This document was prepared as part of the Federal Advisory Committee Act (FACA) Subcommittee process. It is not an EPA document. It is subject to further work group discussion. Interested people should forward their comments to a member of the Base Programs Analyses and Policies Work Group or to the contact person shown below.

Working Draft Paper - Do Not Quote Or Cite

Base Programs Analyses and Policies (BPAP) Work Group

Incentives For Ambient Air Quality Monitoring Under New NAAQS Issue Paper

Date: September 3, 1996

Contact Person:	R. Dworek

Phone: 412-433-5910 / Fax: 412-433-5920

(no electronic address)

Executive Summary

The work groups have expressed a desire to eliminate the disincentives to monitoring and increase the availability of monitoring data. The options outlined in this paper provide a wide spectrum of approaches to accomplish these goals. The work groups believe that the most appropriate way to proceed is to obtain FACA Subcommittee input on a preferred approach or approaches. Based on this feedback, the work groups can factor this into their subsequent design of the implementation program for the potential new national ambient air quality standards (NAAQS). The purpose of this paper is to present incentives and options to the FACA Subcommittee for their consideration and feedback.

Background

There is a general reluctance among State and local governments and businesses to monitor ambient air quality beyond those minimum requirements contained in regulations promulgated by the Environmental Protection Agency (EPA) in the Code of Federal Regulations at Part 58. The reluctance is based in part on the fact that areas are designated to nonattainment where monitoring shows violations of the NAAQS and classified according to the seriousness of the air pollution problem. Currently, such a nonattainment designation and classification automatically triggers the state implementation attainment planning and demonstration requirements, potential stationary and mobile source emission controls, nonattainment new source review for sources wanting to locate or expand in the new nonattainment area, and possibly additional requirements relating to nonattainment of the NAAQS. Thus, the current regulatory system results in a disincentive for detecting violations.

No Federal reference method currently exists for monitoring fine particulate matter although one is planned by the EPA at the time new NAAQS for fine particulate matter (PM) are established.

An earlier paper on designation issues coordinated by the Base Programs Analyses and Policies Work Group with other technical work groups in this process describes these problems. The paper and its recommendations were presented to the FACA Subcommittee on July 30, 1996.

Briefly, the designations paper recommends decoupling areas violating a NAAQS from the current nonattainment designation process and developing a new process consisting of areas of violations (AOV) and areas of influence (AOI). The paper recommends that AOVs and AOIs be determined by an appropriate balance of monitoring and modeling. Further, the paper states that naming areas of violation or influence would not automatically trigger the nonattainment designation and classification actions but would trigger a process to define the boundaries of the areas and a planning process to develop attainment demonstrations and SIPs.

The paper suggests that the current ozone network is inadequate to determine AOVs and AOIs and contemplates expanding the number of monitor sites. The paper encourages EPA to not make the same mistakes on the upcoming fine PM network as exist with the current ozone network. Determination of AOVs and AOIs would be based primarily on an appropriate balance of monitoring and modeling and supplemented by other data. States would be required to prepare a monitoring State implementation plan (SIP).

There are important implications of an expanded national ambient monitoring network and a comprehensive strategy as envisioned by the designations paper. If the designations' recommendations are adopted by EPA, the implication is that ambient air monitoring will play an important and expanded role in defining areas of violation and influence in conjunction with modeling. Further, States and businesses would have an incentive to monitor for data to more accurately determine the extent of the AOVs and AOIs.

Further, a comprehensive monitoring strategy collecting data beyond that currently collected via EPA's minimum required number of sites would support health-effects assessments to set the NAAQS, modeling studies to better define pollution problems, identification of potential pollution problems for enhanced air management programs, the design and implementation of episodic control plans to encourage quick response actions for voluntary emission reduction measures to lower pollution and thereby possibly avoiding nonattainment or 'bump-ups', and to measure progress toward attainment by relating air quality to population.

This paper was initially prepared on May 31, 1996, and subsequently discussed in detail by the Base Program Analyses and Policies Group on July 1 and 2, 1996, at Research Triangle Park, North Carolina. Representatives from the National and Regional Strategies Group and the Science and Technical Support Group also attended. Incentives and disincentives were thoroughly reviewed. At the conclusion of the discussion, the following incentives and options were summarized by the Chairs of the Base Program Analyses and Policies Group as avenues to pursue to overcome the disincentives to ambient air quality monitoring.

Incentives and Options

Incentives

1.	Decouple the link from nonattainment designations to emission reduction controls.

2.	Establish a category of special purpose research monitors scientifically cited to collect research data and decouple the results from these data from the designation process.

3.	Provide financial incentives to States and the private sector such as from lowering new source offset requirements and permit fees in return for monitoring, and using a portion of Title V permit and noncompliance enforcement fees for monitoring.

4.	Secure financial backing from health-based organizations for States to use on monitoring.

5.	Utilize State and private sector monitoring to rebut expanded nonattainment, AOV, and AOI designations based on modeled results.

