====WORKING DRAFT PAPER -- DO NOT QUOTE OR CITE====

Base Program Analyses and Policies (BPAP) Work Group

Incentives for Ambient Air Quality Monitoring Under New NAAQS

Date:	October 18, 1996

Contact Person:	R. Dworek

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

(no electronic address)

Executive Summary

Work group members have expressed a desire to increase the amount and availability of monitoring data. Two broad based options were discussed to accomplish this objective; one, which was generally supported by the industrial and Governmental sector, includes incentives for monitoring, and the other, which was supported by the environmental sector includes no incentives for additional monitoring. The options and incentives outlined in this paper provide a wide spectrum of approaches to accomplish an improved national monitoring network. The work group believes that the most appropriate way to proceed is to obtain FACA Subcommittee input to recommendations (see Attachment 1). Based on this feedback, a work group can factor this into a subsequent design of the implementation program for the potential new national ambient air quality standards (NAAQS).

Introduction

At the present time, the monitors making up the national monitoring network for ozone and PM10 are usually located in major urban centers: few ozone monitors are located in rural areas, even though ozone levels in some of these areas may exceed human health-based standards and may cause damage to vegetation. In addition, the monitoring networks were not designed with the systematic study of pollutant or precursor transport in mind. For these reasons, it is desirable to add additional monitors to the national sampling program.

The existing network consists primarily of National Air Monitoring Stations (NAMS), a network established to provide a systematic, consistent database of air quality in the largest cities, and State and Local Air Monitoring Systems (SLAMS), a network created to serve state and local air quality managers in their immediate regulatory and enforcement needs. (Special Purpose Monitoring Stations (SPMS) are occasionally used by state and local authorities to address incidental and short-term monitoring needs.) The NAMS and SLAMS networks have historically placed monitors in locations where the highest concentrations in the area are expected to occur, while sometimes neglecting population centers.

Due to regulatory interpretations based on the form of the standard, the number and placement of monitors within an MSA has the potential to dramatically affect the attainment status and designation of an area. Indeed, in some areas, the strongest disincentive to the placement of additional monitors is the fact that an area's attainment status and design value are completely determined by readings from individual monitors. The presence or absence of a single monitor, or the location of a single monitor, can be the difference between attainment and nonattainment designations, and with different regulatory consequences. There are currently no official measurements of air quality based on aggregation of monitors, so each individual monitor has the potential to classify an area as "attainment" or "nonattainment."

There are as yet no federally referenced monitors designed to measure particulate matter (PM) fine concentrations. Questions arise about developing a PM fine monitoring network to measure concentrations and/or to distinguish among pollutant species and aid in controlling emissions from specific sources. The best solution probably involves placing a combination of both types of monitors. The appropriate mix and location of these monitors, and the equitable distribution of the costs of placing them, has not yet been determined. Furthermore, given the interest in developing an integrated regulatory strategy for ozone and PM fine, some thought will need to be given to coordination of the PM fine and ozone monitoring networks.

This paper is intended to assist in developing a national monitoring net-work adequate to support the proposed ozone and PM fine (including regional haze) air quality standards and to consider incentives for additional monitoring.

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 are established.

An earlier paper on designation issues coordinated by the Base Program 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 violation (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 demon-strations 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 of "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. As per the charge to the Work Group, 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.

I.	Incentive Options

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.

Decouple the link from nonattainment designations to emission reduction controls. This incentive is compatible with the proposed designation strategy based on AOVs and AOIs. This could remove the single greatest disincentive to placing additional monitors, namely the potential to induce mandatory regulatory action on the basis of a single monitored exceedance.

Allow lead time for States or sources/groups to design and implement a monitoring program based on an early up-front commitment and implementation.

4.	Establish a category of special-purpose research monitors scientific-ally sited to collect research data and decouple the results from these data from the designation process. These monitors could supplement existing required monitors and are not to be used for mandated regulatory purposes.

5.	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.

