Chapter 3 Page 33

Chapter 3 Goal Setting & 

Data Gathering for a

TIP

Since a Tribal Implementation Plan (TIP) only addresses

the criteria pollutants regulated by the National Ambient

Air Quality Standards (NAAQS), it may be just one part of

a broader tribal air program that is concerned with many

different pollutants and air quality problems. This chapter

explains the federal air quality designations based on the

NAAQS, and discusses what your tribe should consider

when setting its air quality goals in relationship to the

NAAQS. Technical information can help the tribe evaluate

the air quality on your reservation, set air quality goals, and

determine the most appropriate control measures for

meeting those goals. This chapter also discusses two tools

for gathering such information: emissions inventories and

air quality monitoring systems.
 Chapter 3 Page 34

Air Quality

Designations

How is air quality classified

in relationship to the

NAAQS?

Bighorn Canyon National 

Recreation Area, MT & WY

Established by an act of

Congress on October 15,

1966, the Bighorn Canyon

National Recreation Area

houses the Yellowtail Dam. 

Named after the famous

Crow chairman Robert

Yellowtail, the dam harnesses

the waters of the Bighorn

River. (National Parks

Service)

The Clean Air Act (CAA) section 107(d) establishes three

air quality designations relative to the NAAQS:

» Nonattainment - any area that does not meet (or

that contributes to ambient air quality in a nearby

area that does not meet) the primary or secondary

NAAQS for the pollutant 

» Attainment - any area (other than an area identified

as being in nonattainment) that meets the primary or

secondary NAAQS for the pollutant 

» Unclassifiable - any area that cannot be classified

on the basis of available information as meeting or

not meeting the primary or secondary NAAQS for

the pollutant

 

EPA is generally required by the Clean Air Act to make

designations for the entire country 2 to 3 years after each

new standard is adopted.1

 However, for the 8-hour ozone

standard and PM2.5 NAAQS, Congress established specific

schedules and EPA is now moving forward with

implementation and rules for the PM2.5 and the 8-hour

ozone standards. It is the EPA’s intent to promulgate

designations for those standards after 2003. A variety of

tools are used to determine the designation for an airshed

area, including nearby monitors, modeling, or other

methods to determine if an area is or is not meeting the

standard. Air pollutant modeling has proven that some

pollutants can be transported great distances. Therefore, it

is possible that relatively rural areas (e. g. Indian country)

with no nearby sources of air pollutant emissions may not

meet the NAAQS. An area can be in attainment for some

pollutants and in nonattainment for others. In some cases

when there is insufficient air quality data to determine

whether ar area meets the NAAQS, the area may be

designated as “unclassifiable.” Such areas are treated in the

same manner as an attainment area. The
 Chapter 3 Page 35

attainment/nonattainment status of your reservation may

influence your air quality goals.

Some areas in the eastern US that are designated attainment

are treated in the same manner as nonattainment. In the

1990 CAAA these areas were established by Congress as

the Ozone Transport Region. The Region is comprised of

the States of Connecticut, Delaware, Maine, Maryland,

Massachusetts, New Hampshire, New Jersey, New York,

Pennsylvania, Rhode Island, Vermont, and the

Consolidated Metropolitan Statistical Area that includes the

District of Columbia..

" Attainment Areas The CAA establishes three classes of attainment/

unclassifiable areas, Class I, II, and III.2

 Class I areas are

held to the strictest air pollution standards. “Federal

Class I” areas are the Class I areas that were created in the

CAA. These areas include national wilderness areas and

national memorial parks greater than 5,000 acres, national

parks greater than 6,000 acres, and international parks. 

Additional areas have since been reclassified as Class I

areas, including some Indian reservations. 

Class II areas initially were all those areas that were in

attainment or unclassifiable that were not established as

federal Class I areas. Class II areas can be redesignated as

Class I and receive greater air quality protection;

information on that process is found later in Chapter 4 in

the section on Regional Air Quality. Class II areas can also

be redesignated as Class III areas, which allows for more

intensive development and greater emissions of criteria

pollutants. 

