NACAA Comments on EPA’s Draft National Program Guidance for FY 2020-2021

May 2, 2019 – NACAA submitted comments on EPA’s draft FY 2020-2021 National Program Guidance documents for the Office of Air and Radiation and the Office of Enforcement and Compliance Assurance.  These guidance documents describe the key activities expected for EPA, states, local agencies and tribes, aligning with the agency’s strategic plan and the Administration’s budget request. The guidance also will be the basis for negotiations between EPA and state and local agencies and the development of workplans.  In the comments, NACAA expressed opposition to the proposed cuts to state and local air grants contained in the Administration’s recommended FY 2020 budget and emphasized the need for additional resources.  NACAA also provided specific comments on elements of the proposed document, including, among others, calling for PM2.5 monitoring grants to remain under the authority of Section 103, where matching funds are not needed, rather than shifting them to Section 105; agreeing with EPA on the need for flexibility and collaboration with state and local agencies to resolve planning issues; recommending adequate funds for training; recognizing the importance of working collaboratively with state and local air agencies on enforcement issues; highlighting the important role of local agencies in enforcement activities; and emphasizing the importance of EPA’s continued role as a federal backstop in enforcement activities.