6.	Establish a system where monitored violations do not immediately lead to designations. Replace it with broader use of alternative approaches. Current examples of alternative approaches are the Tulsa Flexible Attainment Region and the Coeur d' Alene Memorandum Of Agreement (MOA). Involve the community in designing a resolution to the problem. Designate only where States fail to follow through.

7.	Allow lead time for States or sources/groups to design and implement a monitoring program based on an early up-front commitment and implementation. This incentive could be restricted to large areas with broad pollution problems because small areas with localized problems are less likely to benefit from such an approach.

8.	Establish clear consistent Federal regulations and guidance on an adequate expanded number of monitor sites based on --

- population

- area size

- distance between monitors within areas, and

- other relevant factors.

Allow no monitoring exceptions for States with no data or a reluctance to monitor.

9.	Specifically ensure adequate expanded monitor coverage in all actual or potential 'nonattainment' areas.

The following options pertain to private sector monitoring.

10.	Encourage private sector monitoring to supplement but not supplant State monitoring sites.

11.	Use private sector monitoring to provide data to --

- decrease the extent of areas of violation and influence

- initiate episodic control actions during adverse meteorological conditions, and

- expedite the new source review process for receiving permits to expand or locate.

12.	Offer financial incentives for private sector monitoring in the new source review process by diverting a portion of permit fees and/or the purchase price of offset credits to monitoring.

13.	Provide public recognition.

14.	Initiate a national voluntary partnership program for specific selected sources in lieu of 'command and control' requirements, covering the full range of private sector involvement in the development and implementation of integrated strategies designed to attain NAAQSs. Cover monitoring networks as well as inventories, numerical dispersion models, and emission reduction controls. Such a voluntary program would strive to yield cost-effective co-benefits across various pollutants. Include 'bubbling' emission sources over areas of violation and areas of influence. Current examples are EPA's XL Environmental Leadership Program and/or the 33/50 Program.

Private sector companies who decide not to participate in the voluntary program would be subject to 'command-and-control' provisions similar to the current system.

Sources participating in voluntary programs must provide sufficient reporting, commitment, and accountability for implementing voluntary goals in an expeditious time frame.

15.	Combine incentives for private sector monitoring with a national voluntary partnership program of integrated implementation.

Options

1.	Establish new national monitoring guidelines for ozone, fine particulate matter, and regional haze. The monitoring guidelines should consider the following strategies.

- Characterization of the extent of regional scale transport for ozone, fine PM, and regional haze; and the specific AOIs and AOVs via ambient monitoring.

- Integrated and nationally consistent monitoring strategies for ozone and PM, with Federal reference monitors co-located spatially or geographically throughout the nation.

- Location as expeditiously as possible one ozone and one fine particle monitor within every 5,000 square-mile grid (grid monitors) unless exceptions are requested by the local community and approved by the Governor or his/her designee, e.g., a sparsely populated area in the west.

Optional location of additional ozone and fine particulate monitor in grids having more than one million population.

Location of additional monitors from the private sector for 'special or research' purposes.

Minimization of monitoring costs for the grid sampling program, whenever possible and practical, by relocating existing monitors within the state.

- Decoupling the newly located 'grid' monitors, as well as the 'special or research' monitors from the designation process and associated controls for the first five years. After five years, and periodic intervals thereafter, mid-course corrections may occur at the request of the Governor, at which time the grid monitors and 'special or research' monitored data may then be used for designation and additional monitors are added.

- Restriction of monitors to the Federal reference method and strict quality control guidelines. For example, do not allow ozone and fine particle monitors powered via a gasoline or propane generators that operate under procedures that exacerbate the passive buildup of fine particles on sampling filters.

- Finally, providing incentives for States that meet all monitoring (and attainment) requirements such as easier nonattainment and PSD new source permitting, classification revision, or reduced Title V permitting fees for those sources in the grid area.

2.	Deferring designation or 'bump-up' to a higher classification if such exist under new NAAQS where monitored concentrations are close to the NAAQS having only a intermittent, hourly, or 24-hour (not annual) violations primarily associated with adverse meteorological conditions. Allow more time for the State(s) to design a voluntary partnership program or episodic control program similar to the Tulsa Flexible Attainment Region, the Coeur d' Alene MOA and Klamath Falls approach, or the U.S. Steel Clairton Works PM10 Action Plan.

3.	Whenever possible, location of monitors at areas of highest population densities within the grid and near inhabited buildings. An option is to not use monitored data that is not collected near inhabited buildings for official monitors when evaluating attainment and nonattainment.

4.	Requiring Federally referenced continuous and instantaneous-reading monitors for 24-hour PM sampling to avoid subsequent delays for weighing in order to quantify levels of pollutants.

5.	Installation and averaging of data from multiple samplers at the same site to encourage accuracy.

6.	Utilization of fees from the Title V permit program. Raising revenues for additional monitoring from other permit fees, health-based organization with an interest in preventing disease, reduced new-source offset ratios, and supplemental environmental programs (SEPs).

7.	Utilization of private sector and other additional special-purpose monitoring meeting guidelines mentioned above to help define, reduce, or rebut model information sizing AOVs and AOIs.