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

7.	Secure financial backing from health-based organizations (HMOs), environmental organizations, foundations, and industry for States to use on monitoring.

8.	Average or population-weight monitored data for the purpose of measuring progress (ROP):

A future official indicator of progress might be based on a formula that would allow weather-adjusted, population-weighted monitor data (as well as peak monitor readings) to be considered. Such a formula might stipulate that one aspect of demonstrating progress towards air quality goals (ROP) is to show a declining weather-adjusted population-exposure.

The most significant benefit to population-weighting of monitors is that it would provide an incentive to an area to place additional monitors in areas where people are. Particularly in the absence of a new designation scheme such as AOV/AOI, population-weighting of monitors should be included as a measure of progress in meeting air quality goals.

There would likely be more support for contributing to the financing of a new network if violations were based on averages of all monitors (once all monitors required for the new network are installed) rather than on several of the highest-reading monitors.

9.	When it is possible to link individual sources to specific monitors, the specificity of the control requirements for those sources could be lessened, and performance as measured at those monitors could be used to gauge progress. This could apply to all sources including personal automobile drivers, who could contribute to the cost of placing monitors in the form of an additional gas or registration tax (fee) based on tailpipe emissions VMT (for example).

10.	Allow the use of less conservative modeling assumptions once an area has installed all the monitors required for the new network.

In addition to the above ten Incentive Options, the Work Group members with respect to overall monitoring issues suggest:

A.	Developing a monitoring program which should consider the following:

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

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

Locate as expeditiously as possible one ozone and one fine particle monitor, for example, 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.

Decouple 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.

Restrict monitors to the Federal reference method and require 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, make adjustments for forest fire contributions, do not locate monitors near bus stops, etc., in accordance with strict monitor siting criteria.

Provide 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.

B.	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 an 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.

C.	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 as official monitors when evaluating attainment and nonattainment.

D.	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.

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

F.	Utilization of fees from the Title V permit program. It is recognized that shortfalls for funding other activities would need to be dealt with, but it is also recognized that basic monitoring is a building block for future control strategies and control programs. Raise revenues for additional monitoring from other permit fees, health-based organiza-tion with an interest in preventing disease, reduced new-source offset ratios, and supplemental environmental programs (SEPs), and contri-butions from foundations, industry, and environmental groups.

G.	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.

H.	The following options pertain to private sector monitoring.

(a)	Encourage private sector monitoring to supplement, but not supplant State monitoring sites.

(b)	Use private sector monitoring to provide data to:

--	decrease the extent of areas of violation.

--	initiate episodic control actions during adverse meteoro-	logical conditions.

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

(c)	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.

(d)	Provide public recognition.

(e)	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.

(f)	Private sector companies who decide not to participate in the voluntary program may be subject to "command-and-control" provisions similar to the current system.

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

(h)	Combine incentives for private section monitoring with a national voluntary partnership program of integrated implementation.

Incentive Option Recommendation

Summary

It is recommended that a national task force, consisting of representatives of the FACA Work Group members and other interested organizations, be appointed and charged with the responsibility to develop policy and technical guidelines for air quality monitoring which will be used for development of implementation programs to attain the National Ambient Air Quality Standards (NAAQS). The following key monitoring issues shall be considered:

Expansion (as needed) of current national monitoring network:

To protect public health.

To learn about pollutant transport, composition, or chemistry of pollutants and source receptor relationship.

To better define Areas of Violation (AOV) and Areas of Influence (AOI).

To integrate monitoring with, overall implementation program, such as for determining AOVs/AOIs for developing revised attainment dates, for developing new source review provisions, for developing cost-effective control strategies.

Provide incentives for the private sector to support and supplement the basic regulatory monitoring program, to reduce monitoring costs for government agencies, and to promote voluntary pro-active programs.

Eliminate disincentives for monitoring, such as the requirements for mandatory, non-discretionary control programs in response to monitoring violations.