" Nonattainment Areas The 1990 CAA Amendments require nonattainment areas

in states to be further classified for some pollutants,

depending on the severity of the air pollution problem.3

Areas designated nonattainment for the 1-hour ozone

standard are divided into five classifications, depending on

the ambient air quality: marginal, moderate, serious, severe,

and extreme.4

 The regulatory requirements increase for

each class of nonattainment area, with extreme ozone

nonattainment areas having the most stringent set of
 Chapter 3 Page 36

Figure 3-1. Multiple

nonattainment (NA) areas

within a larger NA area. This

map shows two SO2 NA

areas inside the PittsburghBeaver Valley ozone NA

area.

requirements. Attainment deadlines also vary from 3 years

for marginal areas to 20 years for extreme areas. 

Carbon monoxide and particulate matter (with a diameter

less than or equal to 10 micrometers; PM10) nonattainment

areas are classified as either moderate or serious.5 Each

class of nonattainment area has different regulatory

requirements and attainment deadlines. As with ozone

nonattainment areas, tribes have the flexibility to work with

EPA to ensure that appropriate regulatory requirements are

applied to Indian country sources.

For lead, sulfur oxides, and nitrogen dioxide nonattainment

areas there are no further classifications. Currently, there

are no nitrogen dioxide nonattainment areas.6

To find out if your tribe’s reservation is in or near a

nonattainment area, your tribe can consult the Green Book -

Nonattainment Areas for Criteria Pollutants. The Green

Book contains nonattainment areas by county which could

be helpful in determining air quality if your tribe submits a

designation recommendation to EPA (see below). Online,

The Green Book can be found at

http://www.epa.gov/oar/oaqps/greenbook. The Green Book

also contains pertinent Federal Register notices.7

How are air quality areas

determined?

For states, after the promulgation of a new or revised

NAAQS, the Governor of each state is required to submit to

the EPA a list of recommendations for all areas that are in

nonattainment, attainment, or are unclassifiable with

respect to the new or revised standards. A state

recommendation for designation of an area including or

adjoining an area of Indian Country does not necessarily

determine the designation for that area of Indian country. 

However, the conditions that support the state’s designation

recommendation, such as air quality data and the location

of sources, may indicate the likelihood that similar

conditions exist in that area of Indian Country. 

Tribes are encouraged, but not required, to submit

designation recommendations for their reservations, or

other areas under their jurisdiction, to EPA. In cases where

tribes do not make recommendations, the EPA, upon
 Chapter 3 Page 37

Figure 3-2. Overlapping NA

areas. This map shows the

Searles Valley PM10 NA area

which partially overlaps the

San Joaquin Valley ozone

NA area.

Figure 3-3. A NA area in

more than one state. This

map shows the CincinnatiHamilton moderate O3 NA

area, which overlaps the

states of Ohio and Kentucky.

consultation with the respective tribe(s), will promulgate

the designation it deems appropriate.8

 If a tribe chooses to

recommend a designation, EPA will consult with the

affected tribe if EPA wishes to modify the

recommendation.

Designations tell the public about the nature of the air

quality in a given area for one pollutant. The EPA in the

past has used political or physical boundaries as the default

boundaries for area designations. Political boundaries

could include Metropolitan Statistical Area (MSA) or

Consolidated Metropolitan Statistical Area (C/MSA)

boundaries, county or Indian Country boundaries. MSAs

and C/MSAs are often used as useful default boundaries for

urban areas which capture a densely populated and socially

and economically integrated area. Physical boundaries such

as a watershed, valley, or mountain range, may also define

a designation area. 

Designation boundaries can be larger or smaller than any

area of Indian Country, county, or urban area. A tribe may

want to recommend larger area boundaries, for example, if

sources outside their reservation or other areas under their

jurisdiction contribute to violations within such areas. On

the other hand, a tribe may want to recommend smaller

boundaries, for example, if a proposed nonattainment area

covers multiple air basins or includes counties or areas of

Indian Country which are rural in nature. It is possible for

several small nonattainment areas for one pollutant to be

found inside one larger one for a different pollutant (see

Figure 3-1), for two areas designated nonattainment for

different pollutants to overlap (see Figure 3-2)., or for a

nonattainment area to encompass area in more than one

state (see Figure 3-3).

