality program. Tribes presently 

operate three sites. CASTNET is seeking to expand the number of sites in the western U.S. 

CASTNET sites are supposed to remain in operation for a long time. See: 

http://www.epa.gov/castnet for further information. 

National Atmospheric Deposition Program: The NADP program is run by the U.S. 

Geological Survey, and collects data on the chemistry of precipitation. NADP wet 

deposition sites are usually located such that there are no dominant nearby sources, which 

means that a site may not be of direct use of such monitoring data in a tribe=s own air quality 

control program for sources on tribal land. However, a tribe may wish to host a NADP site 

in order to understand its air and water quality as impacted by near and distant sources, 

and/or to help advance the national air quality and water quality programs. A number of 

tribes currently are partners in this program and have sampling sites on their lands. See 

http://nadp.sws.uiuc.edu/ for more information. 

Mercury Monitoring: The NADP and several federal agencies including EPA are 

collaborating on a technical framework for a nationally coordinated network of speciated 

ambient mercury monitoring stations including both gas and particulate forms of mercury. 

Data of this sort eventually will be useful for calculating dry deposition and possibly for 

identifying the emission sources of mercury. Once technical, administrative, and data 

handling procedures are developed, tribes may wish to join this network. Tribes may also 

wish to participate in this development. It is anticipated that a high level of on-site expertise 

will be needed to successfully operate a mercury monitoring stations, even with centralized 

technical and QA support. At this time, no new source of funding exists to support tribal 

mercury monitoring sites. More information is available at http://nadp.sws.uiuc.edu/mtn/ . 

Smoke Monitoring: Tribes who use controlled or prescribed burning to manage forest or 

range land, or whose populations are frequently affected by fires may be interested in 

A-41
Appendix A – Grant Guidance 

monitoring smoke concentrations either to help make decisions on when it is safe to burn, or 

to advise residents of when to take action to avoid smoke exposure. There are no formal 

procedures or standard techniques for such monitoring at this time, but portable monitors and 

satellite data communication devices have been tested and found to be practical by EPA and 

several governmental partners. 

NCore Multi-pollutant Monitoring: The NCore multi-pollutant monitoring network is a 

concept that will be turned into reality over the next few years. Network plans for required 

NCore stations (there are no requirements for tribal NCore stations) are to be submitted by 

July 1, 2009 with stations fully operational by January 1, 2011. The plan is to have a 

network of about 75 sites which simultaneously measure a variety of gas and particle 

pollutants, using continuous methods to follow changes during a single day, across the 

seasons, and over many years. Most of these sites will be in urban areas and will be operated 

by state or local governments. However, about 20 sites need to be in rural areas. While there 

is likely to be a direct use for only some of the monitoring data collected at an NCore station 

in a tribe=s own air quality program, a tribe may wish to host a rural site in order to 

understand its air quality and to help advance the national air quality program. EPA OAQPS 

and regional offices will be planning the location of sites over the next couple of years, and 

regional office staff will contact a tribe if there appears to be an advantage in placing a site 

on a reservation. Alternatively, tribal monitoring programs are encouraged to contact their 

applicable regional office if they have an interest in hosting an NCore station. EPA has not 

yet identified exactly how a rural site on tribal land would be funded, given that the benefit of 

the data from such a tribal site would accrue too many other parties. EPA will be exploring 

this question with tribal and state/local officials over the next year or two. These sites are 

supposed to operate for many years without being moved, once initiated. See 

http://www.epa.gov/ttn/amtic/ncore/index.html for more information. 

Program Support for Monitoring (National/Regional Monitoring Procurement 

Contracts) 

 EPA makes procurement services available to state and local agencies, via national or 

regional contracts or interagency agreements, for a variety of support services and materials. 

These services can be conducted as either associated program support or as in-kind 

assistance. In providing associated program support, EPA works with regions, tribes, and 

state and local agencies in advance to identify needs on a national basis and targets funds for 

the support before determining the final Region-by-Region allocation of grant funds (i.e., 

pre-allotment). In contrast, in-kind assistance is agency-specific and the value of the service 

is included in the grant agreement of a state, tribe, or local agency after final agency-byagency allotments are determined. This approach requires the recipient provide an 

appropriate amount of matching funds and meet other grant administrative obligations 

relative to the in-kind assistance. This occurs when contract support is requested by a grant 

recipient after its grant is awarded. Most support to monitoring programs is provided as 

associated program support, with the in-kind support being used to increase the level of 

support above planned levels if unexpected needs arise. 

A-42
Appendix A – Grant Guidance 

 Traditionally, OAQPS works with regions to determine the level of funds that each state 

or Tribe wants to allocate for the national procurement contracts. The services offered in 

past years included assistance in monitoring site set-up and laboratory sample analysis for 

nonmethane organic compounds, urban air toxics, carbonyls, PAMS, and hazardous air 

pollutants; performance evaluation (PE) sample support for agencies participating in 

NATTS; filters for PM10 and Pb in the form of total suspended particulates; PM2.5 filters; 

laboratory services for PM2.5 speciation; IMPROVE monitoring services; and independent 

audits under the NPAP and PEP programs. Audits are usually provided via contracts 

managed by regional offices. Other services and materials are provided via contracts or 

interagency agreements managed by OAQPS. 

 A new opportunity EPA wishes to make available to monitoring organizations is to 

obtain NADP technical support for speciated ambient mercury monitoring stations via EPA’s 

interagency agreement with the U.S. Geological Survey, as associated program support or inkind service. Organizations interested in this should contact Gary Lear of EPA’s Clean Air 

Markets Division (lear.gary@epa.gov). 

 Table A-5 lists categories and funding amounts for associated program support not 

previously identified under specific monitoring topics: site support and laboratory analysis 

for air toxics and PAMS monitoring and filters for PM10. Typically final amounts to be set 

aside on a pre-allotment basis for the forthcoming fiscal year are identified after EPA and 

states conclude their grant negotiations in the preceding spring and summer. The amounts 

shown in Table A-5 are current best estimates. Final FY 2010 amounts will be based upon 

confirmed needs received from the regions and their state and local agencies by early in FY 

2010. 

Table A-5. Preliminary FY 2010 National Procurement Contract Amounts 

(For Certain Categories of Associated Program Support)

Preliminary FY 2010 Section 105 Contracts in Ambient Air Monitoring and Quality Assurance 

 Region 

Program 1 2 3 4 5 6 7 8 9 10 Totals 

S/NMOC 

Sampling 

Sites (O3) $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 

UATMP Sites 

(Air Toxics) $0 $139,341 $0 $87,063 $49,303 $0 $0 $128,894 $0 $0 $404,601 

PAMS QA 

Support (O3) $12,268 $9,201 $12,268 $35,696 $64,480 $9,201 $0 $0 $24,538 $0 $167,652 

Carbonyl 

Monitoring 

(O3) $0 $34,866 $0 $0 $0 $0 $0 $0 $0 $0 $34,866 

HAP Support 

(Air Toxics) $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 

All PM10 and 

Pb Filters1 $10,643 $6,533 $57,304 $42,872 $46,719 $20,664 $37,052 $29,617 $64,140 $16,189 $331,733 

Sub-total $22,911 $189,941 $69,572 $165,631 $160,502 $29,865 $37,052 $158,511 $88,678 $16,189 $938,852 

Note: Funds for PM10 and Pb filters are calculated based on fall 2008 request for filters. See separate spreadsheet for details. 

(These STAG amounts are considered to be initial placeholders for FY 2010. The final level will depend upon 

a more definite indication of needs from recipients and will be adjusted accordingly. Adjustments will 

A-43
Appendix A – Grant Guidance 

necessarily cause changes in the level of direct grant awards. Residual funds are always returned to regional 

offices for use in direct awards to recipients.) 

 In general, funding that would otherwise go to specific agencies in the form of a direct 

award at the regional office level can be identified in advance for associated program 

support. In essence this reduces the direct award level to that agency. If associated program 

support costs identified for a specific agency are not used or are less than anticipated then 

these resources would ostensibly be returned to that agency’s allotment. However, for some 

associated program support common to all recipients, there is a fixed EPA cost which does 

not depend on the number of individual recipients. An example would be the PEP or NPAP 

programs for auditing monitoring stations, which have fixed costs to pay contractors to 

maintain measurement standards and keep standard operating procedures current. There may 

also be variable costs for the contractor labor and supplies to make monitoring station visits. 

For audits, therefore, changes in the number of audits within a Region will result in a refund 

of only the variable portion of the cost of the station visits (i.e., the associated program 

support). 

 Another exception is that EPA considers the IMPROVE sites representing the Class I 

visibility protection areas to have benefits for all state air grant recipients because of 

interstate transport impacts and the responsibility of each state to protect visibility in every 

Class I area it impacts. Individual states (or regions) therefore cannot “unorder” these 

monitoring sites and receive back their operating costs. In contrast, the cost of supporting 

state/local IMPROVE protocol sites is “refundable” to a regional office. 

Centralized Site Support and Laboratory Analytical Services - The EPA will continue 

coordinating centralized laboratory analytical services to support air toxics, organic 

compound, and PAMS programs in FY 2010 with those regional, state, and local agencies 

wishing to participate. Examples of services available via this national contract include those 

listed below. 

Speciated and Total Nonmethane Organic Compound Program (SNMOC/NMOC): The 

SNMOC/NMOC program has been operating since 1984. The EPA continues to support a 

centralized program for assistance to state and local agencies in the collection of NMOC, 

SNMOC, selected toxic compounds, and carbonyl compounds. This program was initiated to 

provide data for use in development of control strategies for ozone. As part of the SNMOC 

/NMOC program, participating sites are provided with all necessary sampling equipment, 

which they may co-locate with NOx monitors. The SNMOC/NMOC program consists of the 

following base components: 

• Base Site support for sampling equipment preparation, installation and training, 

problem solving, and final reporting; and 

• Canister sample analysis for 78 speciated NMOC or total NMOC. 

