Appendix A-1

Appendix A

Tribal Contacts at EPA

EPA 

Regional Office

Jurisdictions

EPA Regional Offices

Tribal Programs Web Sites

Region 1 www.epa.gov/region01/govt/tribes/index.html

Region 2 www.epa.gov/region2/nations/indian1.htm

Region 3 www.epa.gov/region03/

Region 4 www.epa.gov/region4/ead/GovPartners/tribal.htm

Region 5 www.epa.gov/reg5oopa/tribes

Region 6 www.epa.gov/earth1r6/6xa/tribal/tribal.htm

Region 7 www.epa.gov/region07/

Region 8 www.epa.gov/region8/tribes/

Region 9 www.epa.gov/region09/cross_pr/indian/index.html

Region 10 http://yosemite.epa.gov/r10/tribal.NSF/webpage/tribal+office+ho

mepage?opendocument
 Appendix A-2

EPA Tribal Contacts

Region Name & Address Phone & Fax Email

1 Ida Gagnon

Environmental Engineer

Air Permits Program

1 Congress Street

Suite 1100 (CAP)

Boston, MA 02114-2023

(617) 918-1653 (P)

(617) 918-1505 (F)

gagnon.ida@epa.gov

2 Mazeeda Khan

290 Broadway, 26th Floor

New York, NY 10007-1866

(212) 637-3517 (P) kahn.mazeeda@epa.gov

3 Air Protection Division (215) 814-2100

4 Darren Palmer

Environmental Scientist

Air Permits Section

Atlanta Federal Center

61 Forsyth Street

Atlanta, GA 30303-3104

(404) 562-9052 (P) palmer.darren@epa.gov

5 Ben Giwojna

(Dino Blathras)

AR-18J

77 West Jackson Blvd.

Chicago, IL 60604-3507

(312) 886-0247 (P) giwojna.benjamin@epa.gov

6 Dick Thomas

(Tony Talton)

Air Tribal Coordinator

Fountain Place

1445 Ross Ave.

Dallas, TX 75202-2733

(214) 665-8528 (P)

(214) 665-6762 (F)

thomas.richardm@epa.gov

7 Judith Robinson

ARTD/APDB

Tribal Air Program

Coordinator

726 Minnesota

Kansas City, KS 66101-2728

(913) 551-7825 (P)

(913) 551-7844 (F)

robinson.judith@epa.gov
Region Name & Address Phone & Fax Email

 Appendix A-3

8 Monica Morales

(Bernadette Gonzalez)

8P-AR

Environmental Engineer/

Tribal Air Coordinator

Air and Radiation Program

999 18th St., Suite 300

Denver, CO 80202

(303) 312-6936 (P)

(303) 312-6064 (F)

morales.monica@epa.gov

9 Doug McDaniel

(Sara Bartholomew)

Tribal Team Leader

Air Division

75 Hawthorne St. (AIR-8)

San Francisco, CA 94105

(415) 744-1246 (P)

(415) 744-1076 (F)

mcdaniel.doug@epa.gov

10 Regina Thompson

(Mary Manous)

Tribal Air Program

Development

1200 Sixth Ave (OAR-107)

Seattle, WA 98101

(206) 553-1498 (P)

(206) 553-1059 (P)

thompson.regina@epa.gov

National Darrel Harman

Office of Air and Radiation

National Tribal Coordinator

401 M Street SW - 6101

Washington, DC 20460

(202) 564-7416 (P)

National Laura McKelvey

Office of Air Quality

Planning and Standards

Tribal Coordinator

C504-01

Research Triangle Park, NC

27713

(919) 541-5477 (P) mckelvey.laura@epa.gov

National Julie McClintock

Office of Air Quality

Planning and Standards

Tribal Programs

C539-02

(919) 541-5339 (P) mcclintock.julie@epa.gov
 Appendix A-4

The page intentionally left blank.
 Appendix B-1

Appendix B

Informational Resources

Description Website and/or Other Sources of Information

Starting Points

American Indian Environmental Office

(AIEO) www.epa.gov/indian

Institute for Tribal Environmental Office www.cet.nau.edu/itep/

American Indian Science and Engineering

Society (AISES) www.aises.org

General Law 

The Clean Air Act (CAA) www.epa.gov/oar/caa/contents.html

Plain English Guide to the CAA www.epa.gov/oar/oaqps/peg_caa/pegcaain.html

Code of Federal Regulations (CFR) www.access.gpo.gov/nara/cfr/index.html

Text of 40 CFR (environmental

regulations)

www.epa.gov/docs/epacfr40

Tribal Authority Rule (TAR) 63 Federal Register 7254

40 CFR parts 9, 35, 49, 50, and 81 

www.epa.gov/oar/tribal/airprogs/authrule/http://la

ws.findlaw.com/dc/981196a.html

Laws, regulations, and guidance of special

interest to tribes

www.epa.gov/indian/regulate.htm

National Ambient Air Quality Standards

(NAAQS )

40 CFR 50

www.epa.gov/airs/criteria.html

www.epa.gov/ttn/oarpg/t1main.html

Memoranda for NAAQS -

Policy & Guidance Memos

www.epa.gov/ttn/oarpg/t1pgm.html

Reports for NAAQS -

Background Information Documents

www.epa.gov/ttn/oarpg/t1bid.html
Description Website and/or Other Sources of Information

 Appendix B-2

State implementation plan (SIP)

requirements 

CAA Section 110(a) 

40 CFR parts 51 and 52

Criteria used to determine the

administrative completeness of

implementation plans 

40 CFR 51 Appendix V

Ozone nonattainment area requirements CAA Sections 181 through 185

Carbon monoxide nonattainment area

requirements

CAA Sections 186 and 187

PM nonattainment area requirements §188 to §190

Sulfur oxide, lead, or nitrogen oxide

nonattainment area requirements

CAA Sections 191 and 192

Nonattainment areas www.epa.gov/airs/nonattn.html

www.epa.gov/oar/oaqps/greenbk/index.html

Section 126 petitions to EPA to find that

sources outside your reservation are

contributing to NAAQS violations

www.epa.gov/ttn/rto/126/

Redesignation from nonattainment to

attainment 

CAA Section 107(d)(3)(E)

Emissions Inventories

Emissions Inventory Improvement

Program (EIIP)

www.epa.gov/ttn/chief/eiip/

EIIP Document Series, Volumes I-IX -

the primary guidance on inventory

development

www.epa.gov/ttn/chief/eiip/ 

or the National Technical Information Service

(www.ntis.gov/ or (703) 605-6000)

ClearingHouse for Inventories and

Emissions Factors (CHIEF) 

www.epa.gov/ttn/chief

Handbook for Criteria pollutant Inventory

Development: A Beginner’s Guide for

Point and Area Sources

www.epa.gov/ttn/chief 

(reference number EPA-454/R-99-037)

The Institute for Tribal Environmental

Professionals

www.cet.nau.edu/itep
Description Website and/or Other Sources of Information

 Appendix B-3

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)

AP-42, Emission Factors Handbook -

includes brief descriptions of processes

used, potential sources of air emissions

from the processes, common methods

used to control these air emissions, and

methodologies for estimating the quantity

of air pollutant emissions via emission

factors 

www.epa.gov/ttn/chief/ap42.html#chapter

Air Quality Monitoring

Information on existing air quality

monitoring stations 

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

The Aerometric Information Retrieval

System - Air Quality System (AIRS-AQS)

- a database with information on the levels

of the criteria pollutants in all areas of the

country

www.epa.gov/airs/

Ambient Monitoring Technology

Information Center 

www.epa.gov/ttn/amtic 

Air Pollutant Monitoring website www.epa.gov/oar/oaqps/montring.html

The Tribal Air Monitoring Support Center www.cet.nau.edu/itep/TAMS/TAMS_default.htm

Quality Assurance Handbook for Air

Pollutant Measuring Systems: Volume

1–Principles

Ordering information:

www.epa.gov/ncepihom/Catalog/EPA600R94038

A.html or 1-800-490-9198

Quality Assurance Handbook for Air

Pollutant Measuring Systems: Volume

3–Stationary Source-Specific Methods 

Ordering information:

www.epa.gov/ncepihom/Catalog/EPA600R94038

C.html or 1-800-490-9198

Data analysis requirements 40 CFR 50 

www.epa.gov/ttn/oarpg/t1pgm.html

Control Measures
Description Website and/or Other Sources of Information

 Appendix B-4

Clean Air Technology Center (CATC) - 

a resource on all areas of emerging and

existing air pollution prevention and

control technologies, and information on

their use, effectiveness, and cost 

www.epa.gov/ttn/catc/

NSR RACT/BACT/LAER Clearinghouse http://209.42.208.109/rblc/htm/bl02.htm

Procedures for Identifying Reasonably

Available Control Technology for

Stationary Sources of PM10 (EPA 452/R93-001), September 1992

www.epa.gov/ttn/catc/products/html

Air Quality Modeling

Support Center for Regulatory Air Models www.epa.gov/ttn/scram/

Emissions Measurement

Emission Measurement Center (EMC) www.epa.gov/ttn/emc/

or the EMC 24-hr automated telephone

information hotline: (919) 541-0200

EMC’s promulgated test methods site www.epa.gov/ttn/emc/promgate.html

Enforcement

Office of Enforcement and Compliance

Assurance (OECA) 

http://es.epa.gov/oeca/

OECA’s Compliance Assistance Centers

for specific industry sectors 

http://es.epa.gov/oeca/main/compasst/compcenter

s.html 

National Enforcement Training Institute

(NETI)

www.epa.gov/oeca/neti

or call 1-800-EPA-NETI

American Indian Lands Environmental

Support Project (AILESP) - a database

with release, compliance and enforcement

histories for facilities located on and

within five kilometers of tribal lands 

http://es.epa.gov/oeca/ailesp/
Description Website and/or Other Sources of Information

 Appendix B-5

BEN - a computer model for determining

the economic benefits gained by a source

for avoiding or delaying required

environmental expenditures

http://es.epa.gov/oeca/models/ben.html

Miscellaneous

Criteria pollutants - general information www.epa.gov/oar/aqtrnd97/brochure/sixprin.html

New Source Review www.epa.gov/ttn/nsr/

Visibility / Regional Haze Program www.epa.gov/oar/vis/index.html

Tribal Environmental and Natural

Resources Assistance Handbook - a

central location of federal resources of

both technical and financial assistance

available to tribes for environmental

management

www.epa.gov/indian/tribook.pdf 

Developing a Tribal Air Program,

Training Manual (April 1999) -

information on public relations campaigns

and other topics relating to air program

development 

Institute for Tribal Environmental Professionals

at Northern Arizona University at (520) 523-9555

and ITEP-L@lists.nau.edu (e-mail);

US EPA Region 6

Office of Air and Radiation, TribalAIR www.epa.gov/oar/tribal/

State and Territorial Air Pollution

Program Administrators (STAPPA) and

Association of Local Air Pollution

Control Officers (ALAPCO) - national

associations representing air pollution

control agencies across the United States

www.4cleanair.org

National Tribal Environmental Council

(NTEC) - a membership organization

dedicated to working with and assisting

tribes in the protection and preservation of

the reservation environment

www.ntec.org
Description Website and/or Other Sources of Information

 Appendix B-6

National Service Center for

Environmental Publications (NSCEP) -

has over 5000 EPA publications available

in hard copy and multimedia product, free

of charge

www.epa.gov/ncepihom/
 Appendix C-1

Appendix C

Education and Training Resources

Resource Contact Information

Air Pollution Training Institute (APTI) -

offers classroom, telecourse, selfinstructional courses, and web-based

learning, links to some of which are

provided below

www.epa.gov/oar/oaqps/eog/apti.html

(919) 515-4265 (phone)

(919) 541-5678 (fax)

APTI Area Training Centers - classroom

courses and training opportunities

www.epa.gov/oar/oaqps/eog/atcacad.html

Area Training Centers

Rutgers (Univ. of NJ), New Brunswick: 

 (732) 932-8065

Univ. of IL, Chicago: (312) 996-2094

CA Polytechnic State, San Luis Obispo: 

 (805) 756-2559

Univ. of So. FL, Tampa: (813) 974-5815

Specialized Training Centers

Environmental & Occupational Health Sciences 

 Institute, Piscataway, NJ: (732) 445-0220

Environmental Training Institute, Univ. of 

 OH, Cincinnati: (513) 556-2542

Air Pollution Training Academy, Univ. of TX, 

 Arlington: (817) 272-2915

APTI OL:2000 - an online reference manual

with reading material and problems on

fundamental engineering principles and

concepts, permit review, compliance

monitoring and inspection, and CAA

regulatory requirements

www.epin.ncsu.edu/apti/ol_2000/home/homefr

am.htm

EPA Education and Outreach Group (EOG)

- provides APTI courses and a variety of

other air training events, links to some of

which are provided below

www.epa.gov/oar/oaqps/eog/catalog/ccs2.html
Resource Contact Information

 Appendix C-2

EOG Air Pollution Distance Learning

Network (APDLN) - provides seminars and

telecourses via satellite broadcasts to over

100 governmental and university affiliates 

www.epa.gov/oar/oaqps/eog/apdln.html

(919) 541-5455 (phone)

(919) 541-5678 (fax)

EOG self-instructional courses - both

introductory and advanced courses are

available

www.epa.gov/oar/oaqps/eog/catalog/catsic.html

(919) 515-5875

Institute for Tribal Environmental

Professionals (ITEP) - provides technical

and administrative training (the American

Indian Air Quality Training Program), a

resource center and database (the Tribal

Environmental Resource Center), outreach

to schools, and professional and student

internships

www.cet.nau.edu/itep/default.htm

(520) 523-9555

Tribal Air Monitoring Support Center

(TAMS) - 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

(702) 798-2559
 Appendix D-1

Appendix D

Information on Criteria Pollutants

SO2 What is it? » Sulfur dioxide (SO2) belongs to a family of gases called sulfur

oxides (SOX).

» SO2 is released during the burning or processing of sulfurcontaining ores and fossil fuels.

Health Effects » SO2 contributes to respiratory illness.

» SO2 aggravates asthma, bronchitis, emphysema, cardiovascular

problems.

Environmental

Effects

» Acid rain occurs when SO2 and NOX react with water and oxygen;

Acid rain harms lakes and streams, and damages trees, crops,

historic buildings, and monuments.

» SO2 contributes to visibility impairment in large parts of the

country by contributing to haze.

Common

Emission

Sources

» Utility & industrial boilers

» Primary and secondary copper & lead smelters

» Petroleum refineries

» Aluminum smelters

» Phosphate fertilizer manufacturing

» Diesel vehicles

» Iron & steel mills

» Crude petroleum & natural gas extraction processes

» Carbon black manufacturing

» Sulfuric acid plants

» Portland cement manufacturing

» Pulp and paper mills

NO2 What is it? » Nitrogen dioxide (NO2) belongs to a family of gases called

nitrogen oxides (NOX).

