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Environment and Trade Working Together

U.S. National Advisory Committee
Independent Federal Advisors on the

North American Agreement on Environmental Cooperation

Chair

Theresa A. Pardo
Tel. 518-442-3892
tpardow! ctg.albany.edu

Designated Federal Officer
Oscar Carrillo
Tel. 202-564-2294
carrillo.oscarw! epa.gov

Committee
Members

Theresa A. Pardo
Chair
New York

Andrew P. Carey
California

AnnMarie Chischillyy
California

David T. Dyjack
Colorado

Tracy Hester
Texas

Sara E. Hopper
Washington, DC

Aminata Kilungo
Arizona

Donna Lybecker
Idaho

Justin McCartney
Washington, D.C.

Vincent R. Nathann
Texas

Carlos Perez
New York

Maria Perez-Lugo
Puerto Rico

Luis E. Ramirez
Arizona

Jennifer Ronk
Texas

Simone Sagovac
Michigan

April 27, 2020

The Honorable Andrew R.

Wheeler Administrator
U.S. Environmental Protection
Agency 1200 Pennsylvania
Avenue, N.W. Washington, D.C.

20460

Dear Administrator Wheeler:

The U.S. National Advisory Committee (NAC) to the U.S. Representative to the
North American Commission for Environmental Cooperation (CEC) held its 53rd
meeting via virtual video platform on April 10, 2020. This letter represents our advice
resulting from that meeting.

The main objective of our meeting was to provide you with advice on the Draft 2021-
2025 Strategic Plan of the Commission for Environmental Cooperation. Our meeting
included presentations on U.S Priorities on the CEC, from Jane T. Nishida, Principal
Deputy Assistant Administrator for EPA's Office of International and Tribal Affairs
r(OITA) in conjunction with Mark Kasman, Director of the Office of Regional and
Bilateral Affairs, EPA, OITA. The committee also received an overview of the Draft
CEC Strategic Plan from CEC Executive Director Richard A. Morgan, with support
from Nadtya Hong, Acting CEC Coordinator, EPA, OITA. We also received a report
on activities of the CEC's Joint Public Advisory Committee, from its Chair, Robert
Varney.

The meeting was opened by a welcome from Federal Advisory Committee
Management Division (FACMD) Director Monisha Harris, who provided an update
on FACMD activities. The GAC deeply appreciates the excellent support provided by
the FACMD and thanks Director Harris, NAC/GAC Designated Federal Officer,
Oscar Carrillo and all the FACMD staff for their support, before, during and after the
meeting. We hope this letter will be useful in your deliberations with your
counterparts in the CEC Council.

Sincerely,

CL -fa^do

Theresa A. Pardo,

Chair, National Advisory Committee


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cc: William Charles "Chad" Mcintosh, Assistant Administrator, Office of International
and Tribal Affairs (OITA), EPA

Jane T. Nishida, Principal Deputy Assistant Administrator, OITA, EPA
Monisha Harris, Director, Federal Advisory Committee Management Division
FACMD, OMS, EPA

Oscar Carrillo, Designated Federal Officer, FACMD, OMS, EPA
Mark Kasman, Director, Office of Regional & Bilateral Affairs, OITA, EPA
Nadtya Hong, Acting CEC Coordinator, North American Affairs, OITA, EPA
Robert Varney, Chair, Joint Public Advisory Committee
Richard A. Morgan, Executive Director, CEC

Members of the U.S. National and Governmental Advisory Committees

Administrative support for the NAC is provided by the U.S. Environmental Protection Agency,
Federal, Advisory Committee Management Division, OARM
Mail Code 1601-M, 1200 Pennsylvania Ave. NW Washington, D.C. 20460
(t) 202-564-2294(f) 202-564-8129

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National Advisory Committee (NAC) To
the U.S. Representative to the
Commission for Environmental Cooperation (CEC)

Advice 2020-1: On CEC Draft Strategic Plan, 2021-2015
(April 10, 2020)

The April 2020 Charge Question to the EPA National Advisory Committee (NAC) seeks-advice on four
questions.

1.	Under each strategic priority of the draft CEC 2021-2025 CEC Strategic Plan,

•	What are the environmental issues and challenges facing North America over the next five years?

•	What are the opportunities for the CEC, considering the organization's mission and mandate, to
address these issues/challenges over the next five years?

