Publication Number 450-R-13-001
June 14, 2013
OAR National Program
Manager Guidance
Office of Air and Radiation
U.S. Environmental Protection Agency
Fiscal Year
2014
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Overview from the Office of the Chief Financial Officer 1
1. Office of Air and Radiation Introduction 1
2. National Area of Focus: Improving Outdoor Air Quality 2
2.1 Program Guidance: NAAQS 3
2.2 Program Guidance: Regional Haze 6
2.3 Program Guidance: Title V and New Source Review Permitting 7
2.4 Program Guidance: Ambient Air Monitoring for Criteria Pollutants 9
2.5 Program Guidance: Air Toxics Program Implementation 10
2.6 Program Guidance: Ambient Air Monitoring for Toxics 12
2.7 Program Guidance: Allowance Trading Programs 13
2.8 Program Guidance: Mobile Source Programs 15
2.9 Program Guidance: Tribal Programs 17
3. National Area of Focus: Addressing Climate Change 18
3.1 Program Guidance: Greenhouse Gas Reporting Program 19
3.2 Program Guidance: Public-Private Partnership Programs 20
4. National Area of Focus: Indoor Environments 23
4.1 Program Guidance: Reducing Radon Risk 23
4.2 Program Guidance: Reducing Asthma Triggers 25
4.3 Program Guidance: Comprehensive IAQ Interventions 27
5. National Area of Focus: Radiation Protection 29
5.1 Program Guidance: Radiation Protection 30
5.2 Program Guidance: Radiation Emergency Response Preparedness 31
5.3 Program Guidance: Homeland Security: Preparedness, Response, and Recovery 32
Appendix A Performance Measures
Appendix B Effective Use and Distribution of STAG Funds
Appendix C State and Local Agency Activities
Appendix D Points of Contact for Questions or More Information
Appendix E Key Changes between FY 2013 and FY 2014
Appendix F External Comments and Response to Comments
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Office of Air and Radiation
FY 2014 National Program Manager Guidance
Overview from the Office of the Chief Financial Officer
The OCFO Overview to the OAR NPM Guidance communicates important agency-wide
information and should be reviewed in conjunction with this Guidance as well as other
applicable requirements. The Overview includes background information and the cross-
program areas that are critical to effective implementation of EPA's environmental programs in
FY 2014 and is available at: http://www2.epa.gov/planandbudget/fy2014. OAR has integrated
the cross-program areas into the body of the OAR NPM Guidance, as appropriate.
1. Office of Air and Radiation Introduction
The National Program Manager Guidance: (1) provides information on priorities; (2)
provides a general identification of the types of activities that are the responsibility of HQ,
regions, and air agencies;1 (3) identifies specific activities expected to be major tasks in FY 2014;
and (4) provides information on the State and Tribal Grant program (STAG). The guidance
provides the basis for negotiations between HQ and regions and between regions and air
agencies as to resource allocation and expected performance. Specific expectations and
deliverables will be established through negotiations in grant agreements between regions and
air agencies. EPA does not expect all air agencies to undertake all activities listed, and there
may be activities not listed that will be appropriate in certain grant agreements.
• The guidance is a guide and not a comprehensive compendium of activities and
requirements—other requirements exist through laws, regulations, court orders,
delegation agreements, etc. Additionally, regions might have other or additional
priorities and business practices.
• OAR recognizes that there will not be enough resources to do everything and that not all
programs and requirements apply in the same way everywhere. The highest priority
work is that related to meeting statutory, regulatory, and court-ordered requirements.
Regions can tailor work expectations and resource allocation to meet local
circumstances, and work with air agencies to do the same, as long as priority work
continues.
• Through the joint ECOS/NACAA/EPA Prioritization Process completed in 2011, the
EPA/State Priorities Workgroup identified the "Top 10 opportunities for greater
efficiency or reduced burden without compromising public health."2 The Workgroup
1 Air agencies are defined in this document as state, tribal, or local air pollution control agencies.
2 The "Top 10 Opportunities" include: Monitoring, Mobile Source Issues, Training and Outreach, NSR/PSD
Implementation, SIP Reform, Ozone Implementation, SO2 Implementation, Particulate Matter Implementation,
Key MACT Regulations, and Inspection and Enforcement.
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included members nominated by ECOS and NACAA (Georgia, Kansas City KS, Michigan,
New York, Oregon, and Virginia) as well as EPA participants. A key outcome of the
workgroup effort was to agree on guiding principles for identifying priority work,
identification of the priority work as well as a process for maintaining momentum and
ongoing progress reporting, and lastly a commitment to ensure that the NPM guidance
fully reflects the priority work. If there are not adequate resources to carry out all of the
necessary work, regions will work with air agencies to prioritize activities and agree on
the level of effort for each, relative to its environmental benefit.
• OAR recognizes that things can change during the course of a year due to court
decisions, state or federal legislative action, or other events. As necessary and
appropriate, EPA is prepared to work with air agencies to adjust resources to meet
changing priorities.
• Some activities in this guidance might not apply in FY 2014 but be relevant to years
beyond. These out-year activities are included to inform air agencies of upcoming
activities so they can prepare if desired or applicable. Air agencies should work closely
with the regions to determine which activities should be conducted in FY 2014.
2. National Area of Focus: Improving Outdoor Air Quality
Description: This section addresses attaining and maintaining the National Ambient Air Quality
Standards (NAAQS), improving visibility, and reducing the risks from air toxics.
Activities: Major areas of activity are listed below and detailed in the Program Guidance
sections that follow.
1. NAAQS-related activities including designations and State Implementation Plans (SIPs)
2. Regional haze program implementation activities
3. Title V and New Source Review permitting activities
4. Ambient air monitoring for criteria pollutants
5. Air toxics program implementation activities
6. Ambient air monitoring for air toxics
7. Allowance trading programs
8. Mobile source programs
9. Tribal programs
Measures: Appendix A contains 63 measures related to Improving Outdoor Air Quality, of
which 44 are managed by the Office of Air Quality Planning and Standards and are prefixed with
'OAQPS', and 19 are managed by the Office of Transportation and Air Quality and are prefixed
with 'OTAQ'.
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2.1 Program Guidance: NAAQS
2.1.1 Description: In FY 2014, EPA will work with air agencies to achieve and maintain
compliance with the NAAQS. These standards include ozone standards established in 2008,
1997, and 1979; PM2.5 standards established in 2012, 2006, and 1997; the 1987 PMi0 standard;
the 2008 lead standard; the 2010 N02 standard; the 1971 CO standard; and the 2010 and 1971
S02 standards. EPA also will continue its periodic reviews of the NAAQS as required by the CAA.
EPA expects the current review of the ozone standard will be completed in 2014. EPA will
continue to work closely with air agencies on all aspects of implementing the NAAQS. As part of
the Advance program, EPA will encourage participating entities to consider clean energy as part
of efforts to address air quality and climate change.
2.1.2 HQ Activities
2.1.2.1 Guidance/Rulemakinq
1. In consultation with air agencies, develop the SIP requirements rule and guidance for
the 2012 PM2.5 NAAQS.
2. Provide guidance and/or rulemaking for ozone NAAQS implementation.
3. Provide guidance and/or rulemaking for S02 NAAQS SIP requirements.
4. In consultation with air agencies, implement the good neighbor provision of the Clean
Air Act, especially for air pollutants where interstate transport is a concern.
5. With input and consultation from tribes, develop guidance for tribes to assist them with
developing designation recommendations, Class I re-designations, Tribal
Implementation Plans (TIP), and implementing new source review.
6. Work with Federal Land Managers and air agencies to finalize the EPA Policy to Address
Air Quality Impacts from Prescribed Burns.
7. Support residential wood smoke control measures including development of a new
source performance standard for residential wood heaters, and program
implementation.
2.1.2.2 Designations
1. Work with regions to review state recommendations for area designations and
boundaries for the 2012 PM2.5 NAAQS, develop EPA's preliminary designations decisions
and prepare "120-day letters" communicating EPA's preliminary decisions to states and
tribes.
2.1.2.3 Other
1. Work with regions to ensure states submit attainment demonstrations (due June 2013)
for lead NAAQS. HQ will work with regions to make findings of failure to submit, if
necessary.
2. Continue development of draft CAFO emissions estimation methodologies and
associated implementation tools for CAFO owners/operators.
3. Conduct outreach and education on CAFO air emission issues.
4. Support the Emissions Inventory System (EIS), finish the 2011 National Emissions
Inventory (NEI), and support initial work on the 2014 NEI.
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5. Work with air agencies participating in the Ozone Advance and PM Advance programs.
6. Engage air agencies in guidance and regulation development processes.
7. Provide and promote training opportunities in support of NAAQS implementation
through use of the Air Pollution Training Institute (APTI) learning management system.
8. Update APTI courses and develop e-learning courses in consultation with air agencies.
9. Develop tools and guidance for minority, low-income and indigenous communities to
build capacity to engage in air quality programs, including permitting programs, in a
meaningful way.
10. Continue working with states to identify further opportunities to streamline the SIP
process.
11. Work with regions to implement strategies that will reduce the SIP backlog.
2.1.3 Regional Office Activities
2.1.3.1 Designations
1. Review state recommendations for area designations and boundaries for the 2012 PM2.5
NAAQS, inform EPA's preliminary designations decisions, and issue "120-day letters"
communicating EPA's preliminary decisions to states and tribes.
2.1.3.2 5/Ps
1. Assist states in developing attainment demonstration SIPs for the 2008 ozone NAAQS,
2008 lead NAAQS, and 2010 S02 NAAQS. Review and take action on these SIPs as
expeditiously as possible. (N33)
2. Work with states to develop infrastructure SIPs for the 2012 PM2.5 NAAQS. Review and
take action on ozone, N02, and S02 infrastructure SIPs within 18 months (consistent
with the annual SIP processing goal).
3. Assist states that wish to develop SIP revisions to remove state rules requiring Stage II
gasoline vapor recovery programs.
4. Process, review, and publish for public review and comment submitted SIP revisions.
5. Assist states in the revision of startup, shutdown, and malfunction regulations, as
appropriate.
6. Take final rulemaking actions on any remaining 1997 and 2006 PM2.5 and 1997 8-hr
ozone NAAQS SIP submittals. (N07)
7. Work to reduce backlogged SIP submissions in accordance with agency performance
measures.
2.1.3.3 Other
1. Take final rulemaking action as expeditiously as practical, but not later than 18 months
of receipt of any redesignation request. (N09, N10, Nil, N29)
2. Issue attainment determination actions and clean data determinations for the 1997 and
2008 8-hour ozone nonattainment areas, and the 1997 PM2.5 and 2006 PM2.5
nonattainment areas. (N32)
3. Support the EIS, finish the 2011 NEI, and support initial work on the 2014 NEI.
4. Assist air agencies in conducting air quality reporting and forecasting.
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5. Assist air agencies in developing and/or commencing implementation of innovative and
voluntary emission reduction projects, particularly local programs to help achieve
attainment of 8-hr ozone NAAQS and the PM2.5 NAAQS. These programs include, but
are not limited to, the Ozone and PM advance programs and strategies to control
emissions from wood smoke. (N31)
6. Engage air agencies in guidance and regulation development processes.
7. Assist with outreach and capacity building for minority, low-income, and indigenous
communities to improve understanding of and engagement in regulatory and permitting
processes.
2.1.4 Expected State and Local Agency Activities
2.1.4.1 SI Ps
1. Develop and submit SIP revisions, if desired, to remove active Stage II gasoline vapor
recovery programs.
2. Develop and submit infrastructure SIPs for the 2012 PM NAAQS and 2008 ozone NAAQS,
2010 N02 and S02 NAAQS, if not yet submitted.
3. Develop attainment demonstration SIPs for S02 nonattainment areas designated in
2013 and conduct other S02 air quality planning in accordance with EPA rules and
guidance.
4. Develop and submit attainment demonstration SIPs for 2008 ozone NAAQS and 2008
lead NAAQS.
2.1.4.2 Designations
1. Submit state recommendations for area designations and boundaries for the 2012 PM2.5
NAAQS.
2.1.4.3 Other
1. Conduct public notification and education efforts, including reporting air quality
forecasts and current conditions for ozone and particle pollution.
2. Implement strategies for controlling emissions from wood smoke where it is a
significant contributor to air quality problems, including regulatory and non-regulatory
measures.
3. Submit redesignation requests including maintenance plans for areas with clean data.
4. Implement strategies to attain the 2008 lead NAAQS.
5. Prepare to submit data for the 2014 National Emissions Inventory (due December 2015).
6. Participants in Ozone and PM Advance will continue to implement and, if necessary,
supplement their actions plans.
2.1.5 Measures: OAQPS N07, N09, N10, Nil, N29, N30, N31, N32, N33.
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2.2 Program Guidance: Regional Haze
2.2.1 Description: In FY 2014, EPA will work with air agencies to finalize any remaining actions
on regional haze SIP submittals covering the initial planning period through 2018. EPA will
continue to implement the Regional Haze program in Indian country. A number of states have
deadlines to submit interim progress reports and EPA will continue to collaborate with states
on those submissions. In addition, EPA will be reviewing and acting on interim progress reports
that have been submitted to date. Also, there has been significant litigation related to EPA's
action on the initial SIP submittals and related regional haze rulemakings and EPA will continue
to address the legal actions.
2.2.2 HQ Activities
1. Provide national oversight and coordinate with regions for consistency with regional
haze requirements.
2. Coordinate with Federal Land Managers and other stakeholders on regional haze issues.
3. Consult with air agencies to inform development of SIP guidance for second 10-year SIPs
due July 31, 2018.
2.2.3 Regional Office Activities
1. Work with State and Local Agencies on remaining issues related to submitted regional
haze SIPs.
2. Process SIP revisions to ensure that final rulemaking actions on regional haze SIPs are
consistent with CAA requirements and legal deadlines.
3. Complete remaining Federal Implementation Plans (FIP) needed to fulfill statutory
obligations, and implement the FIPs.
4. Assist states with developing interim progress reports due 5 years after the submittal of
the initial Regional Haze SIP as required under 51.308(g) and 51.309(d)(10).
5. Act on submitted interim progress reports SIP revisions as required under 51.308(g) and
51.309(d)(10) in accordance with CAA timelines.
6. Work with HQ to consult with air agencies to inform SIP development for the second 10-
year SIPs due July 31, 2018.
2.2.4 Expected State and Local Agency Activities
1. Work on remaining issues related to submitted regional haze SIPs.
2. Implement BART requirements.
3. Submit interim progress reports due 5 years after the submittal of the initial Regional
Haze SIP as required under 51.308(g) for applicable states.
2.2.5 Measures: OAQPS N08
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2.3 Program Guidance: Title V and New Source Review Permitting
2.3.1 Description: EPA will continue to support permitting authorities concerning the timely
issuance of permits and respond to citizen's petitions under the title V operating permits
program. EPA will continue to address compliance monitoring issues when reviewing title V
and NSR/PSD permits issued by state/local and tribal permitting authorities, and will continue
to include monitoring as an element in program reviews where appropriate. EPA will continue
to work with states and tribes to implement revisions to the Prevention of Significant
Deterioration (PSD) requirements and NSR rules, including updates to delegation agreements
for delegated states and review of implementation plan revisions for SIP-approved states. State
and tribal operating permit programs are solely supported through the collection of permitting
fees.
2.3.2 HQ Activities
1. Maintain Title V Operating Permits (TOPS) database.
2. Issue final orders on title V citizen petitions.
3. Consider regulatory changes to the title V program rules and implementation guidance
as part of the retrospective review under Executive Order 13563 and to fulfill the
commitments with the inspector general office, drawing on ideas generated by the title
V program review conducted by the Clean Air Act Advisory Committee (CAAAC) and
documented in their April 2006 final report.
4. Coordinate and consult with tribes to develop general minor source permits for Indian
country.
5. Coordinate and consult with air agencies to incorporate EJ considerations into
permitting guidance, including opportunity for meaningful public involvement.
6. Provide training and technical guidance to regions and states/locals.
7. Based on discussions with states/locals at the March 2012 EPA Modeling Conference,
EPA will consider reviewing 40 CFR 51 Appendix W. As part of its commitment to the
State/EPA workgroup on prioritization, EPA will continue discussions about guidance
and regulatory needs.
8. In upcoming NAAQS rules, transitional requirements for PSD permitting will be clarified
and supplemented, as necessary, with the PSD/NSR requirements in the NAAQS
implementation rules.
9. Maintain the Tribal NSR Registration Database.
10. Work on the 5-year GHG NSR Study, due in 2015.
2.3.3 Regional Office Activities
1. Review proposed initial, significant modifications and renewal operating permits, as
necessary, to ensure consistent implementation of the title V program.
2. Update TOPS (working with the states to obtain the data and then Regions enter the
state data into TOPS).
3. Provide appropriate oversight of state permitting programs including conducting title V
program evaluations.
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4. Issue PSD, Nonattainment NSR, Synthetic Minor, Minor Source and Part 71 permits in
Indian country and in states that do not have an approved or delegated program.3
5. Review PSD and Nonattainment NSR permits for new major stationary sources and
major modifications to ensure consistent implementation of the NSR program.
6. Implement greenhouse gas (GHG) PSD FIPs.
7. Incorporate EJ considerations into permits issued by Regional Offices, including
opportunity for meaningful public involvement in accordance with Regional
Implementation Plans.
8. Assist air agencies in developing the technical capacity to address GHG emissions in the
permitting of large sources.
9. Provide training and technical guidance and support to permitting authorities and the
public.
10. Support efforts to build capacity of communities to engage in permit process.
11. Assist permitting authorities with interpreting and implementing title V and NSR
regulatory provisions.
12. Assist headquarters with program rule and guidance development.
13. Recognize the primacy of SIP-approved PSD permitting programs. The agency will
provide adequate oversight and guidance to ensure a level playing field as states/locals
make the various required permitting decisions.
14. Conduct outreach to tribes and sources in Indian country to implement Tribal NSR.
15. Work with headquarters in responding to title V citizen petitions.
2.3.4 Expected State and Local Agency Activities
1. Provide data in a timely manner on new title V permits and significant permit
modifications to EPA for entry into TOPS.
2. Issue initial permits, significant permit modifications, and renewal title V permits and
reduce backlog of renewal permits.
3. Participate with EPA in title V permit program evaluations, set targets to respond to
EPA's evaluation report and implement recommendations.
4. Issue major NSR permits within one year of making the determination of completeness.
5. Issue NSR permits consistent with CAA requirements and enter BACT/LAER
determinations in the RACT/BACT/LAER Clearinghouse (RBLC).
6. Provide data in a timely manner on NSR permits issued for new major sources and major
modifications by entering data including "the application accepted date" and "the
permit issuance date" into the RBLC national database.
2.3.5 Measures: OAQPS P001 through P20
The October 2012 memorandum regarding timely processing of PSD permits when EPA or PSD delegated air
agency issues the permit is available at http://www.epa.gov/region7/air/nsr/nsrmemos/timely.pdf.
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2.4 Program Guidance: Ambient Air Monitoring for Criteria Pollutants
2.4.1 Description: EPA will continue working with states and tribes to implement a strategy
that, where appropriate, supports the development and evaluation of multiple pollutant
measurements. This strategy includes changes, where the agency deems necessary, to
effectively and efficiently implement revised NAAQS monitoring requirements for ozone, lead,
sulfur dioxide (S02), nitrogen dioxide (N02), carbon monoxide (CO), and particulate matter.
* Note that the detailed Ambient Monitoring Guidance is no longer included with this NPM
guidance but instead is posted on EPA's Ambient Monitoring Technology Information Center
website at http://www.epa.gov/ttn/amtic/ under Regulations and Guidance.
2.4.2 HQ Activities
1. Work with air agencies to implement the near-road monitoring network.
2. Provide technical monitoring support and training for revised NAAQS and NAAQS
reviews that may result in changes to monitoring networks and procedures.
3. Manage the national contracts for filter purchases, and the national contracts for
laboratory analysis of filters for speciation and analysis of filters for lead total suspended
particles (TSP) and low volume PMio, including providing data for review by air agencies
and submitting data to AQS.
4. Publish national report on precision and bias performance by September 30, 2014.
5. Publish national report on 2013 Performance Evaluation Program (PEP) and National
Performance Audit Program (NPAP) findings within two months of each audit and
overall by July 1, 2014.
6. Review and approve/disapprove requests for Federal Equivalent Methods (FEM) for
continuous PM2.s methods within 120 days of completed application, and similarly act
on each first request for each Approved Regional Method (ARM).
7. Coordinate the PAMS re-engineering process and share results of equipment shootout
with air agencies.
8. Conduct national ambient air monitoring conference.
9. Work with regional office staff, state and local agencies, and tribes on the new AQS data
certification process.
2.4.3 Regional Office Activities
1. Complete and resolve AQS quarterly data reviews for timeliness and completeness.
(M12)
2. Evaluate submitters' annual data certification requests and documentation and set
appropriate flags in AQS. (M06)
3. Review the evidence that state/local monitoring programs meet 40 CFR Part 58
appendices A, C, D, and E as applicable (evidence is a required element in annual
monitoring plans due July 1) and seek corrective action by monitoring agencies where
needed.
4. Manage contracts for independent performance audits of state/local monitor networks
(PEP and NPAP) for states/locals choosing that approach to independent audits.
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5. Ensure that monitoring networks operated by air agencies for NAAQS, NCore, PM2.5
speciation, and PAMS meet applicable regulations and/or guidance and coordinate with
HQas necessary.
6. Review states' annual network plans and act on requests for changes in state/local
monitoring plans within 120 days. (M08)
7. Perform Technical Systems Audits on V* of reporting organizations, or as required to
achieve an audit of each agency within a 3-year period. (M07)
8. Transfer STAG funds to OAQPS for any additional IMPROVE-protocol sites operated by
air agencies requested by air agencies by March 2014 for monitoring to begin/continue
in July 2014.