Options include: 

• Analysis for 60 toxic and polar compounds; 

• Cartridge sample analysis for 15 carbonyl compounds; and 

A-44
Appendix A – Grant Guidance 

• Concurrent analysis for both toxic and polar compounds and speciated NMOC at 

a cost significantly reduced compared to performing the two analyses separately. 

States collect the samples in canisters and/or cartridges and air freight them to Research 

Triangle Park, NC, for analysis. The samples are collected each week day from 6:00 to 

9:00a.m. during the summer (typically June 1-September 30). In general, 96 samples are 

collected at each site over the study period. However, additional samples may be purchased. 

Urban Air Toxics Monitoring: To support emerging needs for information on levels of 

organic toxic species in ambient air, OAQPS initiated the Urban Air Toxics Monitoring 

Program (UATMP) in 1988. This program serves as an analytical/technical support program 

similar to the SNMOC/NMOC program. The major purpose of this program is to support 

state and local agency efforts to assess the nature and magnitude of various air toxics 

problems via collection of 24-hour integrated ambient air samples at six or twelve day 

sampling intervals, sample analysis in a central laboratory, data reporting to EPA’s Air 

Quality System, and site-specific data analyses. This program continues to be highly 

successful, with excellent overall data capture and data quality that meets well-designed 

program goals. The UATMP consists of the following base components: 

• Base site support for sampling equipment preparation, installation and training, 

problem solving, and final reporting; 

• Canister sample analysis for 60 toxic and polar compounds; and 

• Cartridge sample analysis for 15 carbonyl compounds. 

Options include: 

• Canister sample analysis for 78 speciated NMOC; and 

• Concurrent analysis for both toxic and polar compounds and speciated NMOC at 

a cost that is significantly reduced compared to performing the two analyses 

separately. 

Carbonyl Monitoring: Carbonyl sampling and analysis has been part of the monitoring 

support options that the Agency has provided since 1990. While carbonyl monitoring 

support can still be performed simultaneously with other program elements, the independent 

carbonyl option provides more flexibility for special studies and saturation monitoring 

programs. The Carbonyl Monitoring Program support consists of the following base 

components: 

• Base site support for sampling equipment preparation, installation and training, 

problem solving, and final reporting; and 

• Cartridge sample analysis for 15 carbonyl compounds. 

PAMS and Toxics: PAMS support items will be available to include technical off-site and 

on-site support (initial equipment set-up, on-site technical assistance, consultation, problem 

solving, etc.); quality control (QC); and quality assurance (QA) program support (data 

validation, standards acquisition, and data management support). VOC canister, carbonyl 

A-45
Appendix A – Grant Guidance 

compounds sample and concurrent toxics and speciated hydrocarbon analysis are also 

available. 

 The PAMS and toxics technical support program consists of the following base 

components: 

• Technical site support; 

• QA/QC support; 

• Canister analysis support for PAMS compounds; 

• Cartridge sample analysis for 15 carbonyl compounds; and 

• Concurrent analysis for both toxic and polar compounds and speciated NMOC at 

a cost that is significantly reduced compared to performing the two analyses 

separately. 

 The PAMS automated analysis systems and/or multiple canister collection system 

purchase and installation are the responsibility of the participant. The amount of support an 

agency can order for the PAMS technical site support and QA/QC components of the 

program have been divided into smaller increments so that state, and local agencies can order 

the exact amount of support they require. 

Other Hazardous Air Pollutant Analysis: The national monitoring support programs have 

been expanded to provide for the measurement of additional HAPs to support the effective 

implementation of the CAA and address the needs of other special studies. Analytical 

services support is provided for samples containing specific HAPs, which are a subset of the 

188 compounds listed in the CAA. Participants are responsible for providing all necessary 

sampling equipment. The analysis among categories is based upon the specific needs of the 

state or local agency. This support also will assist the states in implementing the new 

national ambient monitoring network. Some of the available options under this category 

include: 

• Canister sample analysis for 60 toxic and polar compounds; 

• Cartridge sample analysis for 15 carbonyl compounds; 

• Metals, hexavalent chromium, semivolatiles, PAHs, dioxin, etc. 

Air Toxics Performance Evaluation Sample Support: Agencies that are participating in the 

NATTS can receive PE samples on an annual basis. These can include VOCs, Carbonyls, 

SVOCs and metals on quartz filters. The PE samples shall be generated and analyzed by the 

national contractor and sent as “blind” samples to the participating agency. If an agency uses 

the national contractor for analysis, the agency will not be able to use the contractor for PE 

sample support. 

 For more information on Centralized Site Support and Laboratory Analytical Services, 

contact Margaret Dougherty at 919-541-2344 (dougherty.margaret@epa.gov) or Michael 

Jones at 919-541-0528 (jones.mike@epa.gov). 

A-46
Appendix A – Grant Guidance 

Particulate Matter Filters - OAQPS has historically purchased particulate matter filters (for 

PM10 monitoring, total suspended particulate sampling used for Pb and other metals 

monitoring and PM2.5 monitoring) through national contracts and distributed these to state 

and local agencies across the nation. The economies of scale from this type of centralized 

purchasing, centralized acceptance testing, and distribution of filters has produced lower 

costs than if state and local agencies each purchased these filters through their individual 

agencies. State and local agencies are responsible for providing information to the regions 

each year on the numbers and types of filters required prior to shipment. For PM10 filters, 

monitoring agencies will need to specify whether the filters requested are to be used to 

support high-volume samplers (i.e., 8 in X 10 in quartz filters) or low-volume samplers (i.e., 

46.2 mm Teflon filters). 

 For information on filter purchases, contact David Lutz at 919-541-5476 

(lutz.david@epa.gov). 

Section V. PRELIMINARY STATE/LOCAL AIR GRANT ALLOCATION (Table 

A-6 - Reserved) 

Section VI. STATE INDOOR RADON PROGRAM 

 The State Indoor Radon Grant (SIRG) Program distributes grants authorized under 

section 306 and 10(a) of TSCA. The SIRG program’s objectives are outlined in EPA’s State 

and Tribal Indoor Radon Grants Program Guidance and Handbook located at: 

http://www.epa.gov/radon/pdfs/guidance_and_handbook.pdf . See also: 

http://www.epa.gov/radon/sirgprogram.html . 

Recipients of FY 2010 SIRG funds should emphasize radon risk reduction through 

increased action by consumers, homeowners, real estate professionals, homebuilders, and 

state-local governments. Funded projects should clearly result in the following outcomes: 

• Building homes with radon-resistant new construction; 

• Reducing radon in existing homes; 

• Reducing radon in existing schools and building new schools with radon-reducing 

features; and 

• Other projects and activities that clearly contribute to achieving the three preceding 

outcomes. 

EPA will revise the grant allocation methodology for the SIRG program during 

calendar year 2009 and will implement a new methodology in FY 2010. As a result of an 

updated allocation methodology and expected changes in the FY 2010 appropriation amount, 

a new regional distribution will be developed. The Regional Offices will still have discretion 

in determining the actual amounts of the State or Tribal awards. EPA and SIRG recipients 

are expected to continue implementation of the SIRG measures template, checklist and 

guidance. SIRG workplans should reflect radon program priorities and measurable results. 

A-47
Appendix A – Grant Guidance 

Supplemental information will be provided by the Office of Radiation and Indoor Air 

including a final FY 2010 allocation (in Table A-7 - not yet available ). The SIRG program 

contact is Phil Jalbert (202-343-9431, jalbert.philip@epa.gov). 

A-48
Appendix B – FY 2010 Regional Performance Measures 

Office of Air & Radiation 

ACS 

Code Measure Text 

C

OAQPS 

N001 

Percentage reduction in population-weighted ambient concentration of ozone in all monitored counties from 2003 baseline. [HQ reports 

this measure. Regions do not bid or report.] 

OAQPS 

N002 

Percentage reduction in population-weighted ambient concentration of fine particulate matter (PM2.5) in all monitored counties from 2003 

baseline. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N003 

Cumulative percentage reduction in the number of days with Air Quality Index (AQI) values over 100 since 2003, weighted by population 

and AQI value. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N004 

Cumulative percentage reduction in the average number of days during the ozone season that the ozone standard is exceeded in baseline nonattainment areas, weighted by population. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N005 

Percentage improvement in the number of days to process State Implementation Plan revisions weighted by complexity. [HQ reports this 

measure. Regions do not bid or report.] 

OAQPS 

N07 

Number of final rulemaking actions on PM2.5 SIPs (due April 2008) consistent with the annual SIP processing goal. 

OAQPS 

N08 

Number of final rulemaking actions taken on regional haze SIPs consistent with the annual SIP processing goal. 

OAQPS 

N09 

Number of final rulemaking actions taken on redesignation requests for CO, SO2, PM10, and lead areas, consistent with the annual SIP 

processing goal. 

OAQPS 

N10 

Number of final rulemaking actions taken on redesignation requests for 8-hour ozone, consistent with the annual SIP processing goal. 

OAQPS 

N11 

Number of final rulemaking actions taken on redesignation requests for PM2.5, consistent with the annual SIP processing goal. 

OAQPS 

N12a 

(NEW) 

Number of clean air determinations issued and one-year extensions granted for 1997 PM2.5 nonattainment areas with an April 5, 2010 

attainment date. 

OAQPS 

N29 

Number of completed voluntary reclassifications for 8-hour ozone nonattainment areas. 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

OAQPS 

N30 

Percentage of newly violating areas/counties that region is targeting for developing appropriate actions to bring designated attainment 

areas into compliance with the NAAQS. 

OAQPS 

N31 

Number of states or local agencies developing and/or commencing implementation of innovative and voluntary emission reduction 

projects. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for 

regional purposes.] 

OAQPS 

N32 

(NEW) 

Number of completed attainment determination actions for 8-hour ozone nonattainment areas including mandatory reclassifications, clean air data requests or one-year extension requests. 

OAQPS 

N33 

(NEW) 

Number of final rulemaking actions taken on SIPs for 0.08 ppm 8-hour ozone for moderate areas that were formerly subpart 1 or subpart 2 marginal areas reclassified to moderate. 