» NO2 is released when fossil fuels are burned and from high

temperature processes.

» NO2 can react in the presence of water and sunlight to become

ozone (O3).

Health Effects » O3 causes damages lung tissue, reduces lung function and

sensitizes the lungs to other irritants; it also irritates the eyes,

nose, throat.

» O3 is especially bad for those with chronic heart and lung disease,

as well as the very young and old, and pregnant women.
 Appendix D-2

NO2,

cont.

Environmental

Effects

» Acid rain occurs when SO2 and NOX react with water and oxygen;

Acid rain harms lakes and streams, and damages trees, crops,

historic buildings, and monuments.

» O3 is the main pollutant in smog.

» NOX can cause damage to plant foliage.

Common

Emission

Sources

» Metallurgical furnaces

» Blast furnaces

» Plasma furnaces

» Kilns

» Fossil fuel power generation

» On-road vehicles

O3 What is it? » Ozone (O3) is found in two layers of the atmosphere, the

stratosphere and the troposphere. In the stratosphere (the

atmospheric layer 7 to 10 miles or more above the earth’s

surface), ozone is a natural form of oxygen that provides a

protective layer shielding the earth from ultraviolet radiation. In

the troposphere (the layer extending up 7 to 10 miles from the

earth’s surface), ozone is formed through chemical reactions and

is a major component of smog. Ozone in the troposphere is

produced through complex chemical reactions of NOX and

volatile organic compounds (VOC) and sunlight.

» Volatile organic compounds (VOC) are found in everything from

paints and coatings to underarm deodorant and cleaning fluids. 

Areas in nonattainment for O3 regulate NOX and VOC emissions.

Health Effects » O3 causes damages lung tissue, reduces lung function and

sensitizes the lungs to other irritants; it also irritates the eyes,

nose, throat.

» O3 is especially bad for those with chronic heart and lung disease,

as well as the very young and old, and pregnant women.

Environmental

Effects

» O3 is the main pollutant in smog.

» VOC and NOX can cause damage to plant foliage.

Common

Emission

Sources

» Transportation sources

» Power plants

» Industrial boilers and industrial processes utilizing solvents, such

as surface coating (paints) and printing (inks)

» Petrochemical processing 

» Chemical manufacturing

» Dry cleaners

» Paint shops 

» Gasoline storage and transfer
 Appendix D-3

CO What is it? » Carbon monoxide (CO) is a poisonous gas formed when carbon

in fuels is not burned completely.

» CO is a product of vehicle exhaust, which contributes about 77%

of all CO emissions nationwide.

Health Effects » CO reduces oxygen delivery to organs and tissues.

» CO affects cardiovascular and central nervous systems.

» CO causes headaches, dizziness, nausea, and listlessness.

» CO is associated with visual impairment, reduced work capacity

and manual dexterity, poor learning ability, difficulty performing

complex tasks, inability to discriminate time intervals, and in high

doses, may cause death.

Environmental

Effects

» CO is believed to contribute to global climate change.

Common

Emission

Sources

» On-road vehicles

» Non-road sources (lawn & garden equipment, recreational marine

equipment)

» Non-transportation fuel combustion (i.e., wood burning)

» Chemical & allied product mfg. (i.e., carbon black

manufacturing)

» Metals processing (i.e., ferrous metals)

Pb What is it? » Lead (Pb) is a naturally occurring substance.

» Historically, the primary source of Pb emissions was lead

additives in gasoline.

Health Effects » Pb causes damage to kidney, liver, brain, nervous system, and

causes malformation of an embryo or fetus.

» Pb is associated with heart disease, high blood pressure, anemic

disorders, osteoporosis, reproductive disorders, memory

problems, fatigue, and mood changes.

» Infants and young children are especially susceptible to low doses

of Pb, and this age group still shows the highest levels.

Environmental

Effects

» Pb can inhibit photosynthesis and reduce growth in plants.

» Pb can lead to changes in species composition as plant and

microbial communities become lead-tolerant.

» Pb can accumulate in the environment and travel up the food

chain and be ingested by humans.
 Appendix D-4

Common

Emission

Sources

» Lead smelters

» Iron & Steel production

» Mining

» Waste incineration

» Lead alkyl manufacturing

» Battery manufacturing

» Pigment manufacturing

» Fuel combustion (i.e., utility, industrial, other)

PM What is it? » Particulate matter (PM) is solid or liquid material suspended in

the atmosphere (i.e., pieces of ash, smoke, soot, dust, and liquid

droplets).

» PM is directly emitted or formed in the air.

» PM is characterized by coarse and fine size fractions:

› PM10 includes particles # 10 Fm in diameter

› PM2.5 includes particles # 2.5 Fm in diameter

Health Effects » PM causes eye irritation and accumulates in lungs, contributing to

damaged lung tissue, decreased lung function, aggravated asthma,

acute respiratory symptoms, increased hospital visits, increased

frequency in childhood illness such as chronic bronchitis,

premature death

» Children, asthmatics, elderly, and individuals with pre-existing

cardiovascular and respiratory illness are especially sensitive

populations.

Environmental

Effects

» PM contributes to visibility impairment in large parts of the

country by contributing to haze.

Common

Emission

Sources

» Paved and unpaved roads

» Construction activities

» Burning

» Mineral product manufacturing

» Waste disposal and recycling

» Fuel combustion (utilities, industrial)

» Industrial processes (metals processing, oil refining)
 Appendix E-1

 Regional Organizations Regional Organizations



















 



























CENRAP

WRAP Midwest

 RPO

VISTAS

MANE-VU

Appendix E

A Guide to Regional Air Quality Planning Organizations

Name Contact Information Member Governments

Mid-Atlantic/Northeast

Visibility Union

(MANE-VU)

Bruce Carhart

444 N. Capitol St. NW

Suite 638

Washington, DC 20001

(202) 508-3840

http://www.sso.org/otc/re

gional_haze/regionalhaze.

htm#Formal%20Actions

Connecticut

Delaware

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Penobscot Indian Nation

Rhode Island

St. Regis Mohawk Tribe

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. Forest Service

U.S. National Park Service

Vermont 

Washington, DC
Name Contact Information Member Governments

 Appendix E-2

Visibility Improvement

State and Tribal

Association of the

Southeast (VISTAS) 

William P. (Phil) Brantley

2600 Bull St.

Columbia, SC 29201

(803) 898-4116

http://www.vistas-sesarm.

org/

Alabama

Catawba Indian Nation

Eastern Band of the Cherokee Indians

Florida

Georgia

Kentucky

Miccosukee Tribe of Indians of Florida

Mississippi

Mississippi Band of Choctaw Indians

North Carolina

Seminole Indian Tribe of Florida

South Carolina

Tennessee

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. Forest Service

U.S. National Park Service

Virginia

West Virginia
Name Contact Information Member Governments

 Appendix E-3

Midwest RPO Mike Koerber

2250 East Devon Ave.

Suite 216

Des Plaines, IL 60018

(847) 296-2181

http://www.ladco.org/rpo/

rpo.html

Bad River Band of Lake Superior

 Chippewa 

Bay Mills Indian Community

Bois Forte Reservation Business

 Committee

Fond du Lac Reservation Business

 Committee

Forest County Potawatomi Community

Grand Portage Reservation Business

 Committee

Grand Traverse Band of Ottawa and

 Chippewa 

Great Lakes Indian Fish & Wildlife

Great Lakes Inter-Tribal Council

Hannahville Indian Community

Ho Chunk Nation

Illinois

Indiana

Intertribal Council of Michigan

Keweenaw Bay Indian Community

Lac Courte Oreilees Band of Lake

 Superior Chippewa

Lac du Flambeau Band of Lake

 Superior Chippewa

Lac Vieux Desert Band of Lake

 Superior Chippewa

Leech Lake Reservation Business

 Committee

Little River Band of Ottawa

Little Traverse Bay Bands of Odawa

Lower Sioux Indian Community

Match-E-Be-Nash-She-Wish Band of

 Potawatomi

Menominee Indian Tribe

Michigan

Mille Lacs Reservation Business

 Committee

Minnesota Chippewa

Nottawaseppi Huron Potawatomi

Ohio

Oneida Tribe

Pokagon Band of Potawatomi
Name Contact Information Member Governments

 Appendix E-4

Midwest RPO (cont.) Shakopee Mdewakanton Sioux

 Community

Sokaogon Chippewa (Mole Lake)

 Community

St. Croix Chippewa

Stockbridge-Munsee Community

Upper Sioux Community

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. National Park Service

White Earth Reservation Business

 Community

Wisconsin

Central Regional Air

Planning Association

(CENRAP)

10015 S. Pennsylvania

Suite A

Oklahoma City, OK

73159

Larry Byrum (Virginia)

(405) 378-7377

Bob Hannesschlager

(214) 665-3188

http://www.cenrap.org/

Arkansas

Iowa

Kansas

Louisiana

Minnesota

Missouri

Nebraska

Oklahoma

Texas

(Tribal membership in progress)
Name Contact Information Member Governments

 Appendix E-5

Western Regional Air

Partnership (WRAP)

1515 Cleveland Pl.

Suite 200

Denver, CO 80202

Patrick Cummins,

Western Governors’

Association

(303) 623-5635

Bill Grantham,

National Tribal

Environmental Council

(505) 242-2175

1-800-727-2175

www.wrapair.org 

Arizona

California

Campo Band of Kumeyaay Indians

Colorado

Cortina Indian Rancheria

Hopi Tribe

Hualapai Nation of the Grand Canyon

Idaho

Jicarilla Apache Tribe

Montana

New Mexico

North Dakota

Northern Cheyenne Tribe

Oregon

Pueblo of Acoma

Pueblo of San Felipe

Salish and Kootenai Confederated 

 Tribes

Shoshone-Bannock Tribes of Fort Hall

South Dakota

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. Forest Service

U.S. National Park Service

Utah

Washington

Wyoming
 Appendix E-6

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 Appendix F-1

Appendix F

Emission Inventories

This appendix provides additional information on emission inventory development, including:

» Different approaches toward inventory development

» The types of sources to include in an inventory

» The types of emissions to include in an inventory

» The types of data to include in an inventory

» EPA resources for emissions data, emissions factors, and emissions estimation

methods

What approaches can be taken toward inventory development?

There are two main approaches you can follow in estimating emissions: top-down and

bottom-up. Both approaches can be used in one inventory for estimating emissions from

different types of sources.

1. A Top-Down Approach means that you develop emissions estimates based on national

or regional estimates. You scale the national or regional estimates to your inventory area using

some measure of activity data thought to be related to the emissions on your reservation. Sales

data (such as the total amount of gasoline sold at a gas station) or per capita emission factors are

often used.

A top-down approach is typically used to inventory area sources (see below) and is used

when local data are unavailable or when collection of local data is cost-prohibitive. One problem

with this approach is that the emission estimates will lose some accuracy due to the uncertainties

associated with extrapolating national or regional estimates to your area.

2. A Bottom-Up Approach means you estimate emissions for individual sources and sum

all the sources to obtain a reservation-wide estimate. Bottom-up approaches are typically used to

inventory point sources, although they can be used to inventory area sources when resources are

available to collect local activity data through a survey effort. The bottom-up approach requires

more resources to collect site-specific information, but also results in more accurate estimates

than the top-down approach because data are collected directly from individual sources.

What types of sources are included in an inventory?

An emission source can be defined as an entire facility, such as a petroleum refinery with

many emission sites caused by process activities, or just a particular emission site within the
 Appendix F-2

 facility, such as one stack. Sources can also be smaller facilities such as gas stations and mobile

sources such as cars. There are five categories of sources to include in an inventory: point

sources, area sources, mobile sources, biogenic sources, and geogenic sources.

1. Point sources are stationary facilities that emit air pollutants. Examples of point

sources include manufacturing facilities or electric utility sites. Air pollutants may be emitted

from process activities through exhaust stacks or as fugitive emissions. Fugitive emissions are

emission sources that do not come from an exhaust stack or vent and are technically infeasible to

collect and control. Fugitive emissions may escape from industrial buildings or come from

unconfined activities such as outdoor materials storage piles swept by wind and surface mining

activities. 

Point sources can be major or minor sources of emissions. The definition of a major

source under Title I of the CAA in most cases is a source that emits, or has the potential to emit,

100 tons/year of any criteria air pollutant except for lead (Pb); the cutoff for a major source that

emits lead is 5 tons/year. Volatile organic compounds (“VOCs,” an ozone precurser), nitrogen

dioxide (NO2), carbon monoxide (CO), and particulate matter (PM10) have lower thresholds for

major sources in serious, severe, and extreme nonattainment areas (see table below). Minor

sources are sources that emit less than the emission rate that defines a major source.

Thresholds for Major Source Designation

(tpy = tons per year)

VOC

(ozone

precusor)

CO NOX PM10 SO2 Pb

General Cutoff $100 tpy $100 tpy $100 tpy $100 tpy $100 tpy $5 tpy

Serious

Nonattainment

Areas

$ 50 tpy $ 50 tpy $ 50 tpy $ 70 tpy n/a n/a

Severe

Nonattainment

Areas

$25 tpy n/a n/a n/a n/a n/a

Extreme

Nonattainment

Areas

$10 tpy n/a n/a n/a n/a n/a

n/a = Not applicable; There are only serious nonattainment areas for ozone, CO, NOX, and PM10, and there are only

severe and extreme nonattainment areas for ozone (VOCs are an ozone precurser).
 Appendix F-3

2. Area sources are activities that cause emissions over a geographic area, such as

vehicle traffic on unpaved roads, open burning, residential heating, and agricultural activities. 

Area sources are usually minor sources, but the combined emissions of a pollutant from one type

of area source can be a large proportion of the total emissions of that pollutant in an area. 

Emissions from area sources are usually fugitive emissions.

3. Mobile sources include on-road and non-road sources. On-road mobile sources

include vehicles designed for use on public roadways, such as cars, trucks, buses, and

motorcycles. Non-road mobile sources are equipment or vehicles with internal combustion

engines not generally for highway use. Examples of non-road mobile sources are lawn mowers,

chain saws, airplanes, boats, and diesel locomotives. 

4. Biogenic sources are non-manmade or natural emitters of air pollutants. For example,

conifer trees emit terpenes which are volatile organic compounds, a precursor to ozone. 

5. Geogenic sources are natural occurrences that create pollution, such as oil and natural

gas seeps which emit ozone precursors (VOC and NOx), volcanoes which emit PM and SO2, and

wind that blows dust from natural areas, creating particulate matter.

What types of emissions can be inventoried?

Whether a top-down or a bottom-up approach is used, you can compile inventories using

actual emissions, allowable emissions, or emissions based on a facility’s potential to emit,

depending on the purpose of the inventory.