9. Act on second and subsequent requests to approve Regional monitoring methods, per
Headquarters guidance. (Approved methods are referred to as Approved Regional
Method, ARMs.)
2.4.4 Expected State and Local Agency Activities
1. Submit 2015 annual network plan required by 40 CFR §58.10, by July 1, 2014, unless
another schedule has been approved.
2. Install and begin operation of near-road N02 monitors in CBSA's of 1M population or
more by January 1, 2014. Continue planning for next phase of N02 monitors due by
January 1, 2015 (2nd required monitors in largest Core Based Statistical Areas (CBSA) or
areas with road segments > 250K AADT).
3. Convert airport study lead monitors from special purpose monitors to required SLAMS
for any monitors that recorded design values exceeding 50% of the lead NAAQS.
4. Operate monitors for other NAAQS pollutants, NCore, PM2.5 speciation, and PAMS
according to 40 CFR Part 58, approved monitoring plans, and/or grant agreements
including QMPs and QAPPs. (M10)
5. Submit NAAQS pollutant data, PAMS, NCore, and QA data to AQS according to schedule
in 40 CFR Part 58. (Mil)
6. Certify 2013 NAAQS pollutant data in AQS and provide supporting documentation by
May 1, 2014, including exceptional event flags.
7. Ensure adequate independent QA audits of NAAQS monitors including PEP and NPAP or
equivalent.
8. Conduct monthly QA checks for flow rates of PM2.5 speciation monitors and submit data
quarterly to AQS. Target is for 75% completeness.
9. Report real time data to AirNow for cities required to report the AQI.
2.4.5 Measures: OAQPS M06 through M12
2.5 Program Guidance: Air Toxics Program Implementation
2.5.1 Description: The Clean Air Act requires EPA to regulate emissions of toxic air pollutants
from a published list of source categories. The EPA is required to develop regulations for all
industries that emit one or more of the pollutants in significant quantities. In FY 2014, EPA will
revise and amend regulations as mandated by the Act and continue to implement the Urban Air
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Toxics Strategy by providing information and training to states and communities through
documents, websites, and workshops on tools to help them in conducting assessments and
identifying risk reduction strategies for air toxics. The agency will emphasize activities to help
environmental justice communities address air toxics concerns. Depending on resources
available, the agency plans to continue work on a 2011 National Air Toxic Assessment (NATA).
2.5.2 HQ Activities
1. Support the EIS and finish the 2011 National Emissions Inventory.
2. Develop the 2011 NATA assessment, as resources permit.
3. Work with regions and air agencies to develop and implement community-based air
toxics programs that address outdoor, indoor, and mobile sources, including areas near
schools and areas with potential EJ concerns. This includes efforts that support the
Urban Air Toxics Strategy, and the OAR-Office of Enforcement and Compliance
Assistance (OECA) toxics effort.
4. Develop enhanced public outreach and involvement activities both before and after
MACT (and NSPS) rule proposals to promote meaningful involvement of EJ communities.
5. Coordinate and inform regions and air agencies of efforts to implement the residual risk
program.
6. Work with regions and air agencies to assess and address the combined impact of
multiple sources of air toxics, encouraging voluntary reductions of air toxics from indoor
and outdoor sources including residential woodsmoke.
7. Work with air agencies to develop and implement area source regulations.
8. Revise/amend §111, lll(d), 112 and 129 rules and associated Federal Plans. Visit
http://www.epa.gov/ttn/atw/eparules.html for a list of rules under development.
9. Develop tools and guidance for minority, low-income and indigenous communities to
build capacity to engage in air toxics programs in a meaningful way.
10. Evaluate historic environmental justice trends to improve the implementation of
meaningful involvement strategies for communities and regulated entities.
11. Assist in the development of compliance assistance training materials training for
implementing new area source rules.
2.5.3 Regional Office Activities
1. Delegate and assist air agencies with §111,112, and 129 standards.
2. Implement §111, 112 and 129 standards, including Federal lll(d)/129 plans, in areas
where air agencies do not.
3. Support the EIS, finish the 2011 NEI, and support initial work on the 2014 NEI.
4. Assist air agencies in conducting data analysis and assessment of air toxics monitoring
data.
5. Coordinate with Regional and state solid waste offices in implementing non-hazardous
secondary material standards through section 112 and 129.
2.5.4 Expected State and Local Agency Activities
1. Prepare to submit data for the 2014 National Emissions Inventory due December 2015.
2. Develop and implement delegated or approved air toxic standards, as appropriate, for
major sources and area sources.
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3. Implement delegated residual risk standards.
4. As resources allow, work with communities to develop and implement voluntary air
toxics programs that address outdoor, indoor, and mobile sources with emphasis on
areas with potential EJ concerns.
5. Conduct data analysis and assessment of air toxics monitoring data.
2.5.5 Measures: OAQPS T001, T002, T05
2.6 Program Guidance: Ambient Air Monitoring for Toxics
2.6.1 Description: EPA will continue to offer technical support to air agencies as they
implement the National Air Toxics Monitoring Network. The network has two main parts: the
National Air Toxics Trends Sites (NATTS) and Local Scale Monitoring (LSM) projects. The NATTS,
designed to capture the impacts of widespread pollutants, includes 27 permanent monitoring
sites, and the LSMs comprise scores of short-term monitoring projects, each designed to
address specific local issues. See http://www.epa.gov/ttn/amtic/airtoxpg.html for additional
information.
2.6.2 HQ Activities
1. Conduct Proficiency Testing and Technical System Audits for national contract lab and
state/local labs servicing NATTS and report results within 60 days of audit after
opportunity for state/local lab review of draft audit report. Provide means for optional
participation in Proficiency Testing and Technical System Audits by labs that are not
direct NATTS participants. (Cost would be borne by the approved state/local lab.)
2. Monitor NATTS data submissions for completeness and timeliness.
3. Conduct a grant competition for community-scale air toxics ambient monitoring
projects.
4. Award the community-scale air toxics ambient monitoring grants, as resources allow.
5. Manage national contract for NATTS lab analysis.
6. Provide national/regional-scale analysis of currently available air toxics data by
September 2014, with conclusions relevant to air quality management and to
establishing future goals for the NATTS program and other monitoring initiatives.
7. Develop guidance for grants to ensure that data meet risk screening, risk
characterization, and risk assessment requirements where appropriate given study
objectives that were material in selecting the project for funding.
8. Provide tools and guidance for analyzing local air toxics monitoring data.
9. Review Technical Assistance Document and update, if appropriate.
10. Identify areas where training is needed to assist air agencies to enhance air monitoring
efforts and provide such training.
11. Assist air agencies in conducting data analysis and assessment of air toxics monitoring
data.
12. Provide training to air agencies in support of data analysis and assessment of air toxics
monitoring data.
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2.6.3 Regional Office Activities
1. Ensure NATTS sites, including study sites, are operating according to EPA's technical
guidance and the QAPP and QMP.
2. Track status and coordinate needed follow-up actions between OAQPS and air agencies
in support of the NATTS QA program (e.g., TSA and PT activities).
3. Identify and resolve completeness and timeliness issues with regard to quarterly data
submission by monitoring agencies.
4. Ensure NATTS work plans are consistent with HQ template guidance.
5. Ensure NATTS QAPP is adequate to provide quality data for submission to AQS.
6. Participate in NATTS Technical Systems Audits and field site audits. (M18)
7. Review QA programs for community-scale air toxics projects. (M19)
8. Assess and review air toxics networks and assist air agencies with siting, installing, and
operating new and upgraded monitoring equipment.
2.6.4 Expected State and Local Agency Activities
1. Operate NATTS sites, including study sites, according to EPA's technical guidance and
the QAPP and QMP. (M20)
2. Participate in inter-laboratory Proficiency Testing and Technical System Audit programs
according to national guidance and the approved QAPP and QMP.
3. Submit NATTS data to AQS quarterly within 120 days of end of each quarter. The data
objective for completeness rate is 85% of the potential concentration values for each
quarter.
4. Submit data from federally-funded community monitoring projects to AQS quarterly
within 120 days of end of each quarter. The data objective for completeness rate is 85%
of the potential concentration values for the study period.
5. Conduct federally-funded community assessment projects consistent with grant terms
(including schedule), technical guidance, and applicable quality-assurance project plans
(QAPPs) and quality management plans (QMPs).
2.6.5 Measures: OAQPS M18, M19, M20
2.7 Program Guidance: Allowance Trading Programs
2.7.1 Description: The following section assumes that operating programs in 2014 will include
the Clean Air Interstate Rule (CAIR), the Cross-State Air Pollution Rule (CSAPR), or a
replacement program for regional control of transported ozone and PM2.s pollution in addition
to the national Acid Rain S02 and NOX emission reduction programs.4 OAR will continue to
implement the CAIR annual (PM2.s) and seasonal (ozone) programs until replacement programs
are in place, unless the court decision ordering EPA to continue implementation of CAIR is
subsequently reversed or otherwise modified.5 The CAIR trading programs are designed to
4 Please see http://www.epa.gov/crossstaterule/ for updates on CSAPR.
5 In an August 21, 2012 opinion, the U.S. Court of Appeals for the D.C. Circuit vacated the CSAPR and ordered EPA
to continue implementing CAIR pending development of a valid replacement. On March 29, 2013 the Department
OAR Final FY 2014 NPM Guidance 13
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control the significant contributions of power plant emissions of S02 and NOX to air quality
problems (i.e., nonattainment and interference with maintenance of ozone and PM2.5 NAAQS)
in downwind areas.
The programs will continue managing and maintaining their integrated assessment program
that includes enhanced ambient, deposition, and rural ozone monitoring through the Clean Air
Status and Trends Network (CASTNET) and surface water chemistry and aquatic ecosystem
response monitoring through the Temporally Integrated Monitoring of Ecosystems (TIME)
program and Long-Term Monitoring (LTM) programs.6 In FY 2014, CASTNET's rural ozone
monitoring will contribute to implementation of the ozone NAAQS. The TIME/LTM surface
water chemistry monitoring program will provide valuable field measurements for
understanding biogeochemical changes in sulfur, nitrogen, acid neutralizing capacity (ANC),
aluminum, and carbon in streams and lakes in relation to changing pollutant emissions.
2.7.2 Federal Activities
1. In FY 2014; priority activities will include measuring, quality assuring, and tracking
emissions (S02, NOX, C02) using continuous emissions monitoring systems or other
methods, depending on type and amount of fuel combusted, at over 4,700 fossil-fuel
fired units (primarily electric generating units or EGUs).
2. HQ and regions assist states/locals and sources with implementation.
3. HQ and regions assist sources with monitor certifications and recertifications and
emissions monitoring and reporting.
4. Allowance transfers are recorded in a centralized electronic tracking system
administered by EPA. HQ assists sources and other allowance account holders with
allowance transfers and recordation, and records any state-promulgated allocations for
2014 in unit accounts.
5. HQ reconciles emissions against allowances held in accounts, determines compliance,
and deducts penalty allowances for sources not in compliance.
6. HQ performs electronic and field audits of monitor certifications, Part 75 continuous
emissions monitoring systems (CEMS), and emissions reporting by sources. Part 75
CEMS field audits are performed in accordance with the field audit manual located on
the EPA Clean Air Markets website.
7. HQ develops and implements an operations plan that will assure supportability over the
next five years.
8. HQ assesses programs, tracks performance against baselines and objectives, and reports
on emissions, compliance, market analyses, and progress in achieving performance
targets and environmental objectives (e.g. help implement the NAAQS, reduce acid
deposition and regional haze, and reduce the number of chronically acidic lakes and
streams in acid sensitive regions of the U.S. See
http://www.epa.gov/airmarkets/progress/index.html
of Justice filed a petition seeking Supreme Court review of that decision.
For additional information on CASTNET, please visit http://epa.gov/castnet/javaweb/index.html For additional
information on TIME/LTM, please visit http://www.epa.gov/airmarkets/assessments/surfacewater.html.
OAR Final FY 2014 NPM Guidance 14
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2.7.3 Expected State and Local Agency Activities
1. Submit any state-promulgated allowance allocations decisions to EPA for incorporation
into unit accounts.
2. Assist sources with monitor certifications and recertifications, emissions monitoring,
and reporting.
3. Perform electronic and field audits of monitor certifications, Part 75 continuous
emissions monitoring systems (CEMS), and emissions reporting by sources. EPA
encourages states and locals to perform Part 75 CEMS field audits in accordance with
the field audit manual located on the EPA Clean Air Markets website. Provide reports of
the audits and any corrective actions needed to the EPA regional office and HQ.
2.7.4 Measures: None
2.8 Program Guidance: Mobile Source Programs
2.8.1 Description: Mobile source programs include the development, implementation, and
evaluation of regulatory programs and partnership programs to reduce emissions from mobile
sources and fuels. Types of mobile sources addressed include: light-duty vehicles/engines (cars,
light-duty trucks, sport utility vehicles); heavy-duty vehicles/engines (buses, large trucks); nonroad
vehicles/engines (construction, farm equipment, locomotives, marine); and fuels (diesel, gasoline,
renewable).
2.8.2 HQ Activities
1. Promulgate and implement Tier 3 light-duty vehicle and fuel standards.
2. Implement the GHG emission standards for light-duty vehicles and heavy-duty vehicles,
including technology reviews, and continue to test and verify/certify that engines meet
EPA emissions standards. This work supports EPA's priority goal of reducing GHG
emissions, which can be found at www.performance.gov.
3. Build on progress achieved through the heavy-duty GHG standards established for
model years 2014-2018, including exploring a more complete vehicle standard-setting
approach and encouraging a wider range of advanced technologies.
4. Update, as needed, federal guidance on low GHG-emitting vehicles for implementation
of Energy Independence and Security Act (EISA) Section 141 federal vehicle purchase
requirements.
5. Promulgate annual renewable fuel standard; implement renewable fuel standard
program.
6. Develop On-board Diagnostics (OBD) requirements and in-use compliance testing
program for nonroad engines.
7. Work with international organizations to develop GHG and criteria pollutant control
programs for ocean-going vessels and aviation.
8. Update MOVES (the mobile source emissions model).
9. Provide guidance for using updated versions of the MOVES model for SIP and
conformity purposes, as well as other purposes (including GHG estimates).
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10. Provide guidance, training, and support for areas completing PM quantitative hot-spot
analyses and other project-level analyses.
11. Support states/locals with existing, transitioning, and/or new I/M programs by providing
interpretations of existing I/M rules, policies, and guidance.
12. Establish grace period to provide states/locals transition time before any new MOVES
model is required for regional conformity analyses.
13. Finalize and implement strategy for reducing diesel exhaust from the legacy fleet of
diesel engines through award of DERA funding and other incentives and program
activities.
14. Evaluate and assess clean diesel technologies for the in-use legacy fleet.
15. Develop, implement, and evaluate a new clean diesel rebate program as a component
of DERA.
16. Work with multiple stakeholders, including industry, states/tribes/locals, other federal
agencies, and non-governmental organizations to implement strategies to reduce diesel
emissions and address supply chain issues with the legacy fleet.
17. Engage DOT in the development of the National Freight Strategic Plan to improve the
condition and performance of the national freight network, particularly with respect to
establishing environmental performance related goals.
18. Engage DOT and other stakeholders on the development of state freight plans and the
creation of state freight advisory committees to support environmental performance
goals.
2.8.3 Regional Office Activities
1. Assist states in preparing SIPs and in developing, implementing, and transitioning I/M,
and OBD programs, and in implementing fuel programs.
2. Assist with and process conformity determinations and conformity SIPs.
3. Make adequacy determinations for identified mobile source budgets in control strategy
SIPs and maintenance plans submitted by states.
4. Work with states/locals to develop creditable mobile source programs.
5. Award 2014 DERA funding.
6. Continue to implement, with multiple stakeholders, collaborative programs that support
reducing mobile source emissions.
2.8.4 Expected State and Local Agency Activities
1. Implement mobile source control strategies on time and consistent with SIP
commitments.
2. Implement grants effectively to accomplish needed reductions (e.g., DERA grants).
3. Work with transportation agencies as appropriate to update mobile SIP budgets in
response to changing needs such as updates to the mobile model MOVES or other
changes.
4. As appropriate, use flexibilities in the recent rule to update out-of-date conformity SIPs.
2.8.5 Measures: OTAQ Ola through 08
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2.9 Program Guidance: Tribal Programs
2.9.1 Description: EPA and tribes will work together to assess air quality in Indian country, to
set air quality goals, and to develop programs to meet those goals. EPA will continue to fund
tribes and organizations for the purpose of building tribal capacity to implement CAA programs
and to provide technical support, tools, and training for tribes. Priorities include implementing
the tribal new source review regulations and air quality improvements in Indian country. EPA is
committed to fully implementing the May 2011 EPA Consultation Policy and Executive Order
13175 Consultation and Coordination with Indian Tribal Governments by including tribes in
outreach and information sharing leading to consultation on a government to government
basis, as appropriate, and outlined in the Policy and supporting guidance.
2.9.2 Federal (HQ and Regional Office) Activities
1. Implement activities in the 2013 OAR Tribal Agenda. See:
http://www.epa.gov/air/tribal/pdfs/OfficeofAirandRadiation2013TribalAgendafinal.pdf .
2. Consult with tribal leaders and governments on OAR actions that may affect them.
3. Use Direct Implementation Tribal Cooperative Agreement (DITCA) authority to directly
implement federal responsibilities as appropriate.
4. Implement the Part 71, PSD, and tribal NSR rules as they apply to sources located in
Indian country.
5. Implement and enforce federal standards (NSPS, NESHAP, etc.) as they apply to sources
located in Indian country.
6. Provide support for tribes on the TAS and TIP processes and act on TAS and TIP
submittals in a timely manner.
7. Support tribes in taking delegation of CAA programs and program elements.
8. Identify areas requiring a FIP development and implementation process, and
conduct/support appropriate FIP and implementation efforts.
9. Provide grant and technical support to tribes for air quality management and
assessment activities.
10. Provide air quality outreach and training events to tribal staff.
11. Support tribal participation in local, regional, and national policy developments and
actions through the National Tribal Air Association.
12. Invite and provide grant resources and staff support for tribal organizations and tribes
to participate in regional and national level activities such as policy, rule or program
development, and implementation workgroups.
13. Provide training and support for tribes to understand, assess, and respond to indoor air
quality concerns.
14. Implement voluntary emission control retrofit programs for existing heavy-duty diesel
engines and wood stove and hydronic heater changeout campaigns.
15. Support tribal participation in assessment and monitoring activities related to air
pollutants of interest and atmospheric deposition of mercury on tribal lands.
16. Support tribal efforts to understand, assess, and develop plans to mitigate and adapt to
climate change impacts.
17. Implement voluntary programs to integrate nontraditional planning (e.g., land use,
transportation, and energy) into air quality management.
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18. Support OTS Tribal Database by regularly inputting appropriate data and ensuring tribal
activities are accurately reflected.
19. Provide support for tribes on the Quality Assurance Project Plan (QAPP) Process and act
on QAPP submittals in a timely manner.
20. Provide training and support for tribes to understand, assess, and respond to Climate
Change.
2.9.3 Expected Tribal Activities
1. Conduct air quality monitoring according to 40 CFR Part 58. (TR04)
2. Provide air quality monitoring or assessment data to EPA and/or AQS.
3. Work with regions to register minor sources for NSR permit planning.
4. Tribes with approved new source permitting programs should issue permits
5. Tribes determine their role in implementing NSR and participate in permitting, take
program delegation, or develop TIPs as appropriate. (TR02)
6. Complete and submit emissions inventories to the EIS. (TR08)
7. Participate in/attend regional and national meetings, conferences, and teleconferences
on rule and policy development, attend outreach events, and seek training and support
to build capability for effective participation.
8. Submit eligibility determinations under the TAR. (TR01)
9. Submit TIPs to address air quality conditions for reservation areas and for non-
reservation areas within the tribes' jurisdiction. (TR03)
10. Assist in FIP development and implementation process.
11. Participate in local, regional, and national policy developments and actions through the
National Tribal Air Association.
12. Participate in training and technical support activities conducted as part of the AIAQTP,
including attending workshop training both as students and instructors and assisting
tribes in learning from each other. Participate in training on voluntary programs to
address air quality concerns.
13. Implement voluntary emission control retrofit programs for existing heavy-duty diesel
engines and wood stove and hydronic heater changeout campaigns. (TR06)
14. Attend training, develop plans, and develop or acquire capability to understand, assess,
and respond to indoor air quality concerns.
15. Attend training, develop plans, and develop or acquire capability to understand, assess,
and respond to Climate Change.
2.9.4 Measures: OAQPSTR01 through TR08
3. National Area of Focus: Addressing Climate Change
Description: This section addresses the Greenhouse Gas Reporting Program and voluntary
public-private partnership programs such as ENERGY STAR, SmartWay, and others. Regulatory
activities related to emissions of greenhouse gases (GHGs) from stationary and mobile sources,
and permitting, are addressed under Improving Outdoor Air Quality.
OAR Final FY 2014 NPM Guidance
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Activities: Major areas of activity are listed below and then detailed in the Program Guidance
sections that follow.
• Greenhouse Gas Reporting Program
• ENERGY STAR, SmartWay, and other partnership programs
Measures: Appendix A contains three ENERGY STAR measures managed by the Office of
Atmospheric Programs: OAR 1, OAP 7, and OAP 8.
3.1 Program Guidance: Greenhouse Gas Reporting Program
3.1.1 Description: The Greenhouse Gas Reporting Program requires reporting of GHG data and
other relevant information from large sources and suppliers in the U.S. Established in October
2009, the program has 41 sectors with approximately 10,000 reporters. The Program collects
data to better understand where GHG emissions are coming from, and improves the ability to
make informed policy, business, and regulatory decisions. In 2014, EPA will continue to develop
and implement the Greenhouse Gas Reporting Program.
3.1.2 HQ Activities
1. Continue a comprehensive outreach and training effort with covered facilities, including
the identification of facilities that are likely to meet the applicability thresholds. EPA will
provide outreach materials as well as operate a help desk to assist reporters with
completing their annual report electronically.