OAQPS 

N34 

(NEW) 

Number of S/L/T agencies reporting criteria air pollutant (CAP) emissions data as required under the Air Emissions Reporting Requirements (AERR) rule. (Note: The new 12-month timeline for data reporting under the AERR will begin with the 2009 inventory 

year. CAP emissions from Type A point sources for the 2009 inventory year will be due by December 31, 2010.) 

OAQPS 

M06 

Percentage of state and local monitoring agency certification requests region evaluates and forwards to HQ when deemed adequate. [Note: CY 2009 annual data certifications are due May 1, 2010.] 

OAQPS 

M07 

Percentage of required Technical Systems Audits conducted to achieve an audit of each organization within a 3-year period. 

OAQPS 

M08 

Percentage of state and local annual monitoring plans reviewed and approved within 120 days when network changes are proposed. 

OAQPS 

M09 

Percentage of 2nd and later Approved Regional Method (ARM) requests acted on by the region in accordance with HQ guidance. 

OAQPS 

M10 

Percentage of affected entities that operate monitors in accordance with Part 58, grant terms, and QAPP. 

OAQPS 

M11 

Percentage of affected entities who submit data to AQS in accordance with Part 58. Note: Because this is a state grant template measure, 

the actual number of entities that are reported on by regions should not exceed the number of applicable grant recipients. 

OAQPS 

M12 

Percentage of AQS quarterly data reviews completed and resolved for timeliness and completeness. 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

OAQPS 

M18 

Percentage of NATTS Technical Systems Audits the region participates in over a 3-year period. 

OAQPS 

M19 

Percentage of community scale air toxics ambient monitoring programs for which region will review QA requirements and ensure measurement consistency with NATTS when appropriate. 

OAQPS 

M20 

Percentage of affected entities that operate NATTS in accordance with National Guidance and QAPPs. 

OAQPS 

M21 

(NEW) 

Percentage of state and local monitoring agencies with which region will coordinate to get required Pb NAAQS sites installed and operational by January 1, 2010. 

OAQPS 

M22 

(NEW) 

Percentage of 2010 Annual Monitoring Plans reviewed for required new and/or modification to existing population- and source-oriented lead monitoring sites. 

OAQPS 

M23 

(NEW) 

Percentage of state/local agencies 5-Year Assessment Plan Assessments submitted in accordance with 40 CFR Part 58. 5-Year Assessment Plan is due by July 1, 2010. 

OAQPS 

P001 

Percent of major NSR permits issued within one year of receiving a complete permit application. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

P06 

Percentage of Title V program evaluations conducted and reports completed within the fiscal year. 

OAQPS 

P07a 

(NEW) 

Part 70 renewals: Percentage reduction of total Part 70 extended permits. 

OAQPS 

P08a 

Percentage of Title V (Part 70) significant modifications issued within 18 months of receiving a complete permit application. 

OAQPS 

P08b 

Percentage of Title V (Part 70) initial permits issued within 18 months of receiving a complete permit application. 

OAQPS 

P09 

Percentage of state/local major NSR/PSD permits reviewed by region for new and modified sources to ensure consistent implementation of the NSR program. 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

OAQPS 

P11 

Percentage of permitting authorities reporting complete Part 70 TOPs data. 

OAQPS 

P12 

Percentage of Part 71 significant modifications issued by EPA within 18 months of receiving a complete permit application. 

OAQPS 

P13 

Percentage of Part 71 initial permits issued by EPA within 18 months of receiving a complete permit application. 

OAQPS 

P14a 

(NEW) 

Part 71 renewals: Percentage reduction of total Part 71 extended permits. 

OAQPS 

P19 

Percentage of PSD permits issued by region within one year of receiving a complete permit application. 

OAQPS 

T001 

Cumulative percentage reduction in tons of toxicity-weighted (for cancer risk) emissions of air toxics, compared to 1993 baseline. [HQ 

reports this measure. Regions do not bid or report.] 

OAQPS 

T002 

Cumulative percentage reduction in tons of toxicity-weighted (for noncancer risk) emissions of air toxics, compared to 1993 baseline. 

[HQ reports this measure. Neither Region do not bid nor report.] 

OAQPS 

T05 

Number of communities (e.g. CARE communities/projects) the region is working with to assess and address sources of air toxics, including the use of voluntary air toxic reduction programs in their communities. [This is a non-commitment indicator with reporting. 

The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OAQPS 

T06 

Percentage of requests from S/L/Ts for delegation of section 112 standards processed within 180 days of receipt. 

OAQPS 

T07 

Number of S/L/T agencies collecting data for the 2008 HAP emissions inventory. [This is a non-commitment indicator with reporting. 

The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OAQPS 

TR01 

Cumulative number of tribes with approved eligibility determinations under the Tribal Authority Rule. [This is a non-commitment indicator with bidding & reporting. Initial bid values are set at zero.] 

OAQPS 

TR02 

Cumulative number of tribes with delegation of federal programs to address air quality conditions on tribal lands. [This is a noncommitment indicator with bidding & reporting. Initial bid values are set at zero.] 

OAQPS 

TR03 

Cumulative number of tribes with approved TIPs to address air quality conditions on tribal lands. [This is a non-commitment indicator with bidding & reporting. Initial bid values are set at zero.] 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

OAQPS 

TR04 

Number of tribes conducting air quality monitoring activities. [This is a non-commitment indicator with bidding & reporting. Initial bid 

values are set at zero.] 

OAQPS 

TR06 

Number of tribes implementing voluntary or other non-regulatory programs. [This is a non-commitment indicator with reporting only. The initial bid value is set at zero and regions are expected to bid zero but at their option. Regions may bid otherwise for their purposes.] 

OAQPS 

TR08 

(NEW) 

Number of reservations who completed or updated an emission inventory during FY2010. 

OTAQ 

01a 

Number of projects implemented that promote diesel emissions reductions. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01b 

Number of existing heavy duty diesel engines (including school bus engines) that have been retrofitted, replaced, or retired. [This is a 

non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c1 

Annual reductions of NOx emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c2 

Annual reductions of PM emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The 

expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c3 

Annual reductions of HC emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c4 

Annual reductions of CO emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c5 

Annual reductions of CO2 emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The 

expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c6 

Lifetime reductions of NOX emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. Theexpected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c7 

Lifetime reductions of PM emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c8 

Lifetime reductions of HC emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The 

expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

OTAQ 

01c9 

Lifetime reductions of CO emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The 

expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

01c10 

Lifetime reductions of CO2 emissions from NCDC and SmartWay projects. [This is a non-commitment indicator with reporting. The

expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

OTAQ 

02a 

Percentage of timely adequacy/inadequacy determinations made by the region for identified mobile source budgets included in control 

strategy SIPs or maintenance plans for transportation-related criteria pollutants (e.g. Ozone, CO, PM2.5, PM10) submitted by states. 

OTAQ 

02b 

Percentage of approval/disapproval rulemaking actions taken on mobile budgets included in control strategy SIPs or maintenance plans for 

transportation-related criteria pollutants (e.g. Ozone, CO, PM2.5, PM10) at the time of final rulemaking on such SIPs. 

OTAQ 

03a 

Percentage of transportation conformity determinations submitted by US DOT or an MPO that the region reviewed and commented on for 8-hour ozone, PM2.5, PM10, and CO nonattainment and maintenance areas. 

OTAQ 

03b 

Number of final rulemaking actions taken by the region on Transportation Conformity-related SIP revisions consistent with the annual SIP 

processing goal. 

OTAQ 

04 

Number of outreach activities conducted by the region to support SmartWay programs. 

OTAQ 

06 

Percentage of I/M reports submitted by states for existing I/M programs (including OBD) reviewed by the region. 

OTAQ 

08 

Number of CMAQ funded clean diesel projects implemented by state and local governments. [This is a non-commitment indicator with 

reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

SIRG 1 Number of additional homes with operating mitigation systems. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] SIRG 2 Number of additional homes built with radon-resistant new construction. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] SIRG 3 Number of additional schools mitigated and/or built with radon-resistant new construction. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] SIRG 4 

States report the performance measures they use that have clear linkages to those of EPA (homes mitigated, new radon resistant homes 

built, schools mitigated or new radon resistant). [This is a non-commitment indicator with reporting. The expected bid value is set at zero 

but regions may bid otherwise for regional purposes.] 

Final ACS Measures – April 28, 2009 
ACS 

Code 

Measure Text C

ORIA 

IAQ 3 

Number of schools newly using organized indoor air quality management practices consistent with EPA TFS. [This is a non-commitment 

indicator with regional bidding and reporting. Initial bid values are set at zero.] 

ORIA 

IAQ 5 

Aggregate number of people with asthma and/or their caregivers educated about environmental management of asthma and childhood exposure to ETS. [This is a non-commitment indicator with regional bidding and reporting. Initial bid values are set at zero.] 

ORIA 

IAQ 6 

Aggregate number of health care professionals trained about environmental management of asthma and childhood exposure to ETS. [This is a non-commitment indicator with regional bidding and reporting. Initial bid values are set at zero.] 

ORIA 

RAD 1 

Number of radiation exercises the region participates in. 

ORIA 

RAD 2a 

(NEW) 

Number of individuals identified and trained to fill RERT liaison and radiation advisor positions. 

ORIA 

RAD 3 

Number of total operating and approved RadNet sites for monitor installation. 

OAP 1 Percentage increase in total square footage benchmarked compared to the total square footage benchmarked in FY 2008. [This is a non- commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] OAP 2 

Number of articles appearing in consumer publications such as newspapers and/or number of State energy offices or utilities hosting ENERGY STAR homeowner web tools. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but 

regions may bid otherwise for regional purposes.] 

OAP 4 Number of ENERGY STAR products events and/or press releases issued. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] OAP 5 

Number of pledges or pledge renewals generated by the region in its role as a Pledge Driver in the “Change the World, Start with 

ENERGY STAR” campaign. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may 

bid otherwise for regional purposes.] 

OAP 6 

(NEW) 

Number of outreach activities conducted by the region to support climate partnership programs other than SmartWay and Energy Star, 

including Climate Leaders, Green Power Partnership, Combined Heat and Power, and methane programs. 

