RESPONSE TO COMMENTS
FY 2023-2024 NATIONAL PROGRAM GUIDANCE
Office of Enforcement and Compliance Assurance

EPA Publication Number: 300R22001

Instructions:

Comment

Commenter(s)

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in Draft
Guidance

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Specify changes made in
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Template:

Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

1. EPA's discussion of state and local
collaboration includes mention of "building
state capacity, supporting state actions..etc.
EPA needs to be more active and effective at
assuring that its state and local partners are
resourced, trained, and have effective
coordination and technical assistance from
EPA in their role as co-regulators. This may
include specific, line-item designations in State
and Tribal Assistance Grants (STAG) or
Performance Partnership Grants (PPG) towards
technical assistance programs within states.
This also relates the to the prior comment
concerning grant increases to state agencies
(See comment on page 30 of OAR NPG)

National

Steering

Committee

(NSC) of the

Small Business

Environmental

Assistance

Programs

(SBEAPs)

Pages 5, 6, 7
(Introduction)

EPA remains committed to
supporting our co-regulators.
Some programs' STAG do
include line-item designations for
training and other forms of
technical assistance. EPA
continually evaluates how best to
support each program given
individual program needs and
resources.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

la. EPA should coordinate with states
regarding federal inspections and enforcement
actions. Effective consultation and
coordination with the states, consistent with
Assistant Administrator Susan Bodine's July
11, 2019, memorandum, when federal
inspections or enforcement actions are planned
is essential. This is especially true of small
businesses that may have to effectively shut
down to focus on EPA inspections. The better
coordination between EPA and states can result
in less time taken by businesses in relation to
inspections as well as the opportunity for a
more focused and comprehensive overview of
inspection results and how one issue may relate
to other issues that can be solved
simultaneously.

NSC

N/A

Coordination with states, tribes,
and territories with regard to
federal inspections and
enforcement actions is a priority
for EPA. We will continue to
work collaboratively, as
appropriate, to implement federal
environmental laws.

No revision to the National
Program Guidance is
necessary in response to this
comment.

lb. The NSC supports the use of Supplemental
Environmental Projects as part of judicial
settlements and supports EPA is requesting
review and revision of the DOJ policies that
currently limit the use of SEPs.

NSC

Section II.
Key

Programmatic
Priorities,
Page 7

OECA made edits to the final
guidance to reflect that on May 5,
2022, the Administrator of EPA
joined the Attorney General to
announce, among other things,
the restoration of Supplemental
Environmental Projects (SEPs) in
appropriate circumstances as part
of settlements with defendants
who have violated federal
environmental laws.

Made edits to reflect that on
May 5, 2022, the
Administrator of EPA joined
the Attorney General to
announce, among other
things, the restoration of SEPs
in appropriate circumstances
as part of settlements with
defendants who have violated
federal environmental laws.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

lc. The NSC recommends adding PFAS and
PFOS in addition to lead-based paint exposure
in the collaboration with the DoD to protect
military families as military bases were often
where excessive PFAS and PFOS exposure
was first noted as run off from firefighting
drills. Best Practices developed there could
then be applied in additional PFAS and PFOS
areas/actions.

NSC

A:

Background
and Content,
page 5,
Section II.
Key

Programmatic
Priorities,
Page 8

OECA made edits to the final
National Program Guidance to
include collaboration with federal
agencies to address PFAS
chemicals, which include PFOA
and PFOS, as appropriate.

Added a bullet on page 8 on
collaboration with federal
agencies to address PFAS
contamination, as appropriate.

Id. The NSC requests that EPA, through the
State Review Framework, encourage the
support of state SBEAPs. These programs are
designed to provide technical assistance to
small businesses that may not have as much
access to more costly technical assistance
options such as private consultants. It has been
noted that some states are not providing much
support for their SBEAPs or have discontinued
the SBEAP in their state completely. The
SBEAPs are a designated program under
Section 507 of the Clean Air Act and the SRF
should include the SBEAPs in their evaluation
of state performance. For states that do not
implement an SBEAP, per Section 507, EPA
should be implementing the SBEAP for that
state.

NSC

State and
Direct

Implementatio
n Program
Oversight and
Improvement,
Pages 19, 20

OECA's State Review
Framework focuses on
implementation of compliance
monitoring and enforcement
programs; compliance assistance
work is outside the scope of the
State Review Framework.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

le. As an alternative to impoundments and
landfills, coal fired plants that produce Coal
Combustion Residuals could establish
programs for ready-mix concrete companies to
receive shipments of CCR. Fly ash is often
used as an additive to concrete due to its
properties and such use encapsulates the fly
ash, preventing it from becoming mobile.
Encouragement of materials management and
reuse could be a supplement and better use for
some RCRA materials. Support of materials
marketplaces offer a better option for waste
materials than landfilling, which could in term
reduce RCRA wastes.