Some of the factors tribes may wish to consider when

submitting nonattainment area boundary recommendations,

rather than C/MSA boundaries, particularly in Indian

country that may not have adequate or any air quality

monitors, include:

» Location of and data from nearby air quality monitors

» Geographic location of the land
 Chapter 3 Page 38

» Proximity to the nearest designated nonattainment area

» Prevailing meteorology

» Location of nearby emissions sources both inside and

outside the area

» Population density

» Degree of urbanization on or nearby the area (including

existing and future commercial and industrial

development)

» Current level of emissions control

» Expected future growth of emissions sources

Air Quality Goals

What should be considered

in setting air quality goals

for your TIP?

National emission trends.

9

The existing air quality on your tribe’s reservation is the

most important factor in determining the goals for your

TIP. Diverse factors can affect air quality on reservations. 

Some reservations are adjacent to urban areas and are

affected by pollutants from the urban area as well as

sources within their boundaries. Other reservations are

more rural, and may or may not have sources of pollutants

within their boundaries. Because pollutants can travel great

distances, reservations may also be affected by emissions

from sources far outside their boundaries. 

Two measures of the existing air quality are the

concentrations of the criteria pollutants (particulate matter,

ozone, sulfur oxides, nitrogen dioxide, carbon monoxide,

and lead) and the impaired view of distant vistas. For those

pollutants with concentrations below the NAAQS, the tribe

would develop a TIP to specify the actions that will

maintain good air quality and prevent deterioration of air

quality. For those pollutants with concentrations above the

NAAQS, the tribe would develop a TIP to specify the

actions the tribe could take to reduce the emissions from

sources on the reservation. If there are some pollutants that

meet the NAAQS and others that violate the NAAQS, or if

the tribe does not know about the air quality, a tribe may

develop both types of TIPs, one to maintain air quality and

one to improve it, depending on the pollutant.

In addition to the existing air quality on your reservation,

other factors to consider when setting air quality goals

include: the importance or value of clean air and clear
 Chapter 3 Page 39

Air quality monitoring

equipment.

This is an Optec NGN-2

nephelometer operated with

solar power in the Mojave

Desert. Also on the tower are

an air temperature sensor,

datalogger, and data

collection platform with

antenna.

(Photo courtesy of Air

Resource Specialists, Inc.)

vistas to the members of your tribe and the tribal economy;

the existing sources and types of air pollutants on or near

your reservation; public health or environmental problems

related to air quality; and the potential for new air pollution

sources to locate on your reservation. You may also want

to develop air quality standards that are more stringent than

the NAAQS for criteria pollutants. Tribes can also develop

air quality goals for non-criteria pollutants to address their

particular social, cultural, and environmental needs; these

goals and strategies to meet them would not be included in

a TIP. 

What are some typical initial

air quality goals?

Your preliminary air quality goal may be to assess the

current situation on your reservation by developing an

emissions inventory and establishing an air quality

monitoring network. An emissions inventory is a list of

facilities and activities that cause air pollution, including

the types and amounts of pollutants emitted from those

activities. An air quality monitoring network is one or

more sites where instruments are located to sample the air

continuously, daily, or periodically. Meteorological

stations often are part of air quality monitoring networks. 

Monitoring data can be used to determine the

concentrations of pollutants in your communities, and

which of the NAAQS, if any, are being violated. 

Information on emissions inventories and air quality

monitoring is provided later in this chapter.

If your tribe has good reason to believe that existing

pollutant concentrations are below the NAAQS (e.g., there

are no significant sources of air pollution on your

reservation or in adjacent areas), your goal may be to

develop maintenance strategies for one or more air

pollutants. The goal of a maintenance strategy is to limit

air pollutant emissions so as to maintain pollutant

concentrations at levels below the NAAQS. If there are

significant sources of air pollution on your reservation, or

in adjacent areas, the existing concentrations of some

pollutants may violate the NAAQS. If this is the case, your

goal may be to develop an attainment strategy to reduce the

concentrations of those pollutants to levels below the

NAAQS. For more information on these options, see

Chapter 4.
 Chapter 3 Page 40

Requirements for

Redesignation from

Nonattainment to

Attainment:

 » NAAQS attained

 » EPA has approved the

implementation plan

 » Improvements in air

quality are permanent

and emissions

reductions are

enforceable

 » EPA has approved the

maintenance plan

 » All applicable

requirements in the

attainment strategy are

met

How can nonattainment

areas be redesignated as

attainment areas?

