Document 5k8Ynd1aQvzRL9RRB503LzjeV

To: From: Sent: Subject: Hupp, Sydney[hupp.sydney@epa.gov] Bill Becker Mon 3/27/2017 4:50:13 PM NACAA Meeting-May 1st in D.C. Hello Sydney-- I am following up on an invitation we sent to Administrator Pruitt several weeks ago to deliver the Keynote or Luncheon address at our annual meeting on Monday, May 1 in Washington, D.C. Our association represents the top governmental air quality officials in the states and localities throughout the country. We expect about 150 governmental officials attending. I am re-sending the transmittal letter (along with our recommendations on the CAA) requesting his participation at our meeting. I look forward to hearing from you shortly. Thanks. Bill S. William Becker Executive Director National Association of Clean Air Agencies 444 North Capitol St., NW Washington, DC 20001 (t) 202-624-7864 (c) 301-806-6111 www.4cleanair.org 17cv1906 Sierra Club v. EPA ED_001523B_00004988-00001 Improving ur Nation's .......ir Prograr r Recommendations from the National Association of Clean Air Agencies to President Trump's Administration February 17,2017 17cv1906 Sierra Club v. EPA clean air ED_001523B_00004989-00001 Improving Our Nation's Clean Air Program Introduction he National Association of Clean Air Agencies (NACAA)1 is pleased to offer the following recommendations for consideration by Environmental Protection Agency (EPA) Administrator Scott Pruitt and other members of the Administration of President Donald J. Trump related to key issues associated with our nation's clean air program. The Clean Air Act vests state and local governments with primary responsibility for ensuring that everyone in this nation breathes clean, healthful air. The state and local air pollution control agencies that comprise NACAA's membership are front and center in fulfilling this critical ly important responsibiI ity. They are uniquely positioned to identify the greatest air quality challenges of the day and to offeradvice for confronting those challenges. In short, our recommendations include the following: 1. Improve Technical Assistance to State and Local Agencies 2. Ensure State and Local Air Agencies Have the Resources They Need to Implement Federal Requirements 3. Improve Regulatory Assistance to State and Local Air Agencies Through EffectiveFederal Measures for Mobile and Stationary Sources 7. Identify and AddressToxicAir Pol I ution Challenges 8. Support State and Local Efforts to Address Cl mate Change 9. Improve the Integration of Federal, State and Local Data Programsand Requirements Weelaborateon each of these issues in the following pages. NACAA's most important recommendation is that the Trump Administration make working in close collaboration with state and local air pollution control agencies a top priority. We encourage the White House and EPA to forge a truly cooperative partnership with state and local air agencies, which are co-implementers of the Clean Air Act. We invite this Administration not only to reach out to NACAA in the initial stages of any rulemaking and policymaking processes, but also to seek input from and engage NACAA on an ongoing basis. Throughout his campaign, President Trump stated strongly his support for clean ai r and his desi re to ensure it. NACAA urges the Trump Administration to draw on the expertise of state and local air agencies and empower them in every way possible to protect public health and welfare and fulfill their clean air goals. 4. Continue and Expand Efforts to Address the Transport of Air Pollution 5. Ensu re Effect ivCstab I ish merit and Implementation of the National Ambient Air Quality Standards (NAAQS) 6. Address Critical Air Monitoring Challenges 1 NACAA is a national, non-partisan, non-profit association of air pollution control agencies in 40 states, the District of Columbia, four territories and 116 metropolitan areas. The air quality professionals in our member agencies have vast experience dedicated to improving air quality in the U.S. These recommendations are based upon that experience. The views expressed in these recommendations do not represent the positions of every state and local air pollution control agency in the country. http://www.cleanair.org NACAA-^' 17cv1906 Sierra Club v. EPA 1 ED_001523B_00004989-00002 Improving Our Nation's Clean Air Program Improve Technical Assistance to State and Local Air Agencies Background Technical assistance from EPA is crucial to the ability of statesand localities to carry out their mission to clean up air pollution. EPA'stechnical support comes in many forms, including educational programs, implementation guidance, and guidance for the performance of complex technical tasks. Over the past decade, however,the agency has dramatically scaled back its support in a number of critical areas. One area in which EPA's technical assistance is particularly needed is training. Historically, the agency has provided an array of online and classroom courses for state and local agency personnel on a wide variety of air pollution topics - as required under Section 103(a)(5) of the Clean Air Act. State and local agencies relied heavily on this training to familiarize their employees with the intricacies of Clean Air