NSC

RCRA Coal
Combustion
Residuals,
page 36

EPA will continue to encourage
the appropriate beneficial use of
CCR.

No revision to the National
Program Guidance is
necessary in response to this
comment.

2. AAPCA members appreciate EPA OECA's
commitment to state and local government
collaboration in compliance monitoring and
enforcement programs, in particular efforts to
build state capacity and support state actions.

Association of
Air Pollution
Control
Agencies
(AAPCA)

Page 5
Section I.
Introduction

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
implement federal environmental
laws.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

2a. AAPCA continues to support the FY 2020
-2023 National Compliance Initiatives (NCI)
for air. State and local agencies are vital
partners as EPA evaluates the current NCIs and
potential new ones beginning in FY 2023 .EPA
OECA also notes that "EPA and the states
should discuss work-sharing and how to make
the best collective use of EPA and state
resources and expertise to achieve the goals of
the NCIs."Additional information would be
helpful as agencies evaluate resources in
support of EPA's NCIs.

AAPCA

Pages 10-
12C. FY 2020
-2023
National
Compliance
Initiatives—
Also: Pages
24 -25CAA
Title II,
Vehicle and
Engine
Enforcement
Program

EPA will share information with
state agencies once new NCIs are
selected.

No revision to the National
Program Guidance is
necessary in response to this
comment.

2b. AAPCA and state and local agencies are
providing key direction and input as EPA
undertakes modernization of the Integrated
Compliance Information System (ICIS). The
transition to ICIS/ICIS-Air created difficulties
for agencies, and EPA OECA should
consistently engage and take feedback from
agencies during the next transition.

AAPCA

Pages 17-18
Section IV.
Implementing
Other Core
Work A.
Cross-
program
Activities (3.
Data

Reporting)

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
modernize the Integrated
Compliance Information System
(ICIS).

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

2c. EPA OECA states that an Agency activity
for FY 2023 -2024 will be to "Support and
encourage states, territories, and tribes to
support inspector training
development."Additional clarification from
EPA OECA is needed in the final NPG. State
and local agencies have previously stressed the
importance of EPA taking a primary role in the
development of training materials, courses, and
other learning opportunities.

AAPCA

Page 20
Section IV.
Implementing
Other Core
WorkA.
Cross-
program
Activities (6.
Field

Activities)

EPA remains committed to
supporting our co-regulators in
regard to training. Some
programs' STAGs include line-
item designations for training and
other forms of technical
assistance. EPA continually
evaluates how best to support
each program given individual
program needs and resources.
EPA also strives to provides
online and in-person training
opportunities in other areas for
our co-regulators to the extent our
resources allow. At the same
time, EPA cannot take total
responsibility for training. Co-
regulators play an important role
in training their own staff and
partnering with EPA in training
activities at the federal, state,
tribal and local levels.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

2d. EPA OECA's draft Guidance indicates that
in Authorized Programs, the Agency will
negotiate compliance monitoring strategy
(CMS) and alternative compliance monitoring
strategy (ACMS) plans with states, which will
include an effort to "Maximize the flexibilities
by considering each agency's unique
situation." AAPCA members support this
commitment and suggest that OECA consider
off-site compliance monitoring.

AAPCA

Pages 22 -23
Section IV.
Implementing
Other Core
WorkB.
Program-
specific
Activities (1.
Clean Air
Act)

EPA will continue to work
collaboratively with the states
when negotiating CMS plans.
Currently, the CAA CMS does
provide flexibility for states to
augment onsite inspections with
offsite compliance monitoring
activities (e.g., off-site Partial
Compliance Evaluations) and
include such activities in their
CMS plans.

No revision to the National
Program Guidance is
necessary in response to this
comment

3. EPA should discuss the desire to coordinate
with states regarding federal inspections,
violation determination, and enforcement
actions. This will ensure the most strategic use
of limited resources.

Association of
Clean Water
Administrators
(ACWA)

Page 5

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
implement federal environmental
laws and ensure strategic use of
resources.

No revision to the National
Program Guidance is
necessary in response to this
comment

3a. EPA should prioritize inspector training. In
2022 ACWA provided EPA with survey data
on the types of inspector training preferred.