» Actual Emissions record the actual rate of emissions of a pollutant from a source,

calculated using actual operating hours, production rate, and where applicable, fuel

combusted during the period of interest. For example, base-year inventories

developed by states in support of SIPs are compiled using actual emissions. Actual

emissions are used to validate atmospheric models.

» Allowable Emissions are the product of an enforceable emissions rate (e.g., pounds

of NO2 per unit of product), the anticipated operating rate or activity level (e.g., units

of product produced per hour), and the anticipated operating schedule (e.g., hours per

day). In general, allowable emissions are used when emission projections are being

developed for use in atmospheric modeling. 

» Potential Emissions are the capability of a source, at maximum design capacity, to

emit a pollutant after the application of air pollution control equipment. Potential to

emit estimates are based on the maximum capacity of a source after taking into

consideration enforceable permit conditions such as the type of materials combusted,

the type of materials processed, and the annual hours of operation. In general,

potential emissions are estimated and reported in inventories in support of permitting

activities under Title V of the CAA.
 Appendix F-4

What data are necessary for an emissions inventory?

You will need information on the activities causing emissions, the frequency or rate of the

activity, the locations of emissions points, the hours of operation (i.e., hours per day and days per

year), and the temperature, height, and speed at which emissions enter the atmosphere. You will

also need information on the level of emissions control (percent reduction) initially used, if any,

and the level required by your attainment strategy.

What types of resources are available from EPA for emissions data, emissions

factors, and emissions estimation methods?

Resources for Emissions Data, Emissions Factors, and Emissions Estimation Models:

» Air CHIEF CD-ROM provides access to: air emissions data specific to estimating the

types and quantities of pollutants that may be emitted for a wide variety of sources;

AP-42 emission factors for stationary, area, and mobile sources; FIRE (emissions

estimation database, see description below); Standard Classification Codes (SCC);

area and mobile source codes (AMS); 1997 North American Industrial Classification

System (NAICS) matched to the 1987 Standard Industrial Codes (SIC); the Handbook

for Criteria Pollutant Inventory Development; the National Emissions Inventory

(NEI) database (see description below); and several types of emissions estimation

models. More information about this CD-ROM is available at the Clearinghouse for

Inventories and Emissions Factors (CHIEF) website

(www.epa.gov/ttn/chief/airchief.html#order). It can be ordered at that website or

through the Government Printing Office ((202) 512-1800).

Resources for Emissions Data:

» The National Emission Inventory (NEI) is a national repository database that blends

state , local and tribal supplied data with EPA derived data to form a comprehensive

national inventory of criteria and toxic pollutants. The NEI is accessible at www.epa.

gov/ttn/chief/net/index.html#dwnld, and from the AIRData web site at

www.epa.gov/air/data/net.html. 

Resources for Emission Factors:

» Compilation of Air Pollutant Emission Factors (AP-42) contains criteria pollutant

emission estimation factors for point and area sources. It is available at

www.epa.gov/ttn/chief/ap42.html and the AirCHIEF CD-ROM (described above).

» Factor Information Retrieval (FIRE) Data System is a database of EPA’s

recommended emission estimation factors for criteria and hazardous pollutants

(including emission factors from AP-42). FIRE can be accessed at
 Appendix F-5

www.epa.gov/ttn/chief/fire.html and on the Air CHIEF CD-ROM (described above).

Resources on Emission Estimation Models (can be downloaded free-of-charge):

» Landfill Gas Emissions Model (www.epa.gov/ttn/catc/products.html#software).

» TANKS to estimate emissions from fixed- and floating-roof storage tanks (www.epa.

gov/ttn/chief/tanks.html).

» WATER8 and CHEMDAT8 to estimate air emissions from wastewater collection and

treatment systems (www.epa.gov/ttn/chief/software.html#water8).

» MECH for estimating particulate emissions from paved roads, unpaved roads,

materials handling, agricultural tilling, and construction and demolition, and PM for

estimating PM2.5 emissions (www.epa.gov/ttn/chief/software.html#fugitive).
 Appendix F-6

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 Appendix G-1

Appendix G

Air Quality Monitoring

This appendix provides additional information on air quality monitoring including:

» The principle objectives of air quality monitoring

» The types of pollutants that are monitored

» The types of monitors that are available

» The types of monitoring networks

» EPA resources for monitoring network design, installing and operating monitors, and 

reporting air quality monitoring data

What are the principle objectives of air quality monitoring?

One way to protect and assess air quality is through the development of an Ambient Air

Monitoring Program. Air quality samples are generally collected for one or more of the

following purposes:

» To judge compliance with and/or progress made towards meeting ambient air quality

standards.

 

» To activate emergency control procedures that prevent or alleviate air pollution episodes.

 

» To observe pollution trends throughout the region, including non-urban areas.

 

» To provide a data base for research evaluation of effects: urban, land-use, and

transportation planning; development and evaluation of abatement strategies; and

development and validation of diffusion models.

What types of pollutants are monitored?

Currently the air quality monitoring networks in the United States focus on the criteria

pollutants, as well as the relevant ambient air pollution information for visibility impairment and

acid rain. Although there is currently no national air toxics monitoring network, there are

approximately 300 monitoring sites currently producing ambient data on some of the 188

hazardous air pollutants (HAPs) listed in the 1990 Clean Air Act amendments. EPA is working

together with tribal, state and local air monitoring agencies to build upon the existing monitoring

sites to develop a national air toxic monitoring network. It should be noted that many of the

programs designed to reduce ambient concentration of the criteria pollutants also aid in reducing

pollution that contributes to air toxics pollution, visibility impairment and acid rain. In terms of

the six criteria pollutants, particulates and ozone are the pollutants most often monitored.
 Appendix G-2

Criteria Pollutants

In some cases, proxy pollutants may be measured to better understand the criteria

pollutant of interest. For instance, ozone concentrations may be monitored by measuring the

actual level of ozone in a neighborhood, urban area or region or by monitoring for ozone

precursors, NOx and VOC. To monitor for PM2.5, PM10 and PMTSP (total suspended particulates),

organic and elemental carbon, sulfur dioxide and sulfate, particle nitrate, ammonia or nitric acid

may be measured. Lead may be monitored by measuring for PM and then determining the

fraction that contains the pollutant (40CFR Part 50, Appendix G).

Acidic Deposition

Measurements of sulfate, nitrate, hydrogen ion, ammonia, chloride and base cations

(calcium, magnesium and potassium) are taken to assess atmospheric deposition and determine

the contribution of SO2 and NO2 to acid rain.

Visibility-Related Pollutants

Visibility-related characteristics and measurements can be partitioned into three groups:

Aerosol - The physical properties of the ambient atmospheric particles (chemical composition,

size, shape, concentration, temporal and spatial distribution and other physical properties)

through which a scene is viewed.

Optical - The ability of the atmosphere to scatter or absorb light passing through it. The physical

properties of the atmosphere are described by extinction, scattering and absorption coefficients

plus an angular dependence of the scattering known as the normalized phase function. Optical

characteristics integrate the effects of atmospheric aerosols and gasses. 

Scene - The appearance of a scene viewed through the atmosphere. Scene characteristics are

more nearly in line with the simple definition of visibility than aerosol or optical characteristics.

Scene characteristics include observer visual range, scene contrast, color, texture, clarity, and

other descriptive terms. Scene characteristics change with illumination and atmospheric

composition. 

Aerosol and optical characteristics depend only on the properties of the atmosphere

through which light passes. Scene characteristics, however, are also dependent on the scene and

lighting conditions.

"Visual air quality" describes the air pollution aspects of visibility. Visual air quality is

what must be monitored and preserved in class I areas, not the overall visibility which is

influenced by nonpollution factors (i.e., clouds, snow cover, sun angle, etc.).
 Appendix G-3

The distribution and extent of pollutants in the atmosphere relative to the observer's sight

path has a large effect on the appearance of visibility impairment. If the pollutants are uniformly

distributed from the ground to a height well above the highest terrain, it is known as a "uniform

haze." If the top edge of the pollution layer is visible, as is often the case when pollution is

trapped below an inversion, then it is called a "surface layer." A pollution distribution that is not

in contact with the ground is an "elevated layer." "Plumes" can be thought of as a special case of

an elevated layer, though from many vantage points it may not be possible to distinguish a plume

from an elevated layer. It is possible to have combinations of pollutant distributions such as

multiple elevated layers superimposed upon a uniform haze.

Uniform haze and surface layered haze can be monitored from the ground by a variety of

methods. Elevated layers must be either remotely monitored from the ground or from instruments

carried aloft.

What types of monitors are available?

Sampling equipment requirements are generally divided into three categories, consistent

with the desired averaging times:

A. Continuous - Pollutant concentrations determined with automated methods, and recorded

or displayed continuously.

B. Integrated - Pollutant concentrations determined with manual or automated methods

from integrated hourly or daily samples on a fixed schedule.

C. Static - Pollutant estimates or effects determined from long-term (weekly or monthly)

exposure to qualitative measurement devices or materials.

Air monitoring sites that use automated equipment to continually sample and analyze

pollutant levels may be classified as primary. Primary monitoring stations are generally located

in areas where pollutant concentrations are expected to be among the highest and in areas with

the highest population densities; thus, they are often used in health effects research networks. 

These stations are also designed as part of the air pollution episode warning system.

Particulate Monitoring

Particulate monitoring is usually accomplished with manual measurements and

subsequent laboratory analysis. In this method, a filter-based high-volume sampler - a vacuumtype device that draws air through a filter or absorbing substrate - retains atmospheric pollutants

for future laboratory weighing and chemical analysis. This type of sampler provides average

concentrations over a period of up to 24 hours. The total air flow is determined by the difference

in rotameter readings at the start and conclusion of the test. 

Continuous monitoring methods for suspended particles are also available. Continuous

measurement methods include Mass and Mass Equivalent (Tapered Element Oscillating

Microbalance (TEOM), Piezoelectric Microbalance, Beta Attenuation Monitor (BAM) and
 Appendix G-4

Pressure Drop Tape Sampler (CAMMS)), Visible Light Scattering (Nephelometer, Optical

Particle Counter (OPC), Condensation Nuclei Counter (CNC), Aerodynamic Particle Sizer (APS)

and Light Detection And Ranging (LIDAR)), Visible Light Absorption (Aethalometer and

Particle Soot/Absorption Photometer and Photoacoustic Spectroscopy), Electrical Mobility

(Electrical Aerosol Analyzer (EAA) and Differential Mobility Particle Sizer (DMPS)), Chemical

Components (Single Particle Mass Spectrometers, Carbon Analyzer, Sulfur Analyzer, Nitrate

Analyzer and Multi-Elemental Analyzer) and Precursor Gases (Ammonia Analyzer, Nitric Acid

Analyzer, Fourier Transform Infrared (FTIR) Spectroscopy and Other Nitric Acid Instruments). 

Three continuous PM10 monitors based on inertial mass and electron absorption have been

designated as equivalent methods that can be used to determine compliance with the PM10

NAAQS.

Federal Reference Method (FRM) or Federal Equivalent Method (FEM) samplers are to

be used in PM2.5 compliance monitoring networks (i.e., State and Local Air Monitoring Stations

(SLAMS) and National Ambient Monitoring Stations (NAMS)). Interagency Monitoring of

Protected Visual Environments (IMPROVE) samplers may also be used at regional background

or regional transport sites in lieu of FRMs or FEMs. Continuous monitors can be tested and

classified as Class III FEM for compliance monitoring. 

Gaseous Pollutant Monitoring

Monitoring for gaseous pollutants, such as sulfur dioxide, is accomplished with dynamic

samplers for average concentrations over a 24-hour period and with static samplers for longer

periods, e.g., 30 days.

Visibility Monitoring

As indicated above, visibility-related characteristics and measurements can be partitioned

into three groups: aerosol, optical and scene. Thus, visibility monitors are categorized in a

similar way. Aerosol monitors are used to obtain concentration measurements of atmospheric

constituents. Optical monitors are used to measure the light scattering and absorption properties

of the atmosphere, independent of physical scene characteristics or illumination conditions.

Scene monitors use still and/or time-lapse photography (including digital imagery) to provide a

qualitative representation of the visual air quality in the area of interest.

The Interagency Monitoring of Protected Visual Environments (IMPROVE) monitoring

protocol defines that, where possible, aerosol, optical, and scene monitoring shall be conducted

at each site. Site logistics do restrict the operation of certain instruments at some sites. The

instrumentation used to fulfill IMPROVE protocols include: "Aerosol" IMPROVE Modular

Aerosol Sampler; "Optical" Transmissometer or Nephelometer (collocated with an air

temperature/relative humidity sensor); and "Scene" Automatic Camera Systems.
 Appendix G-5

Meteorological Data

Atmospheric considerations may include spatial and temporal variabilities of the

pollutants and their transport. Effects of buildings, terrain, and heat sources or sinks on the air

trajectories can produce local anomalies of excessive pollutant concentrations. Meteorology

must be considered in determining not only the geographical location of a monitoring site but

also such factors as height, direction, and extension of sampling probes. Wind speed, direction

and variability can greatly influence the dispersal of pollutants.

Wind speed affects the travel time from the pollutant source to the receptor and the

dilution of polluted air in the downwind direction. The concentration of air pollutants are

inversely proportional to the wind speed.

Wind direction influences the general movements of pollutants in the atmosphere. 

Review of available data can indicate mean wind direction in the vicinity of the major sources of

emissions.

Wind variability refers to the random motions in both horizontal and vertical velocity

components of the wind. These random motions can be considered atmospheric turbulence,

which is either mechanical (caused by structures and changes in terrain) or thermal (caused by

heating and cooling of land masses or bodies of water). If the scale of turbulent motion is larger

than the size of the pollutants plume, the turbulence will move the entire plume and cause

looping and fanning; if smaller, it will cause the plume to diffuse and spread out.

Most ambient air monitoring programs include meteorological monitoring in order to

obtain more information on pollutant trends. For instance, the Clean Air Status and Trends

Network (CASTNet) records hourly meteorological parameters such as temperature, relative

humidity, solar radiation, ozone, precipitation and wind speed/direction. The National

Atmospheric Deposition Program (NADP) and IMPROVE programs monitor daily precipitation

and relative humidity/temperature respectively. In some cases, temperature sensing at multiple

elevations is used to monitor stability of the air mass. 

What types of monitoring networks are available?

Monitoring networks are designed to meet their network objective (including both the

appropriate spatial scale and pollutant(s)). Spatial scales range from micro to global. Pollutants

can include the criteria pollutants, visibility impairing pollutants, acid deposition, and others. In

addition to monitoring network objectives and spatial scale, three types of monitoring network

are discussed in this section: the ambient monitoring network which measures the criteria

pollutants, the IMPROVE network which characterizes visibility impairment, and two acidic

deposition networks.

