STSWG SUMMARY (prepared October 7,1996)

of the

Base Programs Analysis and Policies (BPAP) Work Group Issue Paper

"Incentives For Ambient Air Quality Monitoring Under New NAAQS"

September 19, 1996 Version

In order to more adequately evaluate air quality through the United States and to support new and perhaps differing concepts of area classifications with respect to the National Ambient Air Quality standards, BPAP has correctly identified a need to increase the availability of monitoring data. They have also correctly identified a powerful disincentive for state and local governments and businesses to undertake the establishment of monitoring sites to collect such data, to whit: should even a single monitor in a network of multiple monitors detect exceedances which lead to violations of the NAAQS, onerous requirements are brought to bear on the area in the form of state implementation plan (SIP) calls which can lead to stationary and mobile source emission controls, non-attainment new source reviews, and off-set requirements for new industries wanting to locate in the area. Additionally, the image of an area suffers by earning a place on a list of "Areas that do not meet an Ambient Air Quality Standard" In sum, absent an overwhelming desire to develop a really credible monitoring program to help protect the health of its citizens, an agency has no incentive to go beyond the bare minimum of what is required by the United States Environmental Protection Agency (EPA) in the Code of Federal Regulations (40 CFR 58).

In examining incentives for establishing an expanded air monitoring network reference was made to the "designations" paper developed by BPAP and presented to the FACA subcommittee on July 30, 1996. This paper proposed a radically new approach to the designation process that used the terms "areas of violation" (AOV) and "areas of influence" (AOI) which would be determined by some balance of monitoring and modeling. Most important, a monitored exceedance or violation of a standard would not in itself automatically trigger the requirements currently specified. The paper correctly indicated that for this approach to work a comprehensive monitoring strategy must be developed and implemented to provide the scientific basis for the multiple activities that would be required under the designations proposal and for the expanded uses suggested for the monitoring data. This "decoupling" of designations from monitored data will remove the single greatest disincentive to ambient monitoring.

The September 19, 1996 revision to the "Incentives" paper expanded the scope beyond the original charge to identify incentives for ambient monitoring. The paper as now configured is intended to suggest a mechanism for the development of a national monitoring network to support the proposed ozone and PM fine (including regional haze) air quality standards as well as suggesting incentives for additional monitoring.

BPAP Recommendations

After identifying the need to develop a scientifically sound monitoring program and the need to overcome the overwhelming disincentive for monitoring that currently exists, i.e.,

the fear of detecting an exceedance of an NAAQS, the Chairs of BPAP developed a list of incentives and options to be pursued which might lead to the development of an air monitoring network adequate to provide essential data without the punitive aspects which now exist. Some ten (10) items were listed as "Incentives," an additional eight (8) items were listed as "Options," and an "Executive Summary Recommendations (Attachment 1)" was prepared. The latter suggests the formation of a national task force to development policy and technical guidelines for air quality monitoring to be used in the development of implementation programs to attain the National Ambient Air Quality Standards (NAAQS). Four key issues are proposed for consideration, including expansion (as needed) of the current monitoring network; provision for private sector incentives for monitoring; elimination of disincentives for monitoring; and finally, evaluation of the previously mentioned options and incentives.

STSWG Perspective

The need to develop an air monitoring network that is adequately configured to permit evaluation of ambient air quality from a scientific basis is an essential element in any proposed revision of the National Ambient Air Quality Standards. The ten incentives proposed by BPAP for the agencies to use as avenues to overcome the disincentives to the establishment of such a network are largely policy in nature, although some do have scientific implications. These include, in order of presentation, the decoupling of monitored violations from immediate redesignations and emission reduction control requirements; lead time to design monitoring programs; the provision for special-purpose research monitors which would not be used for regulatory purposes; provisions for financial incentives; utilization of monitoring to rebut modeling results; permitting the use of weather-adjusted, population-weighted monitoring data to demonstrate "rate of progress" ( ROP ), allowing for an averaging scheme for area monitors instead of using a single monitor; attempting to link individual sources to specific monitors; and, finally, allowing less conservative modeling for areas with a fully developed monitoring network.

From a scientific standpoint, any policy decision that results in additional appropriate monitoring could be supported by STSWG. These would include decoupling the links from monitored violations to nonattainment designations to emission reduction controls and the establishment of special purpose research monitors. Averaging or population-weighting is also a matter of policy. Incentive 6 which proposes using monitoring to refute modeling would have to be examined very closely to ensure each individual proposal was scientifically defensible. The proposal itself is overly broad to receive blanket scientific approval. Incentive 9, which addresses linking individual sources to specific monitors and subsequent controls of those sources, would seem to have narrow applicability from a scientific standpoint. Should an agency wish to pursue this concept, it may well be currently implementable with no additional action needed from a national standpoint. With regard to any use of private sector monitoring, such use must be caveated by a comprehensive quality assurance program approved by the appropriate regulatory agency.