Act requirements that are central to their job functions. In recent years, funding and staffsupport for EPA's training functions have declined dramatically and most of the remaining resources have been devoted to newly issued rules. Accordingly, regional air quality planning organizations have had to shoulder much of the burden of developing and coordinating training opportunities for state and local air agencies. State and local agencies also rely on EPA to provide direction and guidance for the highly technical work they must perform i n areas such as ai r qual ity model i ng. EPA is often slow in providing such guidance and in addressing complex issues that arise with new rulesand policies. A finalarea where EPA's technical support has been lagging is in thedevelopmentof emission factors.Emission factorsare representativevalues that estimate the amount of pollutants discharged into the atmosphere by specific processes, fuels, equipment or sources. State and local agencies rely heavily on emission factors in developing emissions inventories and control strategies, determining the applicability of permitting and control programs, and ascertaining and mitigating the pollution effectsof individual sources. Unfortunately, over the past decade EPA has only rarely updated existing emission factors, many of which are decades old. The Administration should improve the breadth and timeliness of technical assistance programs that are crucial to state and local air agencies. In particular, EPAshould significantlyincrease the resourcesit devotesto developing, updating and providing training opportunities in the air pollution control field. Theagency should strive to issue technical guidance and support, including the development of new and revised emission factors, in a timelier manner. 2 17cv1906 Sierra Club v. EPA NACAA ED_001523B_00004989-00003 Improving Our Nation's Clean Air Program Ensure State and Local Air Agencies Have the Resources They Need to Implement Federal Requirements Background has been a struggle. Recent federal annual appropriations The Administration has expressed a desire to reset under Sections 103 and 105 of the Clean Air Act have been the existing state and federal relationship for implement approximately $228 million -amounts far short of what is ing the Clean Air Act. In light of that, we urge that such needed,especially if thereisashift in responsibi I ties from changes include ensuring that state and local agencies EPA to the states. Exacerbating the situation is the fact have the resources to meet their responsibi I ties. that federal grants have decreased by nearly 17 percent in Funding for state and local air pollution control purchasing power si nee 2000 due to inflationNACAAhas programs comes from a variety of sources, including the calculated that state and local air prog rams face an annual federal Title V permit fee program, state and local permit shortfall of $550 million in federal grants,2 which has and emissions fees and federal grants under Sections 103 caused many agencies to reduce or eliminate important and 105 of the Clean Air Act. Section 105 grants support air pollution programs. This not only harms public health, a host of essential activities to attain and maintain it can slow down the permitting process for businesses, healthful air quality. These include ongoing, day-to-day creating delaysand uncertainties. responsibilities that constitute the foundation or "core" Recent Administration budget requests have identified of state and local programs. Such activities include specific programs for increased funding (for example, effortsto develop and implement State Implementation on climate change). Instead, state and local air agencies Plans, monitor emissions, develop emissions inventories, should be given flexibilityon how the funds would be conduct sophisticated modeling of emissions impacts, used so that they can target the resources to address the analyze data, inspect sources of pollution, conduct issues that are most pressing in their communities. oversight and enforcement, issue minor source permits, A related issue of concern is federal funding for provide technical assistance to regulated sources and PM2.5 monitoring grants. In recent budget requests, the respond to citizens' complaints. Section 103 grants have Administration has proposed to begin to shift the PM2.5 typically funded specificmonitoring efforts,such as the monitoring grant program from Section 103 authority fine particulate matter (PM2.5) monitoring network. to Section 105 authority. Unlike funds provided under Clean Air Act Section 105 authorizes federal grants to Section 103,Section 105grantsrequirestatesand localities cover up to 60 percent of the cost of state and local air to provide matching funds - something many agencies programsand requires states and localities to contribute can ill afford. a 40-percent match. In reality, however, state and local Finally, EPA's methodology for allocating Section air agencies provide over 75 percent of their budgets 105 air grants among the EPA Regions is far out of date. (not including fees collected under the federal Title V Under refinementsto the formula that EPA has proposed program, which can