NACAA Comments on EPA FY 2020-21 National Program Guidance

October 25, 2018 – NACAA has submitted comments in response to EPA’s August 23, 2018 solicitation of early input on the development of the Office of Enforcement and Compliance Assurance (OECA) FY 2020-2021 National Program Guidance (NPG).  The OECA NPG is an EPA planning document that describes expected federal, state, local and tribal actions related to enforcement and compliance for FY 2020-2021.  It is intended to reflect EPA’s FY 2018-2022 Strategic Plan.  In the comments, NACAA emphasized the need for federal, state and local air agencies to work cooperatively and the critical importance of increased federal funding for state and local agencies that are implementing these programs.  NACAA also recommended that EPA treat states in a consistent manner, to the extent possible; work toward global-sector settlements, where appropriate (with state and local input); use settlement monies to advance the objectives of environmental statutes; and provide an environmental presence and support to aid state and local agencies in enforcement activities, when requested.