NACAA Comments on Proposed Revisions to Near-road NO2 Monitoring Rules

June 30, 3016 – NACAA submitted comments on EPA’s proposal to revise the minimum requirements for near-road nitrogen dioxide (NO2) monitoring by removing the requirements for near-road NO2 monitoring stations in Core Based Statistical Areas (CBSAs) with populations between 500,000 and 1,000,000 people.  Under the existing regulations, those monitors must be reflected in states’ Annual Monitoring Network Plans by July 1, 2016, and they must be installed and operational by January 1, 2017.  The monitors would comprise “Phase 3” of the three-stage deployment of the near-road NO2 network.  NACAA supported EPA’s proposal to remove the Phase 3 requirements and commended the agency for recognizing and working to ameliorate the burden it would place on state and local agencies in exchange for minimal public health or research benefits.  EPA’s analysis of the NO2 data collected from Phase 1 and 2 monitors found no NO2 data exceeding or threatening the NO2 National Ambient Air Quality Standards (NAAQS), even in the most highly populated areas.  NACAA agrees with EPA that the Phase 3 monitors, which would be located in relatively smaller cities, would almost certainly measure lower or similar NO2 concentrations well below the NO2 NAAQS.  In light of these conclusions, NACAA opined that the resources that would be required to implement Phase 3 of the near-road NO2 network would be better directed to other, critically important, monitoring activities that state and local agencies will undertake in the coming years.