2. Maintain and update the electronic reporting system in preparation for reporting in
March 2014. EPA will continue to make modifications to e-GGRT based on the changes
made in the Part 98 to address inputs to emission equations discussed below under #5).
3. Carry out a comprehensive QA/QC and verification program on the data reported in
March 2014. The data verification process includes a combination of electronic checks,
staff review, and follow-up with facilities to identify potential reporting errors and have
them corrected before publication.
4. Publish data in a timely manner. This involves updating the data publication website
with the latest annual data as well as enhancing the tool with additional analytical
features.
5. Finalize the last in a series of regulatory actions that are determining which data
reporting elements will be determined to be confidential and which will be made
available to the public. EPA will determine whether public release of inputs to the
equations used to calculate GHG emissions could result in competitive harm and, if so,
alternative approaches to collecting and/or verifying emissions.
6. Provide support to the regions in identifying facilities that are in non-compliance, and in
outreach to facilities that are priorities within specific regions.
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3.1.3 Regional Office Activities
1. Assist HQ in identifying reporters that may be applicable to the GHG Reporting Program,
and continue to provide compliance assistance to these reporters.
2. Work with HQ to communicate with reporters about issues related to noncompliance
including non-reporting as well as correcting errors identified in annual GHG reports.
3. Continue to work closely with HQ to better understand Regional variability in GHG
emissions and to promote use of GHG Reporting Program data within EPA and
externally.
3.1.4 Measures: There are no ACS measures, but, both facilities and suppliers are required to
report their data annually by the reporting deadline of March 31st. After submission of the
data, the agency conducts a verification review that lasts approximately 150 days. The data
verification process includes a combination of electronic checks, staff review, and follow-up
with facilities to identify potential reporting errors and have them corrected before publication.
In FY 2014, 95% of the reports published will be verified prior to publication of the data on or
around October 1.
3.2 Program Guidance: Public-Private Partnership Programs
3.2.1 Description: The focus in 2014 is to continue to implement government/industry
partnership efforts to achieve greenhouse gas reductions.
3.2.2 HQ Activities
1. Continue ENERGY STAR program enhancements including more frequent specification
revisions, new products, and integrated lighting program.
2. Oversee the third-party certification program for ENERGY STAR products.
3. Add new products to the ENERGY STAR family.
4. Implement version 3 of the ENERGY STAR specification for the ENERGY STAR New
Homes program as well as the labeling program for new multi-family buildings.
5. Raise awareness of the ENERGY STAR label for products, buildings, and homes, and
promote superior energy management to public and private sector organizations of all
sizes in all regions of the country.
6. Continue the process to upgrade EPA's ENERGY STAR Portfolio Manager for speed,
flexibility, and usability.
7. Support state/local mandatory and voluntary building benchmarking through ENERGY
STAR.
8. Support implementation of Executive Order 13624 "Accelerating Investment in
Industrial Energy Efficiency."
9. Continue building on the success of non-regulatory programs in the residential,
commercial buildings, and industrial sectors:
a. Enhance the coordination and cooperation with other partnership programs
such as Indoor Air Plus, Water Sense, etc.
b. Promote the ENERGY STAR label for industrial plants and provide energy
benchmarking tools to industry.
c. Promote the increased deployment of combined heat and power.
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10. Provide leadership and technical support for the Global Methane Initiative and the
Climate and Clean Air Coalition (CCAC) to Reduce Short-Lived Climate Pollutants, and
implement domestic methane partnership programs including Natural Gas STAR,
AgSTAR, the Landfill Methane Outreach Program, and the Coalbed Methane Outreach
Program, as well as voluntary programs to reduce fluorinated gas emissions.
11. Promote membership and broad collaborations in the Green Power Partnership and the
Combined Heat and Power Partnership, particularly for larger organizations.
12. Complete GSA's pilot to assist small federal suppliers in developing their GHG
inventories.
13. Promote energy efficiency and the generation of increased amounts of renewable
energy through utility-focused programs.
14. Promote the integration of energy efficiency and clean energy into air quality plans (i.e.,
SIPs) and work with the regions and states to utilize the new SIP Roadmap.
15. Increase tons of emissions reduced and fuel saved through targeted partner recruitment
and stakeholder collaboration aimed at achieving significant environmental, economic
and energy security benefits across the freight supply chain.
16. Continue to foster efficiencies throughout the SmartWay program through
improvements to the program's emissions assessment, tracking tools, and database
management system to enhance accessibility, ease of use, and data management and
processing efficiencies.
17. Coordinate with other diesel legacy fleet (e.g., technology equipment testing and
verification, DERA clean diesel grant programs) and related EPA voluntary programs to
leverage resources and opportunities for evaluating and supporting the adoption of
technologies and freight management strategies that will result in reduced diesel
emissions and fuel consumption, improved efficiencies and productivity, and lower costs
in the goods movement industry.
18. Recognize high-achieving SmartWay partners for their progress and leadership.
19. Encourage manufacturers, dealers, and leasing companies to highlight and market the
environmental and fuel-saving benefits of their SmartWay-designated trucks and
verified equipment.
20. Promote and encourage partner investment in SmartWay designated trucks and verified
equipment that meet SmartWay criteria for superior environmental and energy-efficient
performance.
21. Continue to provide expertise and serve as a technical test bed in support of the
agency's future policy direction for GHG emission reductions.
22. Encourage the adoption of SmartWay methods and tools internationally through
stakeholder development, information sharing, and collaboration on pilot projects.
23. Promote and encourage new members in the Responsible Appliance Disposal (RAD)
Program, and recognize high-achieving RAD partners for their program leadership.
24. Promote and encourage new members in GreenChill, and continue to provide resources,
tools and knowledge to further reduce corporate and supermarket refrigerant
emissions. Recognize high-achieving GreenChill partners and local GreenChill certified
stores for their program leadership with reducing emissions.
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3.2.3 Regional Office Activities
Promote GHG reduction programs and activities to stakeholders. This may include but is not
limited to the following:
1. Leverage accomplishments of the Climate Showcase Communities grant program.
2. Encourage organizations to procure ENERGY STAR-qualified products.
3. Encourage tribal governments and communities to be partners in GHG activities and to
participate in and benefit from ongoing coordinated efforts and outreach programs,
including ENERGY STAR.
4. Encourage organizations to benchmark the energy performance of buildings using EPA
STAR Portfolio Manager, apply for the ENERGY STAR label for the qualifying buildings,
and determine improvement plans for those that do not currently qualify.
5. Support state/local mandatory and voluntary building benchmarking through ENERGY
STAR.
6. Support regional implementation of the ENERGY STAR New Homes program."
7. Encourage organizations to join the ENERGY STAR Buildings Challenge and promote a
10% or more reduction in energy use in buildings, and assist local governments that
have already joined to implement the Challenge.
8. Promote the use of the ENERGY STAR@Home, ENERGY STAR Yard Stick, and Home
Energy Advisor web-tools including the use of Green Button when completed.
9. Support implementation of Executive Order 13624 "Accelerating Investment in
Industrial Energy Efficiency" when possible.
10. Promote integration of energy efficiency and clean energy into SIPs working with
headquarters to collectively better understand what additional tools and assistance the
states need.
11. Encourage truck and rail carriers, and retail and commercial shipping companies to join
SmartWay and reduce emissions.
12. Participate and promote SmartWay at regional and local transportation conferences,
workshops, and events conducted to improve efficiencies and environmental
performance in the goods movement sector.
13. Encourage and support regional clean diesel collaboratives to highlight and promote
SmartWay.
14. Encourage recipients of DERA grant funds targeting the reduction of diesel emissions to
consider using SmartWay designated trucks and SmartWay verified technologies to
achieve those reductions.
15. Encourage major companies, broad coalitions, and organizations headquartered in the
region to join the Green Power Partnership, the Combined Heat and Power Partnership,
and SmartWay programs.
16. Promote the recovery and use of methane as a clean energy source through EPA's
methane partnership programs.
17. Operate pilot programs to use commercially-available advanced technology in fleets
(such as state/municipal vehicles, school buses, or refuse vehicles) to produce cost-
effective emissions and fuel consumption reductions.
18. Encourage and support new member companies in both the RAD and GreenChill
programs, and recognize high achieving partners.
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19. Conduct compliance screens for new RAD and GreenChill members, and for any entity
being recognized or receiving a program-related award.
3.2.4 Measures: GAP 1, GAP 7, GAP 8
4. National Area of Focus: Indoor Environments
Description: The Indoor Environments program fills a unique niche to protect public health by
promoting healthy indoor air quality (IAQ) in buildings where people live, learn, and work. EPA
addresses IAQ issues by developing and implementing voluntary outreach and partnership
programs that inform and educate the public about IAQ and actions that can reduce potential
risks in homes, schools, offices, and other indoor spaces. EPA provides guidance and assistance
to states, tribes, local communities, and the general public to address environmental triggers of
asthma, radon, mold contamination, secondhand tobacco smoke, carbon monoxide, particulate
matter, and indoor air toxics.
EPA Regional programs and grants awarded by Regions under the national RFA "Regional
Indoor Environments: Reducing Public Exposure to Indoor Pollutants," make a significant
contribution toward advancing priority program goals and are an integral component of the
comprehensive national IAQ program. The Indoor Environments program also works with other
EPA programs, the wider Federal community, and partners to provide guidance and assistance
on how to protect public health from poor IAQ and on efforts such as environmental justice,
climate change adaptation, and sustainable communities.
Activities: Major areas of activity are listed below and detailed in the Program Guidance
sections that follow.
• Reducing Radon Risk
• Reducing Asthma Triggers
• Comprehensive Indoor Air Quality Interventions
Measures: Appendix A contains seven Indoor Environments measures managed by the Office
of Radiation and Indoor Air: ORIA IAQ 5 through IAQ 8, and SIRG 1 through 3.
4.1 Program Guidance: Reducing Radon Risk
4.1.1 Description: In 2014, EPA will continue efforts to promote radon risk reduction by
collaborating with other federal departments and agencies as well as states/local/tribes and
those in the private, public health, healthy housing, and other sectors.
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4.1.2 HQ Activities
4.1.2.1 Implement the Federal Radon Action Plan
1. Collaborate with other federal partners to implement the Federal Radon Action Plan.
2. Work with other federal agencies to provide guidance and assistance on how to reduce
exposure to radon through their environmental, public health, and building-related
programs.
4.1.2.2 Drive action on guidance, standards and codes for homes and schools
1. Provide technical support, detailed guidance, and easy-to-use tools on radon resistant
building design, operation, and maintenance practices to building owners and
managers, design and construction professionals, school facility managers, and
educators.
2. Promote the use of radon measurement and mitigation consensus standards.
4.1.2.3 Provide programmatic and technical support to diverse stakeholders
1. Provide guidance and support to address radon in homes and schools.
2. Support states, tribes, and communities in developing and implementing
comprehensive multi-stakeholder indoor air quality improvement efforts to reduce
exposures to radon.
3. Work with national partner affiliates, state/local/tribal partners, and coalitions to
implement integrated IAQ management practices to reduce risks from radon in homes
and schools.
4.1.2.4 Foster awareness and action through partners, states and tribes to achieve risk
reduction
1. On a national level, promote activities that increase the number of homes and schools
mitigated for radon and increase the number of new homes built with radon-reducing
features.
2. Support the Radon Leaders Saving Lives campaign.
3. Facilitate activities associated with Radon Action Month as a way to drive radon action
throughout the year.
4. Aid in designing and implementing regional radon stakeholder meetings that involve
states and industry.
5. Manage grants with national non-profit organizations and other national partners to
reduce risks from radon in homes and schools.
4.1.3 Regional Office Activities
4.1.3.1 Implement the Federal Radon Action Plan
1. Work with other regional offices of other Federal agencies to leverage existing programs
and resources to reduce radon risk for tribes and in low income housing.
2. Assist in the development and promotion of radon measurement and mitigation
consensus standards.
OAR Final FY 2014 NPM Guidance 24
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4.1.3.2 Provide programmatic and technical support to diverse stakeholders
1. Negotiate radon workplans with states and tribes for remaining SIRG funding and track
progress throughout the year.
2. Manage grants to reduce risks from radon, particularly in homes and schools.
4.1.3.3 Foster awareness and action through partners, states and tribes to achieve risk
reduction
1. Assist with the design and implementation of regional radon stakeholder meetings.
2. Participate in the Radon Leaders Saving Lives campaign.
3. Use Radon Action Month as a way to drive action throughout the year.
4.1.4 Expected State, Local, and Tribal Activities
1. While SIRG funding is no longer provided, state and tribal radon programs should use
any available remaining SIRG funds for radon risk reduction by: (1) increasing testing
and mitigation of existing homes by consumers, homeowners, non-profit partnerships,
and real estate professionals; (2) builders voluntarily including radon-reducing features
in new homes, including the use of green-building standards; (3) promoting the
adoption or revision of state-local building codes for radon-reducing features; and, (4)
promoting public education and awareness.
4.1.5 Measures: SIRG 1, SIRG 2, SIRG 3.
4.2 Program Guidance: Reducing Asthma Triggers
4.2.1 Description: The Indoor Environment Asthma Program is aimed at ensuring
environmental controls are integrated into asthma care at all levels. EPA has identified the
reduction of asthma disparities as a national environmental justice priority. FY 2014 program
goals, objectives, and activities are aligned with the Federal Asthma Disparities Action Plan.
Our strategy is targeted to equip an array of stakeholders to take effective action and replicate
best practices to improve health outcomes for children and others with asthma. The program
relies on several key implementation/educational tools:
• National public awareness campaigns;
• Community-based outreach and education (e.g., educating caregivers of children on
environmental triggers of asthma and exposure to secondhand smoke);
• Sound, user-friendly guidance tailored to the program's varied constituencies;
• Knowledge and technology transfer (e.g. training health care providers on asthma
trigger management strategies, building community capacity to deliver comprehensive
asthma care).
OAR Final FY 2014 NPM Guidance 25
-------
4.2.2 HQ Activities
4.2.2.1 Continue to build capacity in community based programs to implement comprehensive
asthma programs that address environmental triggers
1. Expand the Communities in Action asthma campaign through support for at-risk
communities, bringing these communities into the Communities in Action Network,
providing targeted training and outreach to underserved communities and schools.
2. Equip stakeholders with the technical knowledge needed to more effectively deliver
comprehensive asthma management.
3. Continue to surface and promote best practices through the National Environmental
Leadership Award in Asthma Management.
4. Facilitate work with local communities to foster integration and collaboration between
asthma programs and local housing, school, weatherization/energy efficiency, and other
community development initiatives.
5. Manage national grants to reduce risks from asthma triggers in indoor environments.
4.2.2.2 Train health care providers on comprehensive asthma management
1. Equip health care providers with the knowledge and tools they need to incorporate
environmental management strategies and controls into standards of care.
2. Support NGOs efforts to educate and train health care providers.
3. Collaborate with Regions to ensure access to tools and resources to support training and
outreach efforts.
4.2.2.3 Educate children and families on tailored environmental interventions as part of a
comprehensive asthma management program
1. Provide guidance and support to address environmental triggers of asthma.
2. Support states, tribes, and communities in developing and implementing
comprehensive multi-stakeholder indoor air quality improvement efforts to reduce
exposure to indoor asthma triggers.
3. Work with other federal agencies to provide guidance and assistance on how to reduce
exposure to asthma triggers through their environmental, public health, and building-
related programs.
4. Work with national partner affiliates, state/local/tribal partners, and coalitions to
implement integrated IAQ management practices to reduce risks from asthma triggers
in indoor environments.
4.2.3 Regional Office Activities
4.2.3.1 Continue to build capacity in community based programs to implement comprehensive
asthma programs that address environmental triggers
1. Support the expansion of the Communities in Action asthma campaign through support
for at-risk communities, bringing these communities into the Communities in Action
Network, providing targeted training and outreach to underserved communities and
schools. (Note: This activity also supports the agency's Community-based Coordination
efforts)
OAR Final FY 2014 NPM Guidance 26
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2. Work with local communities to foster integration and collaboration between asthma
programs and local housing, school, weatherization/energy efficiency or other
community development initiatives.
4.2.3.2 Support training of health care providers on comprehensive asthma management
1. Equip health care providers with the knowledge and tools they need to incorporate
environmental controls into standards of care.
2. Support NGOs efforts to educate and train health care providers.
3. Support training and outreach efforts in the region.
4.2.3.3 Educate children and families on tailored environmental interventions as part of a
comprehensive asthma management program
1. Work with state/local/tribal partners and coalitions to implement integrated IAQ
management practices to reduce risks from indoor pollutants, including asthma triggers
in homes and schools.
2. Support states, tribes, and communities in developing and implementing
comprehensive multi-stakeholder indoor air quality improvement efforts to reduce
exposure to indoor asthma triggers.
3. Manage grants to reduce risks from indoor pollutants and asthma triggers, particularly
in homes and schools.
4.2.4 Measures: ORIA IAQ 5, ORIA IAQ 6, ORIA IAQ 7.
4.3 Program Guidance: Comprehensive IAQ Interventions
4.3.1 Description: The Indoor airPLUS Labeling program for homes allows builders of new
homes to qualify for an EPA label if they first earn the ENERGY STAR new home label and are
then verified to have implemented all of the indoor air quality specifications developed by EPA.
The Healthy Indoor Environment Protocols for Home Energy Upgrades provide concise
minimum and recommended practices for ensuring that energy retrofit activities support
indoor air quality. These Protocols, in addition to the Indoor airPLUS specifications, provide a
clear set of metrics that may be used by a wide range of Federal, state, and local public and
private sector programs and standard setting bodies to better define and carry out practices
that promote good indoor air quality in homes. The IAQ Tools for Schools Framework and
Technical Solutions provide guidance to the schools community to formulate and sustain
effective and comprehensive indoor air quality management program. The agency will promote
the use of these tools—and new guidance that will ensure energy retrofit activities in schools
properly address IAQ—to promote healthy IAQ in schools.
OAR Final FY 2014 NPM Guidance 27
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4.3.2 HQ Activities
4.3.2.1 Promote adoption of effective IAQ practices in homes and schools
1. Work with healthy home and green home programs, EPA's ENERGY STAR and Water
Sense programs, DOE's Builder's Challenge program, and others to promote adoption of
Indoor airPLUS.
2. Create and disseminate information about the Indoor airPLUS specifications and label
for new homes and support implementation of the program by active stakeholders in
the community.
3. Increase adoption of comprehensive IAQ in homes guidance into other national
standards and programs.
4. Expand the number of home builders, raters and providers committed to Indoor
airPLUS.
5. Work with other federal agencies to provide guidance and assistance on how to reduce
exposure to indoor air contaminants in homes and schools.
4.3.2.2 Address gaps in technical guidance and provide training on IAQ in homes and schools
1. Provide technical support, detailed guidance, and easy-to-use tools on indoor air-related
building design, operation, and maintenance practices to the housing sector, building
owners and managers, design and construction professionals, and school officials.
2. Use cost-effective web technologies to promote proven technical guidance and tools for
comprehensively improving home and school indoor environments.
3. Work with national, state, and regional energy and healthy housing programs to
educate them about the Healthy Indoor Environment Protocols for Home Energy
Upgrades and to encourage their adoption and integration into existing energy
programs.
4. Create and disseminate guidance connecting energy efficiency and healthy school
indoor environments.
4.3.2.3 Increase awareness and demand for indoor air quality protections in homes and schools
through improved partner engagement
1. Work with national partners, state/local/tribal partners, and coalitions to implement
integrated IAQ management practices to reduce risks from indoor pollutants, including
radon and asthma triggers in homes.
2. Manage national grants to reduce risks from indoor pollutants, including radon and
asthma triggers in homes.
3. Leverage national/regional/local conferences, workshops and events to promote IAQ
protections in homes and schools.
4. Build capacity of national leadership network to support, promote and advance IAQ
management programs in schools.
OAR Final FY 2014 NPM Guidance 28
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4.3.3 Regional Office Activities
4.3.3.1 Promote adoption of effective IAQ practices in homes and schools
1. Disseminate information about the Indoor airPLUS specifications and label for new
homes and support implementation of the program by active stakeholders in the
community.
2. Expand the number of builders, raters and providers committed to Indoor airPLUS.
3. Manage grants to comprehensively reduce risks from indoor pollutants in homes and
schools.
4.3.3.2 Provide training on IAQ in homes and schools
1. Work with state, regional, and local energy and healthy housing programs to educate
them about the Healthy Indoor Environment Protocols for Home Energy Upgrades and
encourage their adoption and integration into existing energy programs (e.g.,
weatherization programs).
2. Build capacity of school districts by holding local pacing events (trainings, workshops,
and webinars) to advance IAQ management programs in schools.
4.3.3.3 Increase awareness and demand for indoor air quality protections in homes and schools
through improved partner engagement
1. Work with national partner affiliates, state/local/tribal partners, and coalitions to
implement integrated IAQ management practices to reduce risks from indoor
pollutants, including radon and asthma triggers in homes and schools.
2. Serve as a local, community-based point of contact to disseminate information about
the Indoor airPLUS specifications and label for new homes and support implementation
of the program by active stakeholders in the community.
3. Work with regional, state, and local healthy, energy efficiency, and green home
programs, to promote adoption of Indoor airPLUS in target markets.
4. Serve as a local, community-based point of contact to disseminate information about
the connection of energy efficiency and healthy indoor environments in schools.
4.3.4 Measures: ORIAIAQ8.
5. National Area of Focus: Radiation Protection
Description: Radiation Protection addresses EPA's responsibility to protect the public from
unnecessary risks and potentially harmful exposures to radiation in the environment. The
agency manages and operates a national environmental radiation monitoring program,
conducts radiation dose and risk assessments, manages radioactive releases and exposures,
ensures proper management of radioactive waste and material, maintains a high level of
readiness to respond to radiological emergencies and acts of terrorism and provides
information to the public about radiation and its hazards.
