NACAA Comments on EPA’s Clean Air Act Metrics Plain Language Guide: State Review Framework -Round 5 (August 8, 2023)

Description

NACAA’s letter makes recommendations for greater clarity about how the document is intended to be used and suggests numerous technical improvements that align the guidance with other documents and with the purpose and objectives of the SRF.  It also urges greater clarity about ratings applied during the reviews and recommends differentiation in the guidance (and the reviews) between procedural and reporting deficits and areas for improvement that would result in direct environmental benefit.