A monitoring network should be designed to meet one of six basic objectives listed

below:
 Appendix G-6

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

B. to determine representative concentrations in areas of high population density;

 

C. to determine the impact on ambient pollution levels of significant sources or source

categories;

 

D. to determine general background concentration levels;

E. to determine the extent of regional pollutant transport among populated areas, and in

support of secondary standards; and

F. to determine welfare-related impacts in more rural and remote areas.

These six objectives indicate the nature of the samples that the monitoring network will collect

which must be representative of the spatial area being studied.

Spatial Scales

The goal in siting stations is to correctly match the spatial scale represented by the sample

of monitored air with the spatial scale most appropriate for the monitoring objective of the

station. The representative measurement scales of greatest interest are shown below:

Micro Concentrations in air volumes associated with area dimensions ranging

from several meters up to about 100 meters

Middle Concentrations typical of areas up to several city blocks in size with

dimensions ranging from about 100 meters to 0.5 kilometer

Neighborhood Concentrations within some extended area of the city that has relatively

uniform land use with dimensions in the 0.5 to 4.0 kilometers range

Urban Overall, citywide conditions with dimensions on the order of 4 to 50

kilometers. This scale would usually require more than one site for

definition

Regional Usually a rural area of reasonably homogeneous geography and extends

from tens of hundreds of kilometers

National/Global Concentrations characterizing the nation and the globe as a whole

The following table illustrates the relationships among the six basic monitoring objectives and

the scales of representativeness that are generally most appropriate for that objective.
 Appendix G-7

Monitoring

Objective

Appropriate Siting Scale

Highest Concentration

Population

Source Impact

General/background

Regional Transport

Welfare-related

Micro, middle, neighborhood, sometimes urban

Neighborhood, urban

Micro, middle, neighborhood

Neighborhood, regional

Urban/regional

Urban/regional

Ambient Air Quality Monitoring Program

The EPA's ambient air quality monitoring program is carried out by State, tribal, and

local agencies and consists of three major categories of monitoring stations, State and Local Air

Monitoring Stations (SLAMS), National Air Monitoring Stations (NAMS), and Special Purpose

Monitoring Stations (SPMS). Additionally, a fourth category of a monitoring station, the

Photochemical Assessment Monitoring Stations (PAMS), which measures ozone precursors

(approximately 60 volatile hydrocarbons and carbonyl) has been required by the 1990

Amendments to the Clean Air Act. Sensitive equipment measures the concentration of many

different air pollutants to determine the ambient concentrations of the criteria pollutants. Some

types of equipment run continuously, measuring pollutant concentrations every few minutes, and

calculating an average concentration for each hour of the day and night. Other types of equipment

operate intermittently, perhaps every other day or every sixth day. The equipment runs for a

specified time period, often 24 hours, and subsequent laboratory analysis determines the average

pollutant concentration during the measurement time.

State and Local Air Monitoring Stations (SLAMS)

The SLAMS consist of a network of ~ 4,000 monitoring stations whose size and

distribution is largely determined by the needs of State and local air pollution control agencies to

meet their respective State implementation plan (SIP) requirements.

National Air Monitoring Stations (NAMS)

The NAMS (1,080 stations) are a subset of the SLAMS network with emphasis being

given to urban and multi-source areas. In effect, they are key sites under SLAMS, with emphasis

on areas of maximum concentrations and high population density.

Special Purpose Monitoring Stations (SPMS)

Special Purpose Monitoring Stations provide for special studies needed by the State and

local agencies to support State implementation plans and other air program activities. The SPMS

are not permanently established and, can be adjusted easily to accommodate changing needs and

priorities. The SPMS are used to supplement the fixed monitoring network as circumstances 
 Appendix G-8

require and resources permit. If the data from SPMS are used for SIP purposes, they must meet

all QA and methodology requirements for SLAMS monitoring.

Photochemical Assessment Monitoring Stations (PAMS)

A PAMS network is required in each ozone nonattainment area that is designated serious,

severe, or extreme. The required networks will have from two to five sites, depending on the

population of the area. There will be a phase-in period of one site per year starting in 1994. The

ultimate PAMS network could exceed 90 sites at the end of the 5-year phase-in period.

The individual measurements -- 1-hour and 24-hour average air pollutant concentrations

-- are submitted to EPA and stored in the Aerometric Information Retrieval System (AIRS)

database. They are called AIRS raw data. In addition, AIRS software creates and stores an

annual summary of the air pollution measurements from each unit of monitoring equipment. The

annual summary includes information such as the highest values reported, the average value, and

the number of values above the NAAQS (health-based threshold levels).

Interagency Monitoring of Protected Visual Environments (IMPROVE)

The National Visibility Program established in 1980 requires the protection of visibility

in 156 mandatory federal Class I areas across the county. In 1987, the IMPROVE visibility

network was established as a cooperative effort between EPA, the National Oceanic and

Atmospheric Administration, the National Park Service, the U.S. Forest Service, the Bureau of

Land Management, the U.S. Fish & Wildlife Service, and state governments. The objectives of

the network are to establish current conditions, to track progress toward the national visibility

goal, by documenting long-term trends, and to provide information for determining the types of

pollutants and sources primarily responsible for visibility impairment. Chemical analysis of

aerosol measurements provides ambient concentrations and associated light extinction for PM10,

PM2.5, sulfates, nitrates, organic and elemental carbon, crustal material, and a number of other

elements. The IMPROVE program has established protocols for aerosol, optical, and

photographic monitoring methods, and these methods are employed at more than 100 sites, most

of which are Class 1 areas. In the calendar year 2000, an additional 80 monitoring sites using the

IMPROVE aerosol monitoring protocol were scheduled for placement.

Acidic Deposition Monitoring Networks

Total atmospheric deposition is determined using both wet and dry deposition

measurements. Wet deposition is the portion dissolved in cloud droplets and is deposited during

rain or other forms of precipitation. Dry deposition is the portion deposited on dry surfaces

during periods of no precipitation as particles or in a gaseous form. Although the term “acid

rain” is widely recognized, the dry deposition portion can range from 20-60 percent of total

deposition. The NADP and CASTNet were developed to monitor wet and dry deposition,

respectively.
 Appendix G-9

The National Atmospheric Deposition Program/National Trends Network (NADP/NTN)

NADP/NTN is a nationwide network of precipitation monitoring sites. The network is a

cooperative effort between many different groups, including the State Agricultural Experiment

Stations, U.S. Geological Survey, U.S. Department of Agriculture, and numerous other

governmental and private entities. The NADP/NTN has grown from 22 stations at the end of 

1978, our first year, to over 200 sites spanning the continental United States, Alaska, and Puerto

Rico, and the Virgin Islands. The purpose of the network is to collect data on the chemistry of

precipitation for monitoring of geographical and temporal long-term trends. The precipitation at

each station is collected weekly according to strict clean-handling procedures. It is then sent to

the Central Analytical Laboratory where it is analyzed for hydrogen (acidity as pH), sulfate,

nitrate, ammonium, chloride, and base cations (such as calcium, magnesium, potassium and

sodium). The NADP has also expanded its sampling to two additional networks. The Mercury

Deposition Network (MDN), currently with over 35 sites, was formed in 1995 to collect weekly

samples of precipitation which are analyzed by Frontier Geosciences for total mercury. The

objective of the MDN is to monitor the amount of mercury in precipitation on a regional basis;

information crucial for researchers to understand what is happening to the nation's lakes and

streams. Another network, the Atmospheric Integrated Research Monitoring Network

(AIRMoN), is operated by the National Oceanic and Atmospheric Administration (NOAA) and

was formed for the purpose of studying precipitation chemistry trends with greater temporal

resolution. Precipitation samples are collected daily from a network of nine sites and analyzed

for the same constituents as the NADP/NTN samples.

Clean Air Status and Trends Network (CASTNET)

The CASTNet was primarily designed to measure dry acid deposition. Some monitors

also record rural ozone data as well as the chemical constituents of PM2.5. Established in 1987,

CASTNET now comprises 79 monitoring stations across the U.S., 74 measuring dry deposition,

19 measuring wet-deposition, 68 measuring O3 and eight measuring aerosols for visibility

assessment. The longest data records are primarily at eastern sites.

CASTNET is considered the nation's primary source for atmospheric data to estimate dry

acidic deposition and to provide data on rural ozone levels. Each dry-deposition station measures

weekly average atmospheric concentrations of sulfate (SO4), nitrate (NO3), ammonium (NH4),

sulfur dioxide (SO2), and nitric acid, hourly concentrations of ambient ozone levels and

meteorological conditions required for calculating dry deposition rates. Dry deposition rates are

calculated using atmospheric concentrations, meteorological data, and information on land use,

vegetation, and surface conditions. 

The CASTNET provides atmospheric data on the dry deposition component of total acid

deposition, ground-level ozone and other forms of atmospheric pollution. Used in conjunction

with other national monitoring networks, CASTNET is used to determine the effectiveness of

national emission control programs. The majority of the monitoring stations are operated by
 Appendix G-10

EPA's Office of Air and Radiation; however, approximately 20 stations are operated by the

National Park Service in cooperation with EPA. 

CASTNET complements the database compiled by NADP. Because of the

interdependence of wet and dry deposition, NADP wet deposition data are collected at or near all

CASTNET sites. Together, these two long-term databases provide the necessary data to estimate

trends and spatial patterns in total atmospheric deposition.

Ozone data collected by CASTNET are complementary to the larger ozone data sets

gathered by the State and Local Air Monitoring Stations (SLAMS) and National Air Monitoring

Stations (NAMS) networks. Most air quality samples at SLAMS/NAMS sites are located in

urban areas, while CASTNET sites are in rural locations. Hourly ozone measurements are taken

at each of the 50 sites operated by EPA. Data from these sites provide information to help

characterize ozone transport issues and ozone exposure levels.

What types of resources are available from EPA for monitoring network design,

installing and operating monitors, and reporting air quality monitoring data?

Resources for Guidance, Measurement Equipment, and Network Design:

» Ambient Monitoring Technology Information Center (www.epa.gov/ttn/amtic/)

(AMTIC) is centered around the exchange of ambient monitoring related information.

Established in 1991 as an electronic Bulletin Board System (BBS), AMTIC has

evolved with changing technology into a page on the World Wide Web (WWW). 

AMTIC is operated by EPA's Office of Air Quality Planning and Standards (OAQPS)

through the Monitoring and Quality Assurance Group (MQAG). AMTIC contains

information on all the Reference and Equivalent methods for the Criteria pollutants,

the TO Methods and other noncriteria pollutant methodologies, Federal Regulations

pertaining to ambient monitoring, ambient monitoring QA/QC related information,

information on ambient monitoring related publications, ambient monitoring news

(including the AMTIC Newsletter), field and laboratory studies of interest, and

updates on any new or developing EPA Ambient Air standards.

» The Interagency Monitoring of Protected Visual Environments (IMPROVE)

(http://vista.cira.colostate.edu/improve/Data/GraphicViewer website provides links to

Monitoring Protocol and Information documents such as Quarterly Newsletters and

Standard Operating Procedures as well as Regional Haze Guidance Documents. 

Information is also available on IMPROVE data gathering methods and measurement

equipment Modules A, B, C and D. This site also provides an extensive list of

publications, resources and links to Data Analysis (including analysis tools and

algorithms), Gray Literature (unpublished analyses), Visibility and Aerosols Science

and Policy documents. Monitoring Studies focusing on Class I and Urban areas are

also available.
 Appendix G-11

» Tribal Air Monitoring Support Center (TAMS) (www4.nau.edu/itep/intro.html) was

created through a partnership with ITEP and the United States Environmental

Protection Agency. Located at the Radiation and Indoor Environments National

Laboratory in Las Vegas, Nevada, the TAMS Center will provide instrument training

and filter weighing services to all interested tribes.

Resources for Air Quality Data:

» The Aerometric Information Retrieval System (AIRS) is EPA's repository of criteria

air pollutant monitoring data since the 1970's. Considerably less data for hazardous

air pollutants have been collected, mostly after 1995. The Monitors segment of

AIRData deals with ambient air quality -- the prevailing levels of air pollution in

cities and towns across the United States. Information presented in the Monitors

segment of AIRData comes from the Air Quality Subsystem (AQS) of the AIRS

database (www.epa.gov/ttn/airs/aqs/index.html). EPA updates the AIRS database

every week. Most states submit their air monitoring data monthly, with different

groups of states submitting data during any given week. After the individual

measurements of hourly of daily pollutant concentrations have been stored in the

AIRS database, calendar-year summary values are computed for each air monitor. 

Only these summary values are extracted from the AIRS database and presented in

AIRData reports and queries. The individual hourly and daily monitoring values are

not available at this AIRData website. To receive information directly from AIRS,

you need to register for an account on the EPA mainframe computer. For information

about obtaining an account, call 1-(800)-334-2405, (919)-514-5232, or call the

National Technical Information Service at (703) 605-6000.

AIRData provides two ways to access Monitor data: AIRData Monitor Reports and

AIRData Monitor Queries. AIRData Monitor Reports present annual summary data

for criteria pollutants, and descriptive information about the monitoring sites for those

pollutants. This option is preferred for a quick review of the most significant

measures of air quality. The Reports database is updated monthly. AIRData Monitor

Queries present annual summary data for all pollutants in the AIRS/AQS database.

Queries include many more pollutants and data elements than Reports, and they

display values in a more technical format. Queries are intended primarily for

environmental professionals, but the information is available to all, of course. The

interim database used for Queries is updated two to four times per year.

» The Interagency Monitoring of Protected Visual Environments (IMPROVE) 

http://vista.cira.colostate.edu/improve/Data/GraphicViewer/ website also offers Data

Resources, Graphical Displays and Publications. Data Resources include metadata,

(state by state information on all IMPROVE monitors, including latitude, longitude,

elevation, sampling equipment, documented equipment/monitoring changes, data

collection start and end dates and sponsor), raw data and data products such as

Annual, Seasonal and Monthly Fine Mass Composition and Light Extinction Budgets,
 Appendix G-12

aggregated over the period of March 1996 to February 1999 according to Class I

Area. Light Extinction Diurnal Cycles, Annual Fine Mass/Light Extinction Group 10,

50, 90 Trends, raw Aerosol and Optical data, photographs and Monthly Regional

Haze and RH Correction Factors are also available. 

The IMPROVE Graphic Viewer allows browsing of interactive Spatial, Temporal,

Variable and Frequency displays using the information from the Data Resources

section. It also includes a report on Long-Term Trends of Fine Mass and its Major

Aerosol Types for 1988-1998. 

» The Clean Air Status and Trends Network (CASTNET)

(http://www.epa.gov/castnet/) provides atmospheric data on acid rain (specifically dry

acid deposition), tropospheric (ground-level) ozone and other forms of atmospheric

pollution. A Sampling Matrix, including state and site specific information, provides

details of each CASTNET sampling station. CASTNET Annual Reports (1998 and

1999) may be accessed from this site as well as Data Reports, Charts and Graphs of

hourly, diurnal, geographic and annual assessments of dry acid deposition, ozone and

meteorological parameters.