OAR Final FY 2014 NPM Guidance
29
-------
Activities: The major areas of activity for regional offices and states, tribes, and local air
agencies are listed below and then detailed in the Program Guidance sections that follow.
• Radiation Protection
• Radiation Emergency Response Preparedness
• Homeland Security- Preparedness, Response, and Recovery
Measures: Appendix A contains two Radiation Protection measures managed by the Office of
Radiation and Indoor Air: ORIA RAD 1 and RAD 2.
5.1 Program Guidance: Radiation Protection
5.1.1 Description: This program includes activities for radiation clean up, federal guidance, risk
modeling, regulatory oversight of the Department of Energy's Waste Isolation Pilot Plant
(WIPP), radiation air toxics or National Emissions Standards for Hazardous Air Pollutants
(NESHAPs), technologically-enhanced naturally-occurring radioactive material (TENORM),
radioactive waste management, radioactive and mixed-waste operations and laboratory
analyses. EPA works with other federal agencies, states, tribes, and other government agencies,
stakeholders and the public to inform and educate people about radiation risks and promote
actions that reduce human exposure. EPA provides radiation guidance and tools and develops
regulations to control radiation releases.
5.1.2 HQ Activities
1. Continue to provide regulatory oversight of the WIPP by conducting inspections at DOE
waste generator sites.
2. Improve analytical capacity through updated technology and methods.
3. Improve state radiation laboratory capabilities and capacity through training and
evaluation.
4. Respond to environmental concerns related to nuclear power and radiation.
5. Revise outdated radiation guidance and regulations.
6. Respond to increased uranium extraction and processing.
7. Provide technical assistance to regions and, in close coordination with regions, to states
on decommissioning and other issues related to nuclear power facility operations.
8. Support regional remediation projects.
5.1.3 Regional Office Activities
1. Disseminate information on EPA's radiation protection program to the states.
2. Coordinate regional radiation issues among regional offices.
3. Implement regulatory programs (e.g., radiation air toxics (NESHAPs).
4. Provide technical support to state radiation, solid waste, environmental and health
programs and HQ radiation regulatory, policy, and technical workgroups, as requested.
OAR Final FY 2014 NPM Guidance 30
-------
5. Provide technical support to other regional programs (e.g. Superfund, Formerly Utilized
Sites Remedial Action Program (FUSRAP), Brownfields) and other federal and state site
remediation programs.
6. Work with states on issues involving technologically-enhanced naturally-occurring
radioactive material (TENORM), including issues associated with legacy mine waste and
water treatment residue.
7. Provide comment on nuclear power plant license NEPA reviews addressing radiological
health and safety issues and emergency planning and preparedness activity.
8. Respond to increased uranium extraction and processing including regional review of
extraction facility Environmental Impact Statements and permits.
5.1.4 Measures: None
5.2 Program Guidance: Radiation Emergency Response Preparedness
5.2.1 Description: This program includes federal preparedness activities, ORIA programmatic
readiness, Radiological Emergency Response Team (RERT) personnel and equipment readiness,
development and participation in exercises, training and outreach, radiological emergency
response guidance, extensive laboratory capability for radioactive and mixed waste analyses
and RadNet, EPA's national environmental radiation monitoring system. Using a collaborative
strategy, EPA works with other federal agencies, states, tribes, and local government agencies
to ensure that the appropriate parties are fully informed and prepared to respond should an
incident involving radiation occur.
5.2.2 HQ Activities
1. Maintain the Radiological Emergency Response Team's (RERT) high level of readiness.
2. Develop updates to the 1992 Protective Action Guides Manual.
3. Provide radioanalytical laboratory capabilities and field operations to assess radioactive
contamination during an incident.
4. Provide national, near-real time data on airborne radioactive contamination including
radionuclide-specific concentrations during all phases of an incident.
5. Support urgent regional removal operations.
6. Support regions with radiological emergency response training and at exercises.
5.2.3 Regional Office Activities
1. Disseminate information on EPA's radiation response and preparedness program
activities and capabilities to the states.
2. Provide technical support to state radiation control programs.
3. Support EPA's radiation emergency response operations, including the assignment of
personnel to serve in the positions of Regional Radiation Advisor and RERT Liaison.
4. Participate in state and national radiological response.
5. Participate and support radiological response training and exercises to increase the
capacity of the agency's Response Support Corps.
OAR Final FY 2014 NPM Guidance 31
-------
5.2.4 Measures: ORIA RAD 1 and RAD 2
5.3 Program Guidance: Homeland Security: Preparedness, Response, Recovery
5.3.1 Description: Continue coordinating homeland security activities across the agency, with
the Department of Homeland Security and other federal agencies, to ensure consistency with
the National Response Framework. EPA's Radiation Program continues to integrate radiation
data into the agency's information systems and make radiation information more accessible to
the public. The program continues to enhance the national environmental radiation monitoring
system (RadNet) to better respond to radiation emergencies and prepare for potential terrorist
threats. The program also continues to provide guidance and tools to other federal agencies,
states/tribes/locals, stakeholders, and partners.
5.3.2 HQ Activities
1. Continue the pilot project to improve state radiological laboratory capacity through
provision of, training, proficiency testing, and audits of the selected state laboratories.
2. Continue to enhance the national environmental radiation monitoring system (RadNet)
to better respond to radiation emergencies and prepare for potential terrorist threats.
The RadNet network includes deployable monitors and near real-time stationary
monitors.
3. Continue to upgrade its radiological laboratory response capability, which will include a
network of public and private sector laboratories to provide capacity for radiological
terrorism incidents.
5.3.3 Regional Office Activities
1. Disseminate information on EPA's national radiation monitoring system, RadNet, to the
states.
2. Provide leadership in coordinating inquiries from RadNet monitor site personnel and
station operators; provide practical and technical support for station operators; and
serve as a liaison with RadNet system coordinators and technical experts at
headquarters.
5.3.4 Measures: None
++ End ++
OAR Final FY 2014 NPM Guidance 32
-------
Appendix A- Measures
DRAFT FY 2014 NPM Guidance Measures
Each year, the OAR National Program Guidance identifies key measures that headquarters and regions use to track progress on key
activities. Note: Bracketed text provides clarifying information about the performance measure and this text appears in the
Explanation/Comment field within the Annual Commitment System database.
ACS
Code
OAP1
OAP7
OAP8
OAQPS
M06
OAQPS
M07
OAQPS
M08
OAQPS
M09
Measure Text
Percentage increase in cumulative square footage benchmarked compared to the previous calendar
year. [These data are provided by HQ and lag by approximately one quarter.]
Number of people reached (impressions) during regional outreach/education activities in promoting
ENERGY STAR. [These activities would include presentations, publications, interviews, and webinars.
When reporting results, in the Explanation field, break impressions into categories of Residential,
Commercial, Products, or Programmatic Overview.]
Number of ENERGY STAR technical support activities. [Technical support includes, but is not limited to,
planning meetings, award ceremonies, direct assistance to the public, expertise requests, and meetings
to develop future relationships with stakeholders. When reporting results, in the Explanation field,
break these points of contact into categories of Residential, Commercial, Products, or AIL]
Percentage of state/local monitoring agency certification requests Region evaluates and forwards to
HQwhen deemed adequate.
Percentage of required Technical Systems Audits conducted to achieve an audit of each organization
within a 3-year period.
Percentage of state/local annual monitoring plans reviewed and approved within 120 days when
network changes are proposed.
Percentage of 2nd and later Approved Regional Method (ARM) requests acted on by the Region in
accordance with HQ guidance.
Non-
Commit
ment
Indicator
Yes
No
No
No
No
No
No
State
Grant
Measure
No
No
No
No
No
No
No
FY 14 National
Target
No Target
5,000
240
100%
All Regions
meet once in
3-year goal
100%
100%
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
OAQPS
M10
OAQPS
Mil
OAQPS
M12
OAQPS
M18
OAQPS
M19
OAQPS
M20
OAQPS
N001
OAQPS
N002
OAQPS
N003
OAQPS
N004
OAQPS
N005
Measure Text
Percentage of affected entities that operate monitors in accordance with Part 58, grant terms, and
QAPP.
Percentage of affected entities who submit data to AQS in accordance with Part 58.
Percentage of AQS quarterly data reviews completed and resolved for timeliness and completeness.
Percentage of NATTS Technical Systems Audits the Region participates in over a 3-year period.
Percentage of community-scale air toxics ambient monitoring programs for which Region will review
QA requirements and ensure measurement consistency with NATTS when appropriate.
Percentage of affected entities that operate NATTS in accordance with national guidance, the QMP,
and QAPPs.
Cumulative percentage reduction in population-weighted ambient concentration of ozone in all
monitored counties from 2003 baseline. [HQ reports.]
Cumulative percentage reduction in population-weighted ambient concentration of fine particulate
matter (PM2.5) in all monitored counties from 2003 baseline. [HQ reports.]
Cumulative percentage reduction in the number of days with Air Quality Index (AQI) values over 100
since 2003, weighted by population and AQI value. [HQ reports.]
Cumulative percentage reduction in the average number of days during the ozone season that the
ozone standard is exceeded in baseline nonattainment areas, weighted by population. [HQ reports.]
Percentage improvement in the number of days to process State Implementation Plan revisions
weighted by complexity. [HQ reports.]
Non-
Commit
ment
Indicator
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
State
Grant
Measure
No
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
No
FY 14 National
Target
100%
100%
100%
All Regions
meet 50%
goal
100%
100%
17%
25%
80%
50%
-3.1%
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
OAQPS
N07
OAQPS
N08
OAQPS
N09
OAQPS
N10
OAQPS
Nil
OAQPS
N29
OAQPS
N30
OAQPS
N31
OAQPS
N32
OAQPS
N33
OAQPS
P001
Measure Text
Number of final rulemaking actions on PM2.5 SIPs consistent with the annual SIP processing goal.
Number of final rulemaking actions taken on regional haze SIPs consistent with the annual SIP
processing goal.
Number of final rulemaking actions taken on redesignation requests for CO, SO2, PMi0, and lead areas,
consistent with the annual SIP processing goal.
Number of final rulemaking actions taken on redesignation requests for 8-hour ozone, consistent with
the annual SIP processing goal.
Number of final rulemaking actions taken on redesignation requests for PM2.5, consistent with the
annual SIP processing goal.
Number of completed voluntary reclassifications for 8-hour ozone nonattainment areas.
Percentage of newly violating areas/counties that Region is targeting for developing appropriate
actions to bring designated attainment areas into compliance with the NAAQS.
Number of states or local agencies developing and/or commencing implementation of innovative and
voluntary emission reduction projects, particularly local ozone reductions programs to help achieve
attainment of 8-hr ozone NAAQS and strategies for controlling emissions from wood smoke where it is
a primary contribution to PM2.5 NAAQS problems.
Number of completed attainment determination actions for 8-hour ozone nonattainment areas,
including mandatory reclassifications, clean air data requests, and one-year extension requests.
Number of final rulemaking actions taken on SIPs for 0.08 ppm 8-hour ozone for moderate areas that
were formerly subpart 1 or subpart 2 marginal areas reclassified to moderate.
Percentage of major NSR permits issued within one year of receiving a complete permit application.
[HQ reports this measure]
Non-
Commit
ment
Indicator
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
State
Grant
Measure
No
No
No
No
No
No
No
No
No
No
Yes
FY 14 National
Target
No Target
No Target
No Target
No Target
No Target
No Target
100%
No Target
No Target
No Target
78%
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
OAQPS
P06
OAQPS
P09
OAQPS
Pll
OAQPS
P12
OAQPS
P13
OAQPS
P14
OAQPS
P19
OAQPS
P20
OAQPS
T001
OAQPS
T002
OAQPS
T05
Measure Text
Number of Title V program evaluations conducted and reports completed within the fiscal year.
Percentage of state/local major NSR/PSD permits reviewed by Region for new and modified sources to
ensure consistent implementation of the NSR program.
Percentage of permitting authorities reporting complete Part 70 TOPs data.
Percentage of Part 71 significant modifications issued by Region within 18 months of receiving a
complete permit application.
Percentage of Part 71 initial permits issued by Region within 18 months of receiving a complete permit
application.
Part 71 renewals: Percentage reduction of total Part 71 extended permits.
Percentage of PSD permits issued by Region within one year of receiving a complete permit application.
Percentage of Part 70 initial permits, renewals, merged permits and significant modifications reviewed
by Region.
Cumulative percentage reduction in tons of toxicity-weighted (for cancer risk) emissions of air toxics,
compared to 1993 baseline. [HQ reports.]
Cumulative percentage reduction in tons of toxicity-weighted (for noncancer risk) emissions of air
toxics, compared to 1993 baseline. [HQ reports.]
Number of communities (e.g. CARE communities/projects) the Region is working with to assess and
address sources of air toxics, including the use of voluntary air toxic reduction programs in their
communities.
Non-
Commit
ment
Indicator
No
No
No
No
No
No
No
No
Yes
Yes
Yes
State
Grant
Measure
No
No
No
No
No
No
No
No
Yes
Yes
No
FY 14 National
Target
1 program
per Region
50%
100%
100%
94%
10%
80%
2% of Active
Part 70
Universe
42%
58%
No Target
OAR Final FY 2014 NPM Guidance
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Appendix A- Measures
ACS
Code
OAQPS
TR01
OAQPS
TR02
OAQPS
TR03
OAQPS
TR04
OAQPS
TR06
OAQPS
TR08
ORIA
IAQ5
ORIA
IAQ6
ORIA
IAQ7
Measure Text
Cumulative number of tribes with approved eligibility determinations under the Tribal Authority Rule.
Cumulative number of tribes with delegation of federal programs to address air quality conditions on
tribal lands.
Cumulative number of tribes with approved TIPs to address air quality conditions on tribal lands.
Number of tribes conducting air quality monitoring activities.
Number of tribes implementing voluntary or other non-regulatory programs.
Number of tribes that completed or updated an emission inventory during the fiscal year.
Aggregate number of children with asthma and/or their caregivers, especially in EJ areas of concern,
educated about environmental management of asthma and childhood exposure to ETS, in homes,
schools, and other settings. [In the Explanation field, break out the number of children and/or their
caregivers educated in EJ areas of concern, as determined by the grant recipient having indicated that
in their grant proposal, or as determined by the Region.]
Aggregate number of health care professionals trained about environmental management of asthma
and childhood exposure to ETS.
Number of programs enrolled in www.AsthmaCommunityNetwork.org. [At mid-year and year-end,
report the number of regional programs in Communities in Action for Asthma Friendly Environments
network found at www.AsthmaCommunityNetwork.org. Report numbers in Current Value field and
use Explanation field to describe highlights, innovations, and anecdotal information about health and
other outcomes.]
Non-
Commit
ment
Indicator
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
State
Grant
Measure
No
No
No
No
No
No
No
No
FY 14 National
Target
No Target
No Target
No Target
No Target
No Target
No Target
No Target
No Target
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
Measure Text
Non-
Commit
ment
Indicator
State
Grant
Measure
FY 14 National
Target
ORIA
IAQ8
Number of technical support activities that advance indoor air programs and guidance for healthy
buildings. [Technical support includes, but is not limited to, strategic planning meetings or pacing
events with stakeholders, fulfillment of expertise requests, training sessions, significant
outreach/education events involving healthy buildings, and other significant technical assistance
investments. At mid-year and end-of- year, report the total number to date for the fiscal year. In the
Explanation field, break out the number by building type category (homes, schools, offices, other
buildings, or all). Note: Please do not include direct individual assistance to the public (e.g., telephone
queries) or general education and outreach activities (e.g., participating at a health fair).]
Yes
No
No Target
ORIA
RAD1
Number of radiation exercises the Region participates in annually. [Bid projected number of exercises.
Report numbers in Current Value field and use Explanation field to describe the name, location, and
type of each exercise as well as the number of regional radiation program participants.]
No
No
10
(1 per Region)
ORIA
RAD 2
Number of individuals identified and trained to fill RERT liaison and radiation advisor positions. [Bid
projected total number of personnel identified and fully qualified for the RERT liaison and radiation
advisor positions. Each Region should have 1 RERT liaison and 1 radiation advisor position. Report
numbers in Current Value field.]
No
No
20
OTAQ
Ola
Number of projects implemented that promote diesel emissions reductions. [The baseline is set to zero
at the beginning of each fiscal year. At the end of each quarter, report the cumulative number of
projects since the beginning of the Fiscal Year in the Current Value field. In the Explanation field, report
the numbers and categories of projects in accordance with the Diesel Work Group's instructions and
definitions for reporting. Also in the Explanation field, report whether the data has been entered into
DRIVER. Also in the Explanation field, report the number of diesel grants awarded to projects that
affect or are likely to affect areas that may be disproportionately impacted in whole or part, as
determined by the grant recipient having indicated that in their grant proposal, or as determined by the
Region.]
Yes
No
No Target
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
OTAQ
Olb
OTAQ
Olcl
OTAQ
Olc2
OTAQ
Olc3
OTAQ
Olc4
OTAQ
Olc5
OTAQ
Olc6
Measure Text
Number of existing heavy duty diesel engines (including school bus engines) that have been retrofitted,
replaced, or retired. [The baseline is reset to zero at the beginning of each fiscal year. At the end of
each quarter, report the cumulative number of engines since the beginning of the Fiscal Year in the
Current Value field. Use the Explanation field to report whether that data has been entered into
DRIVER.]
Annual tons of NOX emissions avoided. [The baseline is reset to zero at the beginning of each fiscal
year. At the end of each quarter, report the cumulative reductions of NOX since the beginning of the
fiscal year in the Current Value field. Use the "Explanation" field to report whether the data has been
entered into DRIVER.]
Annual tons of PM emissions avoided. [The baseline is reset to zero at the beginning of each fiscal year.
At the end of each quarter, report the cumulative reductions of PM since the beginning of the fiscal
year in the Current Value field. Use the "Explanation" field to report whether the data has been
entered into DRIVER.]
Annual tons of HC emissions avoided. [The baseline is reset to zero at the beginning of each fiscal year.
At the end of each quarter, report the cumulative reductions of HC since the beginning of the fiscal year
in the Current Value field. Use the "Explanation" field to report whether the data has been entered
into DRIVER.]
Annual tons of CO emissions avoided. [The baseline is reset to zero at the beginning of each fiscal year.
At the end of each quarter, report the cumulative reductions of CO since the beginning of the fiscal
year in the Current Value field. Use the Explanation field to report whether the data has been entered
into DRIVER.]
Annual tons of CO2 emissions avoided. [The baseline is reset to zero at the beginning of each fiscal
year. At the end of each quarter, report the cumulative reductions of CO2 since the beginning of the
fiscal year in the Current Value field. Use the Explanation field to report whether the data has been
entered into DRIVER.]
Lifetime tons of NOX emissions avoided.
Non-
Commit
ment
Indicator
Yes
Yes
Yes
Yes
Yes
Yes
Yes
State
Grant
Measure
No
No
No
No
No
No
No
FY 14 National
Target
No Target
No Target
No Target
No Target
No Target
No Target
No Target
OAR Final FY 2014 NPM Guidance
-------
Appendix A- Measures
ACS
Code
OTAQ
Olc7
OTAQ
Olc8
OTAQ
Olc9
OTAQ
OlclO
02a
OTAQ
02b
OTAQ
03a
Measure Text
Lifetime tons of PM emissions avoided.
Lifetime tons of HC emissions avoided.
Lifetime tons of CO emissions avoided.
Lifetime tons of CO2 emissions avoided.
Percentage of timely adequacy/inadequacy determinations made by the Region for identified mobile
source budgets included in control strategy SIPs or maintenance plans for transportation-related
criteria pollutants (e.g., ozone, CO, PM2.5, PM10) submitted by states. [Report % in the Current Value
field. Use Explanation field to report the actual number of determinations made, for what SIPs, and
which pollutants.]
Percentage of approval/disapproval rulemaking actions taken on mobile budgets included in control
strategy SIPs or maintenance plans for transportation-related criteria pollutants (e.g., ozone, CO, PM2.5,
PMio) at the time of final rulemaking on such SIPs. [Report % in the Current Value field. Use the
Explanation field to report the actual number of approval/disapproval rulemaking actions taken for
what SIPs and which pollutants.]
Percentage of transportation conformity determinations submitted by US DOT or an MPO that the
Region reviewed and commented on for 8-hour ozone, PM25, PMi0, and CO nonattainment and
maintenance areas. [Report % in the Current Value field. Use the Explanation field to list the
conformity determinations reviewed, where, and for which pollutants.]
Non-
Commit
ment
Indicator
Yes
Yes
Yes
Yes
No
No
No
State
Grant
Measure
No
No
No
No
No
No
No
FY 14 National
Target
No Target
No Target
No Target
No Target
100%
100%
100%
OAR Final FY 2014 NPM Guidance
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Appendix A- Measures
ACS
Code
OTAQ
03b
OTAQ
04
OTAQ
06
OTAQ
08
SIRG1
SIRG2
SIRG3
CARE-2
CARE-3
Measure Text
Number of final rulemaking actions taken by the Region on Transportation Conformity-related SIP
revisions consistent with the annual SIP processing goal. [Report number in the Current Value field and
use the Explanation field to provide the actual total number of submitted SIPs where the due date for
final rulemaking falls in FY 2014. Also, explain if bidding fewer than the universe and if reporting Status
as "not on target" or "measure not met."]
Number of outreach activities conducted by the Region to support SmartWay programs. [Report the
number of events in the Current Value. In the Explanation field, list the outreach events including
names and dates of events.]
Percentage of I/M reports submitted by states for existing I/M programs (including OBD) reviewed by
the Region. [Report % in the Current Value field. In the Explanation field, provide the actual number of
I/M reports that were submitted and reviewed, and from which states.]
Number of CMAQ-funded clean diesel projects implemented by state/local governments. [Report the
actual number of projects in the Current Value field. In the Explanation field, indicate whether the data
has been entered into DRIVER.]
Number of additional homes with operating mitigation systems.