fund only activities related to the to be phased in over fiveor ten years, some Regions will Title V permitting), while the federal government provides experience decreased funding. Since Section 105 grants approximate! y25percentof the total state/local air budget. already are inadequate to fund all the programs they Although statesand local ties supply significantresources to thei r ai r qual ity programs, they also rely heavi ly on the federal grant contribution. State and local air agencies have done their best to 2 Investing in Olean Air and Public Health: A Needs Sun^y of State and Local Air Pollution Control Agencies, NACAA, April 2009, operate with insufficientesources for many years, but it BlMneeds^^ NACAA-^' 17cv1906 Sierra Club v. EPA 3 ED_001523B_00004989-00004 Improving Our Nation's Clean Air Program are designed to support, few if any agencies can afford fiscalyear 2017. One way to avoid cuts and to address the to sufferreductions in their grants. In recognition of this Senate's concern is for EPA to request, and Congress to concern, the Senate Appropriations Committee included appropriate, adequate additional Section 105 grants so in its FY 2017 appropriations legislation report language that the revised formulacan be fui ly implemented without instructions to EPA to ensure that all states and Regions reductions to any state or local agency's budget. are held harmless (i.e., do not experience a reduction) in N ACAA recognizes that there are many programs that compete for federal assistance and that increases to provide full funding (an additional $550 million) may not be possible. However, the Administration should propose to Congress, and advocate for, increases in federal grants for state and local air agencies. Increases in an amount that would allow EPA to institute the new allocation formula without reducing any state or local agency'sbudget would be a very helpful start towardfillingthegap. Additional ly,EPAshould providestate and local air pollution control agencies with the flexibilityto use the additional resources on the highest priority activities in their areas. Finally,grants for PM2.5 monitoring should remain under Clean Air Act Section 103 authority, rather than being shifted to Section 105 authority. 17cv1906 Sierra Club v. EPA NACAA ED_001523B_00004989-00005 Improving Our Nation's Clean Air Program Improve Regulatory Assistance to State and Local Air Agencies Through Effective Federal Measures for Mobile and Stationary Sources Background While the Clean Air Act requires state and local air pollution control agencies to implement the national air quality program, these agencies rely on EPAto establish strong federal rules to reduce emissions from mobile and industrial sources of air pollution. This work is import ant for several reasons. First, the interstate transport of air pollution has a substantial adverse impact on air quality in downwind states, particularly on levels of ozone and fineparticulate matter. Downwind states are usual Iy unable to over come the impact of these transported emissions without federal action. Second, many state and local air pollution control agencies are precluded by state or local laws or policies from adopting rules that are more stringent than federal requirements. If the federal rules are not sufficientlyigorous to effectivel^address air quality problems, those agencies may not be able to meet their air quality goals. Third, the Clean Air Act generally precludes states, with the exception of Cal ifornia, from establ ish i ng stan dards to address emissions from mobile sources (certain states can, under Section 177 of the Act, opt into motor vehicle standards adopted by California - an important statutory authority that should be preserved). With mo tor vehicles being dominant contributors to air pollution throughout the country, complying with our statutory obligations to attain and maintain the NAAQS and re duce exposure to hazardousai r pol I utants,such as diesel particulate matter, requires strong federal standards. Fortunately, there are opportunities, for additional, meaningful emission reductions from the transportation sector. In particular, for many areas throughout the country, attainment and maintenance of the ozone NAAQS will require additional reductions in nitrogen oxides (NOX). There is a clear opportunity to garner substantial additional NOX reductions from heavy-duty vehicles and engines. In June 2016, at least 16 state and local air agencies petitioned EPAto adopt an "ultra-low" NOX standard of 0.02 grams per brake horsepower hour (g/bhp-hr), down from the currentstandard of 0.2g/bhphr established in 2000. These improved standards can helpstatesand local agencies achieve their required duty of coming into attainment with existing federal ozone standards. In addition, given the rapid pace at which mobile source greenhouse gas (GHG) emission control technologies are being developed for onroad light-duty and heavy-duty vehicles, there is a great opportunity for further GHG reductions from these vehicles post-model years (MYs) 2025 and 2027, respectively. NACAAs Recommendation EPAshould assist states and localities in meeting their public-health driven clean air goals