» The National Atmospheric Deposition Program/National Trends Network

(NADP/NTN) (http://nadp.sws.uiuc.edu/) is the longest running national deposition

monitoring network. Many data products are accessible from this website, including

weekly and daily precipitation chemistry data, monthly, seasonal, and annual

precipitation-weighted mean concentrations, annual and seasonal deposition totals,

mercury deposition data, daily precipitation totals, color isopleth maps of

precipitation concentrations and wet deposition, site photos, maps, and information

and quality assurance data and information. In addition, publications such as

brochures, manuals, committee meeting proceedings, annual program reports, annual

summaries (1997-2000) and quality assurance reports (1996-1999) are available.
1 This appendix is adapted from Regulatory Development Enforceability on

Regulations by Susan E. Bromm, US EPA., no date.

 Appendix H-1

Appendix H

TIP Enforceability Checklist1

This checklist provides general enforceability guidance applicable to all possible

components of a TIP. However, TIPs do not need to contain all of these components. You need

only to refer to those sections that apply to the provisions included in your tribe’s TIP.

Enforceability Analysis EPA Requirement

Applicability

What sources are being regulated? Clearly stated in the rule. 

What are the criteria for exemptions? Clearly stated in the rule. 

Is the calculation procedure for

exemptions clearly identified?

You must include an example calculation or clear

explanation of how to determine exemption. 

Where Is the emission inventory of

affected sources listed in the

document?

Allowable and actual emissions in the source

category should be included in your TIP, for

enforcement purposes and determination of any

baselines in the regulation(s).

Is the averaging time(s) used in the

rule different from that of the ambient

standards?

The averaging and ambient standard times must be

consistent . The averaging time is typically equal to

or shorter than the ambient standard time. Longer

term averaging is available only in limited instances,

provided the ambient standard is not compromised. 

What are the units of compliance

(pounds VOC per gallon of solids

applied less water, grains per dry

standard cubic foot, etc)?

Clearly stated in the rule.
Enforceability Analysis EPA Requirement

 Appendix H-2

Are there mechanisms for limiting

multiple sources at one facility? Are

they enforceable? 

Explicit description of how overall total facility

emissions are to be determined. VOC equivalency

must be on a “solids applied” basis. Any method

must be independently reproducible. Provision must

be explicit as to whether case-by-case approval is

required. If provision is intended to be generic, then

bubble policy must be met.

If there is a redesignation will this

change your emission limits? If yes,

which ones and how?

Upon the redesignation of your area to attainment,

the Regulation may not allow for self nullification. 

Maintenance demonstration required in order to drop

regulation.

Compliance Dates

What is your compliance date? What

is the area’s attainment date?

Your compliance date Must not be later than

approved (or soon to be approved) date of attainment

unless emission reductions are not necessary for

attainment. In some cases, it will be necessary for

the regulation to specify dates in compliance

schedules.

Specificity of Conduct

What test method is required? Your Test method must be explicitly stated.

What is the averaging time in the

compliance test method?

The Averaging time and application of your

emission limit must be explicitly stated.

Is a compliance calculation or

evaluation required? 

Your formula, period of compliance, and/or

evaluation method must be explicitly stated. 

Incorporation by Reference

What is your tribe’s authority for

rulemaking?

Demonstrate the legal mechanism to promulgate and

enforce rules.

Are the methods/rules incorporated by

reference in the right manner?

Clearly stated in the rule. 
Enforceability Analysis EPA Requirement

 Appendix H-3

Recordkeeping

What records are required to determine

compliance?

Clearly stated in the rule. 

In what form or units (lbs/gal, gr/dscf,

etc.) must the records be kept? On

what time basis?

Records to be kept must be consistent with units of

compliance in the performance requirements,

including the applicable time period.

Does the rule explicitly require the

records to be kept? 

There must be a clear, separately enforceable

provision that requires records to be kept.

Exemptions

What are the allowed exemptions? All exemptions Must be clearly defined and

distinguishable from what constitutes a violation.

Is the criteria for application clear? Same as above.

Include malfunction provisions. Rule must specify what exceedances may be

excused, how the standard is to be applied, and who

makes the determination.
 Appendix H-4

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 Appendix I-1

Appendix I

Procedures for Area Redesignation to Class I

The procedures outlined in this appendix are for tribal governments seeking to have areas

within their jurisdiction that are in attainment of NAAQS redesignated as a Class I attainment

area. Tribes may also seek redesignation for areas other than their reservations. These

procedures are based on requirements set forth in section 164 of the Clean Air Act, 40 CFR

51.166(g) and 40 CFR 52.21(g), and the Tribal Authority Rule, 63 Federal Register 7254 which

is codified at 40 CFR 49.

The lands within the exterior boundaries of an Indian reservation may be redesignated

only by the appropriate tribal government . Before proposing a redesignation, the tribe needs to

prepare a discussion of the reasons for the proposed redesignation, including a satisfactory

description and analysis of the health, environmental, economic, social, and energy effects of the

proposal. 

The tribe is required to hold public hearings on the proposed redesignation in the areas

proposed to be redesignated and in areas that may be affected by the proposed redesignation. At

least 30 days before the hearing, your tribe needs to issue a public notice of the hearing that

includes:

» A prominent advertisement in the area affected announcing the date, time, and place

of the hearing

» Information about the availability of the proposal and discussion document in at least

one location in the area

The tribal government needs to submit a proposal to redesignate to the EPA

Administrator through the appropriate EPA regional office. The tribe also needs to prepare and

retain, for inspection by the EPA Administrator upon request, a record of the hearing that

includes a list of witnesses together with the text of each presentation. Along with the proposal

to redesignate, the tribe must submit to EPA a certification that the hearing was held in

accordance with the requirements of 40 CFR 51.102. If federal lands are included in the

proposed redesignation, the appropriate Federal Land Manager needs written notice and an

opportunity to confer with the tribe regarding the redesignation. 

The EPA Administrator will approve or disapprove the proposed redesignation within 90

days of submission. The proposal will be disapproved after notice and opportunity for public

hearing only if it is found that it did not meet the procedural requirements in the EPA regulations

or it was inconsistent with the Clean Air Act’s restrictions on area classifications. If the EPA

Administrator disapproves a proposed redesignation, it may be resubmitted after correcting the

deficiencies noted by the Administrator.
 Appendix I-2

References:

Section 164 of the CAA; 40 CFR 51.166(g); and 40 CFR 52.21(g).
 Appendix J-1

Appendix J

Regulation Development1

This is a check list of questions to help a tribe in developing an effective rule.

General Considerations

» What is the problem that needs to be resolved by the rule?

» Are the purpose, intent, and requirements as clear as possible in the actual provisions

of the regulation?

» Is the affected regulated community familiar with the program?

» If the rule will bring a significant number of new facilities into the regulated universe,

how will they find out that they are subject to the regulation?

Clarity

Clarity promotes compliance. Regulatory language that is clear and concise will help the

regulated community understand its obligations under the regulation.

» Does the rule contain complex language that could be interpreted in more than one

way by parties acting in good faith?

» Are ambiguous terms defined or clarified?

» Does the rule contain inconsistencies or contradictions?

» Is the date the rule goes into effect stated?

» Are all events or activities that must occur prior to the effective date identified?

» Have clarifying tools such as definitions, tables, or flowcharts been used as

appropriate?

Specificity

If regulatory requirements, standards of performance, or decision-making criteria are left open to

interpretation, regulated entities and enforcement personnel may be inconsistent in their

implementation and application of the requirements.

» Has non-specific language that may require clarification through guidance or policy

been avoided?

» Are performance standards defined in clear and measurable terms?

» Has the latitude of an inspector’s discretion in applying professional judgement been

specified, if applicable?

» Has the regulated community been identified and defined?

» Have the exclusions from the regulation been clearly identified?
 Appendix J-2

Enforcement Practicability

» How will compliance or non-compliance be verified by inspectors or enforcement

personnel?

» What is the potential increase in the size of the regulated universe based on the rule?

» What are the associated implementation and enforcement implications?

» What professional qualifications will be needed to conduct inspections and evaluate

compliance with the rule?

» How will compliance with the regulation be monitored (field inspections, records

review, facility reports, self-enforcing)?

» Has self-reporting/self-monitoring by the regulated entity been used to the maximum

extent possible?

» Have EPA-approved or standardized test methods been incorporated to ensure data

uniformity and comparability?

» Have analytical methods that can be applied in the field or laboratory been

incorporated to the extent feasible?

» If a rule is self-implementing, is it practical to incorporate the requirements into the

permit process?

» Does adequate authority exist for entering, inspecting, and sampling at regulated

facilities?

Burden of Proof

» Is it clearly stated whether the burden of proof lies with the tribal authority or with the

owner/operator?

» Is adequate proof defined?

Notification, Recordkeeping, and Reporting

» Is information that must be recorded and maintained specified?

» Is the period of time for which information must be retained stated?

» Does all information that will be submitted to tribal authorities serve a specific

purpose?

» Is notification required?

» What information should be included in notification?

» Do reporting requirements facilitate review for non-compliance?

Other Programs

» Have you considered the rule’s impact on other tribal environmental programs and

offices?

» Could compliance with the rule result in potential cross-media contaminant transfer?
 Appendix J-3

» Have other program offices been consulted regarding cross-program compliance

issues?

Enforcement Mechanisms

There are numerous mechanisms that can be employed to evaluate and monitor compliance with

regulations. Think about appropriate tools for compliance monitoring and enforcement as the

regulation is being developed.

» Has independent confirmation of compliance (e.g., by professional engineer) been

considered as a means to add credibility to assessment of technical requirements?

» Have self-certification measures such as verifying data accuracy with EPA-approved

methods, training by certified hazardous materials trainers, or other certifications been

considered?

Endnote

1 This appendix is adapted from Regulatory Development Enforceability of Regulations by

Susan E. Bromm, US EPA., no date.
 Appendix J-4

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 Appendix K-1

TIP Completeness Checklist

This TIP completeness checklist is an example used in Region V.

EPA REGION V

COMPLETENESS REVIEW

A. Regulatory (Administrative Materials)

1. Is the submittal accompanied by a formal letter of submittal from the governor’s

designee? yes no 

The date of submittal is 

2. Did the State provide evidence that it has incorporated the revision in the Wisconsin

Administrative Code? yes no 

The month of publication in was 

The effective date is 

Are test methods/rules incorporated by reference correctly? 

Has approval been obtained from the state Attorney General?

yes no not applicable 

3. Did the State provide evidence that it has the necessary legal authority under State law

to adopt and implement the revision? yes no rule analysis which cites

authorizing statutes submitted? yes no 

4. Does the submittal include a copy of the actual regulation or document submitted for

review? yes no 

5. Did the State provide evidence that it followed all of the requirements of its

Administrative Procedures Act in conducting and completing adoption/issuance of the

revision? yes no 

6. Did the State provide evidence that Public Notice was given of the revision, including

the date of publication? yes no 

7. Did the State provide certification that public hearings were held in accordance with

the information provided in the public notice (notarized SIP Revision Certification)?

yes no 
 Appendix K-2

8. Does the submittal contain a compilation of public comments and the State’s

response? yes no 

B. Technical Support

1. Does the submittal identify all regulated pollutants affected by the revision? 

 yes no 

2. Does the submittal identify the designation, status of the attainment plan and

attainment date for the area(s)? yes no 

3. Does the submittal identify the location and types of affected sources?

yes no 

4. Does the submittal quantify the changes in SIP-allowable emissions and estimate or

quantify the changes in actual emissions from affected sources?

yes no 

5. Has the State demonstrated that the NAAQS/PSD increment/RFP

demonstration/visibility will be protected if the revision is approved and

implemented? yes no 

5a. For any request to redesignate an area to attainment, has the State submitted a revision

which provides for maintenance of the primary NAAQS fir at keast 10 years? yes 

no not applicable 

6. Has the State provided modeling information (if necessary) to support the revision?

yes no unnecessary 

7. Has the State provided evidence that emission limitations are based on continuous

emission reduction technology? yes no NA 

8. Has the State provided evidence that the revision contains emission limitations, work

practice standards and recordkeeping/reporting requirements, where necessary, to

ensure emission levels? yes no 

9. Does the submittal contain enforcement/compliance strategies including how

compliance will be determined in practice, and at what frequency? yes no 

10. Does the submittal contain special economic and technical justifications required by

the USEPA policies, or explain why such justifications are necessary? yes no 

not applicable 
 Appendix L-1

United States Environmental Protection Agency

Office of Air and Radiation

Review of Authorities Available for Tribal Air Program 

Financial Assistance Grants

April 19, 2002
 Appendix L-2

Introduction

When EPA proposed its implementing regulations for §301(d) of the Clean Air Act

(CAA) in August 1994, it recognized that tribes (to an even greater degree than states) would

need financial assistance to support the development and implementation of tribal air programs. 

In the preamble to its proposal, EPA discussed at length the various mechanisms available to

tribes for funding their air programs. Since that proposal was published, much has happened to

stimulate interest in air programs in Indian country and many tribes have taken advantage of the

authorities under the CAA and other statutes to begin developing programs. 

 This document is intended to reiterate the discussion EPA presented on financial

assistance in the proposed rule (40 C.F.R. Parts 9, 35, 49, 50 and 81 Indian Tribes: Air Quality

Planning and Management) and provides additional guidance on how these mechanisms might be

used to advance the tribes’ objectives in air quality management. However, this document is only a

summary of available grant funds for CAA activities. EPA has developed formal procedures governing

these activities and tribes should consult these procedures (see list at the end of this document) before

they make formal application to EPA for a grant.

Background

As far back as the 1970's, a limited number of tribes were receiving funding from EPA to

support air program development, usually focusing on air monitoring. With the proposal of the

Tribal Authority Rule in 1994, the reaffirmation of the Agency’s Indian policy, and more

aggressive outreach to tribes on the opportunities available to them under the CAA, more tribes

became interested in air quality management. However, the statutory requirements for tribes to

provide a “match” on federal funding remained a significant barrier to tribes seeking funding.

The elimination of the §103 match requirement in 1996 and the promulgation of the Tribal

Authority Rule in 1998 (which reduced the match for §105 for eligible tribes from 40% to 5-

10%) virtually eliminated the financial barriers to tribes with TAS seeking assistance to

implement tribal air programs. 