++ End ++ 

Final ACS Measures – April 28, 2009 
Appendix C – Draft FY 2010 State Grant Performance Measures 

Office of Air & Radiation 

ACS 

Code Measure Text 

OAQPS 

N001 

Percentage reduction in population-weighted ambient concentration of ozone in all monitored counties from 2003 baseline. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N002 

Percentage reduction in population-weighted ambient concentration of fine particulate matter (PM2.5) in all monitored counties 

from 2003 baseline. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N003 

Cumulative percentage reduction in the number of days with Air Quality Index (AQI) values over 100 since 2003, weighted by population and AQI value. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

N004 

Cumulative percentage reduction in the average number of days during the ozone season that the ozone standard is exceeded in baseline nonattainment areas, weighted by population. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

M11 

Percentage of affected entities who submit data to AQS in accordance with Part 58. Note: Because this is a state grant template measure, the actual number of entities that are reported on by regions should not exceed the number of applicable grant recipients. 

OAQPS 

M20 

Percentage of affected entities who operate NATTS in accordance with National Guidance and QAPPs. 

OAQPS 

P001 

Percent of major NSR permits issued within one year of receiving a complete permit application. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

T001 

Cumulative percentage reduction in tons of toxicity-weighted (for cancer risk) emissions of air toxics, compared to 1993 baseline. [HQ reports this measure. Regions do not bid or report.] 

OAQPS 

T002 

Cumulative percentage reduction in tons of toxicity-weighted (for noncancer risk) emissions of air toxics, compared to 1993 baseline. [HQ reports this measure. Regions do not bid nor report.] 

OAQPS 

T07 

Number of S/L/T agencies collecting data for the 2008 HAP emissions inventory. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

SIRG 1 Number of additional homes with operating mitigation systems. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] SIRG 2 Number of additional homes built with radon-resistant new construction. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

4/28/2009 
ACS 

Code 

Measure Text 

SIRG 3 Number of additional schools mitigated and/or built with radon-resistant new construction. [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] SIRG 4 

States report the performance measures they use that have clear linkages to those of EPA (homes mitigated, new radon resistant homes built, schools mitigated or new radon resistant). [This is a non-commitment indicator with reporting. The expected bid value is set at zero but regions may bid otherwise for regional purposes.] 

++ End ++ 

4/28/2009 
Appendix D – Explanation of Major Changes from FY 2009 to FY 2010 

Office of Air & Radiation 

Change from FY 2009 Guidance Document Reason for Change Ef

Priorities New work related to designating areas for the revised ozone and lead NAAQS promulgated in 2008. The NAAQS for ozone and lead were both revised in 2008. Tech

Funding 

Final FY 2010 budget request has not yet been determined. Continued restructuring in ambient monitoring technical areas anticipated including proposals for support of lead monitoring and high-risk air toxic areas.

Changes due to factors such as revised air monitoring regulations, revised NAAQS for PM, and changes in how monitoring is funded. 

Appe

Strategies None None None 

Annual 

Commitment 

Measures 

Approximately 15 measures (mostly those related to outdoor air) were substantively changed (either added, deleted, or rewritten). 

Outdoor air measures were changed to keep pace with changed program implementation requirements stemming from Clean Air Act-driven timelines. Three non-commitment indicators were added to capture important activities not previously tracked—tribal emissions inventories, and voluntary greenhouse gas reduction activities other than Energy Star. 

Appe

Tracking 

Process 

None None None 

Contacts None None None 

April 24, 2009 
Program Measure Text

DERA Number of projects implemented that promote diesel emissions reductions

DERA

Number of existing heavy duty diesel engines (including school bus engines) 

that have been retrofitted, replaced or retired

DERA

Lifetime reductions of Nox, PM, HC, CO, CO2 (by pollutant) from the ARRA 

DERA projects

DERA

Status of reqests for applications, procurements, bids, loans, subgrants, 

contracts or subcontracts as applicable for each ARRA award

DERA

Amount (in dollars and %) of EPA ARRA funds drawn on each clean diesel 

award

OAR ARRA Measures

**These measures are subject to change

Appendix E
Appendix F 

Comments and Responses to Comments on Draft FY 2010 NPM Guidance 

Office of Air & Radiation 

Comment Commenter Text Location Response Change Y,N,NA 

NAAQS and Criteria Air Pollutants including Transport and CAIR 

We urge EPA to fully embrace its role in addressing the interstate transport of pollutants that frustrate our region’s efforts to attain and maintain the ozone and PM NAAQS, minimize haze, and reduce mercury in our waters. A top priority for EPA should be to revise the CAIR rule and take other action as needed to fully address interstate transport in a manner consistent with Section 110(a)(2)(D) of the CAA. 

New England Commissioners, NESCAUM, NACAA 

Technical Guidance, Exec. Summary, Priorities for Regional Offices 

EPA has an understanding of how interstate pollution transport affects the ability of downwind areas to attain the NAAQS and achieve regional haze goals. In response to the court’s recent remand of the CAIR, we are updating our technical knowledge of pollution transport, and further evaluating how the CAIR helps areas satisfy their requirements under CAA section 110(a)(2)(D). 

N 

States need timely and clear guidance, and rules as appropriate, from EPA on how SIPs should be developed in light of the legal uncertainty of the CAIR cap-and-trade program. 

NESCAUM Not Specified EPA is further evaluating how a replacement to 

the CAIR will assist states in developing approvable attainment and maintenance plans. We are seeking input from the new EPA administration on appropriate rules and guidance to address air quality management challenges presented by recent litigation outcomes. 

N 

EPA, in partnership with the regions and the states, should commit to update RACT to ensure that this is a viable and cost-effective program for addressing transported pollution and attaining the NAAQS. 

NESCAUM Not Specified We can not speak at this time to whether EPA 

intends to update specific guidance until we receive future direction from the new EPA administration. We note that while additional RACT guidance may be helpful, states are independently required to adopt reasonably available control measures, including RACT, to attain applicable standards. 

N 

EPA should adopt national rules for area and industrial sources for which NESCAUM and OTC have been advocating (e.g., industrial boilers, peaking units, consumer products). 

NESCAUM Not Specified We have rulemaking activities underway for 

these categories. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

It is imperative that EPA issue timely guidance and regulations needed by states to implement the 2006 PM2.5 and 2008 ozone NAAQS revisions. This includes guidance related to modeling, implementation, and inventories that will enable development of approvable SIPs. As state resources get tighter, we will need better and more efficient tools and even swifter responses from EPA. EPA should include in the draft guidance plans to address the recent D.C. Circuit Court remand of the PM-fine annual and secondary NAAQS in a timely manner, In the past, EPA has issued guidance for the preparation of SIPs well after it is useful to state and local agencies, if at all. For example, guidance for the implementation of the 1997 ozone and particulate matter NAAQS is still not implemented 

for New Source Review and modeling, yet these SIPs were due over the past few years. 

NESCAUM Not Specified EPA realizes the importance of timely 

implementation guidance to our state, tribal, and local partners. However, we can not speak at this time to whether EPA intends to issue specific rules or guidance until we receive future direction from the new EPA administration. 

N/A 

EPA should provide clear guidance on how to account for peak day emissions in attainment planning. 

NESCAUM Not Specified In general, we recommend that states take any 

factors relevant to planning for and demonstrating attainment into account to the best of their ability. However, we can not speak at this time to whether EPA intends to issue specific guidance until we receive future direction from the new EPA administration. 

N/A 

EPA Region Offices should commit to process SIPs in a timely manner. 

NESCAUM Not Specified EPA regions are processing SIPs in accordance 

with the SIP Processing PART Goal. SIPs that present unique policy determinations or vary from previous practices take longer to process in order to ensure national consistency. At present, we can not speak to whether EPA intends to make specific program revisions until we receive future direction from the new EPA administration. 

N/A 

The draft document does not recognize the attainment deadlines EPA has set (or that the goal is attainment) or the fact that reasonable progress goals for regional haze must be met by 2018 (under Objective 1.1 – Healthy Outdoor Air, page 6). We believe these goals are important and should be articulated. 

NACAA Not Specified EPA believes the NAAQS attainment deadlines 

and the first regional haze progress period deadline are important milestones, and our goal is to help states manage air quality consistent with these goals. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

EPA should foster and promote collaborative air quality planning & multi-pollutant solutions to address criteria pollutants, GHGs, regional haze, and other air quality goals, including opportunities for energy efficiency and renewable energy. 

New England Commissioners, NESCAUM 

Technical Guidance, Federal Support for Air Quality Mgmt 

EPA has several multi-pollutant planning pilots underway that will help future efforts to link air quality and energy goals. The results of these efforts will help inform future decision making. 

Y 

EPA should commit to adopt strong national rules to support states’ NAAQS attainment and maintenance efforts. This should include national ozone rules for area sources consistent with those adopted by OTC and California, and emission standards for new and existing industrial, commercial and institutional (ICI) boilers through RACT and New Source Performance Standards. 

NESCAUM Not Specified EPA is implementing the most protective 

NAAQS in history and continues to implement these standards in accordance with statutes and court decisions. We are currently developing a replacement rule for the recently remanded CAIR. Emission reductions resulting from this rule will continue to help downwind nonattainment areas to attain the standards. However, we can not speak at this time to whether EPA intends to issue specific rules until we receive future direction from the new EPA administration. 

N/A 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

EPA should foster improved coordination between energy and air quality planning, including exploring how EPA can engage in the Federal Energy Regulatory Commission’s process to further air quality objectives. 

NESCAUM Not Specified EPA is placing greater emphasis on program 

coordination and integration, specifically as it relates to energy issues and air quality planning. 

Y 

EPA should ensure timely submission and processing of regional haze plans 

NESCAUM Not Specified EPA has worked with states to promote timely 

submission of the regional haze plans through coordination efforts, and funding of Regional Planning Organizations (RPOs). On January 15, 2009, EPA issued ‘findings of failure to submit’ notices for 37 states that failed to meet the Dec. 17, 2008 deadline for submitting regional haze plans. FIPs will be issued for those states by Jan. 15, 2011 unless EPA has approved a SIP by that time. The recent remand of the CAIR has created uncertainty in evaluating submitted regional haze SIPs. We expect to resolve the delays after the new EPA administration provides future direction. 