by developing in a timely manner appropriately stringent federal rules that address nationally significantstationary and mobile sources, as well as by preserving effective regulations that are already in place. Specifical lyyve urge the President to issue specificdirectivesand schedules for the timely development and promulgation by EPA of an ultra-low N Ox standard of 0.02 g/bhp-hrand additional phases of GHG emission standards for light-duty vehicles post-MY 2025, and for heavy-duty vehicles post-MY 2027. Thiswork has end can be done in collaboration with the California Air Resources Board and other stakeholders to ensure the standards are sufficiently stringent, as well as practical and achievable. NACAA^ jir 17cv1906 Sierra Club v. EPA 5 ED_001523B_00004989-00006 Improving Our Nation's Clean Air Program Continue and Expand Efforts to Address the Transport of Air Pollution Background The transport of ai r po11 ution across state boundaries from "upwind" sources can impede or even prevent entirely the ability of "downwind" states to attain and maintain the National Ambient Air Quality Standards (NAAQS) for ozone and/or particulate matter (PM). Emissions of nitrogen oxides (NOX) and sulfur dioxide (SO2), both of which are precursors to ozone and PM po 11 ution, and even ozo ne i tsel f, can t ravel g reat d stances, affectingair quality and public health hundreds, and even thousands, of m I les away. The problem of interstate transport first rose to prominencein the Eastern and Midwestern Uni tedStates. In response, EPAadopted regulations to reduce NOX and SO2emissions from electric power plants in those regions of the country; first,the Clean Air Interstate Rule, which was promulgated in 2005 and ultimately vacated by the U.S. Court of Appeals for the D.C. Circuit; and then the Cross-State Air Pollution Rule (CSAPR), promulgated in July 2011. Even with CSAPR and its recent update, transport in the East and Midwest remains a serious problem. Further, although transport in the Eastern half of the country has dominated the conversation over the past few decades, it is now eminently clear not only that transport is a pervasive and substantial problem in the Western U.S., but also that there are some unique issues associated with it, including that of international transport. Western states are struggling with how to meet their statutory clean air obligations in light of the challenges posed by transport. EPAshould continueand expend itseffortsrelated to transport by: (1) developingand promulgatinganother regulatory update to CSAPR to address the 70-ppb ozone standard; (2) developing a strategy for addressing Eastern end Midwestern transport that ensures region-wide attainment; and (3) working closely with state and local airpollution control agencies to assess transport in the Western U.Sand put in place appropriate programs to address this problem. 6 17cv1906 Sierra Club v. EPA NACAA ED_001523B_00004989-00007 Improving Our Nation's Clean Air Program Ensure Effective Establishment and Implementation of the National Ambient Air Quality Standards Background Under the Clean Air Act, EPA is required every five years to review and, if necessary, revise the National Ambient Ai r Qual ity Standards (NAAQS) for six common "criteria" pollutants that are harmful to public health and the environment: ozone, particulate matter, carbon monoxide, lead, sulfur dioxide and nitrogen dioxide. The Clean Air Act makes clear that new or revised NAAQS must be based on the most current scientific evidence without regard to the cost or feasibility of implementation. Once EPA promulgatesa new or revised NAAQS, state and local air pollution control agencies are charged with implementing the standard and are dependent upon EPA to provide timely implementation rules and guidance. Without such tools, state and local air agencies' abi I ties to meet their statutory deadlines are greatly impeded. Further, because implementation rules and guidance are developed specificallyfor use by state and local air agencies, it is critical that EPA work closely with these agencies as the materials are drafted. A key component of state and local air agencies' NAAQS implementation effortsis the development of emission reduction strategies and programs to attain and maintain the standard. These strategies are set forth in State Implementation Plans (SIPs), which must be approved by EPA. The manner in which SIPs are developed and submitted by state and local air agencies and evaluated and processed by EPA has been an issue of considerable concern and discussion for a number of years. In 2010, NACAA, the Environmental Council of the States (ECOS) and EPA established a joint SIP Reform Workgroup to work col laboratively to make the SIP process more efficienind effectivewhile ensuring fulfillment of statutory responsibilities to attain the NAAQSas expeditiously as practicable. A February 2014 agreement, NACAA-ECOS-EPASIP Reform Workgroup Commitmentsand Best Practices for Addressing the SIP Backlog, sets forth a total of six commitmentsand seven best practices, including a commitment by EPA to "clear the SIP backlog (as of October 1,2013) by no later than the end of 2017, and manage the review of other