The elimination of these barriers and the aggressive training and outreach to tribes on air

quality management has continued to increase the demand for federal resources to implement

programs. More than one hundred tribes are already operating under CAA grants; many more

have expressed interest in applying for new grants. EPA believes it is appropriate at this time to

clarify in a single source document the various authorities for financial assistance available to

tribes and factors that tribes might consider in choosing among these authorities. 
 Appendix L-3

Objectives of this overview

The objectives of this document are to: 

• Describe the funding authorities available to provide grants for tribes to use to

develop and implement tribal air programs;

• Explain the kinds of activities each of these authorities can fund;

• Promote national consistency on the use of these authorities, while continuing to

respond flexibly to tribal needs; and 

• Suggest strategies to tribes for optimizing the use of these authorities to develop and

implement their programs.

National Consistency

Although EPA’s Tribal Air Program is rooted in the principles of flexibility and

decentralized management, it is important to make clear that a number of factors in the program

are universally applicable and should be applied nationally.

• Since its first articulation in 1984, EPA’s Indian Policy has always been that tribal

governments should be viewed as the primary parties in managing their

environments and should be consulted on any EPA action that affects the tribe. 

Tribal consortia are eligible for financial assistance if they meet the requirements

outlined in 40 C.F.R. §35.504. Assistance is subject to the approval/concurrence

of the consortium’s member tribes, and eligibility requirements are different under

the authorities for General Assistance Program and CAA §105.

• Financial assistance has been provided to tribes to begin conducting

environmental assessments and to develop environmental program management

capacity. As tribes develop a better understanding of their air quality problems

and begin to consider the long term implications of managing air quality, they

should become more interested in moving toward a long term commitment to an

air quality management program. 

Statutory authorities available 

Eligible tribes may seek funding to develop tribal air programs under three separate authorities: 

• Indian Environmental General Assistance Program (42 USC §4368b)

• Clean Air Act Project funding (CAA §103(b)) 

• Clean Air Act Program funding (CAA §105)

• Performance Partnership Grants (PL 104-134 and PL 105-65)
 Appendix L-4

Each of these provisions offers opportunities and limitations that might affect a tribe’s

decision on the appropriate authority to use (in addition to the statutory limitations, tribal grants

are subject to cost allowability limitations set forth in OMB Circular A-87). This document will

attempt to outline those factors that tribes should consider as they look for financial assistance to

develop air programs.

General Assistance Program

1. How can the General Assistance Program be used to undertake the development of

an air quality program?

EPA’s General Assistance Grant Program (GAP) provides resources to eligible tribes to

plan, develop, and establish an environmental protection program. This includes building

the administrative, technical, legal, enforcement, communications, and environmental

education and outreach infrastructure.

Planning and development of an environmental protection program may include

conducting a baseline assessment of environmental degradation for specific media (e.g.,

air, water, etc.). For instance, in developing an air pollution control program, a tribe

could use GAP funds for a baseline assessment of air quality. A tribe could also use GAP

funds for other activities in support of building its air quality program such as completing

an air pollution emissions inventory or setting up an ambient air quality monitoring

network to characterize the air quality of an Indian country area as part of building the

capacity to operate and manage an environmental program. The GAP grant may include

the funds necessary to complete the tasks (staffing, travel, training, etc.) including the

purchase of equipment consistent with EPA’s regulations at 40 C.F.R. Parts 31 and 35

and OMB Circular A-87. EPA regional offices should work closely with tribal

governments as they develop their GAP grant work plans to incorporate media-specific

activities as appropriate. 

2. Are GAP grants competed?

Although GAP grants are not formally competed at the national level, the limited

availability of GAP funding requires some Regional Offices to establish competitive

processes for awarding GAP grants. In these cases, the Regional Office may require that

all grant proposals be submitted within a certain time frame so that the work plans can be

evaluated simultaneously. Although it is EPA’s goal to be able to award a GAP grant to

every tribe requesting one, it is sometimes necessary to negotiate work plans to reduce the

level of effort and the funding required so that all tribes who apply can receive some form

of assistance.
 Appendix L-5

3. Why might a tribe choose the GAP authority rather than a CAA authority?

This funding might be of particular interest to tribes concerned about committing to an air

pollution program infrastructure before they have a complete understanding of the air

quality conditions within Indian country. Including a baseline multi-media assessment of

Indian country in a GAP grant provides an avenue for a tribe to collect the data needed to

make media-specific decisions about media program implementation without taking on

the burden of managing a number of media program grants. For example, a tribe may

have concerns about its aquatic resources and suspect air deposition as a pollution

pathway. It may also be reluctant to take on multiple grants and a large staff just to find

out if there is a problem. In this case, it might be appropriate for the tribe to work with

EPA to develop a GAP work plan that would enable the tribe to build an environmental

protection program that addresses both air and water pollution. A baseline assessment of

both water quality and air quality could be conducted if it is in support of planning,

developing, or establishing such a program. 

4. Are there any limitations on a tribe’s choosing the GAP authority?

Tribes should be aware that this authority is not appropriate “for the principal purpose of

solving particular problems at particular places,” because they are not in support of

planning, developing or establishing an environmental protection program. For instance,

if a tribe has a concern about the transport of air pollution from a specific off-reservation

source and wants to gather data on the impact of that source on its ambient air quality, it

may be more appropriate to use one of the other available CAA grant authorities to

complete the assessment. 

Section 103 Authority

 

1. How can the Clean Air Act §103 authority be used to build tribal air programs? 

CAA §103(a) establishes EPA’s authority to “conduct, and promote the coordination and

acceleration of, research, investigations, experiments, demonstrations, surveys, and

studies relating to the causes, effects (including health and welfare effects), extent,

prevention, and control of air pollution.” CAA § 103(b)(3) authorizes EPA to “make

grants to air pollution control agencies, to other public or nonprofit private agencies,

institutions, and organizations, and to individuals, for [these] purposes.” This broad

authority has been used by many tribes to begin work on tribal air programs. Tribes have

used the CAA §103 authority to begin air quality assessments, develop emissions

inventories, and set up air quality monitoring networks to collect data on ambient air

quality. A number of tribes have hired and trained air quality specialists to oversee the

implementation of these activities. 
 Appendix L-6

2. Are there any limitations on the tribes’ use of the §103 authority?

CAA §103 grants are project grants, and it is EPA’s policy that these grants will not be

approved for a performance period greater than five years. This limitation should not

constrain tribes interested in assessing air quality and undertaking initial developmental

activities since this kind of activity should generally not take more than five years to

complete. It is also possible for tribes to seek multiple project grants under this authority

as long as no single grant activity extends beyond five years in a single grant’s cycle, and

multiple grants are for distinctly different purposes. However, a §103 grant provides no

guarantee of on-going funding beyond the project period.

The authority is not limited to “air pollution control agencies” or “an agency of an Indian

tribe,” which would narrow the field of eligibility (as with the 105 authority). As a

project authority, §103 provides discretion to the Administrator to select those activities

for funding that advance knowledge on the “causes, effects [. . .], extent, prevention, and

control of air pollution.” (CAA §103(a)(1)). Although EPA has established no formal

evaluation and selection criteria for tribes applying for grants under this authority, it may

be necessary to do so as resources become more limited. 

Section 105 Authority

1. What is the purpose of CAA §105 grants? 

EPA has been providing financial assistance to state pollution control agencies under the

CAA §105 authority since the CAA was first authorized in 1970. The authority,

however, has always limited the extent to which the federal government will fund a CAA

program and required states to provide matching funds. Under the initial authorization,

federal funding was limited to 75% of the total program; that requirement was changed by

the 1990 amendments to limit the federal share of a CAA program to 60%. This authority

provides for “implementing programs for the prevention and control of air pollution or

implementation of national primary and secondary ambient air quality standards.” (CAA

§105(a)(1)(A)). The CAA further defines implementation as “any activity related to the

planning, developing, establishing, carrying-out, improving, or maintaining of such

programs.” (CAA §105(a)(1)(A)). The authority is further restricted to state and regional

air pollution control agencies as well as agencies of an Indian tribe, which have been

eligible to receive funding under this authority in the same manner as states since the

1990 Clean Air Act amendments. 

Eligible tribes have authority, if they choose to take it on, to develop and implement

federally enforceable CAA programs. In addition, tribes who seek eligibility to receive a

CAA §105 grant under the 40 C.F.R. §35.573(a) are also eligible for a reduced matching

requirement (5% to 10%, depending on the situation). It is important to note that without

the eligibility determination under 40 C.F.R. §49.6, tribes are required to provide a 40%
 Appendix L-7

match and the tribes’ must expend the same amount of tribal funds for recurrent CAA

§105 activities as it expended in the previous year (maintenance of effort requirement

CAA §105(c)), with no formal waiver provisions, in order to continue receiving §105

funds each ensuing year.

Tribes are generally eligible to receive §105 funding for operating ongoing air quality

programs subject to certain limitations. Proposed programs must satisfy the requirements

in 40 C.F.R. §35.511 including:

:

• Be consistent with 40 C.F.R. Part 31 (requirements involving grants); 

• Be consistent with all applicable federal statutes; regulations; circulars; executive

orders; and EPA delegations, approvals, or authorizations;

• Be feasible, considering the applicant’s existing circumstances, past performance,

program authority, organization, resources, and procedures (40 C.F.R. part

35.511(a)(4)). 

A tribe seeking funding under §105 would have to work with the Regional Office to

ensure that these requirements are fulfilled. These requirements are not intended to act as

obstacles, but provide assurance that funding is being used as intended by Congress.

2. Must a tribe address additional requirements to receive the reduced match?

A tribe seeking eligibility to receive a CAA §105 program grant with a reduced match

must apply for eligibility under 40 C.F.R. part 49.6. A tribe must document that:

(1) The applicant is an Indian tribe recognized by the Secretary of the Interior;

(2) The Indian Tribe has a governing body carrying out substantial governmental

duties and functions;

(3) The functions to be exercised by the Indian Tribe pertain to the management

and protection of air resources within the exterior boundaries of the

reservation or other areas within the tribe’s jurisdiction; and

(4) The Indian Tribe is reasonably expected to be capable, in the EPA Regional

Administrator’s judgment, of carrying out the functions to be exercised in a

manner consistent with the terms and purposes of the Clean Air Act and all

applicable regulations.

If a tribe has already been determined “eligible” under another environmental statute or

under the CAA for another program, it need only identify the prior authorization and

provide the required information which has not been submitted in the previous

application (40 C.F.R. 49.7(a)(8)). 
 Appendix L-8

3. May a tribe seek a waiver for the CAA §105 match requirement?

Even with the reduced match, EPA recognizes that the economic circumstances of some

tribes may preclude them from providing this small match. The Agency’s regulation at

40 C.F.R. §35.575(a) provides discretion to the Regional Administrator to “increase the

maximum federal share if the Tribe or Intertribal Consortium can demonstrate in writing

that the fiscal circumstances within the Tribe or within the member Tribes of the

Intertribal Consortium are constrained to such an extent that fulfilling the match

requirement would impose undue hardship.” This applies only to tribes found eligible

under 40 C.F.R.49.6.

 

4. What are the advantages of §105 funding to tribal governments?

The principal advantage to a tribe is some assurance of continued funding in the future. 

As indicated above, tribes have access to this authority in two ways, through the statute

itself as an “agency of a tribe” or through the TAS eligibility determination process. The

CAA statute provides that “no application by a State [or a tribe] for a grant under this

section may be disapproved by the Administrator without prior notice and opportunity for

a public hearing in the affected State, and no commitment or obligation of any funds

under any such grant may be revoked or reduced without prior notice and opportunity for

a public hearing in the affected State.” (CAA §105(e)). 

EPA has provided in its recently promulgated revisions to the grant regulations similar

assurances of continued financial assistance. That provision reads: “The Regional

Administrator will not disapprove an application for, or terminate or annul an award of,

financial assistance under §35.573 without prior notice and opportunity for a public

hearing with the appropriate jurisdiction. . ..” (40 C.F.R. §35.578). Unlike the CAA

§103 authority, which is project oriented and time limited, the §105 authority provides

financial assistance for ongoing programs and will not be terminated without notice and

an opportunity for public hearing.

Another advantage for a tribe pursuing a CAA §105 grant is that this kind of financial

assistance can be incorporated into a Performance Partnership Grant.

Performance Partnership Grants (PPGs)

1. What is the role of Performance Partnership Grants? 

EPA is authorized to award Performance Partnership grants (PPGs) to tribes and tribal

consortia. PPGs enable Tribes and Tribal Consortia to combine funds from more than

one environmental program grant into a single grant with a single budget under

streamlined administrative requirements (40 C.F.R. §35.530(b)). Environmental program

grant funds eligible for a PPG include the General Assistance Program (GAP) and Clean
 Appendix L-9

Air Act §105 funds. CAA §103 grant funds are not available for inclusion in a PPG (see

40 C.F.R. §35.553).

PPGs offer many benefits to tribes. They offer opportunities to strengthen their

partnership with EPA through joint planning and priority setting. They allow tribes to

direct resources to those areas with the highest priority. They allow tribes to link program

activities more effectively with their environmental and public health goals. And, by

consolidating several programs, PPGs reduce the administrative burden of managing

several grants on the tribe. A tribe looking to develop an integrated environmental

management program that includes an air quality protection program might apply for 

CAA §105 funding (rather than a CAA §103 grant) in order to be able to include it in a

PPG with funds from other eligible programs.

For tribes eligible for §105 grants that have not established eligibility for Treatment as a

State, PPGs offer an option to receive funding under §105 with a reduced match. The

PPG cost share (match plus maintenance of effort) is the sum of the cost shares required

for all individual program grants included in the PPG, but for funds from programs with a

required cost share of greater than 5%, EPA will only require a 5% cost share. However,

after the first two years, it may be raised to 10%. All tribes eligible for §105 grants may

be eligible for a waiver of the cost share in a PPG (see 40 C.F.R. §35.536). This affords

an additional opportunity for tribes unwilling or unable to apply for a grant as an eligible

tribe under 40 C.F.R. §35.573(a). 

Source Documents:

Indian Tribes: Air Quality Planning and Management (40 C.F.R. Part 49)

Environmental Program Grants for Tribes (40 C.F.R. Part 35 subpart B)

Office of Air and Radiation FY 2002 National Program Guidance

Office of Air and Radiation FY 2002 Grant Guidance

OMB Circular A-87: Cost Principles for State, Local, and Indian Tribal Governments

OMB Circular A-102: Uniform Administrative Requirements for Grants and Agreements

with State and Local Government. 40 C.F.R. Part 31.
 Appendix L-10

Frequently Asked Questions

1. What are the key differences between the CAA §103 and §105 authorities?

Section 103 authority is a project-oriented grant. Activities under this authority are for

efforts like research, investigations and surveys, and tribes have used §103 grants for

activities associated with setting up air quality programs. These activities include initial

air quality assessments, emission inventories, gathering monitoring data to understand air

quality within Indian country, attending air quality training courses, preparing outreach to

tribal members and becoming involved with local, regional and national planning and

policy efforts. Section 105 grants are program grants provided to tribes to carry out

ongoing air quality programs. The key difference is that ongoing activities like long term

monitoring networks, inspections and enforcement, regulatory development and similar

activities which are part of an ongoing air program should be funded by §105. Another

key difference is that a §105 grant typically requires that a Tribe share some of the cost of

the work plan budget.