A nonattainment area can be redesignated to attainment if

the following conditions are met:10 

» The EPA must determine that the NAAQS are attained

based on an appropriate demonstration, which could

include air quality modeling

» The applicable implementation plan must be fully

approved by EPA as meeting all applicable

requirements

» The EPA must determine that improvements in air

quality are due to permanent and enforceable reductions

in emissions; attainment resulting from temporary

reductions in emissions rates (such as reduced

production, shutdown, or temporary adverse economic

conditions) or unusually favorable meteorology would

not qualify

» The EPA must fully approve the maintenance plan

under the CAA section 175A. Maintenance plans may

be submitted prior to or at the same time as the

redesignation request. Section 175A defines the general

framework of a maintenance plan, which must provide

for maintenance of the relevant NAAQS in the aea for

at least 10 years after redesignation. The core

provisions that should be included to ensure

maintenance of the relevant NAAQS are:

› An attainment emissions inventory

› A maintenance demonstration showing

future emissions will not cause a violation of

the NAAQS

› Contingency measures to promptly correct

any violation of the NAAQS that occurs

after redesignation, including all measures

that were contained in the attainment

strategy prior to redesignation

Tribes are encouraged to work closely with states and their

regional EPA office early in the redesignation process to

help ensure that a redesignation request has a high
 Chapter 3 Page 41

likelihood of being approved by EPA (see Appendix A,

Tribal Contacts at EPA).

What if you want to set

standards more stringent

than the NAAQS?

If the air quality on your reservation is currently better than

the NAAQS, your tribe may want to set air quality goals

more protective than the NAAQS. The Prevention of

Significant Deterioration (PSD) program is a source

preconstruction permitting program applicable to areas with

air quality that is better than the NAAQS. The primary

purpose of the PSD program is to preserve good air quality

in areas that meet the NAAQS while still allowing

economic development to occur. For more information on

this program, see Chapter 4.

Developing An

Emissions

Inventory

What is an emissions

inventory?

An emissions inventory identifies the activities on your

reservation that cause air pollution and the types and

amounts of pollutants emitted by those activities. A source

of air pollution is any activity that causes pollutants to be

emitted into the air. An emissions inventory is a

quantitative list of the amounts and types of pollutants that

are entering the air from all sources within a certain area. 

The fundamental elements in an emissions inventory are the

characteristics and locations of the sources, as well as the

amounts and types of pollutants emitted. 

How can an emissions

inventory be useful to your

tribe?

An emissions inventory can help identify air pollution

concerns and determine the air quality goals your tribe

wants to meet. Detailed information on activities on your

reservation that cause air pollution, and the types and

quantities of pollutants generated by those activities, can

help your tribe set and attain its air quality goals. 

An emissions inventory is one of the most basic tools of air

quality management. With an emissions inventory, your

tribe can simulate air pollutant formation and transport

(e.g., ozone), estimate potential pollutant concentrations on

your reservation, and estimate the effectiveness of potential

emission reduction requirements. Chemical transformation
 Chapter 3 Page 42

and computer dispersion models use emissions data and

meteorological data to project how pollutants will form and

spread (disperse) across a region. 

Are there any regulations

governing the tracking and

reporting of emissions?

For many years EPA has maintained a number of

requirements for emissions inventory reporting. EPA

recently revised and simplified the reporting requirements,

added several new requirements related to particulate

matter and regional haze, and moved them all to a single

location in the Code of Federal Regulations. This action

was called the Consolidated Emission Reporting Rule

(CERR).11 Although the notice publishing the rule says

specifically that Tribes are not required as a general matter

to develop emission inventories or to comply with the

requirements of the CERR, it provides additional guidance

to Tribes on how to develop and quality assure emission

inventories, and discusses some of the benefits of reporting

emissions from Tribal lands into the National Emission

Inventory.

What types of emissions

inventories are there?