ACWA

Page 5

EPA will consider the input from
the States that ACWA shared
with us as we work to identify
training opportunities for State
inspectors.

No revision to the National
Program Guidance is
necessary in response to this
comment

3b. EPA should continue to work closely with
states in prioritizing violations and specifically
identify those with environmental justice
concerns.

ACWA

Page 8

EPA will continue to cooperate
with states to address violations
with an emphasis on communities
with environmental justice
concerns.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

3c. EPA should include remote compliance
monitoring and desk reviews as critical tools
for assessing noncompliance.

ACWA

Page 17

Experience over the past few
years has shown that alternative
compliance monitoring strategies
such as offsite compliance
monitoring can be used
successfully to augment on-site
inspections. EPA's Compliance
Monitoring Strategies will
continue to include flexibilities
for states to use offsite
compliance monitoring activities,
including remote compliance
monitoring and desk reviews, as
appropriate. An EPA-state team is
currently evaluating the
effectiveness of offsite
compliance monitoring under the
Compliance Learning Agenda.
We intend to use results from this
evaluation, as well as other
information from state and EPA
experiences, to inform our
policies and recommendations for
when and how to use of offsite
compliance monitoring while
maintaining a robust on-site
compliance monitoring program.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

3d. EPA should continue to work closely with
states on the SNC NCI and support efforts that
help address the largest universes of SNC.

ACWA

Page 13

Thank you for your continuous
support for the SNC NCI. We
will continue to work closely with
the states and ACWA on the SNC
NCI and to focus our efforts, in
consultation with our state
partners, on areas and sectors
where we believe our work can
make a difference in compliance,
e.g., small municipal wastewater
treatment plants.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

3e. EPA should thoughtfully review all of the
challenging guidance/policies identified by the
ICIS Modernization Board to determine
appropriateness of revision.

ACWA

Page 27

EPA will ensure that the
appropriate national program
offices within the Agency are
engaged in the review of the
identified challenging
guidance/policies put forth by the
ICIS Modernization Board. It
should be noted that in most cases
the national program offices
responsible for the review and
appropriate modification of
guidance and policies are
different than the national
program office responsible for the
technical implementation of the
Integrated Compliance
Information System (ICIS)
modernization. EPA will clearly
communicate when a revision is
deemed appropriate, and be as
transparent as possible about the
revision process. As always,
EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
modernize ICIS.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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4. One of the most pressing challenges state
and tribal drinking water programs continue to
face is prioritizing competing programmatic
needs without increased funding for the
programs. States are in the process of
implementing the new Lead and Copper Rule
Revisions (LCRR) while waiting for the Lead
and Copper Rule Improvements (LCRI),
preparing for a new drinking water regulation
for PFAS, and helping systems comply with
already existing regulations.

4a. EPA OW, OECA, and Regions should
work together with states to identify program
areas that could be deemphasized at this time
or shifted to a lower priority. There must be an
acknowledgement and allowance from EPA to
states that with the increasing workload from
new issues, there must be existing work that
becomes a lower priority. These priorities may
have regional variations and should reflect
local concerns in the states and regions. Polices
that reflect allocating efforts based on biggest
yield for the investment for public health
protection would be welcomed by the states.
For example, states having to chase down
paperwork for outdated public notice violations
rather than increasing time spent assisting
systems with current or health-based
violations. States are asking EPA to recognize
the high volume of work completed by the
state primacy programs and the successes
states have already achieved in reducing non-

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 5

EPA understands the need to
coordinate, focus, and shift
resources as new priorities arise.
EPA strives to set priorities via
the NCI selection process and
NPG review as well as during
ongoing regional/state
discussions.

No revision to the National
Program Guidance is
necessary in response to this
comment.

EPA recognizes that Primacy
Agencies have many
responsibilities under SDWA, and
will continue to collaborate with
all stakeholders to make sure
regulators' limited resources are
being used to address the most
pressing public health issues.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

compliance.

The current approach by EPA to continue to
add regulatory and non-regulatory
requirements, without additional resources and
without guidance on disinvesting in lower
priority issues, is not sustainable. With the
ongoing workforce issues faced by states,
states are at a critical point in which they must
disinvest in lower priority activities or risk
significant public health impacts and burn out
or loss of state staff.









4b. Identify the section describing OECA's
two financial assistance programs.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 6

The appropriate Section has been
identified in the NPG.