2. When should a tribe consider moving from a §103 grant to a §105 grant? Can a

tribe be granted a §103 grant and a §105 grant at the same time? 

Tribes typically should move to §105 funding when their research and investigation under

§103 funding enables them to determine that an ongoing air quality program is needed or

desired by the tribe. A number of factors could be important in making this decision, and

a primary factor would likely be the quality of the air within Indian country. Tribes in

areas not meeting national or tribal standards would likely want to carry out a §105

program to address air quality issues both on the reservation and in non-reservation areas

within their jurisdiction. In many cases, a tribe may have good air quality but still be

concerned with impacts from sources outside of Indian country as well as issues such as

long range transport and regional haze. The tribe might wish to maintain some ongoing

air quality expertise and capacity in order to review and comment on permits for sources

affecting their airshed, carry out an outreach program for tribal and neighboring

communities, and participate in local, regional and national planning and policy efforts. 

It is possible and not unusual for tribes (and other eligible grantees) to be funded under

both authorities at the same time. In some instances, as a tribal air program develops, the

tribe might choose to fund their ongoing activities under §105 while retaining funding for

project activities under §103 until they are completed. In addition, a tribe being funded

under §105 that wishes to carry out a new project, can apply for §103 funding for that

project while continuing with ongoing §105 activities. These activities can be carried out

concurrently but should be accounted for and reported as separate grants.
 Appendix L-11

3. How can a tribe meet the match requirement under a §105 grant?

There are three options for meeting the match requirements under §105. The most

common way is to provide 5 or 10% of the grant (if required) from tribal funding sources. 

This would often be drawn from a “general” fund maintained by the tribe, but could be

provided from any source of tribal revenue excluding all funds provided to the tribe by

the federal government, with the exception of federal funds specifically allowed by statute

to be used for match. See 40 C.F.R. §31.24(b)(1) (e.g. funds provided under PL 638). A

tribe may also provide a match through “in kind” sources, commonly contributions to the

program from other tribal personnel, or through the provision of office space, supplies or

overhead costs. This type of contribution would need to be supported by documentation

quantifying its value. The third option available to tribes is to demonstrate hardship in

providing match and apply to the Regional Administrator for a waiver. This generally

takes the form of a letter describing to the Regional Administrator how the fiscal situation

of the tribe prohibits the provision of matching funds. 

Note that for tribes choosing not to seek TAS eligibility to receive §105 funds under 40

C.F.R. §35.573(a), the statutory requirement to provide a 40% match remains in effect. 

However, those tribes without TAS may reduce the match requirement by including the

§105 funds in a PPG.

4. Under what circumstances can the match requirement for §105 grants under 40

C.F.R. §35.575(a) be waived?

Tribes are eligible for a waiver of the 5 or 10% match requirement at the discretion of the

Regional Administrator. A tribe would write to the Regional Administrator and present

information to demonstrate that providing the matching amount would cause the tribe

undue hardship.

5. For a tribe applying for CAA §105 funds as an eligible tribe under 40 C.F.R. §49.6, 

how can it meet the “reservation or other areas within the tribe’s jurisdiction”

requirement?

To show that the tribe meets the “reservation” requirement, a tribe needs to show “with

clarity and precision the exterior boundaries of the reservation including, for example, a

map and a legal description of the area.” 40 C.F.R. §49.7(a)(3). For applications

concerning “other areas within the tribe’s jurisdiction,” the tribe should include a map or

legal description of the area covered by the application and a statement by the applicant’s

legal counsel that describes the basis for the tribe’s assertion of authority over that area

for purposes of the grant.

To satisfy the capability requirement, the tribes must be reasonably expected to be

capable of carrying out the functions to be exercised in a manner consistent with the

terms and purposes of the Clean Air Act and all applicable regulations. A tribe should
 Appendix L-12

include a narrative statement describing the capability of the tribe to carry out the

functions to be exercised under the grant. The narrative statement may include a

description of: (1) the Tribe’s previous management experience; (2) existing

environmental or public health programs administered by the Tribe; (3) the agency or

office that will carry out the primary functions to be exercised under the grant; and (4) the

technical and administrative capabilities of the staff to administer and manage the

functions to be exercised or a plan which proposes how the tribe will acquire

administrative and technical expertise. EPA recognizes that certain tribes may not have

substantial experience administering environmental programs. A lack of experience will

not preclude a Tribe from demonstrating the required capability. Rather, Tribes should

show that they either have the necessary management and technical skills or submit a plan

detailing steps for acquiring those skills.

6. Are there specific activities that are allowed or not allowed under the authorities for 

§103 and §105?

While specific activities are generally decided by the Regional Offices, there are some

principles required by OMB Circulars that apply to all granting offices. As discussed

earlier, §103 activities should be research and demonstration projects with a distinct

duration and result. As part of a project, a tribe would generally be investigating their air

quality through inventories, assessments and monitoring. In addition, the tribe could be

developing their capacity to operate an air quality program by attending training, and

networking with their peers at local, regional and national meetings and events involving

the discussion and creation of air quality policies such as regional haze planning.

Under the §105 authority, many of these same activities would be allowable, as well as

additional activities such as regulatory development, inspection of sources, major and

minor source permitting, and ongoing monitoring efforts. The principle difference is an

air quality project compared to an ongoing air quality program, and the activities may be

similar, but have a different objective.

Please note that these lists are not inclusive and Regional Offices have some flexibility in

allowing tasks that they find appropriate to be performed under either grant authority.

7. What are the requirements to assure the quality data being developed by tribes? 

Many tribal programs are expected to undertake projects or programs which involve the

collection or creation of environmental data, (an example is ambient monitoring). While

there is some flexibility in the Regional offices regarding how this requirement is

implemented, in general, tribes must have an approved quality assurance project plan

(QAPP) to assure the quality of data being collected or created, prior to beginning the part

of the project or program that involves data collection (40 C.F.R. §31.45). An EPA

guidance document is available at http://www.epa.gov/quality1/qs-docs/r5-final.pdf, and

the Institute For Tribal Environmental Professionals and Northern Arizona University

offers regular workshops for tribes to learn how to develop these plans. 
 Appendix L-13

8. Can a tribe use federal financial assistance to defend itself in court?

Reimbursement of legal expenses is governed by the cost principles in OMB Circular A87. Funds from either §103 or §105 should be used for activities stated and approved as

part of the project workplan. In addition, consistent with the Agency’s annual

appropriation act, a chief executive officer of every assistance recipient is required to

certify that none of the federal funds were used to lobby the federal government or in

litigation against the United States unless authorized under existing law. 
 Appendix L-14

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 Acronym List1

Acronym List

AIRS-AQS Aerometric Information Retrieval System - Air Quality System database

(EPA)

AILESP American Indian Lands Environmental Support Project (EPA)

BACT Best Available Control Technology

BACM Best Available Control Measures

CAA Clean Air Act

CATC Clean Air Technology Center (EPA)

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations 

CHIEF Clearinghouse for Inventories and Emissions Factors (EPA)

C/MSA Consolidated Metropolitan Statistical Area

CO Carbon Monoxide

EIIP Emissions Inventory Improvement Program (EPA)

EMC Emissions Monitoring Center (EPA)

EPA Environmental Protection Agency

FIP Federal Implementation Plan

GCVTC Grand Canyon Visibility Transport Commission 

HAPs Hazardous Air Pollutants

IPP Inventory Preparation Plan

LAER Lowest Achievable Emission Rate

MACT Maximum Achievable Control Technology

minor NSR Minor Source New Source Review 

MSA Metropolitan Statistical Area

NA Nonattainment

NAAQS National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Pollutants

NET National Emissions Trends database (EPA)

NETI National Enforcement Training Institute (EPA)

NO2 Nitrogen Dioxide

NSPS New Source Performance Standards
 Acronym List-2

NSR New Source Review (for major sources in either attainment or

nonattainment areas)

NTIS National Technical Information Service 

OECA Office of Enforcement and Compliance Assurance (EPA)

O3 Ozone

Pb Lead

PM10 Particulate Matter with a diameter less than or equal to 10 micrometers

PM 2.5 Particulate Matter with a diameter less than or equal to 2.5 micrometers

ppm Parts per million (a unit of measurement)

PSD Prevention of Significant Deterioration program (New Source Review for

attainment areas)

QA/QC Quality Assurance / Quality Control

RACM Reasonably Available Control Measures

RACT Reasonably Available Control Technology

RFP Reasonable Further Progress

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAMS Tribal Air Monitoring Support Center

TAR Tribal Air Rule

TIP Tribal Implementation Plan

Fg/m3 Micrograms per cubic meter of air (a unit of measurement)

VOC Volatile Organic Compounds

WRAP Western Regional Air Partnership
 Glossary-1

Glossary

acid deposition - the process by which acidic particles, gases, and precipitation leave the

atmosphere. Although it is more commonly referred to as acid rain, acid deposition has

two components: wet deposition (through snow, rain, and fog) and dry deposition

(through the settling of gases and particles out of the atmosphere). 

acid rain - primarily the result of sulfur dioxide (SO2) and nitrogen oxides (NOX) reacting in the

atmosphere with water and returning to earth as rain, fog, or snow. This term is broadly

used to include both wet deposition and dry deposition (through the settling of gases and

particles out of the atmosphere).

Aerometric Information Retrieval System (AIRS-AQS) - a database with 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. The public may browse and obtain reports from AIRS-AQS at

www.epa.gov/airs/.

ambient air - any unconfined portion of the atmosphere; open air, surrounding air.

area source - any small source of non-natural air pollution that is released over a relatively small

area but which is not classified as a point source. Such sources may include vehicles and

other small engines, small businesses, and household activities.

attainment area - an area considered to have air quality as good as or better than the national

ambient air quality standards as defined by the Clean Air Act. An area may be an

attainment area for one pollutant and a nonattainment area for others.

baseline - the ambient concentration level of a pollutant that exists at the time of the first

application for a PSD permit. The baseline concentration is established for each pollutant

(and relevant averaging time). In areas with a PSD program, ambient air concentration

levels may not exceed the baseline plus an established increment.

Best Available Control Measures (BACM) - a term used to refer to the most effective measures

(according to EPA guidance) for controlling small or dispersed particulates from sources

such as roadway dust, soot and ash from woodstoves and open burning of brush, timber,

grasslands, or trash.

Best Available Control Technology (BACT) - an emission limitation based on the maximum

degree of emission reduction (considering energy, environmental, and economic impacts)

achievable through application of production processes and available methods, systems,

and techniques. BACT does not premit emissions in excess of those allowed under any

applicable CAA provisions. Use of the BACT concept is allowable on a case by case
 Glossary-2

basis for major new or modified emission sources in attainment areas (used under the

Prevention of Significant Deterioration program) and applies to each regulated pollutant.

biogenic source - non-manmade or natural emitter of air pollutants. For example, conifer trees

emit terpenes which are volatile organic compounds, a precursor to ozone.

carbon monoxide (CO) - a colorless, odorless, poisonous gas produced by incomplete fossil fuel

combustion. CO is a criteria pollutant regulated under NAAQS.

Class I, II, and III attainment areas - classifications of attainment/unclassifiable areas established

in the CAA. Class I areas are held to the strictest air pollution standards; Class III areas

allow for the greatest amount of emissions of criteria pollutants. “Federal Class I” areas

are the Class I areas created in the CAA: 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. Class II areas

initially were all those areas that were in attainment or unclassifiable that were not

established as Class I areas. Class II areas can be redesignated as Class I or Class III

areas. 

Clean Air Act (CAA) - the basis of U.S. clean air programs. The original CAA passed in 1970

and was amended in 1977 and 1990. It is comprised of nine sections or Titles that cover,

in order, the National Ambient Air Quality Standards, mobile sources, hazardous air

pollutants, acid-deposition control, stationary source operating permits, stratospheric

ozone and global climate protection, enforcement, miscellaneous provisions, and clean air

research.

continuous emission monitoring systems (CEMS) - the total equipment necessary for

determining the gas or particulate matter concentration or emission rate using pollutant

analyzer measurements and a conversion equation, graph, or computer program to

produce results in units of the applicable emission limitation or standard. CEMS are

required under some of the EPA regulations for either continual compliance

determination or determination of exceedances of the standards.

Code of Federal Regulations (CFR) - a codification of the general and permanent rules published

in the Federal Register by the executive departments and agencies of the federal

government. The CFR is divided into 50 titles which represent broad areas subject to

Federal regulation. Title 40 consists of regulations related to protection of the

environment. The CFR is available online at www.access.gpo.gov/nara/cfr/index.html. 

Clearinghouse for Inventories and Emissions Factors (CHIEF) - an on-line resource

(www.epa.gov/ttn/chief/) with information on emissions factors, emissions inventories,

and emissions estimation software. 

contingency measures - the part of an attainment strategy that provides extra emission reductions

if your basic control strategy fails to achieve reasonable further progress or fails to attain
 Glossary-3

the primary NAAQS on schedule. Contingency measures should accomplish about one

year’s worth of progress toward meeting the NAAQS or an additional 20 to 25% of the

emissions being reduced. 

criteria pollutants - pollutants known to be hazardous to human health for which the 1970

amendments to the Clean Air Act required EPA to set National Ambient Air Quality

Standards (NAAQS). EPA has identified and set standards to protect human health and

welfare for six pollutants: ozone (O3), carbon monoxide (CO), total suspended

particulates (also known as particulate matter or PM), sulfur dioxide (SO2), lead (Pb), and

nitrogen dioxide(NO2). The term, “criteria pollutants,” derives from the requirement that

EPA must describe the characteristics and potential health and welfare effects of these

pollutants. It is on the basis of these criteria that standards are set or revised.

design value - the ratio of current pollutant concentration to the National Ambient Air Quality

Standards (NAAQS). A design value greater than one indicates the area is in violation of

the NAAQS for that pollutant.

eligible tribe - a tribe that has received a determination of eligibility to run CAA programs

(formerly known as “treatment in the same manner as a state”). To become eligible, your

tribe must demonstrate federal recognition, have a governing body carrying out

substantial governmental duties and powers, provide evidence it will perform functions

pertaining to the management and protection of air resources within its jurisdiction, and

demonstrate the capability to implement the programs for which it is seeking approval.

emission - pollution discharged into the atmosphere from smokestack, other vents, and surface

areas of commercial or industrial facilities; from residences; and from motor vehicle,

locomotive, or aircraft exhausts.

emissions factor - a ratio that relates emissions of a pollutant to an activity level at a plant that

can be easily measured, such as the amount of material processed or an amount of fuel

consumed. Given an emissions factor and a known activity level, multiplication yields an

estimate of emissions.

emissions inventory - a listing, by source, of the amount of air pollutants discharged into the

atmosphere of a geographic area.