Dispersion models use

emissions and meteorological

data to project how

pollutants will spread

(disperse) across a region.12

There are three types of emissions inventories, depending

on the intended use of the data: base-year, periodic, and

modeling.

» Base-year inventories provide information about the

emission levels at the start of pollution-control efforts. 

These inventories provide a baseline against which

progress in reducing or maintaining emissions can be

measured. They also inform decision-makers about

how much and what types of pollutants are being

emitted which can be used in future permitting

decisions. The other types of inventories are derived

from the base-year inventory, so it is important that it is

as comprehensive, accurate, and current as possible. 

» Periodic inventories are generally done every 1-3 years

after the base-year inventory, depending on the needs of

your program. Periodic inventories are used to track

changes in emissions over the time that emission

reduction strategies are implemented in nonattainment

areas. They can be compared to the base-year inventory

to identify the progress achieved in reducing emissions

over the interim period. 
 Chapter 3 Page 43

» Modeling inventories are only prepared to support air

quality modeling efforts. Air quality models are used to

simulate the chemical reactions of pollutants and their

dispersion in the atmosphere. Very specific information

on emission sources is required for air quality models

(e.g., stack height, emissions temperature, etc.). 

Modeling inventories are based on either allowable or

actual emissions, depending on the purpose of the

modeling. Allowable emissions are the type and

quantity of emissions allowed by regulations. 

Allowable emissions for the base-year and projected for

the attainment year are used to evaluate whether an

attainment strategy will reduce emissions enough to

meet the NAAQS. Actual emissions are the type and

quantity of emissions actually emitted from sources

during normal operation and may be more or less than

the allowable emissions. Actual emissions data are 

used with air quality monitoring data to evaluate model

performance. 

What is an Inventory

Preparation Plan?

Careful and thorough planning can greatly facilitate the

inventory development process and prevent the need for

costly revisions. Before an inventory is developed, an

Inventory Preparation Plan (IPP) should be prepared.13 An

IPP is a concise, prescriptive document that includes

inventory objectives and general procedures, and clearly

describes how the tribe will document and present the

inventory to EPA and/or others. 

As part of the IPP process, the tribe should consider:

» Scope of the inventory

» End uses of the data

» Availability and usefulness of existing data

» Strategy for data collection and management

In general, most IPP’s:

» Define the geographic inventory area

» Define the attainment or nonattainment status of the

area

» Define the scope of the inventory (i.e., identify which

types of sources and pollutants will be covered, and for

which year)
 Chapter 3 Page 44

Emissions

 Factor

Activity 

 Data

Emissions 

 Estimate

Formula for calculating

emissions estimates.

» Specify who is responsible for preparing the inventory

and each person’s responsibilities

» Identify plans for data collection, analysis, and emission

estimation procedures

» Describe quality control and quality assurance

procedures14

How does your tribe start

creating an emissions

inventory?

To begin creating an emissions inventory, your tribe will

need to identify potential sources of emissions on your

reservation. The EPA’s Office of Air Quality Planning

and Standards, Emissions Monitoring and Analysis

Division, maintains a preliminary database of emissions

inventory information on many sources in Indian country

and the states. A local business directory and phone book

can also be a good starting point. Service and retail

businesses can usually be ruled out (with some exceptions,

such as sources that use a lot of solvent or gasoline

distribution facilities); concentrate on manufacturing,

treatment plants, assembly, extraction, storage, engines, and

utilities. Other types of sources include burning and dust

from construction and unpaved roads. 

While planning your inventory, the tribe may want to send

a letter to the business asking for general information on

the work they do. Your tribe can also obtain information

by visiting the facility and asking for a tour. Once you have

a list of sources, the tribe can begin compiling information

for your inventory.