Financial incentives are strictly policy issues that should probably best be left to individual regulatory agencies and not be made a part of the FACA process. There are too many variables among the states with regard to whether or not permit fees are charged, how the individual State Implementation Plans defined the Title V program, and restrictions on use of enforcement penalties and taxes to attempt to specify the appropriate funding mechanism for the monitoring program as part of FACA.

With regard to the eight (8) proposed options presented in the September 19 paper, several do have a scientific component. It is certainly appropriate to establish new national monitoring guidelines for ozone, fine particulate matter, and regional haze, as proposed by Option 1. Some of the suggested strategies under this option, however, are questionable from a scientific standpoint.. The concept of a grid-based monitoring network ignores the information gained from a long history of monitoring and lacks a scientific basis. Monitoring network design exceptions should not be at the behest of a "local community" but only allowed as part of an overall plan-- which does not fall under the grid scheme. Under the "designations" paper concept, all monitors would be decoupled from the designation process, not just the grid monitors. It would seem much more scientifically beneficial to design a monitoring network based on a careful evaluation of population and source locations, with periodic review for adjustments, than to simply grid the country with monitors. Finally, incentives that relate to agency fees should not be under the purview of FACA.

Option 2 speaks to deferred designations and is a policy matter. However, designating a control program or assessing exposure risk based on extreme meteorologically driven values is not scientifically defensible.

Option 3 again references a grid concept in which monitors are placed at area of highest population density and "near inhabited buildings". A network would certainly have population based monitors, as is done now, but should also include regional scale or rural monitors to measure the impacts of transport and baseline trends. The requirement for inhabited buildings does not seem versed in science. However the issue of personal exposure versus ambient air could be addresse d in the design of a monitoring program.

Option 4 requires continuous and instantaneous-reading monitors for PM sampling. While this may be important as part of a strategy to proactively reduce PM to avoid an exceedance situation or to provide additional data for planning purposes, the delay in weighing samples does not present a significant scientific problem. In addition, filters are necessary for chemical analysis to determine sources of PM, especially given the increased need for speciation in a fine particulate or regional haze network.

Option 5 suggesting that the installation of multiple monitors at a single site would improve accuracy is invalid. Precision would be defined by multiple monitors (see 40 CFR 58, Appendix A)

Option 6 dealing with financial incentives, including the use of Title V fees, is a policy matter best left to the regulatory authority. This was also discussed in the "Incentives" section above.

Option 7 discusses the use of private sector and special-purpose monitoring to help define, reduce or rebut model information. As was previously mentioned, any such use from a scientific standpoint demands an approved quality assurance plan comparable to that required by 40 CFR 58, as well as careful examination of the monitoring network to determine whether such use is appropriate.

Option 8 in this version of the issues paper now contains the discussion of the possible uses of and incentives for private sector monitoring. To a large extent these are again policy matters. However, to the extent such monitoring is conducted in cooperation with the appropriate regulatory agency and in conformance with an approved quality assurance monitoring plan, such monitoring could provide needed scientific information to supplement other monitoring efforts.

In conclusion, the decoupling of monitoring results from the automatic designation process makes scientific sense. Until the data are analyzed and accurate and comprehensive modeling performed, it is impossible to determine the AOV and AOI. Even after appropriate monitoring and modeling, a phased control strategy, in conjunction with on-going monitoring and modeling, should be required to allow for mid-course corrections due to scientific uncertainties. What will be required is the design and adoption of a process that integrates modeling, data analysis, and especially ambient and source monitoring that will result in real improvement in air quality. Such a process is described in an EPA funded report entitled "A New Approach for Demonstrating Attainment of the Ambient Ozone Standard," authored by Demerjain and Roth (1995).

Once the decoupling has taken place there will be a need for monitoring data to determine the AOV and AOI. Monitoring data will provide a scientific basis for the AOV and AOI boundaries rather than conservative modeling results, thus providing a great incentive for additional monitoring. In addition, to avoid designing a program based on extreme values (i.e. 100 year flood) appropriate consideration should be given to adjusting monitored data for meteorological influences (S. T. Rao , 1995) and for exposure risk.

The Executive Summary Recommendation (Attachment 1) provides an appropriate mechanism and next step to seek implementation, as appropriate, of the incentives and options presented in the paper and should be supported by the STSWG. The establishment of a national task force to develop policy and technical guidelines for air quality monitoring can provide a platform for an in-depth review of the rationale for network design, i.e., health-based, local vs transport, etc., as well as an evaluation of the need to expand the parameters to be monitored, e.g., additional meteorological monitoring, aloft measurements, and speciation .