2.	How can the CEC amplify its work through partnerships in North America?

3.	Where in this Strategic Plan do you see opportunities for enhanced roles for stakeholders and citizens?

4.	General Comments and Recommendations.

Note: In preparation for the NAC discussions, which were held online over a four-hour period rather than
a two-day meeting, NAC members completed an online survey to select the top related issues for each of
the five strategic priorities of the CEC Strategic Plan. A compilation of results was used to guide the
discussion related to the prioritized issues for each strategic priority.

ADVICE QUESTION # 1. ENVIRONMENTAL ISSUES AND CHALLENGES AND
OPPORTUNITIES FOR THE CEC

Advice Question # 1 seeks advice on the development of the new draft CEC 2021-2025 Strategic Plan. The
plan includes five new strategic priorities and two cross cutting approaches:

Strategic Priority 1 - Circular Economy and Resource Efficiency

Strategic Priority 2 - Clean Air, Land and Water

Strategic Priority 3 - Shared Ecosystems and Species

Strategic Priority 4 - Resilient Communities

Strategic Priority 5 - Effective Enforcement of Environmental Laws

Cross-cutting Approach 1 - Modernized and Effective Solutions

Cross-cutting Approach 2 - Diverse & Inclusive Stakeholder Engagement & Public Participation
Strategic Priority # 1. Circular Economy and Resource Efficiency

Related Issues as Prioritizedfor Discussion by NAC Members Prior to the April 10th meeting:

1.	Recycling and waste management in North America

2.	Sustainable production, resource and energy efficiency practices

3.	Plastics and micro plastics

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The NAC recommends:

•	a focus on issues that have a broad reach to downstream effectors, such as (1) recycling, especially
plastics, and (2) sustainable production in terms of a redesign of materials, new processes and
sharing of research. Further, they recommend a focus on cooperation (e.g., mechanisms on which the
three countries can collaborate), best practices, data and scientific information.

•	that the CEC emphasize thinking about sustainability broadly as feeding the world and making sure
people have access to food, rather than solely focusing on some of the assumptions of sustainable
production as cleaner chemistry.

•	focusing on transboundary benefits, being action oriented and providing advice on efforts that ensure
a more sustainable future around the circular economy.

•	ranking the draft CEC 2021-2025 Strategic Plan priority areas by the impact of the related issues
trilaterally and not endorsing the numerical order in the draft CEC Strategic Plan as indicating the
level of importance.

•	highlighting issues excluded in the Strategic Priority areas, such as climate change, which should be
included in circular economy and resource efficiency priorities. This recommendation is made with
recognition that although the term climate change is not specifically stated, it is indirectly addressed
in the broad Strategic Priority 2 and related issues focusing on alternatives to ozone-depleting
substances and HFCs.

Strategic Priority 2—Clean Air, Land and Water

Related Issues as Prioritizedfor discussion by NAC Members Prior to the April 2020 meeting:

1.	Air quality

2.	Fresh water science, data and management

3.	Pollutant release data and information

The NAC recommends:

•	continued use of health-based standards to make decisions on regulations and NOT use
economic-based standards solely for decisions on de-regulations regarding clean air, land
and water.

•	revisiting previous advice letters addressing issues related to deregulating health-based
standards (given the health-based default values) in terms of the impact on the most
vulnerable populations.

Strategic Priority 3—Shared Ecosystems and Species

Related Issues as Prioritizedfor discussion by NAC Members Prior to the April 2020 meeting:

1.	Priority migratory species

2.	Connected and priority habitats

3.	Sustainable management of coastal and marine ecosystems

NAC members call attention to:

•	the fact that preservation and recovery of a species (e.g., monarch butterfly) requires
understanding its decline, and recommend attention to opportunities for the three countries
to collaborate on one species that requires healthy habitats, for example, in each of the
three countries, regardless of the burden to one particular country. NAC Members

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recommend a focus on prompting high-impact change by adopting a common
understanding of what needs to be accomplished and then aiming to achieve it.

• the borderland issues involving the Tijuana River Valley pollution affecting the United
States and Mexico, in which significant financial investments have been proposed. Impacts
to the border regions, as well as the other environmental issues raised by members,
particularly in the May 2019 NAC advice letter, should remain at the forefront of the NAC
recommendations to EPA.