N 

Air Toxics 

Establish MACT standards to control mercury from existing & new coal-fired power plants under §112 of the CAA, in accordance with our 2008 petition under §319 (g) of the CWA. 

New England Commissioners 

Technical Guidance, Federal Stationary Source Regs 

Utility MACT (formerly CAMR) is underway and we are currently under litigation for deadline dates. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

NACAA recommends that EPA identify the measures that will achieve the goals stated in the plan (under Subobjective 1.1.2 – Reduce Air Toxics, page 7). These should include completing the statutory and court-ordered mandates under the NESHAP program (e.g., Portland Cement and Utility Boiler MACT). 

NACAA Not Specified EPA intends to complete statutory and court 

ordered mandates. 

N 

It is critical that EPA take swift action to regulate mercury under section 112 of the CAA. The NESCAUM states have previously urged EPA to establish MACT standards to control mercury from existing and new coal-fired power plants. Such an effort should be reflected in the program guidance. In addition, the New England states and New York have petitioned EPA under section 319(g) of the Clean Water Act for a management conference to address out-of-region mercury sources contributing to mercury impairment in water bodies within the region. We encourage EPA’s air and water staff to provide a coordinated and appropriate response to the petition. 

NESCAUM Not Specified To address mercury emissions, we have several 

activities underway including: 

Mercury limits for the NESHAP for Portland Cement, NESHAP for Mercury Cell Chloralkali, and NESHAP for Gold Mines. 

N 

Mobile Sources 

Complete the response to the Supreme Court decision with respect to an endangerment finding. 

NESCAUM Not Specified On Friday, April 17, 2009, EPA issued a 

proposed finding that GHGs contribute to air pollution that may endanger public health or welfare. 

N 

Complete the agency’s reconsideration of California’s waiver request 

NESCAUM Not Specified The reconsideration process is underway; EPA 

will confirm or reverse the decision to deny the request of the State of California to regulate greenhouse gas emissions from new motor vehicles by June 30, 2009. 

N 

Climate Change 

We ask EPA to work closely with the states in the development and implementation of any federallymandated economy-wide GHG reduction program. 

New England Commissioners 

Technical Guidance, Climate Change chapter 

Agree. Per Administrator’s April 2 letter to Commissioner Burack, EPA will be coordinating with the states as we work on economy-wide GHG programs. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

We believe it is important that EPA collaborate with The Climate Registry (TCR) in developing any federal mandatory GHG reporting system to ensure consistency with TCR protocols and complementary state and federal roles. 

New England Commissioners, NESCAUM 

Technical Guidance, Climate Change chapter 

Agree. Per Administrator’s April 2 letter to Commissioner Burack, EPA will work closely with the states on the rollout of the GHG reporting rule. 

N 

We urge EPA to engage with states to foster dialogue and information exchange as federal programs are planned, developed, and implemented, with the goal of ensuring real environmental benefits as expeditiously as possible. 

NESCAUM Not Specified EPA agrees and intends to work closely with the 

states as new programs are planned and developed. We welcome ideas the states may have. 

N 

We seek collaboration with EPA to move beyond traditional program and agency silos in order to implement complementary climate change, transportation and energy strategies that improve air quality and increase energy efficiency and use of renewables. (4) exploring existing and planned programs to reduce GHG emissions, including economy-wide approaches; and (5) supporting the nexus between climate, air quality, and non-EPA jurisdictional areas in addressing the challenges of climate change. 

New England Commissioners 

Technical Guidance pages 13-26: Federal Support for Air Quality Mgmt, & State & Local Air Quality Mgmt 

EPA welcomes the opportunity to collaborate and engage in additional dialogue in these areas. Currently, EPA is working with interested U.S. areas on an initiative to integrate transportation, energy, land use and air quality planning through its Sustainable Skylines Initiative. In addition, EPA is piloting a new way to approach air quality management planning with three geographic areas that encourages comprehensive, multi-pollutant planning. 

Y 

Funding Issues: Ambient Monitoring, RPOs, Training, Diesel Grants 

NACAA is very concerned that EPA is proposing to eliminate funding for the RPOs. We believe this will deprive the RPOs – and state and local agencies – of necessary tools and resources to help them carry out technical activities related to regional haze. The need for the services that the RPOs provide is ongoing. While it is difficult to discuss precise amounts for the RPO funding without knowing what the total Section 103/105 budget request will be, NACAA urges EPA to provide at least $2.5 million in FY 2010 for the RPOs. Additional recommendations will be forthcoming when the total Section 105/103 request is known. 

NACAA, NESCAUM, NTAA 

Grant Guidance, Appendix A 

Limited funding and new mandates within STAG dictate that choices have to be made about how the resources are best used. The RPOs have received more than $66 million to assist states in developing their regional haze SIPs, and yet 37 states have failed to submit the required SIPs due in December 2007. We will review the RPO budget request with the new EPA leadership in the coming months. We note that if individual states have a regional haze need that can be filled by the RPOs, they may request EPA to withhold part of their grant allocation to fund the RPOs. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

Numerous small towns – particularly in the western states – have expanded beyond the 50,000 population level and are now subject to minimum federal PM2.5 monitoring requirements. EPA should address this problem and provide funding as appropriate. 

NACAA Grant 

Guidance Appendix A 

States should identify growing population centers, including smaller areas (e.g., 50,000 population towns) as part of the 5 year assessments due to EPA on July 1, 2010. In subsequent annual monitoring network plans States should work with the EPA Regional Offices to transition their networks to meet new needs, including those in small towns. 

N 

EPA is soliciting comments on a proposal to shift grants for the PM2.5 monitoring program from Section 103 authority to Section105 authority. In previous years, this proposal has been accompanied by a recommendation to also cut those funds by the amount of the 40% match. NACAA is strongly opposed to such an approach. To keep the program whole and to accept the monitoring grants, state and local agencies would need to supply additional matching funds. However, many agencies are currently overmatched and would not be required or able to increase their contributions and, therefore, may not target additional funds to PM2.5 monitoring. Furthermore, other agencies that do not have additional resources for the match could not make up the difference and may possibly be forced to turn away much-needed grant funds. Shifting the monitoring program to Section 105 authority could result in significant cuts to this important program. 

NACAA Grant 

Guidance Appendix A 

While EPA and States continue to make important improvements to the PM2.5

monitoring network (e.g., implementation of new carbon samples), most of the network is in a mature phase. EPA would prefer to implement new monitoring networks with section 103 funds so that networks can be deployed relatively quickly and consistently. Once implemented, EPA would prefer to have the States maintain monitoring networks with section 105 funds. The section 105 program provides a more efficient funding mechanism to maintain the networks since funding is shared by both EPA and the States. However, EPA expects that Congress will continue to provide funding for PM2.5 monitoring in FY 2010 via CAA section 103 authority. 

N 

The draft calls for Section 105 funds to be set aside for the NOx/CAIR Budget system. Several years ago, the states participating in the NOx SIP call agreed to off-the-top funding for this program because it was a state initiative used as a SIP strategy that was more efficiently funded that way. Now that EPA has adopted the CAIR program, we believe EPA should take responsibility for administering the program in the same way that the agency administers the Acid Rain program. The cost for administering CAIR should be absorbed by EPA’s budget, not from Section 105 grants. 

NACAA Grant 

Guidance, Appendix A 

The NOx/CAIR Trading program includes resources from the affected States to assist in the effective implementation of their NOx SIPs as well as funds from states that elected to participate in the CAIR seasonal trading program. EPA agrees that is appropriate to reassess the cost of the program and the relative contributions from the section 105 program when the new CAIR rule is completed. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

EPA indicates that the annual PM2.5 standard was not changed. However, on 2/24/09 the US Court of Appeals remanded the annual standard to EPA. It is possible (likely) that there will be revisions of that standard and a need for additional monitors in new areas. Therefore, additional funding would be needed. 

NACAA Grant 

Guidance Appendix A 

EPA and the States work together through the Annual Monitoring Network Plans, due to each Regional office each July 1, and the 5-year assessments, with the first one due by July 1, 2010 to review and assess the ambient air monitoring networks. For PM2.5, monitoring 

network minimum requirements are based on population and design value. If a decision is made by EPA to further strengthen the PM2.5

NAAQS, this information will automatically be factored into the existing monitoring requirements, which can then be included in assessments of the networks. However, with operation of over 900 FRM/FEMs already, EPA is not expecting a large number of new monitoring stations needed to support any further strengthening of the PM2.5 NAAQS. 

N 

For many years NACAA has recommended that EPA fund training from its own budget, and we have agreed to match EPA’s expenditures for training from the Section 105 grant during the transition to full EPA funding. Reductions in training funds will result in a loss of training infrastructure that will be very difficult to replace later. Further, elimination of training is not a wise funding choice as it will reduce 

the effectiveness of federal, state and local programs in the long run. As in the past, NACAA recommends that EPA hold $1,995,000 off the top for training and urges the agency to at least match the Section 105 grant funding for training from EPA’s own budget. Further, NACAA recommends that adequate staffing support be allocated within EPA to provide necessary training services to state and local agencies. NACAA’s Training Committee will convene on March 23-25, 2009 and, as a part of that meeting, will define the critical tasks that EPA should assume to provide a strong national training program to meet future air pollution control needs. 

NACAA Grant 

Guidance, Appendix A 

EPA has allocated contract funds, staffing, and material to support training development and delivery. EPA is working closely with the NACAA training committee to ensure we meet the training needs of states, tribes, and local agencies as cost effectively and thoroughly as possible. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

The draft discusses the new lead standard and related new monitoring requirements and requests comment on the use of community-scale monitoring funds to support the lead monitoring network. The draft also states that state and local agencies should begin network planning now, using Section 105 funds. NACAA has previously expressed concern about the financial obligations placed on agencies by new federal mandates. While we understand the budgetary difficulties at the federal level, state and local agencies face even more severe budget constraints. Community-scale project funds have been useful to state and local efforts to identify health risks from air toxics emissions and NACAA would prefer that those funds continue to be made available for their original purpose, rather than expanding them to cover lead as well. However, if no other source of lead monitoring funds is available, NACAA suggests that EPA provide the regions with maximum flexibility to utilize community-scale funding and other funding sources to assist the state and local agencies to develop and operate lead monitoring networks. All funds made available for lead monitoring should be awarded under Section 103 to avoid the requirement to provide matching funds. 