Number of additional homes built with radon-resistant new construction.
Number of additional schools mitigated and/or built with radon-resistant new construction.
Number of communities who have developed and agreed on a list of priority toxic and environmental
concerns using the CARE partnership process (annual).
Number of communities who, through the CARE Program, implement local solutions to address an
agreed upon list of priority toxic and environmental concerns using the CARE partnership process
(annual).
Non-
Commit
ment
Indicator
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
State
Grant
Measure
No
No
No
No
Yes
Yes
Yes
No
No
FY 14 National
Target
Sum of Bids
No Target
100%
No Target
No Target
No Target
No Target
No Target
No Target
++ End ++
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
Effective Use and Distribution of STAG Funds
1. GRANT ASSISTANCE TO CO-IMPLEMENTERS
The President's FY 2014 budget requests $276.4 million in State and Tribal Assistance Grant
(STAG) funds for air grant programs. $257.2 million is targeted for continuing air programs
carried out by states/locals—which is $21.5 million higher than the FY 2012 enacted level. The
request for the diesel emission reduction program is $6.0 million and the Tribal air grant
program is $13.3 million. The agency is not requesting funds for a state indoor radon grant
program in FY 2014.
Table B-l. Comparison of State and Tribal Assistance Grants for Air: FY 2011-2014
(in $Ms)
Program Area
Continuing State/Local Air Program
Diesel Emission Reduction Program
State Indoor Radon
Tribal Air Program
Total
FY 2011
Enacted
236.107
49.900
8.058
13.273
$307.338
FY 2012
Enacted
235.729
29.952
8.045
13.252
$286.978
President's
FY 2013
Request
301.500
15.000
0.0
13.566
$330.066
President's
FY 2014
Request
257.229
6.000
0.0
13.252
$276.481
A. Continuing Air Program
The $257.2 million state/local continuing air program portion of the President's request
includes an increase of $21.5 million over FY 2012 enacted levels and in total supports
state/local continuing air programs including the expanded core state/local agency work
associated with implementing revised or new NAAQS and monitoring adherence with stationary
source regulation; the increased number of monitors required by new or revised NAAQS; and
the development of state/local technical capacity to address GHG emissions in permitting of
large sources. The requested resources will provide vital assistance to states and locals to
design, implement, and fund plans to meet standards to improve air quality in communities
across the nation and that further build the framework to produce air quality and climate-
change co-benefits wherever possible.
Core Activities: EPA's requested increase will support expanded core state workload to
implement revised and more stringent NAAQS, monitor industry compliance with EPA
stationary source regulations, and to meet revised NAAQS ambient monitoring requirements.
As EPA continues to update and issue more protective NAAQS according to CAA deadlines,
revision of the NAAQS typically triggers the preparation of new or updated SIPs. Due to the
multi-pollutant, and often regional nature of air pollution, preparation and implementation of
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
state air quality implementation plans (SIPs) to address it have become increasingly complex
requiring additional modeling, technical analysis, refined emission inventories, monitoring, and
increased stakeholder involvement and coordination. States/locals are also addressing
hazardous air pollutants and new types of air pollution sources, such as biomass and
agricultural sources, and carrying out new and more complicated planning strategies to address
GHGs. Additionally, funds will support GHG permitting to provide state and local agencies the
resources to review permit applications and issue permits to large sources of greenhouse gas
emissions and especially to handle sources that are new to air permitting.
Ambient Monitoring: The CAA requires EPA to review each NAAQS every five years and revise
them if necessary. A revision of a NAAQS may place new monitoring requirements on
states/locals/tribes. The funding requested in FY 2014, will support purchase costs of
states/locals for new or replacement monitors for ozone, lead, S02, and N02. Funding of air
monitoring, including a proposed transition in funding authorities for PM2.s monitoring and
changes in the provision of associated program support, is addressed in greater detail in the
Monitoring Guidance available on the web at http://www.epa.gov/ttn/amtic/. The Agency is
developing a detailed allocation of its monitoring resources which will be influenced by the final
NAAQS rules and the refinement of existing networks.
Allowance Trading Programs: EPA intends to continue to use approximately $2.3 million in
STAG funds as associated program support to operate the Clean Air Interstate Rule (CAIR) NOx
Ozone Season Trading Program on behalf of participating states. These states, in the future,
may transition into other programs for control of transported pollution and will need to
continue making contributions.7 States not affected by or participating in a regional program do
not contribute funding to it. Pending state-by-region figures are shown in Table B-2.
7 In an August 21, 2012 opinion, the U.S. Court of Appeals for the D.C. Circuit vacated the Cross-State Air Pollution
Rule (CSAPR) and ordered EPA to continue implementing the previously remanded CAIR pending development of a
valid replacement. On March 29, 2013, the Department of Justice filed a petition seeking Supreme Court review of
the D.C. Circuit decision. Even though CSAPR was vacated, and regardless of the outcome of remaining litigation,
EPA and the states are still responsible under the Clean Air Act for addressing inter-state transport of air pollution.
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
Table B-2: Draft FY 2014 Contribution
CAIR NOX Ozone Season Trading Programs by Region and State ($)
Region
1
2
3
4
5
6
7
State
Connecticut
Massachusetts
New Jersey
New York
Delaware
District of
Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Alabama
Florida
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Illinois
Indiana
Michigan
Ohio
Wisconsin
Arkansas
Louisiana
Iowa
Missouri
Total Annual Units/Dollars
Units Affected by
CAIR Ozone Program
62
90
152
178
363
541
40
5
50
211
137
80
523
126
299
109
103
159
100
105
1001
280
187
158
193
106
924
49
107
156
68
121
189
3,486
Contribution to NOX
Trading Program Cost
41,230
59,850
101,080
118,370
241,395
359,765
26,600
3,325
33,250
140,315
91,105
53,200
347,795
83,790
198,835
72,485
68,495
105,735
66,500
69,825
665,665
181,596
124,355
105,070
128,345
70,490
609,856
32,585
71,155
103,740
45,220
80,465
125,685
$2,313,586
* Processing cost per source calculated as $665 by OAP/CAMD.
Trans-Boundary Program - Great Lakes Air Deposition (GLAD) Program: The GLAD program is
part of the overall Great Lakes program, the goal of which is to restore and maintain the Great
Lakes ecosystem. GLAD promotes the coordination of efforts to reduce air toxics deposition
and its resulting adverse impacts by supporting scientific research, information gathering, and
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
collaboration among policy makers. The program, which also supports the Great Lakes Water
Quality Agreement with Canada, shares STAG resources among the eight Great Lakes states:
Illinois, Indiana, Minnesota, Michigan, New York, Ohio, Pennsylvania, and Wisconsin. In FY
2014, approximately $1.2 million is proposed to be awarded to these states under §105 as part
of their categorical air program grant or as an air work plan element in a performance
partnership grant.
Program Contact: Erin Newman, Region 5, (312) 886-4587.
Trans-Boundary Program - US-Mexico Border Air Program: EPA and its Mexican counterpart
SEMARNAT have established Border 2020, a bi-national program focused on cleaning the
environment, protecting public health, and ensuring emergency preparedness for the 12 million
people who live along the border. The program supports the initiatives of the affected state,
local, and multi-jurisdictional agencies on both sides of the border and uses regional
workgroups, task forces, and policy forums to develop and implement pollution reduction
strategies. In FY 2014, approximately $2.2 million is proposed to be awarded to eligible
states/locals as part of their §105 air grant.
Program Contacts: Ruben Casso, Region 6, (214) 665-6763 and Dave Fege, Region 9, (619) 235-
4769.
Multi-Jurisdictional Organizations (MJOs): Numerous states/locals have found it advantageous
to form MJOs to help coordinate their geographically specific clean air interests at the regional
level. A state or local agency wishing to fund an MJO may: a) direct that the Regional Office set
aside that agency's desired contribution from its prospective portion of the regional allotment
(i.e., on a pre-allotment basis); or, b) directly fund the MJO once the state or local agency
receives its allotment. A Regional Office may provide STAG funding to such an organization
using §103 authority only if: the contributing agencies provide their prior consent; the MJO is
eligible for the funding; and, the MJO's activities are appropriate as associated program
support. Funding for regional-scale MJOs is not delineated as part of the national region-by-
region allocation of STAG funds but is instead identified within the respective Region's
allotments to its state/local agencies.
Currently only one national-level MJO has its funding delineated as part of the region-by-region
allocation of STAG funds—the National Association of Clean Air Agencies (NACAA). NACAA is
the national association of state, territorial, and local air pollution control agencies and it is
comprised of representatives from member air pollution control agencies. NACAA provides
associated program support to its member state/local agencies by coordinating their air quality
activities at the national level and engaging in activities that enhance their effectiveness.
Member agencies support NACAA with their own STAG funds by either: (a) providing their prior
consent to EPA to target a portion of the funds that would otherwise be allotted to them to go
instead for direct award to NACAA; or (b) directing that NACAA bill them directly for their
membership dues. Section 105 recipients who are not members of NACAA do not have their
allotments affected. The award of funds to NACAA is subject to Agency review and approval.
Approximately $1.4 million was awarded to NACAA for its most recent grant year.
Program Contact: Margaret Walters, OAR, (202)564-4107.
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
Clean Air Act Training: CAA §103(b) authorizes EPA to provide training for air pollution control
personnel and agencies, and to make training grants related to the causes, effects, extent,
prevention, and control of air pollution available to air pollution control agencies and other
qualified entities. EPA is targeting approximately $2 million in STAG funds for the support of
CAA training provided by MJOs and other state training programs in FY 2014. These funds are
subject to consultation and concurrence with participating states/local agencies. As discussed
with the State/EPA workgroup on prioritization, EPA will continue working with the NACAA
Training Committee and the MJOs (MARAMA, WESTAR, Metro4/SESARM, LADCO, CENSARA and
NESCAUM)to:
1. Implement a learning management system to improve the administration and delivery
of classroom and web-based training;
2. Update self-instructional courses into a web-based format; and,
3. Develop curricula to facilitate the training of state and local air pollution agency staff on
both introductory and more advanced SIP development.
In addition, the EPA is expanding its use of training webinars, and expects to continue with
web-based videos, website development, and other available means to support training and
outreach for state and local agencies. The Agency intends to continue to record and post all of
our training on the Air Pollution Training Institute website (http://www.epa.gov/apti/) as on-
going training tools.
Program Contact: Debbie Stackhouse, OAR, (919) 541-5281.
Ozone Transport Commission (OTC): For FY 2014, a total of about $639K has been targeted to
support the OTC which represents Northeastern and Mid-Atlantic States in the Ozone Transport
Region (OTR). The OTC is funded through CAA §106 grants and matching support of 40% of the
total approved program costs is required from member agencies.
Program Contact: Pat Childers, OAR, (202) 564-1082.
B. Diesel Emission Reduction Program
The FY 2014 request is $6 million. These funds are proposed to be allocated for rebates and
low cost loans to reduce emissions from older engines, and to national grants in priority areas
and areas of highly concentrated diesel pollution.
For additional information see http://www.epa.gov/cleandiesel/grantfund.htm.
Program Contact: Jennifer Keller (202) 343-9541.
C. Other Grant Programs
Tribal Air Grants: Through CAA §105 grants, tribes may develop and implement programs to
prevent and control air pollution or to implement national ambient air quality standards, NSR
and permit programs, and delegated federal programs like Part 71 and MACT standards.
Through CAA §103 grants, tribes, tribal air pollution control agencies, and multi-tribe
jurisdictional air pollution control agencies may conduct and promote research, investigations,
experiments, demonstrations, surveys, studies and training related to ambient or indoor air
OAR Final FY 2014 NPM Guidance
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Appendix B- Effective Use and Distribution of STAG Funds
pollution on tribal lands. For additional information see http://www.epa.gov/air/tribal.
Information on the allocation of tribal air grants will be provided at a later date.
Program Contact: Pat Childers, OAR, (202) 564-1082.
State Indoor Radon Grant (SIRG) Program: EPA is not providing states or Tribes with new funds
for the State Indoor Radon Program (SIRG) program. However, some state and tribal programs
will be able to continue operations in FY 2014 with funding provided in FY 2012 and FY 2013
continuing resolutions. EPA is encouraging state and tribal radon programs to maintain their
programs to the extent possible. The construction of new homes and schools with radon-
resistant features should remain a priority. The mitigation of homes and schools with radon at
or above the EPA action level should also be a priority.
Human exposure to radon gas continues to be an important risk to human health. Over the past
24 years, the SIRG program has provided important general and technical guidance to build
capacity, and helped establish state radon programs - with a few of them now being self-
sustaining. It is hoped that states will seek ways to continue their radon programs in the
absence of new federal funding. EPA will continue efforts to motivate the public to mitigate
homes and schools with high radon levels. EPA will continue its collaborative work to develop
standards of practice, and to institutionalize radon-resistant construction in state and local
building codes. EPA will also continue driving radon risk reducing action at the Federal level
through its implementation of the Federal Radon Action Plan, and in collaboration with private
sector industry partners and non-governmental organizations.
Program Contact: Phil Jalbert, OAR, (202) 343-9431.
2. EFFECTIVE GRANTS MANAGEMENT
Administrative and programmatic provisions for effective oversight and utilization of
continuing program and project-specific grants awarded to states/locals/tribes and multi-
jurisdictional entities are summarized below. The list is not exhaustive but includes the proper
use of award authority, adherence to specific grant program requirements, effective post-
award oversight, identification of performance measures and results, the funding of co-
regulator organizations, and the promotion of competition.
Using Proper Authorities for Award: OAR provides guidance to its program offices and the
regions via the intranet that clarifies who is eligible for grant assistance given the purpose of
the funded activity, the appropriation, and the grant authority associated with the funds. OAR
will update the guidance to reflect any changes associated with its annual appropriation, as
needed.
Program Contacts: Courtney Hyde, OAR, (202) 564-1227 and Margaret Walters, OAR, (202)
564-4107.
Ensuring Effective Oversight of Assistance Agreements: EPA Order 5700.2A2, effective January
1, 2008, updated and streamlined the post-award management of grants and cooperative
agreements. The Order requires EPA offices to monitor a recipient's compliance with its
programmatic terms and conditions, the correlation of the work plan and application content
OAR Final FY 2014 NPM Guidance
-------
Appendix B- Effective Use and Distribution of STAG Funds
with actual grant progress, the use of equipment, and compliance with relevant statutory and
regulatory requirements. Offices are required to submit oversight plans and document their
execution. For EPA personnel, the Order may be found at
http://intranet.epa.gOV/ogd/policy/4.0-PostAward-Topics.htm. See also:
http://www.epa.gov/ogd/EO/finalreport.pdf.
Improving Grant Workplans: States/tribes/locals seeking single media air grants or
Performance Partnership grants containing air or radon elements should submit grant work
plans that show clear linkages between the recipient's efforts and the agency's Strategic Plan
goals and objectives. The agency's long-term goal is for EPA and the states to achieve greater
consistency in work plan formats. Accordingly, the Office of Grants and Debarment (OGD)
issued Grants Policy Issuance (GPI) 11-03, "State Grant Workplans and Progress Reports."
(http://www.epa.gov/ogd/grants/final grants policy issuance 11 03 State Grant Workplans
.pdf.) Regional Program Offices should ensure that the GPI is incorporated in workplan
negotiations, and provides appropriate outreach to recipients.
Contact: Jennifer Hublar, OARM/OGD, (202) 564-5294.
Achieving Programmatic and Environmental Results: Recipients have the obligation to
articulate sound measures of performance and report insightful and useful results data. EPA
Order 5700.7 - "Environmental Results in Grants" applies to all grants not just categorical
grants to states. The Order requires EPA project officers to assure that each grant: (a) links to
the Agency's strategic architecture, (b) articulates measurable outputs and outcomes, and (c)
reports the programmatic, and where possible, environmental results achieved. For more
information, see http://www.epa.gOV/ogd/grants/award/5700.7.pdf.
Promotion of Competition: Agency policy is to promote competition in the award of grants and
cooperative agreements where practical. EPA Order 5700.5A1 presents the Agency's
competition policy. The Order exempts grants for continuing environmental programs, such as
those funded under §105 as well as §103 grants for PM2.s monitoring, §103 national air toxics
monitoring trends network grants, federally-recognized tribes, and inter-tribal consortia under
OAR's tribal grant program; and TSCA §306 grants for state indoor radon programs. Radon
grants to tribes and intertribal consortia under TSCA §10 grants must be competed. EPA is not
precluded from awarding grants through competition for a portion of the exempted programs if
the Agency determines it is in the best interest of the public to do so. The Competition Policy
may be found at http://www.epa.gov/ogd/competition/5700 5Al.pdf.
Contact: Maureen Hingeley, OAR, (202) 564-1306.
Approval Process for STAG Awards to Co-Regulator Organizations: A co-regulator organization
is defined by EPA as a national or regional (i.e., multi-jurisdictional) organization that represents
the interests of co-regulators/co-implementers (state, tribal or local governments) in the
execution of national or regional environmental programs. EPA issued a policy on December 1,
2006 that clarified that the head of the affected state agency or department (e.g., the state
environmental commissioner or head of the state public health or agricultural agency) be
involved in the funding process and that EPA request and obtain the prior consent of this
official before taking funds off the top of a state grant allotment for direct award to a
OAR Final FY 2014 NPM Guidance
-------
Appendix B- Effective Use and Distribution of STAG Funds
state/local co-regulator organization. On October 12, 2011, the Agency further clarified that
co-regulator organizations are exempted from competition for awards made using funds
appropriated by Congress under the STAG appropriation for certain co-regulator activities that
clearly support, or are extensions of, core state, local or tribal agency responsibilities. The
clarification also notes that awards made to co-regulators using other than STAG funds, though
not exempted from competition, could qualify for an exception from competition on a case-by-
case basis, if properly justified.
3. CATEGORIZATION and ALLOCATION of §105 GRANTS
In January 2010, after several years of planning, analysis and stakeholder consultation, EPA
produced an updated approach for the allocation of CAA §105 state/local continuing air
program grants. The approach adhered to the considerations in the CAA of population, actual
and potential air pollution, and relative financial need and used a set of guiding principles that
featured relevance, feasibility, transparency and maintaining the stability of ongoing state/local
operations. A category and factor-driven methodology developed by a contractor-supported
EPA workgroup (see Table B-3) served as the initial basis but was subsequently adjusted by OAR
to limit the maximum percentage reduction from the prior year for any one region.
Table B-3. EPA Workgroup Allocation Methodology (w/o OAR Adjustment)
Category
SIP Planning
and
Implementation
Monitoring
Air Toxics
Compliance
Category
Weight
38
33
15
14
Factors
Population-weighted design value in N/A areas
measuring unhealthy air
Number of non-attainment areas
Population-weighted design-value in areas
within 90% of the NAAQS
Number of states
Adequate monitoring network
Cancer risk
Non-cancer risk
Diesel emissions
Number of regulated minor sources
Number of MACT area sources
Number of mobile source compliance programs
Factor
Weight
60
10
20
10
100
45
30
25
50
30
20
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Appendix B- Effective Use and Distribution of STAG Funds
In April 2011, the Assistant Administrator indicated that the agency would move towards a
reallocation consistent with its guiding principles and would work with states/locals in
implementing a reasonable, equitable approach. To date, the agency has not implemented the
reallocation due to congressional language that directs the EPA to use the existing allocation
methodology.
In FY 2014, the EPA anticipates implementing the revised allocation formula in order to target
resources to the most pressing air quality problems while maintaining the integrity of
state/local air program operations. The FY 2014 President's Budget Request includes $257.2
million for the state/local continuing air program, an increase of $21.5 million over FY 2012
enacted levels. Should EPA not receive the requested increase, shifts in funding will be
moderated so that no region will experience a decline of more than 5% of its prior year funding
level. This approach will be phased in over a multi-year period and can be re-evaluated based
upon the analysis of relevant and current data, changes in air quality, and/or changes in
available funding.
Table B-4 outlines potential funding scenarios given the President's request level as well as the
possibility of static funding or reduced funding.
Table B-4. Potential Funding Scenarios and Re-Allocation
Funding
Scenario
FY 2014
President's
Request
FY 2012
Enacted
Level
Funding Level
$257.2M
(Actual amount
directly
attributable to
S/Ls is less.)
$235.7M
(Actual amount
directly
attributable to
S/Ls is less.)
Possible Re-
Allocation
Approaches
OAR-Adjusted
OAR-Adjusted
Explanation
• Uses EPA WG Methodology but adjusts results
so that no Region's percentage share of total
dollars available to S/Ls declines by more than
5%.
• OAR-adjusted percentages would be applied to
the full amount of available funds but no
Region's allotment could decline by more than
5% from the previous year's enacted level each
year over a defined multi-year period.
++ End ++
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Appendix C - State and Local Agency Activities
State and Local Agency Activities
For ease of reference, below is a compilation of the expected activities of state/local agencies
listed under the different program/topic headings in the Outdoor Air Quality chapter of the
main document.
NAAQS
SIPs
1. Develop and submit SIP revisions, if desired, to remove active Stage II gasoline vapor
recovery programs.
2. Develop and submit infrastructure SIPs for the 2012 PM NAAQS and 2008 ozone NAAQS,
2010 N02 and S02 NAAQS, if not yet submitted.
3. Develop attainment demonstration SIPs for S02 nonattainment areas designated in
2013 and conduct other S02 air quality planning in accordance with EPA rules and
guidance.
4. Develop and submit attainment demonstration SIPs for 2008 ozone NAAQS and 2008
lead NAAQS.
Designations
1. Submit state recommendations for area designations and boundaries for the 2012 PM2.5
NAAQS.
Other
1. Conduct public notification and education efforts, including reporting air quality
forecasts and current conditions for ozone and particle pollution.
2. Implement strategies for controlling emissions from wood smoke where it is a
significant contributor to air quality problems, including regulatory and non-regulatory
measures.