Strategic Priority 4—Resilient Communities

Related Issues as Prioritized by NAC Members Prior to the April 2020 meeting:

1.	Sustainable cities

2.	Remote, coastal and indigenous communities

3.	Resilience offood production sectors

NAC Members recommend that the CEC consider including extreme weather events in the
priorities on resilience and that extreme weather events could be included in the issues related to
remote, coastal and indigenous communities.

Strategic Priority 5—Effective Enforcement of Environmental Laws

Related Issues as Prioritized by NAC Members Prior to the April 2020 meeting:

1.	Illegal trafficking and traceability of CITES (Convention on International Trade in
Endangered Species) species

2.	Illegal trafficking of HFCs

3.	Transboundary movements of hazardous wastes

NAC Members recommend that the issue of the safety of environmental defenders be prioritized
because of the long-term implications.

ADVICE QUESTION # 2. HOW CAN THE CEC AMPLIFY ITS WORK THROUGH
PARTNERSHIPS IN NORTH AMERICA?

NAC Members remarked on how increasing awareness in the environmental community of the
substantial number of CEC grant opportunities would be one way to strengthen partnerships and
build participation in the CEC initiatives and projects. Providing co-investment opportunities to
interested parties, including philanthropic groups, could increase the CEC collection of resources
and help resolve some of the environmental issues discussed in this meeting.

NAC Members noted that the provisions in the new ECA allow the CEC, for the first time, to
accept resources and donations from other organizations to supplement the CEC budget.
Partnerships with nonprofits or nongovernmental organizations are, in the view of the NAC, now
possible.

NAC members recommend reviewing the ECA identify new structures that the CEC could
advocate for concerning new partners and additional resources for the CEC.

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ADVICE QUESTION # 3. WHERE IN THIS STRATEGIC PLAN DO YOU SEE
OPPORTUNITIES FOR ENHANCED ROLES FOR STAKEHOLDERS AND CITIZENS?

NAC members suggest a review of recommendations regarding youth engagement provided in
prior NAC Advice Letters.

NAC Members recommend exploring collaborative partnerships between the three countries that
could address environmental issues in border-states. Such partnerships have been established
between the United States and Mexico for California/Baja, Arizona/Sonora and Texas/Chihuahua.

A potential list of partners were suggested: Border Trade Alliance, Arizona-Mexico Commission,
Smart Border Coalition, Flex Ltd., Border Legislators Conference, Borderplex Alliance, US-
Mexico Border Philanthropy Partnership, US-Mexico Border Mayors Conference, Council of State
Governments and Border Legislatures across the three countries, as well as two tribal consortia:
the Inter-Tribal Council of Arizona and California Tribal Leaders Council. Both Councils work
with tribes in the border-states and would be ones to engage in partnerships.

NAC Members suggested establishing stakeholder groups in Canada and Mexico similar to the
United States NAC and GAC and engaging watershed commissions.

ADVICE QUESTION # 4. GENERAL COMMENTS

NAC Members pointed out the likely change in governments and leadership in the three countries
over the span of the 5-year Strategic Plan and recommend that attention to how these leadership
changes are likely to affect the Strategic Priorities of the CEC.

Given the COVID-19 pandemic and the restrictions on travel and gatherings, NAC Members asked
how opportunities were being created and policies implemented to further environmental goals at
the state and local levels. NAC Members called attention to the efforts in Flint and Detroit,
Michigan, where various cooperative entities are forming to connect people to resources and are
using advanced technologies. The obvious positive environmental impact is a decrease in air
pollution because of the reduction in travel and the increase in virtual meetings.

NAC members suggest that the CEC and EPA seek opportunities to incentivize innovative
initiatives in response to emergency situations, such as COVID-19, including innovative working
from home and telecommuting efforts that could be linked to the Strategic Plan.

NAC Members underscored the use of science-based decision-making and ways to reduce political
polarization around issues of science and facts as they relate to the environment.

NAC Members called attention to funding issues in Indian country for tribes depending on federal
funds to support their environmental programs. Because of COVID-19, most of the work
orders/deliverables are not being met. In a support letter to EPA, the tribes have asked for
flexibility on work plan deliverables and the extension of grants. This is an issue likely affecting
all three countries.

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