NACAA Grant 

Guidance Appendix A 

EPA is committed to provide flexibility for States to work with the Regional Offices on how to best put monitoring resources to use. Deployment of the lead (Pb) network is to take place over two years (i.e., 2010 and 2011). Therefore, EPA both in the national program office and in Regional Offices will work closely with monitoring agencies to ensure implementation of a revised Pb network over this two year period. 

N 

NACAA recommends that the funds to support the Diesel Emission Reduction (DERA) provisions of the Energy Policy Act of 2005 not be part of the STAG account, since many of the funds are not provided to state and local governments. We recommend that the funds be provided through one of EPA’s other accounts. With respect to the distribution of the diesel funds, NACAA hopes that EPA will continue to keep the program open to both attainment and nonattainment areas. Many state and local agencies have active diesel emission reduction programs that apply outside of nonattainment areas to reduce air toxics, GHGs, and haze. 

NACAA Grant 

Guidance, Appendix A 

Congress, not EPA, determines which funds are put in what accounts. EPA intends to keep the DERA program open to distributing funds to all areas of the U.S. 

N 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

With respect to grant competition, EPA notes that co-regulator status is no longer available as an exception to competition for grants for MJOs. As we have indicated in previous comments, we disagree with this view and believe that co-regulator organizations such as NACAA and other MJOs should continue to be treated under an exception to competition requirements. It would be very inefficient for EPA and those organizations to go through a competitive process when those entities are each uniquely qualified to perform their missions and were established by their members for this express purpose. There are no other organizations that directly represent their members and are able to carry out the national and regional environmental and public health objectives of their members. 

NACAA Grant 

Guidance, Appendix A 

While co-regulator status as an exception to competition has been removed, there are other exceptions which can account for the unique working relationship that many multijurisdictional organizations have with their member state and local agencies - in particular, the ‘in the public interest’ exception. 

N 

Tribal Air Program 

EPA states that “[b]y 2014, 12 additional tribes will possess the expertise and capability to implement the Clean Air Act in Indian country (as demonstrated by successful completion of an eligibility determination under the Tribal Authority Rule).” This priority ignores the fact that Indian tribes can achieve similar expertise and capability by entering into Direct Implementation Tribal Cooperative Agreements (DITCAs) to administer EPA programs or federal implementation plans on their reservations. As such, the NTAA recommends that EPA expand its priority to include DITCAs as another means for measuring a tribe’s success in possessing the expertise and capability to implement the Clean Air Act in Indian country. 

NTAA Technical 

Guidance 

This comment is on the EPA Strategic Plan section of the guidance, and needs to be addressed as part of that process. We do agree however, to add a 2010 priority to use DITCA authority where appropriate. 

Tribes should be included in the priority on page 14: “continue to work with financial experts to identify and develop tools, resources and programs for states and regional authorities to implement innovative financial programs....” 

NTAA Technical 

Guidance 

Agreed this language should be changed to reflect the comment. 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

NTAA is concerned about what came out of a 2005 GAO report that called out the TAS process for its shortcomings. Equally alarming is EPA’s response to GAO. NTAA remains unconvinced that the criticisms and subsequent recommendations made by the GAO have been adequately addressed by 

EPA. Most notably, the EPA strategy fails to include specific deadlines by which EPA must adhere to with respect to future TAS applications. NTAA recommends that EPA develop a strategy that specifically responds to and meets the recommendations made by the GAO concerning the TAS process. 

NTAA Technical 

Guidance 

OAR is committed to working with the Regions Offices to process TAS applications in a timely manner. OAR will also continue to participate in Agency activities to ensure full implementation of actions to address the findings of the GAO. 

To better understand the number of tribes that are expected to obtain TAS approval by 2014, the NTAA also recommends that the EPA provide our organization with a clear rationale as to how the number was arrived at. 

NTAA Technical 

Guidance 

EPA Regional Offices nationwide were asked to prepare an estimate based on their close working relationships with tribal governments and the knowledge that development of a TAS application generally requires the prior development of expertise in air quality on the part of the applicant. Each Regional Office subsequently submitted an estimate of which tribes in that Region were expected to be prepared to submit a TAS application in each of the applicable years. The results were compiled at HQ to develop the estimate. 

As a result of federal law, most Indian tribes in Oklahoma have been unable to receive TAS and only one Alaska Native village is currently eligible for TAS. Perhaps the next best option available to them to address issues and concerns is through the use of Direct Implementation Tribal Cooperative Agreements (DITCAs). The NTAA therefore recommends, as it did for the FY 2008 and 2009 OAR Guidance, that EPA regions (specifically Regions 6 and 10), provide specific resource and technical assistance to Alaska Native villages and Oklahoma tribes in the form of DITCAs. 

NTAA Technical 

Guidance 

EPA’s DITCA authority is available in every Region (including 6 and 10) and has been supported by OAR and AIEO for activities implemented by federally recognized tribes. 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

EPA states that it will “continue to provide guidance to tribes on planning and implementing air monitoring programs” and “continue to provide guidance on implementing air monitoring programs.” Generally speaking, the NTAA recommends that these two priorities be consolidated into one priority so as to avoid any redundancy. Additionally, NTAA recommends that EPA conduct a representative analysis of the existing tribal and non-tribal air monitoring networks to identify those Indian tribes that do not currently have a source of air monitoring data relevant to their lands. 

NTAA Technical 

Guidance 

Agree. The language will be changed to avoid redundancy. OAQPS is initiating a representative analysis that will generate GIS maps of emissions sources, monitoring location and tribal boundaries to help look at the potential for air quality concerns in Indian country and determine if monitoring is adequate. 

Include Indian tribes in the priority on page 15 that reads: “support state monitoring network implementation of lead and rural ozone monitors.” 

NTAA Technical 

Guidance 

Agree the language should be changed to include tribes. 

Indian tribe diets have not been adequately considered by EPA in the process of addressing emissions standards for mercury. For example, in developing the former Clean Air Mercury Rule, the Agency considered two segments of the population to be relevant to its analysis – i.e., recreational anglers, and “high level” consumers such as some Native American and other ethnic populations. In calculating the risk to these groups, the EPA used maximum fish consumption levels of 25 g/day for anglers and 170 g/day for high consumers. These levels, however, are far from adequate for some tribal populations. For example, a survey of Great Lakes area tribes produced a range of 189.6 to 393.8 g/day, and the Minnesota Chippewa Tribe has adopted 227 g/day as its treaty-protected subsistence quantity. 

NTAA Technical 

Guidance 

We will work to ensure tribal outreach and consultation on our rulemaking is conducted as we move forward on these rules to ensure tribal issues are considered. EPA welcomes and encourages tribes to provide input to this process to help us ensure these concerns are addressed.

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

The NTAA acknowledges the possibility that RPOs may continue to exist even in the absence of EPA funding. If this should become the case, the NTAA alternatively recommends that OAR establish a tribal set-aside fund, be it through EPA discretionary funds or some other means, to allow tribes to continue their involvement in RPOs, and to help advance tribal issues and concerns. Establishment of the tribal set-aside fund in no way diminishes the need to continue to fund the RPOs in general so that tribes may continue to work together with states, federal agencies, environmental organizations and industry to protect and preserve the nation’s air quality which knows no boundaries. 

NTAA Technical 

Guidance 

OAR also encourages NTAA to provide this recommendation in the budget planning process conducted annually. 

The guidance refers to a tribal database on pages 31 without explaining what this database is or its intended purpose. The NTAA would appreciate additional information regarding the database so we, as an organization, can provide specific input about it if necessary. 

NTAA Technical 

Guidance 

OAR has developed a management database to help track activities in the OAR Tribal Program called OAR Tribal Database. It is an internal database that tracks activities such as the number of TIPs, TAS, EIs, Permits, the goal of the database is to better understand the activities in tribal air programs across the country and to effectively communicate that to EPA management. 

NTAA recommends that the TEISS and TurboQAPP (see page 30) software packages continue to be funded by EPA during FY 2010. These software packages continue to provide Indian tribes with the resources necessary to collect and package valuable information for the Agency at a limited cost. Updates are also needed to the software packages to reflect changes in federal emissions inventory and QAPP requirements and to include GHG. 

NTAA Technical 

Guidance 

OAR has provided funding for continued work with both TEISS and Turbo-QAPP. 

EPA’s use of the term “in Indian country” in several places throughout the documents excludes other tribes, namely those from Alaska Native villages and Oklahoma. The language should be changed to “in Indian country, and on the lands of Alaska Native villages and tribes in Oklahoma.” 

NTAA Technical 

Guidance 

OAR proposes changing the references to “Indian country” to “federally recognized tribes” to assure NTAA of OAR’s commitment to working with all federally recognized tribal governments in keeping with federal trust responsibilities and policies. Indian country is a legal term that includes all lands within reservations, as well as all Indian allotments, which do continue to exist in Oklahoma and Alaska. 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

There is a marked absence of mercury deposition data in the western U.S., where the majority of the tribal land base exists. Because the dry deposition monitoring technique is not as developed as its wet deposition counterparts, data is particularly lacking in the Southwest where dry deposition predominates. Acquiring more deposition and health effects data is a priority for tribes in the years to come. The NTAA therefore recommends that the EPA list as one of its priorities, the provision of tribes with the necessary resources to conduct monitoring for mercury emissions based on their respective needs (e.g., dry versus wet deposition monitoring techniques). 