To collect data, the tribe may need to develop reporting

forms. Your regional EPA office and the states

surrounding your reservation may have a sample reporting

form that your tribe can use or modify. Examples of the

type of information it would be useful to obtain from each

source:

» The name and location of the source

» The owner/operator’s contact information

» A description of the activities causing the emissions

» The source’s current compliance status with regulations

» The source’s operating parameters and schedules

» The pollutants emitted (controlled and uncontrolled)

» The emission rates of each pollutant emitted

» The control methods used
 Chapter 3 Page 45

» Characteristics of the emissions (i.e., ground level, roof

level, stack, gas temperature)

» Activity data (i.e., tons per year of input used (e.g.

gallons of paint) or output produced)

The EPA provides several resources and guidance

documents to assist the tribe in planning and developing an

emission inventory.15 

» The ClearingHouse for Inventories and Emissions

Factors (CHIEF)

» Emissions Inventory Guidance for Implementation of

Ozone and Particulate Matter NAAQS and Regional

Haze Regulations

» The Emissions Inventory Improvement Program (EIIP)

» The Compilation of Air Pollutant Emission Factors,

AP-42, Volumes I and II

» Additional information, including the types of sources

and emissions to include in an emissions inventory,

approaches to inventory development, and additional

resources, are provided in Appendix F, Emissions

Inventories.

Developing An

Air Quality

Monitoring

Program

What is an air quality

monitoring program? Does

your Tribe need one?

An air quality monitoring program provides information on

the ambient pollution levels for a given area. This

information can be used to identify changes in air quality

and to determine whether the area meets the NAAQS for

the criteria pollutants. Air quality data are also important

for determining the goals of your TIP and the actions

necessary to obtain or sustain good quality air. However,

your tribe does not need to have a NAAQS determination

or monitors to develop a TIP.
 Chapter 3 Page 46

Jay Littlewolf, Administrator

of the Northern Cheyenne

Tribe’s Air Quality Program,

checks PM monitoring

equipment.

Scott Williams, technician for

the Norther Cheyenne Tribe’s

Air Quality Program,

changes a filter on a PM

monitor.

Information on existing monitoring stations is available

through the Office of Air Quality Planning and Standards at

www.epa.gov/oar/oaqps/qa/monprog.html. You can

discuss with EPA what currently available ambient

monitoring data may be representative of pollutant levels

for your reservation. Based on this discussion, your tribe

may decide to accept the existing ambient monitoring

networks as being adequate to provide data which are

representative of your reservation. Or your tribe may

decide, in conjunction with EPA, that additional monitoring

on your reservation by either your tribe or EPA is needed to

establish and track ambient pollutant levels there. 

The tribe is not required to have an air quality monitoring

network in order to adopt TIP measures. If your tribe

decides to implement an air quality monitoring system, data

from an emissions inventory can be useful in determining

where to site or locate the monitors. 

What should a monitoring

program achieve?

Monitoring programs usually measure the concentrations of

the criteria pollutants across an area at regular intervals; the

concentrations of hazardous air pollutants can also be

measured. Before designing a monitoring network, it is

helpful to determine your purpose in monitoring. Does the

tribe want to: 

» Determine whether average pollutant concentrations are

above or below the NAAQS?

» Determine highest levels of air pollution expected to

occur in the area?

» Determine the extent of regional pollutant transport?

» Determine representative levels of air pollution in areas

of high population density?

» Determine general background concentrations of

pollutants?

» Determine the impact of significant sources of air

pollution on overall levels of air pollution?

» Determine the economic, cultural and public welfarerelated impacts of pollutants on visibility, vegetation,

health, and other factors?
 Chapter 3 Page 47

A monitoring station used by

the Norther Cheyenne Tribe’s

Air Quality Program.

If an objective of your monitoring program is to determine

if the NAAQS are being met, the program must satisfy the

technical requirements given in 40 CFR 58 to achieve the

following goals:16

» Acceptable quality assurance procedures, which are

necessary to provide data that meet the basic objectives

and to minimize loss of data

» Proper equipment and methods

» Proper location and number of monitoring stations

» Proper location of the equipment that collects air

samples (after selection of the general location of a

monitoring station)

» At least one monitor that operates during air pollution

emergency episodes

How does the tribe report

and use the data?

Data on air pollution levels obtained using federal reference

methods are submitted to the EPA’s Aerometric

Information Retrieval System-Air Quality System (AIRSAQS). This database provides easily-retrieved information

on the levels of the criteria pollutants in all areas of the

country. The EPA’s procedures for reporting and using

data ensure timely and widespread access to accurate

information. Anyone who has access to the World Wide

Web may browse and obtain reports from AIRS-AQS at

www.epa.gov/airs/. 