SIPs consistent with Clean Air Act deadlines." With respect to implementation of the ozone NAAQS in particular, states across the country, and especially in the West, are confronted with the vexing issue of "background" ozone, which can contributesignificantly to monitored ozone concentrations. EPA should: (1) continue the science-based process for reviewing and revising the NAAQS, leaving consideration of cost or feasibility of attainment to the implementation phase; (2) issue timely rulesand guidance related to implementation of the NAAQS, developed in close consultation with state and local air agencies; (3) continue to implement the February 2014 NACAA-ECOS-EPASIP Reform Workgroupcommitments and Best Practices for Addressing the SIP Backlog, including clearing the SIP backlog by the end of 2017;and (4) work with state and local air agencies to better understand the sources and contributions of background ozone. NACAA-^' 17cv1906 Sierra Club v. EPA 7 ED_001523B_00004989-00008 Improving Our Nation's Clean Air Program Address Critical Air Monitoring Challenges Bac und Air monitoring is the backbone of the nation's air pollution control program. The routine, systematic collection of ambient air monitoring data is necessary for determining the extent and location of air pollution problems and for assessing the efficacyof existing emissions control strategies. Monitoring is also used to provide air quality information to the public on a continuous basis, to provide information on air quality trends, to evaluate air quality models, and for research purposes. The vast majority of the nation's ambient air monitoring networks are operated and maintained by state and local agencies, in accordance with design and operational criteria established by EPA. These monitoring networks comprise hundreds of sites across the country with thousands of monitors measuring ground-level concentrations of criteria pollutants and their precursors, air toxics, meteorological conditions and other parameters. A very significantportion of state and local air program resources is devoted to routine monitoring tasks that must be performed on an ongoing basis by knowledgeable employees. Unfortunately,state and local agencies are now facing unprecedented challenges in carrying out their critical air monitoring activities. As they struggle to modernize aging monitoring equipment and stave off further deterioration,stateand local agenciesmust also regularly address important new EPA monitoring requirements. For example, over the next several years, many statesand local ties wil I contend with expanded ozone monitoring seasons under existing federal requirements. While they confront major challenges to traditional air monitoring networks, state and local agencies are also contending with rapid developments in small, portable ai r sensor technologies. Sensor technologies hold a great deal of promise in providing readily available ambient data, not only for individuals, but also for air pollution agencies. On the other hand, many devices are unrel able and the data they produce is not readily comparable to monitoring data measured against the health-based National Ambient Air Quality Standards. State and local agencies are working collaboratively with each other and with EPA to evaluate new sensor technologies, identify goals for their use and to address how to best communicate and educate the public about how to interpret the data they provide. The Administration should address the need for significant federal resources to maintain the nation's ambient air monitoring networks. EPA should continue to work with state and local agencies to prioritize the implementation of any new monitoring requirements to make the best possible use of limited state and local resources. EPA should also expand its efforts to confront the opportunitiesand challenges associated with rapidly advancing air sensor technologies. 8 17cv1906 Sierra Club v. EPA NACAA ED_001523B_00004989-00009 Improving Our Nation's Clean Air Program Identify and Address Toxic fg Air Pollution Challenges Background They tend to be located in highly populated areas, many Hazardous air pollutants (HAPs), also referred to of which face disproportionate risks from toxic air "toxic air pollutants" or "air toxics," are substances that pollution. are known or suspected to cause cancer or other serious, Mobi Ie sources are also significantemitters of HAPs, adverse health effectsThe Clean Ai r Actoutl inesa multi including diesel particulate matter. State and local air pronged process for EPA to address HAP emissions. First, agencies (with the exception of California) are general ly Section 112(b)oftheActidentifieSl 87 HAPs that EPAmust precluded from establishing emission standards for regulate. Second, Section 112(c) requi res EPA to identify mobile sources. Therefore, they are unable to address the categories of sources that emit the listed HAPs and this significantsource of HAP emissions on their own, to update that I st every eight years. Finally,Section 112(d) yet they are expected to reduce the public'sexposure to requiresEPAto establish standards to control emissions these dangerous substances. from the source categories it has