II.	"No Incentives for Monitoring" Option

It is agreed that additional monitoring in some areas would be useful. It is strongly disagreed, however, with proposals that appear throughout the issue paper to relax planning and control requirements as "incentives" to encourage more monitoring. Such an approach defeats the very purpose of monitoring -- namely, to promote better public health protection.

It is also strongly disagreed with the proposal to establish a system where monitored violations do not immediately lead to designations. This is nothing more than a prescription for interminable delay. Equally objectionable are proposals to: decouple the link from nonattainment designations to emission reduction controls; lower offset requirements and permit fees in return for monitoring; ease nonattainment designations to emission reduction controls; lower offset requirements and permit fees in return for monitoring; ease nonattainment and PSD new source permitting requirements for states that meet all monitoring requirements; defer bump ups where monitored concentrations are "close to" the NAAQS; and population-weight monitored data for the purpose of measuring progress (a proposal that has repeatedly been rejected by subcommittee members). These and other proposals in the issue paper would severely undermine certainty and enforceability in air quality control, all in the name of encouraging more monitoring.

The way to obtain more monitoring by the states and the regulated community is to mandate it. Monitoring is not merely a desirable practice -- it is an essential component of a viable air quality control program. The problem to date has been the lack of clear federal mandates for minimum numbers of monitors in various air quality control regions.

"No Incentive" Option Recommendation

The following recommendations for "No Incentives for Monitoring" are made in lieu of providing incentives for monitoring:

1. EPA should adopt national guidelines specifying the minimum number of monitors required for each NAAQS pollutant (including precursors thereof) in each MSA, SMSA, or similar area of reference. The guidelines should also specify requirements for additional monitors in areas of influence, and in potential hot-spot locations. In addition, the guidelines should set criteria for the spacial siting of monitors (supplementing or amending EPA's existing spacial siting criteria). The goal of all these guidelines should be to create a high probability that all NAAQS exceedances will be detected, that ambient levels of the pollutants of concern are accurately characterized, and (where relevant) that sufficient data exists to support reasonable projections of pollutant transport.

2. Each state should be required to submit a "monitoring SIP" that provides for establishment and operation of a monitoring network meeting the EPA guidelines. Failure to submit such a SIP, or EPA disapproval thereof, would trigger the relevant sanctions under the Act for planning failures. In addition, such failure would result in the affected areas being automatically designated nonattainment for the relevant pollutants.

Attachment I

Executive Summary Recommendation

The assignment to the Work Group was to evaluate "How can we create incentives for monitoring?" and "How can we create incentives for private-sector / regulator monitoring partnerships?"

As a result of Work Group discussions, two options were discussed:

Option 1. Promote incentives for monitoring and improve the current monitoring network by appointment of a national task force, consisting of representatives of the FACA Work Group members and other interested organizations, who would be charged with the responsibility to develop policy and technical guidelines for air quality monitoring which will be used for development of implementation programs to attain the National Ambient Air Quality Standards (NAAQS). The following key monitoring issues should be considered:

1.	Expansion (as needed) of current national monitoring network:

(a)	To protect public health.

(b)	To learn about pollutant transport, composition, or chemistry of	pollutants and source receptor relationship.

(c)	To better define Areas of Violation (AOV) and Areas of Influence	(AOI).

(d)	To integrate monitoring with, overall implementation program, such as for determining AOVs/AOIs for developing revised attainment dates, for developing new source review provisions, for developing cost-effective control strategies.

2.	Provide incentives for the private sector to support and supplement the	basic regulatory monitoring program, to reduce monitoring costs for	government agencies, and to promote voluntary pro-active programs.

3.	Eliminate disincentives for monitoring, such as the requirements for	mandatory, non-discretionary control programs in response to monitoring	violations.

Option 2. Provide no incentives for additional monitoring. Rather, EPA should adopt national guidelines, specifying the minimum number of monitors for each NAAQS pollutant in each MSA, SMSA, or similar area of reference, and each state should be required to submit a monitoring SIP that provides for establishment and operation of a monitoring network meeting the EPA guidelines.