If your tribe is administering an air quality monitoring

program, the tribe should also prepare an annual statistical

report for the EPA. This report should summarize

information about the highest levels recorded for each

criteria pollutant and monitoring station.

Your tribe can use the data collected to determine whether

the reservation’s air quality is better or worse than the

NAAQS. If the tribe is collecting data for determining

whether an area meets the NAAQS, EPA’s regulations

require complete data from three consecutive calendar

years. The requirement of complete data underscores the

importance of following quality assurance procedures

because they ensure minimal data loss. If your tribe is 

collecting data to compare to air quality modeling results, it

is also useful to collect meteorological data, such as

temperature, wind speed, and wind direction. 
 Chapter 3 Page 48

Outdoor training and

evaluation platform at the

TAMS Center in Las Vegas.

How does your tribe start an

air quality monitoring

program?

In addition to the resources mentioned above, there are

additional resources available to assist your tribe in

developing an air quality monitoring program:17

» 40 CFR Parts 50, 53, 58

» EPA’s Air Pollutant Monitoring website provides

general monitoring information and information on

existing monitoring systems (www.epa.gov/oar/

oaqps/montring.html).

» The EPA’s Ambient Monitoring Technology

Information Center (www.epa.gov/ttn/amtic) provides

technical information on monitoring programs and

methods, along with monitoring guidance documents

and articles.

» The Tribal Air Monitoring Support Center (TAMS),

located at EPA’s Radiation and Indoor Environments

National Laboratory at the University of Nevada, Las

Vegas, provides hands-on training and support services

for tribal air professionals on the topic of air quality

monitoring (www.cet.nau.edu/itep/TAMS/

TAMS_default.htm).

» Additional information, including the types of monitors

and monitoring networks, the objectives of a

monitoring network, the spatial scales for monitoring

networks, and additional resources are provided in

Appendix G Air Quality Monitoring.

Conclusion The air quality goals your tribe sets for criteria pollutants

can be addressed in a TIP. To set such goals, it may be

helpful to gather data about the sources of air pollution and

the ambient air quality on your reservation through an

emissions inventory and an air quality monitoring program. 

If your tribe develops a monitoring program, your tribe

should periodically review it to determine whether it

achieves the basic objectives. If the program does not

achieve its objectives, it can be modified. The tribe can use

information from these data gathering techniques to guide

your decision-making, determine which control strategies

to use, and later, evaluate the effects of your efforts. 
 Chapter 3 Page 49

1. The EPA revised the air quality standards for particulate matter and ground level ozone in

1997. Implementation of the revised standards was delayed by litigation until February

27, 2001, when the U.S. Supreme Court ruled in the case. EPA must determine how it

will implement the revised standards consistent with the Court’s decision. 

2. For more information on Class I, II, and III designations of attainment areas, see the CAA

section 162.

3. For more information on the NAAQS, see the Office of Air Quality Planning and

Standards’ NAAQS information page (www.epa.gov/airs/criteria.html) and criteria

pollutant page (www.epa.gov/oar/aqtrnd97/brochure/sixprin.html). Information on

NAAQS standards can be found at www.epa.gov/ttn/oarpg/t1main.html. For more

information on nonattainment areas, see the Office of Air Quality Planning and Standards

nonattainment website, www.epa.gov/airs/nonattn.html. For a complete listing of

nonattainment areas, see EPA’s Green Book, accessible at www.epa.gov/oar/

oaqps/greenbk/index.html. 

4. For more information on ozone nonattainment area requirements, see the CAA

sections 181 through 185.

5. For more information on carbon monoxide nonattainment area requirements, see the

CAA sections 186 and 187. For more information on PM nonattainment area

requirements, see the CAA sections 188 through 190.

6. For more information on sulfur oxide, lead, or nitrogen dioxide nonattainment area

requirements, see the CAA sections 191 and 192.

7. The Green Book can also be found at 40 CFR Part 81.

8. For more information on ozone designations, see EPA’s Guidance on 8-Hour Ozone

Designations for Indian Tribes, available on the Office of Air and Radiation’s TribalAIR

website, www.epa.gov/oar/tribal/airprogs/tribe8hd.html.