identified. The National Air Toxics Assessment (NATA)is EPA's NACAA recently collected information from its mem comprehensive evaluation of HAPs across the United bers about numerous facilities located throughout the States. NATA includes emissions data as well as modeled country that emit major amounts of listed HAPs but do estimates of health risks associated with exposures to not fal I under any of the source categories I isted by EPA HAPs. Federal, state and local air quality agencies, as under Section 112(c) of the Act. Methyl bromide fumi wel I as the publ ic, use this important tool to help identify gation faci I ties, which are located in multiple locations the locations and pollutants of greatest concern and across the country, are a source of particular concern. to help prioritize programs. Unfortunately, due to the Another issue of concern is HAP emissions from tremendous effortnecessary to collect the information sources that are not large enough to be considered and run the models, by the time the NATA results are "major" sources, including what are referred to as "non released they are several years out of date. EPA has point," "minor" or "area" sources. These sources are recently begun effortsjnvolvingstateand local input, to often numerous and widespread, and in some areas, streamline and improve the NATA process. they collectively emit more HAPs than major sources. EPA should take the following actions related to hazardous air pollutants: (1) evaluate the completeness of and update as necessary the source category list under Clean Air Act Section 112(c) and, specifically, promulgatea Maximum AchievableControl Technologystandard for the methyl bromide fumigation source category; (2) continue and ensure programs address non-major (i.e., non-point, minor or area) and mobile sources of HAPs that can significantlyaffectlocal communities); and (3) continue to support NATA and expand on EPA effortsto accelerate the NATA process so that the results can be made avai table to state and local agencies and the public more quickly. NACAA-^' 17cv1906 Sierra Club v. EPA 9 ED_001523B_00004989-00010 Improving Our Nation's Clean Air Program Support State and Local Efforts to Address Climate Change Background Greenhouse gas (GHG) emissions contribute to global climate change. EPA has adopted a number of federal programs to reduce GHG emissions, including regulations to limit GHG emissions from motor vehicles, mandatory GHG reporting requirements and GHG permitting regulations. State and local agencies are required under the Clean Air Act to implement and enforce many of these programs. Aside from their federal obligations, many states and localities have exercised leadership through local, state and regional action plans and initiatives to address the serious risks that climate change poses to public health and the environment. These effortdiave focused largely on emissions from the power sector and involve a wide variety of reduction strategies, including increasing power generation from low- and zero-emitting resources, modernizing the electric grid and reducing electricity demand through improved energy efficiency. Importantly, many GHG reduction approaches offer substantial corollary benefits,including reductions of non-GHG pollutants such as ozone. States have diverging views over how best to reduce GHG emissions and adapt to climate change. Nonetheless, there has been increased dialogue over the last few years among state and local ai r agencies, energy regulators, utilities and other stakeholders over how to achievemultiplegoalsof clean air, cleaner transportation and energy production, grid modernization and GHG emission reductions. NACAA's members are critical parties to these discussions, and federal decisions and requirements may affecttheir work. The experiences of state and local agencies can serve as guideposts when crafting responses to global climate change. As the Administration considers federal policies related to GHG emissions, we encourage the White House and EPA to consult with state and local air pollution agencies. Further, to the extent that state end local air agencies are obligated to implement and enforce federal GHG-related programs, we request that EPA provide them with the appropriate level of financial and technical resources to meet those responsibilities. 10 17cv1906 Sierra Club v. EPA NACAA ED_001523B_00004989-00011 Improving Our Nation's Clean Air Program Improve the Integration of Federal, State and Local Data Programs and Requirements Background The national air pollution control program relies heavily on electronic data collected by federal, state and local air agencies, including emissions data, facility operational data and many other types of information. These data are vital for assessing air quality and for purposes of compliance assurance, program evaluation, enforcement, regulatory development and other activities. Therefore, it is useful if the data can be shared among the various levelsof government.The publ ic must be provided with timely access to ai r qual ity data as wel I. State and local air agencies have been collecting air quality data for years, and many have expended significantresourcesto