1. A Regional Response to New Air Monitoring Requirements
Michael Koerber Lake Michigan Air Directors Consortium
October 3, 2011

2. Overview
Background
Air monitoring in Region 5
Regional Network Review (July 1, 2010)
Region 5 States’ Plan to Address New Requirements (April 7, 2011)

4. Major Findings
Existing state/local monitoring networks provide valuable data and need to be maintained
A few improvements recommended – both shutdowns (disinvestments) and new monitoring (investments)
Many new EPA monitoring requirements expected over next several years
Sufficient funding/staffing not available to implement all of the requirements

5. New Monitoring Requirements
Pollutant
Type
Requirement
Timeframe
Carbon Monoxide
Near-roadway
1 monitor at near-roadway NO2 site
Jan 2015
(CBSAs > 2.5 M)
Jan 2017
(CBSAs > 1 M)
Nitrogen Dioxide
1 monitor in CBSA > 0.5 M
Jan 2013
2nd monitor in CBSA > 2.5 M (or AADT > 250K)
Community-wide
1 monitor in CBSA > 1 M
Susceptible/vulnerable populations
40 additional sites nationwide
Sulfur Dioxide
Source/pop.-oriented
3 monitors in CBSAs with PEI > 1 M
2 monitors in CBSAs with PEI > 100K
1 monitor in CBSAs with PEI > 5K
Ozone
Rural areas, smaller cities
3 rural sites per state
TBD
(proposed)
1 monitor in MSAs between 50K and 350K
Particulate Matter
Lead
Source-oriented
1 monitor near all point sources > 0.5 TPY
Dec 2011
Airport special study
Urban NCORE sites

6. Costs Existing S/L Monitoring Programs New Monitoring Requirements
Other
(air toxics)
PM2.5
(Sec. 103)
Other Criteria
Pollutants
(Sec. 105)
NCore Pb
SO2
NO2
Existing S/L Monitoring Programs New Monitoring Requirements

7. Letters to EPA
July 1, 2010: Due to lack of resources, we “believe that we will be unable to fully comply with all of the new requirements. We would like to discuss the implications of this with EPA.”
April 7, 2011: Provides EPA with “our recommendations concerning implementation of the air monitoring requirements.”

8. What is the problem?
States are struggling to maintain high value and high quality air monitoring data, due to flat/decreasing budgets and staffing, and:
rising operating costs for existing monitoring (and unfunded operating costs for new monitoring),
need for periodic equipment replacements,
increased reporting burden for quarterly progress reports,
increased staff costs (and staff turn-over),
increased travel costs,
changes in operating procedures,
limited ability to reduce design of networks due to more stringent standards, and
demands of increasing EPA monitoring requirements.

9. Summary of Recommendations
Phased approach for near-roadway NO2 and CO
1 site in 2-3 cities
Establish new near-source Pb (Phase II) and O3 (smaller cities, rural) sites, as resources permit
No new SO2 sites
Reduce existing networks for PM10, PM2.5, CO

10. Top “10” Monitoring Programs
PM2.5 mass (FRM)
O3 - existing
PM2.5 mass (continuous)
PM2.5 speciation
Pb – Phase I
NCORE
NATTS
O3 – new
State air toxics
Pb – Phase II and SO2 – existing (tie)

11. NO2 Proposal: Phased approach with 1 NR site in
Current Network
Required Network
PAMS
Other
Pop/NR/EJ
Illinois 1 6
1/2/?
Indiana 4
(+1 ind.)
1/1/?
Michigan 5
1/3/?
Minnesota
Ohio 3
3/7/?
Wisconsin 2
Subtotal 23
8/17/?
Tribes
TOTAL 25
Proposal: Phased approach with 1 NR site in
2-3 cities. Maintain/reduce network – satisfies population and EJ(?) requirements.

12. CO
Current Network
Required Network
NCORE
Other
Near-Road
Illinois 1 8
Indiana 5
(+1 ind.)
Michigan 2
Minnesota
Ohio 3 13
Wisconsin
Subtotal 9 31
Tribes
TOTAL
Proposal: Scale back existing network - move monitors to near-roadway sites, as needed.

13. SO2 Proposal: No new sites (and scale back
Current Network
Required Network
NCORE
Other
NAAQS
Illinois 1 13 4
Indiana 7
(+17 ind.) 5
Michigan 2
Minnesota 6
Ohio 3 29 9
Wisconsin
Subtotal 59 28
Tribes
TOTAL 60
Proposal: No new sites (and scale back
existing network) – NAAQS implementation based primarily on modeling

14. PM10 Proposal: Scale back existing network Current Network
Required Network
NCORE
Other
NAAQS
Illinois 1 4
Indiana 15
(+5 ind.) ?
Michigan 2 3
Minnesota 5
Ohio 33
Wisconsin
Subtotal 9 64
Tribes
TOTAL 66
Proposal: Scale back existing network

15. PM2.5 and O3 Question: Can we/should we cut PM2.5 and O3 now, in
=current D.V. > NAAQS
=current D.V. > NAAQS
Question: Can we/should we cut PM2.5 and O3 now, in
light of possible future tightening of these standards?

16. Summary Near-roadway NO2 and CO
“Build and hold” goes beyond what we proposed (8 v. 3 sites), but can do if get new $$$ and site shutdowns (resource shifts) approved by EPA
Reduce existing networks for SO2, PM10, CO, and areawide NO2
Need to free up resources/staffing to cover unfunded monitoring activities (e.g., O&M for Pb and near-roadway)
Establish new Pb (Phase II) sites
Sit tight on existing PM2.5 and O3 networks

17. Next Steps Recent EPA actions encouraging Still need help….
O3 – dropping proposal for more monitoring
Secondary NOx/SOx – proposed no new monitoring
NO2, CO – scaling back near-roadway monitoring requirement
Still need help….
NO2, CO
S.103 $$$ for equipment/set-up (FY11 and FY12 grants)
Resources for O&M (???)
Do we continue NR monitoring if concentrations << NAAQS ?
SO2 – drop requirement for new monitoring
PM2.5 – need resolution of FEM v. FRM (and no new monitoring requirements, especially in light of pending funding transition from S.103 to S.105)
Approval of monitor/site shutdowns