NTAA Technical 

Guidance 

The National Atmospheric Deposition Program (NADP) administers the Mercury Deposition Network (MDN) to monitor mercury in precipitation at sites across North America. Operating since 1996, MDN has grown to over 100 monitoring sites that provide valuable information on mercury wet deposition in locations nationwide. While scientists have a good handle on quantifying mercury in rainfall, the measurement of dry deposition remains a challenge. Lacking dry deposition measurements, EPA has worked with NADP and launched a new network that monitors the concentrations of ambient mercury fractions that contribute to dry deposition. NADP initiated this network to serve a number of objectives: estimating mercury dry deposition; understanding the impact of mercury emitting sources; providing data for evaluating models; and analyzing status and trends in atmospheric mercury. As part of this initiative, EPA is collaborating with the Cherokee Nation to establish a new atmospheric mercury monitoring site in Stillwell, OK. NADP and EPA continue to seek tribal collaborators to help address network monitoring gaps and build monitoring capacity on tribal lands and in other locations. Resource issues should be discussed in the annual budget process, and NTAA is encouraged to participate in that process. OAR is committed to supporting assessment of mercury deposition in Indian country based on national and tribal priorities and resources. We will continue to support tribal participation in activities related to the deposition of mercury.

In all parts of the guidance where governmental jurisdictions (tribes, states, locals) are cited, “tribes” should be placed in front of “locals,” and ideally, tribes, as sovereign nations, should be listed first. 

NTAA Throughout There is no accepted convention for order-ofimportance when referring to partner 

governmental entities, and any order used should not be interpreted as hierarchical. 

April 28, 2009 
Comment Commenter Text Location Response Change Y,N,NA 

EPA should establish a priority specific to international issues. A number of tribes, specifically those on the border of neighboring countries and those along coastal waters, are impacted by air pollutants from both near and far away lands. As such, some effort on the part of OAR to address these emissions would subsequently help to address tribal issues and concerns regarding the air quality over their respective lands. At the very least, the NTAA recommends that the EPA expand its research on international transport and atmospheric deposition, including research on the effects of atmospheric deposition on the food chain of tribal subsistence foods and treaty-reserved lands. 

NTAA Technical 

Guidance 

OAR works closely with EPA’s Office of International Affairs, and affirms that tribal issues are included in activities related to international transport, atmospheric deposition and other border and international issues. 

With respect to EPA’s regional priorities in the name of reducing GHG emissions and mitigating climate change impacts on human health and the environment, the Agency plans to “ensure tribal governments and communities are included as partners in GHG activities and participate in and benefit from ongoing coordinated efforts and outreach programs” (see page 45). To be full partners, however, tribes need to know their carbon footprint from which they can begin to reduce GHG emissions and contribute to the nation’s overall effort to reduce the adverse impacts of climate change. The NTAA therefore recommends that EPA regions work with tribes to provide them with the necessary resources to develop GHG emissions inventories. 

NTAA Technical 

Guidance 

EPA has developed or supported the development of guidelines and tools for state, regional, and local governments, as well as parks and schools, to conduct GHG inventories. These tools are freely available and can also be used by tribes. It may be necessary for tribes to pick and choose elements from the different protocols that best fit their unique circumstances (eg, a city-based protocol may miss out on land management, the state-based tools rely on data that may not be readily available to a tribe). Descriptions of these tools as well as free online trainings on Inventory Development are available on EPA's Climate Change website at: http://epa.gov/climatechange/emissions/state_guidance.html. EPA is available to help individual tribes assess their options for inventory development and looks forward to expanding the material on our website to include clearer guidance for tribal governments on GHG Inventories. 

++ End ++ 

April 28, 2009 
June 23, 2009

1

ADDENDUM NO. 1

Office of Air and Radiation

Fiscal Year 2010 National Program & Grant Guidance

The following information is an update to Appendix A (Grant Guidance and Preliminary 

Allocation) of the Office of Air and Radiation Final Fiscal Year 2010 National Program & 

Grant Guidance, dated April 28, 2009:

Summary

 A preliminary distribution of state and local air grants that reflects the President’s FY 

2010 budget submission has been included (see Table A-6). A total of $226.6 million is 

being requested for state and local air programs.

 Tribal funding remains at $13.1 million, and includes approximately $2.1 million to assist 

Tribes in analyzing and addressing the impacts of increased energy development 

facilities. Funds may be awarded using either §103 or §105 authority, depending upon 

the nature of the work and the eligibility of the recipient.

 State Indoor Radon Grants (SIRG) continue at just under $8.1 million. The Office of 

Radiation and Indoor Air is continuing to work with states on updating the distribution of 

these funds. Once determined, an updated narrative and distribution of SIRG funds 

(Table A-7) will be provided. 

 The President’s FY 2010 request level for Diesel Emission Reduction programs (DERA)

is $60 million, not $49.2 million.

 Funding for fine particulate monitoring is being requested for award under §105 

authority, as is funding for lead (Pb) monitoring. However, initial language in 

appropriations bills for EPA would continue the §103 authority for particulate 

monitoring. Additional information on the use of funds for photochemical assessment 

monitoring has been included.

 A total of $2.5 million in funding for air toxics monitoring around schools has been 

requested, equaling the FY 2009 level. The manner and authority for award for these 

funds is still to be determined pending an assessment of the FY 2009 results.

 The funding level for U.S.-Mexico Border air quality work is again set at just over $2.5 

million. A total of over $1.2 million has been targeted for Great Lakes air pollution 

deposition analysis and remediation work. Updated narratives are included in this 

addendum.
June 23, 2009

2

 Updated funding tables are included that cover: the comparison of recent STAG levels 

and the President’s request (Table A-1), the distribution and targeting of funds for 

photochemical assessment monitoring (PAMS) support (Table A-3), and an overall 

preliminary FY 2010 state/local air grant allocation (Table A-6). 

Updated Table A-1. Comparison of STAG Assistance:

FY 2008 through FY 2010 Request (in $ Millions)

U.S.–Mexico Border Air Program

The proximity of states and localities in EPA’s Regions 6 and 9 to the U.S-Mexico border 

presents a number of trans-boundary air quality challenges. Many border area residents, 

especially those in heavily urbanized areas, are exposed to health-threatening levels of air 

pollutants such as ozone, PM, and air toxics. Visibility impairment exists in most of the Class I 

areas along and near the border. Accurate evaluation of air quality in the border region will 

allow both countries to successfully target controls and reduce air pollutants. Capacity-building 

through such evaluation, training, and pilot projects that can be expanded by Mexico will further 

reduce air emissions along the border.

The Border 2012: U.S.–Mexico Environmental Program agreement, signed by both 

countries on April 3, 2003, was created to promote regional as well as border-wide strategies to 

improve air quality through coordinated air quality planning and management activities, such as 

the development of emissions inventories; the deployment, operation, and maintenance of air 

monitoring networks; the development of alternative fuels and energy sources; the development 

of innovative and progressive air quality management approaches; the design of air quality plans 

for the reduction and control of air pollution; pilot emissions reductions projects; and training 

and workshops aimed at building capacity and the development of public awareness and 

participation.

Milestones for demonstrating progress towards clean air in the border region are outlined 

by the Border 2012 Program and in EPA’s long and short term strategies goals and objectives. 

Program FY 2008

Enacted Level

FY 2009

Estimated Level

FY 2010

President’s Budget

Continuing Air Program * $165.7 $174.7 $216.6

PM 2.5 Air Monitoring (§103) $41.8 $41.9

Air Toxics Monitoring (incl. schools) $6.8 $7.5 $10.0

Regional Haze Planning (§103) $2.5

Diesel Emission Reduction Program ** $49.1 $60.0 $60.0

Tribal Air Program $10.8 $13.3 $13.3

State Indoor Radon $7.9 $8.1 $8.1

Total $284.6 $305.4 $308.0

* Includes continuing §105 program and NE OTC under §106. In FY 2010 this amount would also include grants for 

PM2.5 monitoring, unless changed by the Congress.

** Funds for California Emission Reduction projects are not included in FY 2008 and FY 2009 levels. Funds for State and 

Local Climate Change Initiatives are not included in the FY 2009 total. Also note that the President signed a FY 2009 

economic stimulus bill that provided an additional $300 million for DERA implementation, approximately $88 million of 

which was targeted by formula for state and local air quality agencies.
June 23, 2009

3

Grant assistance plays a key role in helping achieve them. Early efforts focused on developing an 

organizational infrastructure, raising awareness, gathering information and establishing baseline 

information. Recent assistance has increasingly been focusing on critical analysis and mitigation 

measures such as retrofitting diesel engines aimed at attaining clean air goals and building 

capacity for Mexico to manage these and similar programs. In FY 2008, the Border 2012 

Program Objectives for the Air Program were amended to include building border greenhouse 

gas (GHG) information capacity and expanding existing voluntary cost-effective programs for 

reducing GHGs in the border region.

In addition to supporting the efforts of affected state, local and multi-jurisdictional 

agencies, the Border 2012 Program uses regional workgroups, task forces, and policy forums to 

develop and implement air pollution emission reduction strategies. Many of these rely heavily on 

grass-roots input and actions. For example, OAR and its Mexican counterpart lead the Border 

2012 Air Policy Forum, established to employ a bottom-up collaborative approach to develop 

strategies for cooperative emissions reduction efforts along the border. EPA’s activities are 

designed to encourage, develop and implement cooperative projects with various levels of 

federal, state, and local government, tribes, academics, non-governmental organizations and 

others, so that sustained, comprehensive pollution abatement can occur in the common air sheds 

of border sister cities, as well as in remote areas where trans-border air pollution occurs. Air 

Policy Forum members additionally advise EPA and Mexico’s SEMARNAT on potential 

strategic funding needs and opportunities.

EPA Region 6 and 9 use a combination of direct grants and competitive solicitation to 

support state, local, and tribal initiatives. In encouraging local and grass-roots strategies, the 

Agency is committed to full and open competition for many grants and contracts. This empowers 

a larger number of state, local, tribal entities (also working with academics and NGOs) to 

become active participants in border air quality improvements. The combination of these STAG 

funds with directed, specific projects facilitated by contracts has yielded very positive results. 