developsophisticatedsystemsfor gatheri ng and analyzi ng the i nformation. These state and local information col lection systems ref lectthe agencies' own data needs as well as requirements for electronic data submission to the federal government. However, in recent years, EPA has made changes to its compliance and enforcementprogram'sminimumdata requirements, some of which may requi resignificantlynore data to be submitted than in years past. State and local agencies have traditionally been willing to provide additional data to EPA when requested, but it is not always clear why the data are needed or how they will be used to further the shared goal of improving the environment. Some of this newly required information is too vast for EPA to properly store and process. Moreover, some of EPA's requi rementscal I for the data to be submitted in a format that does not necessari ly mesh wither accommodate the needs of existing state and local programs. Fi nal ly, federal effortsto provide the publ ic with access todataonafastertrack have led tostateand local concerns that information may be made publicly available before federal, state and local agencies have had the opportunity to conduct quality assurance and quality control checks on it. Providing inadequately reviewed, or even flawed datawill not serve the public'sneeds and could undermine the credibiIity of the air quality program. Federal, state and local data collection programs should be moreeffectivelyintegrated to address concerns about minimum data requirements, data quality and data use (including public access to data that have not been quality assured). Federal effortsto improveefficienc^and streamline data reporting requirements must accommodate existing data col lection systems in which state and local agencies have al ready invested significant resources. NACAA-^' 17cv1906 Sierra Club v. EPA 11 ED_001523B_00004989-00012 N AC A A r - P- -, u, n -, Oeiiii Kiaip if . KbweIw Sttii, iil l*rt . Speniii wwMiM IIbIiw -feliE U. hi.o.-u-- tlWBiilO IlitliUlfe OliicO^ P.lH fe Pu-nfete liitrO liiiliiliisi: fev.t.o lltiilfe -JU Cwintcfeil Chris Uncota, ME EcMfc Torii OfcEEwt , 4 I f * I, i ( S, WtlUH* fester February 17,2017 The Honorable E. Scott Pruitt Administrator U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Washington, DC 20460 Dear Administrator Pruitt: On behalf of the National Association of Clean Air Agencies (NACAA) we are pleased to convey to you our congratulations on you r confirmation as Administrator of the U.S. Environmental Protection Agency. NACAA is a n ational, non-partisan, non-profit association of state and local air pollution contro I agencies in 45 states, the District of Columbia and tour territories. For over 40 years, o ur association has dedicated itself to promoting clean air and a healthy population. We w ere, therefore, heartened to hear you testify before the Senate Environment and PublicWo rks Committee, during your confirmation hearing, "If I have the honor to serve as EPA Administrator, my overarching goal will be to lead in a way that our future gener ations inherit a better and healthier environment. It will be my absolute privilege tow ork with the thousands of dedicated public servants at EPA who have devoted their careers to helping realize this shared goal." As you well know, states and localities are vested with primary responsibility under the Clean Air Act tor preventing air pollution and controlling air pollution at its source. This is a mandate we take very seriously. Wiile the pro grams that state and local air agencies have undertaken to address air pollution under the CAA have been hugely successful, many air quality challenges still exist. FulfiIIing the many facets of our statutory responsibility and the ever-increasing obligations with which we are tasked requires that state and local air agencies have adequate regulate ry tools and financial resources, including sufficient grant funds under CAA Sections 103 and 105. This is but one of a set of challenges we face and for which we offer, in th e attached paper, recommendations to President Trump and his Administration. \Ne look forward to working with EPA under your lead ership toward the mutual goal of improving public health and the environment. V\fe would welcome an opportunity for a small group of NACAA leaders to meet, at your ear liest convenience, with you and your staff about NACAA's recommendations, your agenda and how we can work in partnership. Efe liter* Capitol SMb< MW Suits EOT WafeingiB, DC 20001 p 2OE.62< tat 17cv1906 Sierra Club v. EPA ED_001523B_00004990-00001 In addition, we invite you to provide the keynote a ddress at NACAA's 2017 Spring Membership Meeting in VWshington, DC. The meeting will take pl ace May 1 -3,2017 and we are happy to schedule your remarks at a time that is convenient for you. Once egain, congratulations on becoming EPA Adminis trator. We wish you all the best in your new role. If you have any questions, feel free to contact either of us, or S. William Becker, NACAA's Executive Director. Sincerely, David Klemp Montana NACAA Co-President Craig T. Kenworthy Puget Sound Clean Air Agency, WA NACAA Co-President 17cv1906 Sierra Club v. EPA ED_001523B_00004990-00002