NACAA Comments on Proposed Ozone Implementation Rule

February 13, 2017 – NACAA submitted to the docket comments on EPA’s proposed rule on implementation of the 2015 ozone National Ambient Air Quality Standards (NAAQS) published in the Federal Register on November 17, 2016 (81 Fed. Reg. 81,276).  Among NACAA’s comments with respect to international transport is that EPA should not place any unreasonable limitations on the opportunity for states to make demonstrations under Clean Air Act 179B (related to areas affected by international transport).  The association also comments that in cases where emission sources are beyond a state’s jurisdiction and where international sources contribute significantly to ozone levels, it is unlikely that state efforts to impose control measures will have any meaningful impact on mitigating the public health effects of exposure to ozone, especially in many rural counties in the Western U.S.  NACAA also notes that many states are struggling with how to meet their statutory clean air obligations in light of the challenges posed by transport, with Western states, in particular, concerned with the growing impact of international transport.  Therefore, EPA should work closely with state and local air pollution control agencies to assess transport throughout all regions of the country and put in place appropriate programs to address this problem.  On the issue of resources, NACAA calls on EPA to request additional, adequate federal funding to enable state and local air agencies to successfully fulfill their statutory responsibilities.  In the comments, NACAA also addresses issues such as the transition from the 2008 ozone NAAQS to the 2015 ozone NAAQS, interprecursor trading for the nonattainment New Source Review offset requirement and Reasonably Available Control Technology determinations.