State Air Pollution Control Agencies Submit Recommendations to Trump’s Administration

Shortly after EPA Administrator Pruitt’s confirmation, the National Association of Clean Air Agencies (NACAA)—a nonpartisan association of air pollution control agencies in 40 states, the District of Columbia, four territories, and 116 metropolitan areas—submitted a set of nine policy recommendations to the Administrator entitled “Improving Our Nation’s Clean Air Program: Recommendations from the National Association of Clean Air Agencies to President Trump’s Administration.”

The recommendations include the following:

  1. Improve Technical Assistance to State and Local Agencies, especially in the areas of providing training on air pollution topics and developing new and revised emission factors.
  2. Ensure State and Local Air Agencies Have the Resources They Need to Implement Federal Requirements by, among other things, increasing federal funding for state and local air agencies and providing the agencies with flexibility over how the funds are used.
  3. Improve Regulatory Assistance to State and Local Air Agencies Through Effective Federal Measures for Mobile and Stationary Sources, including by adopting more stringent standards for nitrogen oxides from heavy-duty vehicles and engines and for greenhouse gas emissions from both light- and heavy-duty vehicles.
  4. Continue and Expand Efforts to Address the Transport of Air Pollution by updating transport standards for the East and Midwest and by assessing and developing programs to address transport in the Western United States.
  5. Ensure Effective Establishment and Implementation of the National Ambient Air Quality Standards (NAAQS) by, among other things, continuing “the science-based process for reviewing and revising the NAAQS, [and] leaving consideration of cost or feasibility of attainment to the implementation phase,” “issu[ing] timely rules and guidance related to implementation of the NAAQS,” and “work[ing] with state and local air agencies to better understand the sources and contributions of background ozone.”
  6. Address Critical Air Monitoring Challenges by investing federal resources to maintain and modernize ambient air monitoring infrastructure and continuing to evaluate new air sensor technology.
  7. Identify and Address Toxic Air Pollution Challenges by, among other things, continuing to evaluate sources of Hazardous Air Pollutants, especially minor or mobile sources or those that are not listed as a source category under Section 112(c) of the Clean Air Act, and streamlining the National Air Toxics Assessment process so that results are made available in a more timely manner.
  8. Support State and Local Efforts to Address Climate Change by continuing to “consult with state and local air pollution agencies” and to provide “the appropriate level of financial and technical resources” if “state and local air agencies are obligated to implement and enforce federal GHG-related programs.”
  9. Improve the Integration of Federal, State, and Local Data Programs and Requirements “to address concerns about minimum data requirements, data quality and data use (including public access to data that have not been quality assured).”
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