3. Submit redesignation requests including maintenance plans for areas with clean data.
4. Implement strategies to attain the 2008 lead NAAQS.
5. Prepare to submit data for the 2014 National Emissions Inventory (due December 2015).
6. Participants in Ozone and PM Advance will continue to implement as desired and, if
necessary, supplement their actions plans.
Regional Haze
1. Work on remaining issues related to submitted regional haze SIPs.
2. Implement BART requirements.
3. Submit interim progress report SIP due 5 years after the submittal of the initial Regional
Haze SIP as required under 51.308(g) for applicable states.
Title V and NSR
1. Provide data in a timely manner on new title V permits and significant permit
modifications to EPA for entry into TOPS.
OAR Final FY 2014 NPM Guidance
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Appendix C - State and Local Agency Activities
2. Issue initial permits, significant permit modifications, and renewal title V permits and
reduce backlog of renewal permits.
3. Participate with EPA in title V permit program evaluations, set targets to respond to
EPA's evaluation report and implement recommendations.
4. Issue 78% of major NSR permits within one year of making the determination of
completeness.
5. Issue NSR permits consistent with CAA requirements and enter BACT/LAER
determinations in the RACT/BACT/LAER Clearinghouse (RBLC).
6. Provide data in a timely manner on NSR permits issued for new major sources and major
modifications by entering data including "the application accepted date" and "the
permit issuance date" into the RBLC national database.
Ambient Monitoring for Criteria Pollutants
1. Submit 2015 annual network plan required by 40 CFR §58.10, by July 1, 2014, unless
another schedule has been approved.
2. Install and begin operation of near-road N02 monitors in CBSA's of 1M population or
more by January 1, 2014 Continue planning for next phase of N02 monitors due by
January 1, 2015 (2nd required monitors in largest CBSA's or areas with road segments >
250K AADT).
3. Convert airport study lead monitors from special purpose monitors to required SLAMS
for any monitors that recorded design values exceeding 50% of the lead NAAQS.
4. Operate monitors for other NAAQS pollutants, NCore, PM2.5 speciation, and PAMS
according to 40 CFR Part 58, approved monitoring plans, and/or grant agreements
including QMPs and QAPPs. (M10)
5. Submit NAAQS pollutant data, PAMS, NCore, and QA data to AQS according to schedule
in 40 CFR Part 58. (Mil)
6. Certify 2013 NAAQS pollutant data in AQS and provide supporting documentation by
May 1, 2014, including exceptional event flags.
7. Ensure adequate independent QA audits of NAAQS monitors including PEP and NPAP or
equivalent.
8. Conduct monthly QA checks for flow rates of PM2.5 speciation monitors and submit data
quarterly to AQS. Target is for 75% completeness.
9. Report real time data to AirNow for cities required to report the AQI.
Air Toxics Program Implementation
1. Prepare to submit data for the integrated 2014 emissions inventory due December
2015.
2. Develop and implement delegated or approved air toxic standards, as appropriate, for
major sources and area sources.
3. Implement delegated residual risk standards.
4. As resources allow, work with communities to develop and implement voluntary air
toxics programs that address outdoor, indoor, and mobile sources with emphasis on
areas with potential EJ concerns.
5. Conduct data analysis and assessment of air toxics monitoring data.
OAR Final FY 2014 NPM Guidance
-------
Appendix C - State and Local Agency Activities
Ambient Air Monitoring for Toxics
1. Operate NATTS sites, including study sites, according to EPA's technical guidance and
theQAPPandQMP. (M20)
2. Participate in inter-laboratory Proficiency Testing and Technical System Audit programs
according to national guidance and the approved QAPP and QMP.
3. Submit NATTS data to AQS quarterly within 120 days of end of each quarter. The data
objective for completeness rate is 85% of the potential concentration values for each
quarter.
4. Submit data from federally-funded community monitoring projects to AQS quarterly
within 120 days of end of each quarter. The data objective for completeness rate is 85%
of the potential concentration values for the study period.
5. Conduct federally-funded community assessment projects consistent with grant terms
(including schedule), technical guidance, and applicable quality-assurance project plans
(QAPPs) and quality management plans (QMPs).
Allowance Trading Programs
1. Submit any state-promulgated allowance allocations decisions to EPA for incorporation
into unit accounts.
2. Assist sources with monitor certifications and recertifications, emissions monitoring,
and reporting.
3. Perform electronic and field audits of monitor certifications, Part 75 continuous
emissions monitoring systems (CEMS), and emissions reporting by sources. EPA
encourages states/locals to perform Part 75 CEMS field audits in accordance the field
audit manual located on the EPA Clean Air Markets website. Provide reports of the
audits and any corrective actions needed to the EPA regional office and HQ.
Mobile Source Programs
1. Implement mobile source control strategies (such as I/M programs and Transportation
Control Measures) on time and consistent with SIP commitments.
2. Implement grants effectively to accomplish needed reductions (e.g., DERA grants).
3. Work with transportation agencies as appropriate to update mobile SIP budgets in
response to changing needs such as updates to the mobile model MOVES or other
changes.
4. Update out-of-date conformity SIPs to allow states to use flexibilities in the recent rule.
++ End ++
OAR Final FY 2014 NPM Guidance
-------
Appendix D - Contacts
Points of Contact for Questions or More Information
Subject Area Contact Name Phone Email
Criteria Pollutants, Air Toxics, Multi-
pollutant Planning, and Regional
Haze
Trading Programs
Mobile Sources
State/Local Air Grants
Tribal
Indoor Environments
Radiation
Climate Change: GHG Reporting
Rule
Climate Change: ENERGY STAR and
Related Programs
Climate Change: Voluntary Methane
Programs including Global Methane
Initiative
Climate Change: Mobile Source
Programs
General Questions
Jeff Whitlow
Doris Price
Larry Kertcher
Courtney McCubbin
Margaret Walters
Pat Childers
David Rowson
Jonathan Edwards
Anhar Karimjee
Karen Schneider
Pamela Franklin
Courtney McCubbin
Margaret Walters
919-541-5523
202-343-9067
202-343-9121
202-564-2436
202-564-4107
202-564-1083
202-343-9449
202-343-9437
202-343-9260
202-343-9752
202-343-9476
202-564-2436
202-564-4107
whitlow.ieff@epa.gov
price. doris@epa.gov
kertcher.larry@epa.Rov
mccubin.courtney@epa.Rov
waiters. marRaret@epa.Rov
childers.pat @epa.Rov
rowson.david@epa.Rov
edwards.ionathan@epa.Rov
karimiee.anhar@epa.Rov
schneider.karen@epa.Rov
franklin. pamela@epa.Rov
mccubin.courtney@epa.Rov
waiters. marRaret@epa.Rov
++ End ++
OAR Final FY 2014 NPM Guidance
-------
Appendix E - Key Changes from FY 2013 Guidance
Appendix E - Key Changes in FY 2014 NPM Guidance Compared to FY 2013
Chat
General
General
General
Annual
Commitment
Measures
Funding
Contacts
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The draft OAR FY 2014 NPM Guidance follows the new format
for all NPM Guidances; includes a new OCFO Overview; and is
streamlined and uses weblinks where appropriate. The
document also shifts from a Chapter focus to "National Areas
of Focus."
Chapter on Stratospheric Ozone is dropped.
The detailed Ambient Air Monitoring guidance is no longer
included with this NPM guidance but instead is posted on
EPA's Ambient Monitoring Technology Information Center
website at http://www.epa.gov/ttn/amtic/ under Regulations
and Guidance.
OAQPS P20: Percentage of Part 70 initial permits reviewed by
Region and OAQPS P21: Percentage of Part 70 permit
renewals reviewed by Region are streamlined and merged
into revised OAQPS P20: Percentage of Part 70 initial permits,
renewals, merged permits and significant modifications
reviewed by Region.
Funding information reflects FY2014 President's Budget
Submission to Congress.
Margaret Walters is now the overall contact for OAR's NPM
Guidance. Other contacts in Guidance updated as appropriate.
The draft OAR FY 2014 NPM Guidance incorporates the
results of the agency's NPM Guidance Lean effort.
Because the Stratospheric Ozone program is headquarters in
nature, it has been dropped from the document.
Reduce the paper footprint of the NPM guidance. The
monitoring guidance is mostly of interest to a specific
technical community of practitioners.
Measures merged after consultation with the regions to
reflect streamlining of measurement based on the nature of
the program oversight and relations with their states.
Updates budget year.
Personnel change
Effected
Sections
All Sections
The Ambient Air
Monitoring
guidance
Appendix A
Appendix B
Appendix D
++ End ++
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
FY 2014 EXTERNAL COMMENTS AND RESPONSE TO COMMENTS
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Issue Area: General Comments - Agriculture
Finalize emissions estimation methodologies for
animal feeding operations (AFOs) to use to
determine whether such operations are subject to
the Clean Air Act
NACAA
2.1.2.3
EPA will continue development of draft CAFO
emissions estimation methodologies and associated
implementation tools for CAFO owners/operators. In
April 2013, we received recommendations from the
SAB on our draft emission estimation methods for two
types of animal feeding operations.
No change
Issue Area: General Comments - Enforcement
Work with state and local air agencies to devise air
enforcement reporting requirements that are not
overly burdensome and minimize resource
demands while meeting EPA oversight
requirements (i.e., assure EPA that delegated
agencies are meeting federal grant commitments
are provide information for the public that
demonstrates state agency air pollution control
program compliance and enforcement activities at
stationary sources); and Modernize the Air Facility
System , while minimizing agency resource
demands required to enter data, operate and
maintain the system.
NACAA
NA
To manage the national air stationary source
compliance monitoring and enforcement program, the
EPA Office of Enforcement and Compliance Assurance
(OECA) has established a set of minimum data
requirements (MDRs). As discussed in the currently
approved OMB Source Compliance and State Action
Reporting (Renewal) Information Collection Request
(ICR), the compliance and enforcement information
collected from state and local air agencies is a well
established process. OECA reaches out and
extensively consults with our state/local partners in
development of the MDRs to ensure that the Agency
meets its responsibilities such as ensuring effective
and consistent compliance and enforcement programs
by the delegated agencies and to minimize the
state/local reporting burden by obtaining only the
information that is critical for our needs.
In acknowledging the increased resource constraints
now being encountered by the state/local agencies,
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
OECA is also currently reviewing underlying guidance
documents such as the Timely and Appropriate (T&A)
Enforcement Response to High Priority Violations
(HPVs) Policy and the Clarification Regarding Federally-
Reportable Violations for Clean Air Act Stationary
Sources to determine if the state/local reporting
burden can be reduced to a greater degree. The
delegated agencies and various air associations such as
NACAA have been included in this review and their
input is being taken into account. While striving to
minimize the reporting burden, the Agency is
cognizant of the requirement to continue obtaining
the information necessary for multiple purposes such
as using data to assist in implementing national
programs and enforcement efforts, understanding the
ability of regulated entities to comply with regulations
and permits, supporting better targeting and
enhanced enforcement strategies, and informing the
Agency oversight responsibilities.
OECA also appreciates and values the involvement of
NACAA members in the AFS modernization process to
date. Burden reduction was identified as a
fundamental principle of the AFS modernization effort,
and we believe the modernized AFS will result in
burden reduction for NACAA members through such
things as improved usability, eliminating duplicate data
entry, and making data easier to retrieve from the new
system. Also, NACAA members will not be responsible
for the operation and maintenance of the modernized
system; rather, EPA will maintain this responsibility.
We remain committed to working with NACAA
members during the design and development of ICIS-
Action Taken
in Final
Guidance
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Issue Area: General Comments - Energy Efficiency and Renewable Energy
Support state and local efforts to deploy energy
efficiency and renewable energy.
NACAA
NA
We will continue to work with state and local
governments to account for energy efficiency (EE) and
renewable energy (RE) in their ozone SIPs. In
particular, we're encouraging interested states to use
the process and the supporting analytical resources
highlighted in the EE/RE in SIPs Roadmap. We will
continue to work through NACAA to help states
quantify the emissions benefits of EE/RE. Additionally,
we're using insights from 3 states that are
participating in a pilot through NESCAUM to enhance
policy and analytic capabilities in preparation for
formal SIP submittals. In the near future, we'll be
asking states for their input on two new analytical
resources that will help them understand the
estimated impacts of EE/RE policies on emissions.
Finally, we are working with 50 Climate Showcase
Communities across the U.S. who are demonstrating
innovative, cost-effective and replicable strategies to
reduce GHGs, often leveraging EE/RE.
No change
Issue Area: General Comments - Direct Funding and Support of Local Air Pollution Control Agencies
There are a number of issues covered in this
document and whereas we certainly have opinions
on these issues, the purpose of this letter is to
address one primary topic, that being the direct
funding and support of local air pollution control
agencies.
RAPCA
NA
EPA recognizes the important role that local air
pollution control agencies serve, many of which
receive direct federal grants to carry out significant
implementation activities. The OAR NPM Guidance
identifies the types of activities that are the
responsibilities of Headquarters, regions, tribes, and
state and local air agencies. When EPA provides
No Change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
guidance to air agencies, we define those as state,
tribal, or local air pollution control agencies.
In order to carry out a national system of
environmental protection, EPA and state
environmental agencies work together. CAA Section
302(b) refers to the designation of agencies by the
Governor or elected officials and their role in charging
local air agencies with specific responsibilities under
the Act. Clearly, local agencies have a role in
implementing air programs. EPA continues to be
mindful of the unique opportunities to address air
pollution at the local level and we will continue to
work with both state and local agencies recognizing
the challenging fiscal environment.
Issue Area: General Comments - Recognize Resource Limitations and Need for Flexibility
All NPM guidance documents should include a
statement regarding both potential state and
federal resource limitations and that explicitly
allows for exploration of flexibility in state-region
negotiations to fit local priorities in recognition of
these limited resources.
ECOS
Introduction; pg
1-2
Included in OAR NPM Guidance.
No change
Issue Area: General Comments - Delineate Expected State Activities with Increased Coordination and Collaboration
All NPM offices should employ a uniform format
throughout each NPM guidance document of
identifying activities by audience, with help of
OCFO. Such an approach will aid state readers to
quickly identify expected state activities for various
ECOS
OAR NPM Guidance includes Appendix C: State and
Local Agency Activities.
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
programs.
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
It would help EPA to engage states and localities in
consistent and meaningful ways, especially early on,
when the agency initiates the development of rules,
guidance and other policies and processes. EPA
should also provide flexibility to its co-regulators to
determine where to target scarce resources.
NACAA
Overview, pg 1
We are constantly seeking ways to improve our
collaboration with air agencies and to engage them in
developing rules and policies early in the process. We
agree with providing flexibility for air agencies in
determining where to target scarce resources and
have reflected this in the guidance - e.g., "Regions can
tailor work expectations and resource allocation to
meet local circumstances, and work with air agencies
to do the same."
No change
NACAA appreciates EPA's recognition that state and
local air agencies are co-regulators and should have
a say in the decisions that affect the air program.
State and local agencies should be given flexibility
when meeting commitments for enforcement
activities such as inspections. The guidance should
state that identification of priorities within a region
will be accomplished collaboratively among federal,
state and local officials.
NACAA
Introduction
(Guidance, pgs
1-2)
Thank you for the positive comment on the
introduction to OAR's NPM Guidance. We have also
shared the enforcement-related comment with EPA's
Office of Enforcement and Compliance Assurance
(OECA). Please refer to OECA's final FY 2014 NPM
Guidance for a discussion of compliance and
enforcement related expectations for FY 2014 and
associated flexibilities for state and local agencies.
EPA is engaged in ongoing discussions with state and
local air agencies regarding opportunities for using the
flexibility provided in the CAA Stationary Source
Compliance Monitoring Strategy to address local air
pollution and compliance problems/priorities. The
Agency welcomes such continued collaboration.
No change
Issue Area: Other General Comments
EPD would like to acknowledge and commend EPA's
Office of Air and Radiation (OAR) on the
improvements it has made to the National Program
Manager Guidance. The streamlined focused
The Air
Protection
Branch of
Georgia
Thank you.
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
format is a significant improvement over versions
from years past.
Environmental
Protection
Division
On page 1, OAR makes the statement: The guidance
provides the basis for negotiations between HQ and
regions and between regions and air agencies as to
resource allocation and expected performance.
Specific expectations and deliverables will be as
established through negotiations in grant
agreements between regions and air agencies.
In the second bullet, OAR goes on to state: OAR
recognizes that there will not be enough resources
to do everything and that not all programs and
requirements apply in the same way everywhere.
The highest priority work is that related to meeting
statutory, regulatory, and court-ordered
requirements. Regions can tailor work expectations
and resource allocation to meet local circumstances,
and work with air agencies to do the same, as long
as priority work continues.
EPD couldn't agree more with OAR's position, but
must take exception to these statements because,
at least in our experience, there is little to no
negotiation with our regional office when
developing our Air Partnership Agreement. For the
past several years, Region IV posts their
expectations in an electronic form on their web site,
EPD then agrees or disagrees with the proposed
expectations, and then the Region sends us a letter
of conditional approval. The expectations we have
disagreed with in the past continue to show up year
The Air
Protection
Branch of
Georgia
Environmental
Protection
Division
Office of Air and
Radiation
Introduction
Pg. 1
In order to streamline the grants process, the Region 4
Air Planning Agreement (APA) is in electronic format
with identical commitments for each state and local
agency except where a particular program does not
apply. For example, not all local programs in Region 4
have authority for Prevention of Significant
Deterioration/New Source Review, so the
commitments that address those programs are not
initially loaded for those particular agencies. The
commitments that are loaded for each agency are
then negotiated during the process.
As mentioned earlier, those commitments include
National Program Manager priorities (both OAR and
OECA), Regional priorities, SIP requirements, etc. The
Regional Priorities are commitments which generally
outline elements needed to implement a program
delegated to a state or local agency or promote the
use of compliance tools available to these agencies. Of
the 52 commitments in the APA, eight (15%) are
categorized as Regional Priorities. The APA
negotiation process recognizes the concerns about
limited resources at the state or local level. As we go
through the process, an agency may either agree to
the commitment or not agree to the commitment for
that particular grant cycle. The reason that a
commitment which was not agreed to in a particular
cycle continues to appear in subsequent cycles is that
it continues to be an important element of the
program for consideration for the Agency at the
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
after year, clearly indicating that there is little room
for actual negotiation.
Also, as we have commented in the past, there are
a significant number (approximately 50%) of the
expected activities that the Region proposed for us
to do in our Air Planning Agreement that did not
appear as state/local expected activities in the NPM
guidance document. So, at least in our experience,
the NPM does not serve as much of a basis for the
start of negotiations.
We are hopeful, that as the next phase of improving
and making the NPM more meaningful, that OAR
will communicate their expectations to the Regions
to use the NPM as a true basis and to actually
engage in meaningful negotiations with the states,
so that the final grant agreements are a true
reflection of the expectations for the upcoming
fiscal years activities.
Location in
Draft Guidance
NPM Response
Regional or national level. We do not view a "yes" or
"no" commitment to continue in perpetuity, rather
that the commitment is to be renegotiated each grants
cycle.
When specific commitments are no longer applicable
such as when deadlines have already passed and been
met, they are removed from the APA. Each year as we
draft the APA, we review the individual commitments
to make sure that they are still applicable, that they
have a regulatory or statutory basis, and that they fit
into the national and Regional priorities. EPA Region 4
each year provides a draft set of commitments and
opportunity to discuss the APA with the state and local
agencies. The final APA for the state and local agencies
only obligates the agencies to those items that are
finalized upon completion of negotiations.
Action Taken
in Final
Guidance
EPA should address the complex issue of
background ozone, the definition and the impact
background ozone may have on attaining the
lowered ozone standard. International background
is a complicated matter that has significant impact
on how states proceed and how this issue is
addressed with stakeholders.
Texas
Commission on
Environmental
Quality
General
Comment
EPA agrees that these are both important issues. They
are being addressed in the ozone NAAQS review and
the ozone implementation rule.
No change
EPA should identify and discuss in more detail the
guidance that is applicable to specific state and local
programs. Texas is a State Implementation Plan
(SIP) - approved state, and the guidance is not clear
as to which measures, if any, EPA believes to apply
Texas
Commission on
Environmental
Quality
Section 1, pg. 1
On page 1, the guidance provides the basis for
negotiations between HQand regions and between
regions and air agencies as to resource allocation and
expected performance. Specific expectations and
deliverables will be established through negotiations in
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
to TCEQ's air permitting program. States with SIP-
approved programs may have their own permitting
targets and goals, and it would not be appropriate
for such programs to be subject to duplicative or
conflicting performance measures. If EPA disagrees
with this viewpoint, EPA should explicitly address
this issue in the guidance, and provide justification
as to why these types of performance measures
should apply to SIP-approved states.
grant agreements between regions and air agencies.
EPA does not expect all air agencies to undertake all
activities listed, and there may be activities not listed
that will be appropriate in certain grant agreements.
The OAR Introduction indicates that the
prioritization process within the NPM document
was established by the EPA/State Priorities
Workgroup, which consisted of representatives
from ECOS, NACAA, and EPA. TCEQ notes that
many states do not belong to ECOS or NACAA and
not all states affected by this proposed document
had direct input into its content and priority list. In
order to achieve national consistency, it would be
helpful if all affected states and programs have the
opportunity to be involved in the document's
creation, or at least be provided with
developmental drafts before being given a final
draft release for comment with a short comment
period.
Texas
Commission on
Environmental
Quality
Section 1, pp. 1-
2
Informing the EPA/State Priorities Workgroup, ECOS
and NACAA identified workgroup members and
nominated Georgia, Kansas City KS, Michigan, New
York, Oregon, and Virginia as representatives. As we
move forward collaboratively to update the "working
priorities list," EPA will look to state associations to
identify workgroup representatives; and, we will work
with them to ensure there is opportunity for comment
on updated priorities. We agree that providing
adequate time for review and comment is important.