9. This graph is from the National Air Pollutant Emission Trends Update: 1970 - 1997,

December 1998, www.epa.gov/ttn/chief/trends/trends97/index.html. 

10. The criteria for redesignation from nonattaiment to attainment are given in the CAA

section 107(d)(3)(E).

11. The Consolidated Emission Reporting Rule (CERR) can be found in the Federal Register,

67 FR 39602, June 10, 2002 (www.access.gpo.gov/su_docs/fedreg/a0206/oc.html).

12. Image provided courtesy of AirNova, Pennsauken, NJ.

Endnotes
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13. For more information on developing an Inventory Preparation Plan, see EPA’s,

Handbook for Criteria Pollutant Inventory Development: A Beginner’s Guide for Point

and Area Sources (www.epa.gov/ttn/chief/txt/beginner.pdf) or see Emissions Inventory

Guidance for Implementation of Ozone and Particulate Matter NAAQS and Regional

Haze Regulations (www.epa.gov/ttn/chief/txt/eidocfnl.pdf; reference number 

EPA-454/R-99-006).

14. Quality Control (QC) includes the system of technical activities your tribe implements to

measure and control the quality of the inventory as it is being developed. Examples of

QC measures include technical reviews, accuracy checks, and the use of approved

emissions estimation procedures. Quality Assurance (QA) is an external review and audit

conducted by personnel not working on the inventory’s development to assess the

effectiveness of the QC program and the completeness and accuracy of the inventory.

15. The following resources on emissions inventories are presented in this chapter:

» The ClearingHouse for Inventories and Emissions Factors (CHIEF) at

www.epa.gov/ttn/chief is an on-line resources with information on emissions factors,

emissions inventories, and emissions estimation software. This site includes a link to

the Handbook for Criteria Pollutant Inventory Development: A Beginner’s Guide for

Point and Area Sources (reference number EPA-454/R-99-037).

» The Emissions Inventory Guidance for Implementation of Ozone and Particulate

Matter NAAQS and Regional Haze Regulations, April 1999,

www.epa.gov/ttn/chief/txt/eidocfnl.pdf (reference number EPA-454/R-99-006). This

document contains information about preparing IPPs, as well as information

concerning the preparation of emission inventories for nonattainment area planing.

» The Emissions Inventory Improvement Program (EIIP). The primary guidance on

inventory development is summarized in the EIIP Document Series, Volumes I-X,

accessible through the EIIP website

(www.epa.gov/ttn/chief/eiip/techreport/index.html) and the National Technical

Information Service (www.ntis.gov/ or (703) 605-6000). These volumes contain

information on planning an emissions inventory, estimating emissions from different

types of sources, data management, recordkeeping, and quality control and quality

assurance.

» The Compilation of Air Pollutant Emission Factors, AP-42

(www.epa.gov/ttn/chief/ap42/), contains information on over 200 stationary,

including brief descriptions of processes used, potential sources of air emissions from

the processes and in many cases common methods used to control these air emissions.

Volume II contains information on emission factors from mobile sources. 

16. Regulations on ambient air quality monitoring can be found in 40 CFR 51 Appendix P

and 40 CFR 58 .

17. The following resources on air quality monitoring are presented in this chapter:

» Information on existing air quality monitoring stations is available through the Office
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of Air Quality Planning and Standards at www.epa.gov/oar/oaqps/qa/ monprog.html.

» The Aerometric Information Retrieval System—Air Quality System (AIRS-AQS) is a

database with information on the levels of the criteria pollutants in all areas of the

country (www.epa.gov/airs/).

» 40 CFR Parts 50, 53, 58.

» The EPA’s Ambient Monitoring Technology Information Center (www.epa.gov/

ttn/amtic) provides technical information on monitoring programs and methods, along

with monitoring guidance documents and articles.

» EPA’s Air Pollutant Monitoring website provides general monitoring information and

information on existing monitoring systems (www.epa.gov/oar/oaqps/montring.html).

» The Tribal Air Monitoring Support Center provides hands-on training and support

services for tribal air professionals on the topic of air quality monitoring

(www.cet.nau.edu/itep/TAMS/ TAMS_default.htm) or (702) 798-2559.
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