For example, Mexico has assumed increased ambient monitoring responsibility along portions of 

the border region. In FY 2010, approximately $2.5 million will be divided between Regions 6 

and 9 to continue a focus on three major areas: public outreach and involvement, the 

enhancement of scientific knowledge, and the support of projects that deliver tangible emission 

reductions. The Regions will work with OAR to assure that the activities funded are appropriate 

to the entities eligible and the appropriate authority for award. For more information on the 

program please contact: Ruben Casso in Region 6 (214-665-6763); and in Region 9, Christine 

Vineyard (415-947-4125) or Andrew Steckel (415-947-4115).

Great Lakes Air Quality Initiative

Atmospheric deposition of persistent bioaccumulative toxics (PBTs) and other pollutants 

poses a serious human health and environmental risk in the Great Lakes freshwater ecosystem. 

Numerous PBT risks already identified in the Great Lakes Region, and emerging chemicals such 

as polybrominated diphenylethers (PBDEs), siloxanes, and perfluorinated compounds (PFCs) are 

now widely found in water, fish or sediment samples in the Great Lakes. The Great Lakes 

Initiative supports improvements to, and applications of, multi-media strategy development and 
June 23, 2009

4

assessment tools needed to identify the contribution and effects of toxic air deposition to the 

Great Lakes region.

EPA Region 5 coordinates with EPA Regions 2 and 3 and the Great Lakes National 

Program office to support the Great Lakes states deposition-related activities. In prior funding 

years, EPA Region 5 has used a combination of direct grants and competitive solicitation to 

support state and tribal initiatives PBT research and reduction.

Priority activities of the program include: identification of air toxics sources, 

development of accurate and comprehensive air toxics emission inventories, monitoring of air 

toxics deposition, modeling of atmospheric dispersion and deposition of toxic pollutants, 

assessment of long-range atmospheric transport of toxic pollutants to the Great Lakes region, and 

assessment of the effects of atmospheric toxic pollutants on fish and wildlife. These activities 

are consistent with the goals of the CAA, the Great Lakes Bi-national Toxics Strategy, the Great 

Waters Program, and the Office of Water’s Total Maximum Daily Load (TMDL) Program. 

Development of this information is critical in establishing the basis to create further regulations 

and strategies to minimize atmospheric loadings to the Great Lakes and other inland water 

bodies. The results of this work are used to guide federal, state, and local policy for the Great 

Lakes and other fresh water ecosystems.

EPA will continue to work closely with the Great Lakes states to see continued 

improvement and application of multi-media strategies to address air deposition. EPA will 

highlight priority projects based on the regulatory and scientific needs of the Great Lakes states. 

To support the Great Lakes activities in FY 2010, the Agency has allocated just over $1.2 million 

in STAG resources. For more information, including guidance on those entities eligible for 

receipt of funds, contact Erin Newman at 312-886-4587 or Shari Holloway at 312-886-6778.

Section IV. AMBIENT MONITORING

EPA is providing this addendum to Appendix A of the 2010 National Program & Grant 

Guidance Section IV – Ambient Monitoring, to either help clarify the Agency’s position or to 

share additional information.

Funding for PM2.5 Monitoring

During the development of the FY 2010 grant guidance, EPA wrote that we expected

“...to provide funding for PM2.5 and air toxics monitoring funding through §103 authority.” 

Since this time, EPA’s budget has been submitted to Congress. In this budget request for FY 

2010, the Administration did not request section 103 authority for this purpose. However, initial 

versions of the appropriations bills for EPA include the section 103 authority.
June 23, 2009

5

Funding for Air Toxics Monitoring

As described in the 2010 National Program & Grant Guidance of April 28, 2009, EPA 

expects to continue support for the National Air Toxics Trends Stations (NATTS) and associated 

data analyses, methods, and quality assurance using §103 authority.

Also at that time, the Agency noted that it was “...seeking comment on supporting 

monitoring projects involving “hot-spots,” such as locations where schools may be impacted 

from a local source or sources with elevated levels of air toxics emissions,” as part of its overall 

community-scale air toxics monitoring program. EPA is again committing $2.5M in FY 2010 

funds to support additional monitoring and assessment activities of air toxics at high priority 

schools nationwide. 

Funding for the Photochemcial Assessment Monitoring Stations (PAMS)

In the 2010 grant guidance OAR asked for input on the merits of utilizing $700K and 

$150K of the approximate $14M of PAMS STAG funds to provide upgrades of expensive 

monitoring equipment used in PAMS and continued work on assessment of the PAMS data, 

respectively. Since that time EPA staff has met with the ambient air monitoring experts of state 

and local agencies, and they have strongly endorsed this approach. 

The intent of the equipment funds is to target approximately two Regions each year for 

upgrades of major measurement systems in the PAMS monitoring program. An example of the 

approach would be to: (a) upgrade gas chromatographs or vertical profilers in PAMS monitoring 

networks where the state is unable to budget adequate funds in within the one year upgrade 

period, (b) in subsequent years, rotate the upgrades to additional PAMS networks in other 

Regions. The targeted equipment funds are not intended to replace routine monitoring equipment 

such as ozone analyzers. Upgrade of this equipment should be included in the normal budget of 

each agency’s program.

Unless directed otherwise, EPA will target $700K and $150K of the available PAMS 

funds for equipment upgrades and assessment of PAMS data respectively. These funds will be 

targeted for equipment funds for the initially targeted two Regions. EPA will work closely with 

affected recipients to determine if it would be best for the monitoring agency to purchase the 

equipment or, if the recipient prefers, to have EPA perform the purchasing and provide the 

equipment as in-kind assistance.
June 23, 2009

6

The following Table provides the anticipated funding breakdown for PAMS in FY 2010.

Revised Table A-3. Distribution of Funds for PAMS Support

Region

Number 

of 

PAMS 

Areas

Data 

Analysis

Implementation 

and Operation Total

1 5 $695,371 $1,983,820 $2,678,979 

2 1 $222,519 $532,916 $754,701 

3 3 $333,779 $1,015,239 $1,349,328 

4 1 $139,074 $342,344 $481,020 

5 21 $278,149 $895,642 $1,174,372 

6 5 $591,306 $1,923,361 $2,516,030 

7 0 $0 $0 $0 

8 0 $0 $0 $0 

9 82 $1,112,594 $3,086,389 $4,198,071 

10 0 $0 $0 $0 

National Data 

Analysis/Equipment 

Replacement $150,000 $700,000 $850,000 

Totals 24 $3,522,791 $10,479,711 $14,002,502 
June 23, 2009

7

Table A-6 Preliminary FY 2010 State/Local Air Grant Allocation

As of June 19, 2009

Region

Program Area 1 2 3 4 5 6 7 8 9 10 Total

Ozone 7,953,506 6,818,425 5,708,968 7,258,477 11,608,654 9,297,405 1,622,569 1,460,596 13,601,103 1,541,113 $66,870,817

PM 1,780,574 2,876,493 4,811,776 4,575,958 4,892,859 1,260,072 2,059,450 2,935,643 7,847,714 3,266,524 $36,307,062

PM (US-Mexico Border in ROs 6/9) 0 0 0 0 0 1,247,869 0 0 1,245,896 0 $2,493,765

PM (WRAP in R9) 0 0 0 0 0 0 0 0 152,484 0 $152,484

Visibility 38,798 438,554 786,472 2,008,186 558,878 747,815 545,790 1,717,071 68,361 669,056 $7,578,980

NO2 26,970 336,654 478,316 0 91,122 291,736 34,757 139,882 108,008 39,066 $1,546,511

Lead 0 0 117,666 101,120 108,208 41,677 92,685 26,624 12,001 0 $499,981

CO 665,350 123,907 446,748 303,359 486,934 83,353 14,482 289,061 450,034 215,090 $3,078,318

SO2 231,695 317,172 844,707 404,479 875,627 125,030 26,068 328,786 276,021 41,312 $3,470,897

Air Toxics Implementation 2,242,585 1,660,017 1,349,913 1,807,368 3,691,982 1,163,268 666,439 371,478 3,560,703 1,878,674 $18,392,428

Air Toxics Characterization 982,483 1,876,975 2,858,295 2,409,825 2,125,847 1,661,812 522,810 459,625 1,197,799 907,435 $15,002,905

Air Toxics - Great Lakes 0 0 0 0 1,218,550 0 0 0 0 0 $1,218,550

Acid Rain 0 326,269 242,173 393,825 1,059,119 0 0 223,019 178,193 0 $2,422,598

Subtotal 13,921,961 14,774,466 17,645,034 19,262,597 26,717,780 15,920,037 5,585,050 7,951,785 28,698,317 8,558,269 $159,035,296

NOx Trading $2,327,550

NACAA $1,558,820

NPAP $454,080

National Procurement $818,454

NE OTC $639,000

Energy Facility AQ Analysis 195,000 303,333 195,000 411,667 195,000 520,000 411,667 845,000 520,000 303,333 $3,900,000

U.S.-Mexico Border Inventory $275,000

IMPROVE $1,228,800

PM2.5 Monitoring Direct to ROs 1,818,000 1,898,263 3,024,069 5,822,751 4,952,042 3,236,628 1,627,619 1,814,900 3,396,070 1,917,639 $29,507,981

PM2.5 Monitoring APS Recipients 614,961 743,531 1,015,633 1,526,087 1,533,280 579,417 812,325 548,644 1,103,628 412,281 $8,889,787

PM2.5 Monitoring APS – HQ $3,477,232

NATTS Monitoring Direct to ROs 233,674 181,856 208,868 470,902 229,362 310,000 29,176 82,974 286,328 356,600 $2,389,740

NATTS Monitoring APS Recipients 231,326 128,144 101,132 282,098 235,638 0 125,824 227,026 243,672 108,400 $1,683,260

NATTS Monitoring APS – HQ $900,000

School Air Toxics Monitoring $2,500,000

Lead (Pb) Monitoring 30,513 91,536 257,075 329,451 451,318 275,331 375,581 61,024 168,178 61,024 $2,101,031

Lead (Pb) Monitoring APS – HQ $398,970

Community-Scale Air Toxics Monitoring $2,500,000

CAA Training $1,995,000

Sub-total $67,544,704

Total $226,580,000