No change
OAR acknowledges there will not be enough
resources to do everything in the draft document
and that some programs and requirements will not
apply nationally. The document also suggests that
EPA regions will work with their air agencies to
tailor work expectations and resources. Therefore,
this guidance should specifically direct regions to
tailor expectations to consider state resources,
Texas
Commission on
Environmental
Quality
Section 1, pg. 1
The tailoring of grant agreements is best left between
the Regions and the grant recipients. We state that not
all activities in the guidance apply to all States.
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
reflect a state's status (delegated or approved), and
acknowledge requirements adopted into approved
SIPs.
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
We appreciate the revised layout and summaries
found in the draft guidance for FY 2014.
As resources continue to be lost, reprioritization of
air quality work is an ongoing need. Further, it is
important to limit the mandatory requirements to
those that pay the greatest dividends. We presume
that EPA's most important expectations are
specified in the national program manager
guidance. It would be helpful for EPA to ensure
careful alignment of regional grant requirements
with the national priorities specified in the NPM
guidance, absent compelling environmental/public
health reasons to do otherwise.
Metro 4/SESARM
NA
Thank you. We have included our most important
expectations in the guidance. To the extent possible,
Regions want to ensure that regional grant
requirements are aligned with our National Areas of
Focus.
No change
Issue Area: Reduced Mercury Emissions from Electric Arc Furnaces
The U.S. EPA, in collaboration with the states,
should improve the effectiveness of the final
NESHAPS rule for Electric Arc Furnace (EAF)
Steelmaking Facilities by including provisions that
augment the existing rule's recordkeeping and
reporting, mercury emissions testing, monitoring
and verification requirements, and other measure
that ensure reduced mercury emissions from these
facilities.
ECOS
OAR draft FY14
NPM guidance;
pglO
EPA appreciates that this issue is a priority for the
states. It is one of a number of air toxics rulemakings
that is pending. EPA how to prioritize these
rulemakings in light of statutory and court deadlines,
expectations about opportunities to improve public
health and other factors.
No change
OAR Final FY 2014 NPM Guidance
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Issue Area: Air Toxics Emissions Inventory
In section 2.5.4 ("Expected State and Local Agency
Activities" for Air Toxics Program Implementation),
the first item is "Prepare to submit data to the
integrated 2014 emissions inventory due December
2015." Is this the same as the 2014 National
Emissions Inventory (NEI) identified on page 5
(section 2.1.4.3) under the NAAQS section? If it is
the same inventory, then we suggest the agency use
consistent terminology. If it is a different inventory,
we recommend this be clarified in the guidance.
NACAA
Guidance, page
11
Reference changed under section 2.5.4.
Change
made.
Issue Area: National Ambient Air Quality Standards (NAAQS)
EPA states it will continue to work closely with air
agencies on all aspects of implementing the NAAQS.
TCEQ finds that past engagement to develop
regulations and guidance has not been effective.
For example, EPA has not provided sufficient
guidance for states to implement the PM2.5
standards into the new source review (NSR)
permitting programs but continues to include
performance measures relating to PM2.5 NSR
implementation in PPG agreements. In December
2010, EPA granted TCEQ's petition to reconsider
portions of the October 20, 2010, rulemaking for
Prevention of Significant Deterioration (PSD) for
Particulate Matter Less Than 2.5 Micrometers
(PM2.s)—Increments, Significant Impact Levels (SILs)
and Significant Monitoring Concentration (SMC),
but has not acted further on the petition, nor
Texas
Commission on
Environmental
Quality
Section 2.1.1,
pg. 3 and
Section 2.1.2.3,
P§. 4
EPA appreciates comment from TCEQ. However, we
disagree with the TCEQ position that performance
measures relating to PM2.5 NSR implementation
should not be included in PPG agreements. All PSD
permits must be reviewed for compliance with the
PM2.5 requirements within the context of existing
rules and guidance. The PM10 Surrogate Policy is no
longer in effect; thus, all permits must address PM2.5
directly.
With regard to the 2010 EPA grant to address the
TCEQ petition for reconsideration, we agreed to re-
propose 3 provisions contained in the PSD PM2.5
Increments, SILs, and SMC Rule. The rule to re-propose
was initiated but then delayed to await a Court
decision on a judicial challenge to the PM2.5 SILs and
SMC. As a result of the January 22, 2013 Court
decision, there is no longer a basis for proceeding with
No change
OAR Final FY 2014 NPM Guidance
10
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
committed to a timeline for doing so.
In March, 2013, EPA finally provided draft PM2.5
modeling guidance in an attempt to mitigate
significant technical implementation challenges, but
EPA has not provided a single-source model needed
to conduct highly complex PM2.5 permit modeling,
and has not begun rulemaking to update the
Guideline on Air Quality Models (40 CFR 51,
Appendix W). EPA was quite clear in notifying
states that while EPA asked for comment on the
draft modeling guidance, EPA staff would not
provide any response to comments.
TCEQ recommends that EPA not develop or require
performance measures for new NAAQS until
needed implementation rules and guidance
documents are provided. In addition, well-thought-
out implementation processes before a new NAAQS
is adopted would be very helpful in implementing
any new NAAQS into NSR permitting programs and
to ensure that required source impact analyses are
conducted in a nationally consistent manner.
Location in
Draft Guidance
NPM Response
the re-proposal rule on its own. First, the PM2.5 SMC
was declared unlawful by the court and it would be
inappropriate to re-propose. Second, the definition of
"baseline area" involves the use of the PM2.5 SIL value
to determine the boundaries for a PM2.5 increment
baseline area. It would not be appropriate to re-
propose the definition relying on the existing PM2.5
SIL until the PM2.5 SILs are reconsidered in accordance
with the court remand.
Finally, the interpretation of what emissions must be
considered in comparing to the PM2.5 SIL is contained
in paragraph (k)(2) of the PSD regulations, which has
been vacated by the court. The EPA will address this
issue when it revises paragraph (k)(2) to address the
PM2.5SILs provision.
The PM2.5 modeling guidance provides a more
comprehensive methodology for addressing PM2.5
impacts, even though new modeling techniques are
not yet available for states and sources to use for
completing the required air quality impact analysis. As
new techniques and models are developed, we will
incorporate them into the process for estimating a
source's air quality impacts.
EPA appreciates TCEQ's recommendation. EPA has
been working with states through the NACAA-EPA
PM2.5 Implementation Work group and the
EPA/NACAA/ECOS SIP Reform Workgroup to
understand the implementation guidance and rule
lead times needed by states. From these workgroups,
EPA intends to institutionalize state engagement and
implementation planning to future processes.
Action Taken
in Final
Guidance
OAR Final FY 2014 NPM Guidance
11
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Therefore, EPA believes these performance measures
are appropriate.
Action Taken
in Final
Guidance
In addition to implementing the good neighbor
provision of the Clean Air Act, HQ should prioritize
providing guidance on how states should address
CAIR in their existing SIPs and how CAIR will be
administered moving forward.
Texas
Commission on
Environmental
Quality
Section 2.1.2.1,
P§. 3
The Court of Appeals for the DC Circuit provided clear
direction that EPA must continue to administer CAIR.
Unless the DC Circuit's decision in EME Homer City v.
EPA is reversed or otherwise modified by the Supreme
Court, EPA will continue to administer CAIR as
promulgated and enforce existing CAIR SIPs and FIPs
until a valid replacement rule is developed and
implementation plans ensuring compliance with any
requirements in the replacement rule are in place.
No Change
The deadlines to submit 2010 NO2 and 2010 SO2
infrastructure SIPs are January 22, 2013 and June 2,
2013, respectively. These are therefore due in
FY2013, and will be well past due by FY2014.
Texas
Commission on
Environmental
Quality
Section 2.1.2.3,
P§. 3
Agreed. Activity 1 under section 2.1.2.3 is deleted.
Change made
EPA Headquarters and regional offices should
consider moving reduction of backlogged SIP
submissions up their priority list. The SIP backlog is
a perennial issue; however, the backlog only
continues to grow, which leads to uncertainty for
states and the regulated community.
Texas
Commission on
Environmental
Quality
Section 2.1.2.3
and
2.1.3.2, pg. 4
The reduction of backlogged SIPs is a high priority for
EPA. The position of the priority in the list of activities
does not indicate its relative priority to other activities
in the list. The Agency has established a Key
Performance Indicator that annually sets targets and
measures success in reducing the SIP backlog. EPA,
ECOS and NACAA are discussing the use of best
practices and other approaches to address the SIP
backlog and prevent future SIPs from becoming
backlogged. We have also been in discussions
regarding the development of a joint strategy or
strategic planning document to guide future actions to
address backlogged SIPs. Therefore, EPA does not
believe any changes are needed to the listed activities.
No change
OAR Final FY 2014 NPM Guidance
12
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Regional Offices should prioritize review of
exceptional event flagging, especially when making
final designations. The length of time it takes EPA to
review and provide a decision to states on the
acceptance of flagging has been an ongoing issue.
Texas
Commission on
Environmental
Quality
Location in
Draft Guidance
Section 2.1.3.1,
P§. 4
NPM Response
Generally, EPA Regions will prioritize action on
exceptional events flags and demonstrations to
address those impacting near term regulatory
decisions first. For example, if flags and
demonstrations could have a direct impact on the final
designations decision for an area, EPA Regions would
prioritize action on them. When a NAAQS is revised or
finalized, EPA promulgates the schedule by which data
flagging and documentation for related exceptional
events would be due. The promulgated schedule
balances the time needed for states to flag and submit
demonstrations and the time EPA needs to process
them to be timely for designations decisions. States
and EPA Regions should work closely together to
ensure flags, demonstrations, and ultimate exceptional
events decisions are possible within this timing.
Additionally, on May 10, 2013, EPA signed and issued
the "Interim Guidance to Implement Requirements for
the Treatment of Air Quality Monitoring Data
Influenced by Exceptional Events," to streamline and
improve the efficiency and effectiveness of the
exceptional event demonstration preparation and
review process.
Action Taken
in Final
Guidance
No change
Attainment demonstration SIPs for the 2008 ozone
standard are not due until FY2015. Although
development will begin by FY2014, it is not a
priority to submit them in FY2014, well before the
deadline.
Texas
Commission on
Environmental
Quality
Section 2.1.4.1,
P§. 5
That is correct. Attainment Demonstration SIPs for the
2008 ozone NAAQS are not due until July 20, 2015. The
proposed SIP Requirements Rule for the 2008 ozone
NAAQS attempts to provide flexibility for when these
SIPs are submitted, but they can be submitted no later
than July 20, 2015.
Change made
While we appreciate the commitment to finalize
policy to address air quality impacts from
Texas
Commission on
Section 2.1.2.1,
On May 10, 2013, EPA signed and issued the "Interim
Guidance to Implement Requirements for the
No change
OAR Final FY 2014 NPM Guidance
13
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
prescribed burns, it is critical that the exceptional
events flagging guidance documents and rules
receive continued input for revision. Predicted
drought conditions can likely lead to more
uncontrolled wildfires and the impact on areas
reaching the ozone standard will be increasingly
critical. The importance of continued
understanding of this factor and impact is
important. The Guidance/Rulemaking statement
must be more inclusive
Agencies need implementation guidance in a more
timely fashion after each NAAQS is finalized. This
includes PM2.5, ozone, and SO2.
EPA should continue to work with agencies to
address the transport obligations of the Clean Air
Act in a reasonable way. We appreciate recent
efforts of EPA to solicit input on the issue and
Environmental
Quality
Metro 4/SESARM
P§. 3
2.1.2.
2.1.3.
Treatment of Air Quality Monitoring Data Influenced
by Exceptional Events." This guidance resulted from a
multi-year effort to identify and address concerns
raised by air agencies and other interested parties in
implementing the 2007 Exceptional Events Rule (EER)
and included both an informal comment period and a
formal public notice and comment period following a
Federal Register Notice of Availability. Upon signing
the Interim Guidance, EPA simultaneously announced
its intent to pursue rule revisions to the 2007 EER
through a notice and comment rulemaking process,
which will include an opportunity for all interested
parties, including those that commented during the
2012 public comment period, to raise any issues or
concerns.
In May 2013, EPA announced that it is currently
developing a separate draft guidance document
addressing the preparation of demonstrations to
support data exclusion requests for wildfire-related
events that may have affected ozone concentrations.
EPA anticipates preparing this guidance within the
same timeframe as the EER revisions and we will
provide an opportunity for stakeholder input on this
guidance.
We are working with the Regions and the states to
develop timely guidance for NAAQS implementation.
EPA is also working with NACAA and ECOS to
determine how to best provide for the issuance of
timely guidance (e.g., NACAA/ ECOS/EPA Work Group
on SIP Reform).
We have also committed to the states to work
No change
OAR Final FY 2014 NPM Guidance
14
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
encourage continued dialogue with the agencies.
EPA should continue its efforts to evaluate the
circumstances surrounding prescribed fires and
offer every accommodation that is possible.
Prescribed fires reduce the threat of out-of-control
wildfires and resultant emissions. They are also
necessary for forest and agricultural land
management and for habitat restoration.
EPA should consult closely with states during the
NAAQS attainment/nonattainment designation
process to ensure that all unique factors in specific
areas are adequately considered before official
designations are finalized.
We encourage EPA to continue working with the
states and locals on programs promoting early
attainment of NAAQS. This includes the Ozone
Advance and PM advance programs.
We appreciate EPA's recent efforts to invite
collaboration on rulemaking. States and locals have
significant experience implementing requirements
and understand the most cost-effective ways to
implement emission control requirements.
Continued consultation with our agencies is
important.
We appreciate the efforts of EPA to develop a new
national learning management system (APTI-Learn).
There are occasional missed opportunities for
additional collaboration. The resources of the
agencies should be called upon during all critical
decision making. The LMS is functional from a
Location in
Draft Guidance
NPM Response
together to address the CAA mandate to address the
transport of air pollution. We recently held several
teleconference and in-person listening sessions with
the States to lay the foundation for addressing
transport, and plan to have future discussions.
In May 2013, EPA released interim guidance for
treating air quality data influenced by "exceptional
events," and plans to undertake future actions,
including revisions to the 2007 Exceptional Events
Rule. In addition, we have indicated our intent to
revise the 1998 Interim Air Quality Policy on Wildland
and Prescribed Fires, along with necessary air agency
engagement.
EPA is working closely with States during the NAAQS
designation process. The designation process follows
specific technical criteria to ensure that the process is
fair and transparent and allows for a very fact specific
analysis.
In April, following consultation with state agencies, we
issued guidance for area designations for the 2012
PM2.5 NAAQS.
We agree with the value of the Advance Programs and
will continue to work with interested organizations.
EPA is working with NACAA and ECOS to determine
how to best provide for air agency engagement (e.g.,
NACAA/ ECOS/EPA Work Group on SIP Reform). EPA
has undertaken a number of state engagement
activities over the past couple of years, such as the
NACAA/EPA Implementation Workgroup for PM2.5,
Action Taken
in Final
Guidance
OAR Final FY 2014 NPM Guidance
15
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
student standpoint but needs considerable
enhancement to make it fully a Learning
Management System.
We encourage EPA to continue to address the SIP
process by improving flexibility and efficiency and
reducing the backlog of unaddressed SIP submittals.
We understand that there will always be a
necessary backlog to some degree, but reductions
in the legacy backlog continue to need to occur.
and the Full Cycle Analysis Project.
We continue efforts to improve the APTI LMS. We are
working with the MJOs to prioritize revisions to the
LMS to improve its functionality within available
personnel resources.
EPA is working with NACAA and ECOS on ways to
improve the SIP process and reduce the SIP backlog
(e.g., NACAA/ ECOS/EPA Work Group on SIP Reform).
Issue Area: Regional Haze
Reference is made in the two cited sub-sections to
due dates for second 10-year regional haze SIPs.
We believe the date in 2.2.2.3. is incorrect and the
date in 2.2.3.6 is correct. If the intention in 2.2.2.3.
is to indicate the internal EPA due date for guidance
for 2018 regional haze SIPs, that is much too late to
serve the needs of the agencies. If EPA will require
a similar process to what was required for the 2007
SIPs, EPA needs to be developing guidance now for
the states to use towards development of the 2018
SIP packages. Some states will need to have their
draft packages essentially complete by July 2017 in
order to have time for sharing the drafts with EPA,
federal land managers, and the public in advance of
what we believe to be the July 31, 2018 submittal
deadline.
We encourage EPA to identify ways to leverage
work on criteria pollutants towards the
requirements of future regional haze SIPs.
Resources will likely not allow the same level of
Metro 4/SESARM
2.2.2.
2.2.3.
The July 2018 date is correct. Thank you for your input.
We agree that leveraging work on criteria pollutants
and regional haze is important, and we look forward to
working air agencies on how to best accomplish this.
Change made
OAR Final FY 2014 NPM Guidance
16
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
effort in the next round of regional haze SIPs that
was used in the last round.
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
If the second 10-year regional haze SIPs are due in
July 2018, December 2017 is far too late to
complete guidance for those SIPs.
Texas
Commission on
Environmental
Quality
Section 2.2.2,
P§. 6
Item 3 in section 2.2.2 inadvertently references
December 2017 as the due date for the second 10-
year regional haze SIPs. It will be corrected to July 31,
2018, which corresponds with item 6 in section 2.2.3
immediately following. In the event that we issue
guidance to support the development of these SIPs,
we will do so in a timely manner.
Change made
Issue Area: Title V and New Source Review Permitting and Appendix A Measure Text
EPA identifies six basic areas of expected state and
local agency responsibility. EPA should also identify
and clearly address the measures and national
targets that apply to state and local programs. The
guidance is not clear whether or not the OAQPS
measure relating to the percentage of major NSR
permits issued within one year of permit application
applies to a SIP-approved state such as Texas. TCEQ
contends that this requirement should not apply to
a SIP-approved state. States that operate under SIP
approved programs may have their own NSR permit
processing targets and goals. These measures may
be included in state statute, rule, or policy. The
expectation of SIP approved states is that they will
be able to develop specific language, with their
respective EPA regional office, and are not
potentially held to a double standard of meeting an
EPA requirement in addition to their own. If EPA
does not agree with this viewpoint, EPA should
explicitly address this in the guidance, and provide
Texas
Commission on
Environmental
Quality
Section 2.3.4,
pg. 8, and
Appendix A,
OAQPS P001,
P09, Pll, P19,
P20, and P21,
pg. 3-4
The purpose of and the responsibility for addressing
the measures and national targets that apply to state
and local programs may not be clear.
The measure (P001) is reported by OAR as a single
number based on information contained in the RBLC. It
does not identify individual state programs but is a
measure of a specific statutory requirement for which
EPA oversight is expected. P20 and P21 are also
measures that pertain to EPA oversight of the permit
process, rather than performance of individual state
permitting programs.
Measures PO9, Pll, and P19 are all measures of
permits issued by the EPA Regional Offices—not
permits issued by SIP-approved States.
No change
OAR Final FY 2014 NPM Guidance
17
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
justification as to why these types of performance
measures should apply to SIP-approved states.
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
We understand that EPA must have an oversight
program for Title V permitting. To the extent that
the NPM guidance is designed for grant and non-
grant activities, inclusion of Title V requirements in
the guidance is appropriate. However, if the NPM
guidance is intended to drive grant conditions, it
may be inappropriate to include Title V expectations
in this document.
Metro 4/SESARM
2.3.2.
2.3.3.
2.3.4.
Besides informing the development of grant
requirements, this guidance is used to communicate
all priorities and expectations even those in the Title V
program. The only Title V priorities are those that
relate to issuing data for TOPS, issuing permits, and
participating in program evaluations.
No change
Issue Area: Ambient Air Monitoring
Our agencies continue to have concern about
resources required to meet expanded monitoring
obligations. We appreciate the fact that EPA
worked with the agencies to defer some monitoring
deadlines, but we are concerned about funding
implications of federal budget constraints related to
the sequestration and any other funding cuts that
EPA may be planning to impose. Adequate funding
of this important program is required, along with
proper prioritization, cost-sharing, and phase-in of
monitoring requirements.
It remains helpful that EPA support newer
monitoring requirements including those for PM2.5
via the Section 103 funding mechanism. Many
states advocate for continuation of Section 103
funding as is currently being done. Whatever EPA's
ultimate plan is, agencies should not be subjected
to net loss of funding for monitoring. EPA should
not reduce grant awards to reflect any match
Metro 4/SESARM
2.4.2.
2.4.3.
2.4.4.
EPA will continue to encourage use of Section 103
funds as appropriate for the development of new
monitoring networks and other unique monitoring
approaches. EPA has also worked with states to
develop phased approaches to deploying new or
expanded networks. EPA encourages air agencies to
optimize their monitoring networks, including pursuing
appropriate disinvestments, to be more responsive to
current and future needs, which should be done as
part of the 5-year network assessments (next due in
July 2015) and, as necessary, the annual network
reviews.
Since the late 1990's, the funding for the monitoring of
fine particles (PM2.5) has been awarded to states
using EPA's authority under section 103 of the Clean
Air Act. Section 103 authority allows full federal
funding for the establishment of monitoring networks.
Now that the PM monitoring network has "matured,"
it is time for the funding to transition to section 105
No change
OAR Final FY 2014 NPM Guidance
18
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
requirements for new funding approaches.
Location in
Draft Guidance
NPM Response
authority which is more in line with established
programs.
Action Taken
in Final
Guidance
Consider utilizing state and local government,
environmental laboratories to provide assistance
and collaboration in accomplishing OAR's goals of
ambient air monitoring for criteria pollutants and
toxics. These laboratories have the expertise and
capabilities to conduct the necessary monitoring
and evaluation while being geographically located in
a way to conduct effective evaluations.
Assoc. of Public
Health
Laboratories
p. 9 et seq., p.
12 et
seq.,
Many of these labs are already collaborating. We offer
national contracts as a convenience.
No change
Issue Area: Air Toxics Program
Consider utilizing state and local, government,
environmental laboratories for accomplishing OAR's
air toxics goals. These laboratories can assist in
monitoring, method development, and analyses
needed for these priorities.