Emissions Inventory Improvement Program (EIIP) - a jointly sponsored effort of the State and

Territorial Air Pollution Program Administrators/Association of Local Air Pollution

Control Officials and EPA. The goal of EIIP is to provide cost-effective, reliable

inventories by improving the quality of emissions information and developing systems for

collecting, calculating, and reporting emissions data. 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/). 
 Glossary-4

emission standard - the maximum amount of air polluting discharge legally allowed from a single

source, mobile or stationary.

emissions trading - EPA policy that allows a plant complex with several facilities to decrease

pollution from some facilities while increasing it from others, so long as total results are

equal to or better than previous limits. Facilities where this is done are treated as if they

exist in a bubble in which total emissions are averaged out. Complexes that reduce

emissions substantially may “bank” their “credits” or sell them to other industries. 

enforcement - EPA, state, tribal, or local legal actions to obtain compliance with environmental

laws, rules, regulations, or agreements and/or obtain penalties or criminal sanctions for

violations. Enforcement proceedings may vary, depending on the requirements of

different environmental laws and related implementing regulations. 

Federal Implementation Plan (FIP) - under current law, a federally implemented plan to achieve

attainment of air quality standards, used when a state or a tribe is unable to develop an

adequate plan.

federal land manager - with respect to any lands owned by the government of the United States,

the Secretary of the department with authority over such lands. Four agencies administer

the majority of this land: the Forest Service (in the Department of Agriculture), the

Bureau of Land Management, the Fish and Wildlife Service, and the National Park

Service (in the Department of the Interior). Management authority may be delegated to

regional or local officials, such as the Regional Forester or the individual Forest

Supervisor for Forest Service lands.

fugitive emissions - sources of emissions that do not come from an exhaust stack or vent and are

not collected or controlled. Fugitive emissions may escape from buildings or come from

unconfined activities such as outdoor materials storage piles swept by wind and surface

mining activities.

geogenic sources - natural sources that create pollution, such as oil and natural gas seeps which

emit ozone precursors (VOCs and NOX), volanoes which emit PM and SO2, and wind that

blows dust from natural areas, creating PM.

Grand Canyon Visibility Transport Commission (GCVTC)- a regional planning group that

developed a strategy for dealing with visibility impacts in the national parks and

wilderness areas on the Colorado Plateau. The GCVTC was comprised of tribal, state,

and federal representatives. Once the GCVTC made its recommendations, the Western

Regional Air Partnership (WRAP) was formed to implement them. 

Hazardous Air Pollutants (HAPs) - 188 air pollutants that are not covered by ambient air quality

standards, but which, as defined in Title III of the Clean Air Act, may reasonably be

expected to cause or contribute to irreversible illness or death. Such pollutants include
 Glossary-5

asbestos, beryllium, mercury, benzene, coke oven emissions, radionuclides, and vinyl

chloride.

increment - the maximum allowable increase in concentration that is allowed to occur above a

baseline concentration for a pollutant in areas with a PSD program. Class I areas have the

smallest increments and thus allow only a small degree of air quality deterioration. Class

III areas have the largest increments and therefore allow for a larger amount of

development than either Class I or Class II areas.

inventory preparation plan (IPP) - a concise, prescriptive document that states exactly how you

intend to develop and present your inventory. The IPP should include inventory

objectives and general procedures, and should clearly describe how you will present and

document the inventory for submission to EPA and/or others. 

knowing violation - a violation in which the responsible party is aware of an environmental

regulation, yet still takes an action that causes the regulation to be violated.

lead (Pb) - a heavy metal that is hazardous to health if breathed or swallowed. Its use in gasoline,

paints, and plumbing compounds has been sharply restricted or eliminated by federal laws

and regulations. Lead is a criteria pollutant regulated under NAAQS.

Lowest Achievable Emission Rate (LAER) - under the Clean Air Act, the rate of emissions that

reflects (a) the most stringent emission limitation in the implementation plan of any state

for such source unless the owner or operator demonstrates such limitations are not

achievable; or (b) the most stringent emissions limitation achieved in practice, whichever

is more stringent. A proposed new or modified source may not emit pollutants in excess

of existing new source standards. LAER is usually required in nonattainment areas under

the New Source Review program.

major modification - any physical change in or change in the method of operation of a major

stationary source that would result in a significant net emissions increase of any pollutant

subject to regulation under the CAA. See 40 CFR 51.165(a)(1)(v)(A).

major stationary source - a source that emits, or has the potential to emit, 100 tons per year or

more of any pollutant subject to regulation under the CAA. See 40 CFR

51.165(a)(1)(iv)(A). 

minor stationary sources - any stationary source of air pollutants that does not meet the definition

of a major stationary source.

mobile source - any non-stationary source of air pollution such as cars, trucks, motorcycles,

buses, airplanes, and locomotives.
 Glossary-6

minor New Source Review (minor NSR) program - applies in both attainment and

nonattainment areas to smaller new facilities and expanding facilities that are not large

enough to qualify as major new sources or major modifications.

National Ambient Air Quality Standards (NAAQS) - national standards for pollutants considered

harmful to public health and the environment. The Clean Air Act requires EPA to set

NAAQS and established two types of national air quality standards. Primary standards

set limits to protect public health, including the health of "sensitive" populations such as

asthmatics, children, and the elderly. Secondary standards set limits to protect public

welfare, including protection against decreased visibility, damage to animals, crops,

vegetation, and buildings. The EPA Office of Air Quality Planning and Standards

(OAQPS) has set NAAQS for six principal pollutants, which are called "criteria"

pollutants: ozone, carbon monoxide, total suspended particulates (also known as

particulate matter), sulfur dioxide, lead, and nitrogen dioxide. 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) - emissions standards

set by EPA for an air pollutant not covered by the National Ambient Air Quality

Standards (NAAQS) that may cause an increase in fatalities or in serious, irreversible, or

incapacitating illness. 

New Source Performance Standards (NSPS) - uniform national EPA air emission and water

effluent standards which limit the amount of pollution allowed from new sources or from

modified existing sources.

National Emissions Trends (NET) Database - a national database that blends state and locally

supplied data with EPA derived data to form a comprehensive national inventory of

criteria and toxic pollutants. The NET inventory does not necessarily include state data

for any particular source or pollutant. However, in the 1996 NET inventory, EPA intends

to provide statewide emissions inventory data on a county level basis to every state in the

county. The NET is accessible at www.epa.gov/ttn/chief/net/index.

new source - any stationary source built or modified after publication of final or proposed

regulations that prescribe a given standard of performance.

New Source Review (NSR) preconstruction permitting program - requires all new major sources

or existing sources with major modifications in both nonattainment areas and attainment

areas to obtain preconstruction permits. The nonattainment NSR and the Prevention of

Significant Deterioration (PSD) programs, collectively known as major NSR, are federal

regulations under the CAA. The programs focus primarily on the criteria pollutants

regulated by the NAAQS. See also “minor New Source Review,” “nonattainment New

Source Review,” and “Prevention of Significant Deterioration.”

nitrogen dioxide (NO2) - the result of nitric acid combining with oxygen in the atmosphere;

major component of photochemical smog; a criteria pollutant regulated under NAAQS.
 Glossary-7

nonattainment area - an area that does not meet one or more of the National Ambient Air Quality

Standards for the criteria pollutants designated in the Clean Air Act.

noncriteria pollutant - an air pollutant other than one of the six criteria pollutants [ozone (O3),

carbon monoxide (CO), particulate matter (PM), sulfur dioxide (SO2), lead (Pb), and

nitrogen dioxide(NO2)]. 

nitrogen oxide (NOX) - a product of combustion from transportation and stationary sources and a

major contributor to the formation of ozone in the troposphere and to acid deposition.

nonattainment New Source Review (nonattainment NSR) preconstruction permitting program -

in areas where air quality is worse than the NAAQS, this program prevents increases in

emissions from major new sources and major modifications of existing sources and thus

ensures progress toward meeting the standards. To obtain a permit under NSR, a facility

must install control equipment ensuring the Lowest Achievable Emission Rate (LAER)

and obtain emission “offsets” or reductions from other sources equal to the increased

pollutant emissions.

offsets - emissions reductions obtained from existing source(s) by a prospective major new

stationary source, or a source planning major modifications, in order to offset the increase

in pollutant emissions caused by the new or modified source (thereby creating no net

increase in emissions). Offsets are generally secured from other sources in the vicinity of

the new source or modification. However, in the case of modifications, offsets can also

be obtained, with limitations, from the source itself.

opacity - the amount of light obscured by particulate pollution in the air; clear window glass has

zero opacity, a brink wall is 100 percent opaque. Opacity is an indicator of changes is

performance of particulate control systems.

ozone (O3) - found in two layers of the atmosphere, the stratosphere and the troposphere. In the

stratosphere (the atmospheric layer 7 to 10 miles or more above the earth’s surface),

ozone is a natural form of oxygen that provides a protective layer shielding the earth from

ultraviolet radiation. In the troposphere (the layer extending up 7 to 10 miles from the

earth’s surface), ozone is major component of smog. It can seriously impair the

respiratory system and is one of the most widespread of all the criteria pollutants for

which the Clean Air Act required EPA to set standards. Ozone in the troposphere is

produced through complex chemical reactions of nitrogen oxides, which are among the

primary pollutants emitted by combustion sources; hydrocarbons, released into the

atmosphere through the combustion and processing of petroleum products; and sunlight.

particulates - fine liquid or dust particles such as dust, smoke, mist, fumes, or smog, found in air

or emissions; particulate matter is a criteria pollutant regulated under NAAQS.
 Glossary-8

permit - an authorization, license, or equivalent control document issued by EPA or an approved

state or tribal agency to implement the requirements of an environmental regulation; e.g.,

a permit to operate a wastewater treatment plant or to operate a facility that may generate

emissions.

particulate matter (PM) - (1) PM10 - a standard for measuring the amount of solid or liquid

matter suspending in the atmosphere, i.e., the amount of particulate matter over 10

micrometers (Fm ) in diameter; smaller PM10 particles penetrate to the deeper portions of

the lung, affecting sensitive populations groups such as children and individuals with

respiratory ailments. (2) PM 2.5 - particulate matter greater than or equal to 2.5 Fm in

diameter. PM is a criteria pollutant regulated under NAAQS.

point source - a stationary location or fixed facility from which pollutants are discharged; any

single identifiable source of pollution, e.g., a pipe, ditch, ship, ore pit, factory

smokestack.

potential to emit - emission estimates for a source based on the maximum capacity of that

source, taking into consideration enforceable permit conditions, such as the type of

materials combusted, the type of materials processed, and the annual hours of operation.

precursor - a substance from which another substance is formed; ozone precursors, such as NO2

and VOC, react in sunlight to form ozone.

Prevention of Significant Deterioration preconstruction permitting program (PSD) - an EPA

program in which state, tribal, and/or federal permits are required in order to restrict

emissions from new or modified sources in places where air quality already meets or

exceeds primary and secondary ambient air quality standards.

public comment period - the time allowed for the public to express its views and concerns

regarding an action by the EPA or other regulating authority (e.g,. a Federal Register

notice of proposed rule-making or a public notice of a draft permit).

quality assurance/quality control (QA/QC) - a system of procedures, checks, audits, and

corrective actions to ensure that all EPA research design and performance, environmental

monitoring and sampling, and other technical and reporting activities are of the highest

achievable quality.

reasonably available control measures (RACM) - a broadly defined term referring to

technological and other measures for pollution control.

reasonably available control technology (RACT) - control technology that is both reasonably

available, and both technologically and economically feasible. RACT is usually applied

to existing sources in nonattainment areas; in most cases it is less stringent than new

source performance standards.
 Glossary-9

reasonably severable - means that the TIP elements selected for the TIP must be able to stand

alone and meet applicable CAA and regulatory requirements

source - any activity that causes pollutants to be emitted into the air. A stationary source is a

fixed-site producer of pollution, such as power plants, industrial facilities, and gas

stations. A mobile source is any non-stationary source of air pollution such as cars,

trucks, motorcycles, buses, airplanes, and locomotives. A major source is one that emits,

or has the potential to emit, pollutants over a major source threshold. 

A minor source is any source which emits less pollutants than the major source threshold.

State Implementation Plan (SIP) - EPA approved state plans for the establishment, regulation,

and enforcement of air pollution standards. A detailed description of the programs a state

will use to carry out its responsibilities under the Clean Air Act. Collections of

regulations used by the state to reduce air pollution.

sulfur dioxide (SO2) - a pungent, colorless, gaseous pollutant formed primarily by the combustion

of fossil fuels.

stationary source - a fixed-site producer of pollution, such as power plants, industrial facilities,

and gas stations. 

synthetic minor - a source with major source potential to emit that agrees to enforceable emission

limits below the major source threshold. Synthetic minor provisions can be included in

minor New Source Review programs.

tribal air program - a program that incorporates technical, administrative, and outreach elements

to address air quality concerns on a reservation or other area under a tribe’s jurisdiction. 

Technical elements in a tribal air program may include identifying emission sources,

establishing and maintaining an emissions inventory, collecting meteorological data,

monitoring air quality, rule-making, and enforcing rules.

Tribal Authority Rule (TAR) - The TAR identifies eligibility criteria for tribes seeking to

implement CAA programs and defines the process for EPA approval of tribal CAA

programs. The TAR was issued on February 12, 1998 (63 Federal Register 7254) and the

regulatory provisions codified at 40 CFR Section 49. 

Tribal Implementation Plan (TIP) - a practical and enforceable plan, the primary purpose of

which is to ensure that the National Ambient Air Quality Standards (NAAQS) are not

violated. Tribes may choose to develop TIPs, whereas states are required to develop state

implementation plans (SIPs). The EPA may develop and implement a federal

implementation plan (FIP), where necessary or appropriate, for areas of Indian Country

where the tribe is unable to or chooses not to develop an implementation plan that meets

EPA approval.
 Glossary-10

volatile organic compounds (VOCs) - any organic compound that participates in atmospheric

photochemical reactions, except those designated by EPA as having negligible

photochemical activity. Atmospheric photochemical reactions can transform VOCs into

ozone.

Western Regional Air Partnership (WRAP) - the organization created to implement the Grand

Canyon Visibility Transport Commission’s (GCVTC) recommendations for dealing with

visibility impacts in the national parks and wilderness areas on the Colorado Plateau. 

The WRAP’s goal is to “promote and monitor the implementation of the

recommendations from the GCVTC and, with the concurrence of its members, engage in

other common regional air quality issues.” The members of WRAP include governors

from western states, western tribal leaders, and representatives of the Departments of

Agriculture and Interior, and EPA.