Assoc. of Public
Health
Laboratories
p. 10 et seq.
Some states already utilize state laboratories. For
efficiency and convenience of other states, we offer
national contracts that are optional for the states to
use in lieu of their own labs.
This guidance should specifically reflect a state's
status (delegated or approved), and acknowledge
requirements adopted into approved SIPs. Under
Section 2.5.4, "Expected State and Local Agency
Activities," items 2 and 3 should clearly provide
flexibility to assume implementation of toxic
standards and residual risk standards in recognition
of state resources, applicable laws and rules, and
delegated responsibilities. In addition, to facilitate
delegation discussions, EPA should provide
guidance concerning specific delegation
responsibilities for these programs before they can
be accepted and incorporated into a state's SIP.
Texas
Commission on
Environmental
Quality
Section 2.5.4,
pp. 11-12
Section 112(1) of the Clean Air Act offers states the
option to receive delegation of standards promulgated
under section 112. The NPM guidance does not
mandate that any state must assume delegation of any
standard that they do not have the resources to
implement.
No change
OAR Final FY 2014 NPM Guidance
19
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Issue Area: Mobile Source Programs
The majority of our agencies encourage timely
completion of the Tier 3 light-duty vehicle and fuel
standards. Mobile source emission reductions are a
key component of strategies to maintain
compliance with current standards and move
towards compliance with future tighter standards, if
any. Much work has been done to reduce
emissions from the stationary source and mobile
source sectors. Completion of the Tier 3 regulations
will contribute towards continued maintenance as
well as improved air quality in metropolitan areas
with higher VMTs that have difficulty meeting the
NAAQS.
Metro 4/SESARM
2.8.2.
EPA agrees that mobile source emission reductions are
a key component of strategies to maintain compliance
with current air quality standards and move towards
compliance with any future tighter standards.
Recognizing this, the Agency has identified the
completion of the Tier 3 vehicle emissions standards
addressing gasoline sulfur as a top priority.
No change
Issue Area: Tribal Programs
An addendum to Federal (HQ& Regional Office)
Activities: "Provide support for tribes on the Quality
Assurance Project Plan (QAPP) Process and act on
QAPP submittals in a timely manner. "
An addendum to Federal (HQ& Regional Office)
Activities:
"Provide training and support to Regional Project
Officers to understand Tribes and their unique
cultures. "
An addendum to Federal (HQ & Regional Office)
Activities:
Region 6 Tribal
Planning
Subcommittee
Region 6 Tribal
Planning
Subcommittee
Region 6 Tribal
Planning
Section 2.9.2,
page 17.
Section 2.9.2,
page 17.
Section 2.9.2,
page 17.
This action is consistent with the latest version of the
OAR Tribal Air Agenda and will be incorporated.
EPA currently provides annual training to employees
on working effectively with tribal governments. OAR
encourages EPA tribal air program staff to attend the
National Tribal Air Quality Forum to familiarize
themselves with Tribes and their unique culture.
This action is consistent with the latest version of the
OAR Tribal Air Agenda and will be incorporated.
Change made
No change
Change made
OAR Final FY 2014 NPM Guidance
20
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
"Provide training and support for tribes to
understand, assess, and respond to Climate
Change."
Subcommittee
Action Taken
in Final
Guidance
An addendum to Expected Tribal Activities: "Attend
training, develop plans, and develop or acquire
capability to understand, assess, and respond to
Climate Change."
Region 6 Tribal
Planning
Subcommittee
Section 2.9.3,
page 18.
This action is consistent with the latest version of the
OAR Tribal Air Agenda and will be incorporated.
Change made
Issue Area: SIRG Program
As the cause of as many as 15% of all lung cancer
deaths, radon is a serious public health issue that
can be largely prevented through effective testing,
notification and disclosure policies. The U.S. EPA's
approach to reducing exposure to radon has been
impeded by its reliance on voluntary programs. The
2008 U.S. EPA DIG report stated, "Nearly two
decades after passage of the Indoor Radon
Abatement Act of 1988 (IRAA), exposure to indoor
radon continues to grow." The report
recommended that the U.S. EPA use its authority
granted under IRAA to reduce exposure to radon
and prevent radon-induced lung cancer.
The June 2011 U.S. EPA Federal Radon Action Plan
aims to reduce radon exposure in homes, schools
and daycare facilities, as well as new construction.
The plan contains an array of current federal
government actions to reduce radon exposure and
a series of new commitments for future actions.
Although the actions outlined in the plan are
important steps in reducing exposure to radon,
additional policy actions are necessary. Our
American
Association of),
Cancer Survivors
Against Radon
(CanSAR)
Section 4.1,
Pages 23-25
EPA does use its authority under IRAA to reduce
exposure to radon. EPA believes that, in combination
with efforts at the state and local levels, federal-level
voluntary methods are appropriate to this issue. EPA
also believes that, when imposed at the appropriate
level of government, regulatory approaches to radon
risk reduction may be warranted and often effective.
An example is the enactment of building codes which
require radon-resistant techniques in new-home
construction. Historically, the authority to impose such
restrictions was been exercised at the state and local
level.
The goal of IRAA, stated in Section 301, is to "reduce
radon levels in all buildings to that of ambient outdoor
air." The level of radon in outdoor air averages about
0.4 pCi/L Radon mitigation methods currently
available can significantly reduce the public's exposure
to radon from high levels to appreciably lower levels,
well below our recommended action level of 4pCi/L in
many cases. They cannot typically or reliably achieve a
level as low as 0.4 pCi/L in a given dwelling, and
certainly not in all dwellings. Lacking technologically or
No change
OAR Final FY 2014 NPM Guidance
21
-------
Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
requests for consideration of inclusion in the action
plan are as follows:
1. Requiring testing, notification and disclosure on
all buildings with federally-insured mortgages;
2. Requiring testing, notification and disclosure on
all public buildings, including schools, daycare
facilities and workplaces;
3. Requiring testing, notification and disclosure on
all tenant-occupied buildings;
4. Requiring testing, notification and disclosure
prior to occupancy for all new construction.
5. Increasing the State Indoor Radon Grant (SIRG)
categorical grant from $8.0 million to $12.0
million in FY2014 to allow state programs to
continue vital education and outreach efforts;
and
6. Funding a $3.0 million dollar grant program to
allow a non-profit partner to establish
important environmental justice projects,
sustain the development of professional
standards and credentials, and increase
research and development initiatives.
Support for the development and implementation
of these policies will provide an important
component in preventing cancer mortality and
lessening the burden caused by radon-induced lung
cancer on our healthcare system. Another
important item to note is implementation of these
policies will create the demand needed for
thousands of new jobs in the housing sector for
radon testing, mitigation and new construction.
Until this critical public health issue is addressed,
Americans will continue to die from a disease that is
Location in
Draft Guidance
NPM Response
economically feasible ways to meet the statutory goal,
the regulatory authority offered by Section 310 to
meet the provisions of IRAA will not enable its
achievement.
EPA agrees that more policy actions are needed in the
Federal Radon Action Plan. In response to each of the
suggested additions to the Plan raised by AARST EPA
notes the following points:
1. AARST and other interested NGO's and
stakeholders could raise this idea with federal
mortgage insurers. EPA agrees that such an approach
would greatly reduce radon exposure.
2. This is beyond the scope of the FRAP, as most
public buildings are not owned or operated by the
federal government. The FRAP included only federally
owned or influenced buildings, and specifically focused
on homes, schools and daycare centers (not
workplaces).
3. This is beyond the scope of the FRAP, except for
federally owned/financed tenant occupied buildings.
There has been some progress with HUD's multifamily
housing radon rule, and into other HUD programs.
AARST, other NGO's, and stakeholders should raise
their ideas with HUD. EPA agrees that requiring
testing and fixing in more HUD-influenced housing
would have a major impact.
4. This is beyond the scope of the FRAP as such
requirements would go well beyond the scope of the
federal government.
Action Taken
in Final
Guidance
OAR Final FY 2014 NPM Guidance
22
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
largely preventable through development and
implementation of effective testing, disclosure and
notification policies.
Location in
Draft Guidance
NPM Response
5. and 6. Appropriations levels and newly funded
programs are beyond the scope of the FRAP and fall in
the purview of the Agency's congressional
appropriators.
Action Taken
in Final
Guidance
Issue Area: Radiation
Consider utilizing state and local, government
environmental laboratories to conduct efforts
related to radon protection and community
outreach efforts. These laboratories can be
resources for direct outreach to those at-risk for
radon exposure.
Assoc. of Public
Health
Laboratories
p. 23 et seq.
Agree. However, to our knowledge, very few state
and/or local labs have the necessary capacity to make
these types of measurements. Most state and local
radon programs contract out these services to the
commercial industry.
No change
Consider utilizing state and local environmental
laboratories for assistance in conducting laboratory
analyses related to radiation protection efforts.
Assoc. of Public
Health
Laboratories
p. 29 et seq.
Agree, see page 31, Section 5.1.2, No. 3. EPA's
National Analytical Radiation Environmental
Laboratory continues to lead this effort by conducting
the following activities with commercial and state
laboratories: laboratory pilot program; performance
testing and evaluation; lab capacity audits and
assessments, radio-chemistry and MARLAP trainings
courses.
No change
Consider utilizing APHL and state and local,
government environmental laboratories as a
partner in Homeland Security preparedness and
response efforts. APHL and its members work
closely with the ERLN, LRN-R, and other LRN
sections to provide laboratory preparedness and
responses activities within the National Response
Framework.
Assoc. of Public
Health
Laboratories
p. 31 et seq.
Agree. See comment above.
No change
OAR Final FY 2014 NPM Guidance
23
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Issue Area: Continuing Air Program
NACAA appreciates EPA's explicit acknowledgement
that the funding should support "continuing air
programs," as well as "expanded core state/local
agency work." While addressing new efforts is
important, the increase in funds should also be used
to address some of the deficits in state and local
resources that have existed for many years and
support continuing activities that have been
underfunded.
NACAA
Appendix B,
page 1
Thank you.
No change
Issue Area: Grant Assistance to Co-lmplementors
We appreciate the proposed budget amount which
includes a proposed increase of $21.5 million in
STAG funding to the local and state agencies for the
air program.
Metro 4/SESARM
Appendix B, 1.
Table B-l
Thank you.
No change
Issue Area: Ambient Monitoring
Please see above about funding, prioritization, cost-
sharing, and phase-in.
Metro 4/SESARM
Appendix B. 1.
A. Continuing
Air Program
Page 2
See response to earlier question.
No change
Issue Area: Monitoring
EPA should continue to work with state and local
agencies to prioritize new monitoring equipment
purchases and implementation over the next
several years, and ensure that expectations for new
NACAA
Appendix B,
page 2
IEPA is committed to working with the NACAA/EPA
Joint Monitoring Steering Committee to address
monitoring priorities and corresponding resource
needs. In addition, EPA encourages air agencies to
No change
OAR Final FY 2014 NPM Guidance
24
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
monitoring are consistent with the funding available
to support that monitoring both in amount and in
timing. NACAA also recommends that EPA continue
to work with the NACAA/EPA Joint Monitoring
Steering Committee in determining the best use of
scarce resources, including identifying opportunities
for disinvestment of existing monitoring activities
and providing realistic estimates of the associated
cost savings.
Location in
Draft Guidance
NPM Response
optimize their monitoring networks, including pursuing
appropriate disinvestments, to be more responsive to
current and future needs, which should be done as
part of the 5-year network assessments (next due in
July 2015) and, as necessary, the annual network
reviews.
Action Taken
in Final
Guidance
Issue Area: Allowance Trading Program
NACAA recommends that EPA fund the
administration of the Clean Air Interstate Rule
(CAIR) nitrogen oxide (Nox) Ozone Season Trading
Program in the same way that the Acid Rain
program is administered - using funds from EPA's
own operating budget, not state and local air
grants.
NACAA
Appendix B,
page 2
The Acid Rain program is authorized and funded by the
Clean Air Act Amendments of 1990. In contrast,
regional air programs such as the CAIR seasonal NOx
trading program for controlling the interstate
transport of pollution do not have their own funding
source. These programs have been created by EPA to
enable the affected states to comply more cost-
effectively with the "good neighbor" requirements of
CAA section 110(a) (2)(D)(i) than they could do on their
own without the benefits of interstate allowance
trading and centralized emissions tracking, quality
assurance, and monitor certification systems.
Accordingly, EPA has asked affected states that
participate in an interstate emissions allowance
trading program administrated by EPA to satisfy the
CAA section 110(a) (2)(D)(i) requirements to share the
program costs. Each year, EPA contributes 14 - 16
FTE for program administration, monitor certification,
compliance determination, and assessment whereas
the participating states contribute a portion of their
Sec 105 funds towards the implementation and
No change
OAR Final FY 2014 NPM Guidance
25
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
Funding of the CAIR NOX ozone season allowance
trading program continues to be imposed on the
states. We have previously commented and
continue to do so that this funding should be borne
by the EPA budget as is done for the Acid Rain
Program. Further, it is of note that EPA does not
fund the states and locals in the Southeast based on
work load and program cost but instead continues
to use an antiquated allocation formula. However,
EPA distributes the cost of the CAIR NOX trading
program based on the proportion of units subject to
the rule in the Southeast versus the entire country.
The Southeast receives about 12% of the national
STAG funds for the air program, but is required to
pay nearly 29% of this trading program. The
Southeast encourages EPA to rectify this disparity, if
it intends to continue charging the states for
operation of this program.
Metro 4/SESARM
2.7. and
Appendix B,
Table B-2
operation of the centralized allowance trading and
emissions tracking systems. For over a decade, all the
affected states in each of three successive interstate
air pollution control programs have participated in
these regional air programs and contributed towards
the "shared cost" of program administration with EPA.
Please see EPA's response to NACAA's comment above
on why EPA and the affected states share the program
costs for administering interstate air pollution control
programs such as the CAIR NOx ozone season
allowance trading program. Program administration
costs for source monitor certification; emissions
reporting, quality assurance, and tracking; source
compliance determination; and allowance accounting
and transfers are directly proportional to the number
of affected sources (units) in the program. Therefore,
EPA believes that it is most appropriate and equitable
to allocate the states' collective share of total program
administration costs to the individual states
participating in the EPA-administered centralized
allowance trading and emissions tracking systems in
proportion to the number of units subject to the rule
and reporting emissions in each state.
No change
Issue Area: Clean Air Act Training
While EPA indicates that it is directing $2M in STAG
funds for training, which NACAA approves, it does
not specify EPA's financial commitment from
agency funds for training. NACAA believes that EPA
should support the training program from its own
NACAA
Appendix B,
pageS
EPA continues to support the CAA training program
funded through STAG. EPA will also continue to
provide in-kind support and assistance to the training
program from EPA's operating budget.
No change
OAR Final FY 2014 NPM Guidance
26
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
operating budget.
Please see previous comment about enhancement
oftheLMS.
EPA must engage all agencies, regardless of MJO
affiliation, in planning training activities, funding of
those activities, and allocation of costs among the
regions and states.
Metro 4/SESARM
Appendix B. 1.
A. Continuing
Air Program
PageS
EPA is committed to working with the NACAA/EPA
Joint Training Committee to address training priorities
and corresponding resource needs.
No change
Issue Area: Diesel Emission Reduction Program
NACAA believes more funds should be available for
the DERA program. Future DERA activities should
not be funded through the STAG account. Instead,
NACAA suggest that the grants be provided through
one EPA's other accounts.
NACAA
Appendix B,
pageS
EPA appreciates NACAA's support for the DERA
program, to reduce emissions from the legacy fleet of
diesel engines. Unfortunately, the Agency has to make
tough choices to allocate limited resources. We will
continue to ensure that funds for the DERA program are
used in the most effective manner possible to protect
human heath and the environment, by targeting older
engines that negatively affect sensitive populations and
those who are disproportionately impacted by diesel
emissions.
Congress appropriates the DERA funding through the
STAG account. EPA does not control how the funds are
provided.
No change
Issue Area: Streamlining Grants for STAG Awards to Co-Regulator Organizations
Metro 4 and SESARM appreciate the assistance of
EPA in streamlining the competition policy for
awarding grants to MJOs.
Metro 4/SESARM
Appendix B. 2.
Page?
1 Thank you
No change
OAR Final FY 2014 NPM Guidance
27
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
As EPA works with grants to states, locals, and
MJOs, it should limit grant conditions to those most
critical to the mission of the grant recipient and the
purpose of the project. EPA should work with grant
recipients to design grant conditions and reporting
requirements that make sense with consideration
of environmental and human health needs and
available resources.
Metro 4/SESARM
Location in
Draft Guidance
Appendix B. 2.
Page?
NPM Response
The Office of Grants and Debarment is currently
conducting a "Lean" review on all the different stages
of the grants process in an effort to minimize
administrative burdens on our state, local, MJOs and
tribal recipients. This effort was begun in response to
states and tribes voicing their concern about the
increase of time and effort put upon their
organizations in managing federal grants. Full
implementation of changes as a result of the review is
expected to be completed by FY 2015.
Action Taken
in Final
Guidance
Issue Area: Section 103 PM 2.5 Funding Transition to Section 105 Funding
ECOS opposes the U.S. EPA shifting PM2.5
monitoring funding away from 100 percent federal
funding under Section 103 grants to cost-share
funding under Section 105 grants.
ECOS
Page 830 of
FY14 President's
Budget request
for the U.S. EPA
Since the late 1990's, the funding for the monitoring of
fine particles (PM2.5) has been awarded to states
using EPA's authority under section 103 of the Clean
Air Act. Section 103 allows full federal funding for the
establishment of monitoring networks. Now that the
PM monitoring network has "matured," it is time to
transition to section 105 authority which is more in
line with established programs. EPA will work closely
with state/local/tribal agencies on a smooth transition
of the PM2.5 program from §103 to §105.
No change
Funding for the PM 2.5 monitoring program should
continue under Section 103 authority. Additionally,
state and local agencies will face new and/or
expanded monitoring requirements to address NO2
and air toxics. Since these are either monitoring
start-ups or expansions, it is critical that they be
adequately funded under Section 103 authority.
NACAA
Appendix B,
page 2
EPA will work closely with NACAA and the
state/local/tribal agencies on a smooth transition of
the PM2.5 program from §103 to §105. Where
feasible, EPA will pursue the use of §103 to fund new
monitoring requirements.
No change
OAR Final FY 2014 NPM Guidance
28
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Continue to provide funding for the PM 2.5
monitoring network from Section 103.
Rhode Island
Department of
Environmental
Management,
Office of Air
Resources
Location in
Draft Guidance
Ambient
Monitoring
Appendix-
page 9 of 25
NPM Response
EPA understands the current economic difficulties
being faced by states and the difficulty expected with
the transition of PM2.5 funding to §105. We will
continue to work closely with state/local/tribal
agencies on a smooth transition that will still provide
for an adequate monitoring network.
Action Taken
in Final
Guidance
No change
Issue Area: Allocation of §105 Grants
The agencies which comprise the membership of
Metro 4 and SESARM continue to request that EPA
institute use of the new allocation formula for
awarding STAG funds among the regions. The
Southeast consists of 8 state agencies and 17 local
agencies that conduct the bulk of the air pollution
control work in the region. The demographics of
the region clearly indicate that, over the past
several decades, there has been a shift of
population and business activity to the region. Our
25 agencies have considerable investment of
organization and resources in the region for the
purposes of maintaining air quality where it is
acceptable and improve it where it is not. These
factors suggest that our workload may equate to
more than 20% of the national workload. However,
our agencies receive about 12% of the national
STAG funding while being asked to support the CAIR
NOX trading program at a cost allocation that is
more than double our regional grant allocation. We
have previously shown flexibility by accepting EPA's
proposal to phase in the new allocation formula.
While we continue to deserve immediate phase-in,
we continue to be willing to accept a moderate
Metro 4/SESARM
Appendix B. 3.
Pages 8-9
EPA intends to move to the revised allocation formula
in FY 2014 although Congressional report language has
prohibited EPA from implementing a revised allocation
methodology since FY 2011. In moving to a revised
allocation, the Agency must assure that STAG funds
are targeted to the most pressing air quality problems
and that the integrity of all state/local air program
operations are maintained. While EPA has requested
an increase in STAG resources for FY2014, if funding
remains static, EPA has indicated that shifts will be
limited so as to minimize the impact. This allocation
approach will be phased in over a multi-year period to
minimize disruptions to state and local program
operations and can be re-evaluated based on updated
data, changes in air quality, or changes in available
funding.
No change
OAR Final FY 2014 NPM Guidance
29
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Appendix F - External Comments and Response to Comments
Comment from State, Tribe, or Other Stakeholder Commenter(s)
Location in
Draft Guidance
NPM Response
Action Taken
in Final
Guidance
phase-in period. We encourage EPA to work with
Congress to resolve this problem as the 2014 EPA
budget markup occurs.
EPD reiterates it comments from last year with
regards to OAR's discussion related to the
categorization and allocation of Section 105 grants.
While we support the agencies position to finally
begin to update the air grant allocation consistent
with the approach it laid out in January 2010, we
still are concerned with the proposal that the
update be phased in over a multi-year period and
be moderated such that no region would
experience a decline of more than 5% of its prior
year funding level. Our position, as stated in the
April 11, 2011 and July 18, 2011 letters submitted
by the 8 commissioners of the Southeastern
environmental agencies, and submitted for the
record as comments on last year's NPM, that this
continued delay is an untenable situation for the
southeastern agencies. Consistent with the
Southeast's larger and growing proportional share
of the national air pollution control workload, EPA
should immediately increase the Southeast's
proportional share of the annual Section 105 grant
allocation to allow Region 4 states to respond more
effectively to the region's air quality challenges.
The Air
Protection
Branch of
Georgia
Environmental
Protection
Division
Appendix B
Section 3.
Categorization
and allocation
of §105 grants
pp. 8-9
Please see response above to Metro 4/SESARM.
No change
++ End ++
OAR Final FY 2014 NPM Guidance
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