Revision made. Section V has
been added to NPG.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4c. ASDWA encourages EPA to continue to
work with the DOJ on the inclusion of SEPs in
civil settlements. ASDWA strongly supports
the use of SEPs for compliance. SEPs are a
tool that can be utilized to address recalcitrance
and in lieu of a penalty, return a public water
system to compliance by investing in
remediation actions (e.g., a system that has
repeatedly failed to collect samples may
undertake a SEP to contract out sampling).

This is especially important where penalties
may be assessed to a community-owned PWS
and passed on to rate payers as this money
would be better spent on remediating the
concern. Additionally, at systems with critical
technical, managerial, and financial (TMF)
issues, assessing financial penalties, in lieu of
offering a SEP, exacerbates these TMF issues,
which may contribute to additional public
health concerns.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 7

OECA made edits to the final
guidance to reflect that on May 5,
2022, the Administrator of EPA
joined the Attorney General to
announce, among other things,
the restoration of Supplemental
Environmental Projects (SEPs) in
appropriate circumstances as part
of settlements with defendants
who have violated federal
environmental laws.

As a clarification, SEPs are not
accepted in lieu of a penalty. A
violator's agreement to perform a
SEP that benefits public health
and/or the environment is a
relevant factor for the EPA to
consider in establishing an
appropriate settlement penalty
amount, just as factors like good
faith and cooperation are
considered. Further, settlements
with SEPs must always include a
final settlement penalty that
retains the deterrent value of the
settlement.

Made edits to reflect that on
May 5, 2022, the
Administrator of EPA joined
the Attorney General to
announce, among other
things, the restoration of
Supplemental Environmental
Projects (SEPs) in appropriate
circumstances as part of
settlements with defendants
who have violated federal
environmental laws.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4d. ASDWA recommends that OECA partner
with states, in addition to regions, regarding
the type and frequency of increased inspections
to address environmental concerns discussed in
the April 30, 2021 memo - coordination is
critical.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 7

EPA will confer with our partner
states when planning and
conducting federal inspections to
ensure the most effective use of
the compliance assurance tools at
our disposal.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4e. The drinking water industry is impacted
directly by climate change and faces challenges
due to drought and other extreme weather
events; however, the compliance and
enforcement activities discussed in Part B of
Section II do not outline efforts to ensure
resilience to climate change for the water
sector.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 9

We agree that the drinking water
systems face many climate
change challenges and we will
continue to work collaboratively
with states, territories, tribes, and
local agencies, as appropriate, to
ensure safe drinking water.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4f. ASDWA recommends that OECA partner
with states in conducting additional inspections
to identify and address risks for the
noncompliance at community PWSs. Unless a
case has been referred for federal enforcement,
the state has primary enforcement authority
and should be the lead for inspections and
communications with systems - OECA can fill
in gaps or where inspections are requested by
the state. Duplicating states' efforts is not
effective. A robust dialogue with states
regarding violations and significant
deficiencies will be a more effective approach
to increasing compliance, in addition to the
increased inspections.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 13

Joint strategic planning with
primacy agencies will continue to
play an important role in EPA's
implementation of the drinking
water NCI. Each Region, in
collaboration with primacy
agencies, will be developing a
drinking water NCI action plan to
ensure the efficient allocation of
scarce resources and identify
where the EPA support can most
effectively complement,
supplement, and not duplicate, the
states' ongoing efforts.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4g. OECA should partner with OW in all
compliance reviews, as the burden of
conducting the review is otherwise doubled for
the states. States have limited capacity and are
facing funding and workforce issues on top of
heightened expectations and a growing number
of regulations; as such, a streamlined process
among OECA, OW and the regions to inspect
their efforts is needed. Many states welcome
collaboration with EPA; however, historically
states have not felt that EPA appreciates the
drain on resources that competing compliance
reviews have on their programs.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 14

EPA is currently piloting its
enforcement file reviews. The
pilots include recommended
coordination steps between
regional enforcement and
program reviews. As part of the
pilot process, EPA is seeking
feedback from primacy states on
opportunities for streamlining and
specifically on the question of
their preference for joint or
separate reviews.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4h. Is OECA considering monitoring and
reporting violations to be health-based
violations with respect to the NCI? This
question merits additional discussions with
ASDWA's members

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 14

OECA recognizes monitoring and
reporting and health-based
violations as different. We will
engage the appropriate
stakeholders on these issues
through the SDWA Community
Water System NCI.

No revision to the National
Program guidance is
necessary in response to this
comment.

4i. Is OECA considering an action level
exceedance or a significant deficiency a
violation for purposes of the NCI? This
question merits additional discussions with
ASDWA's members.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 14

When implementing national
compliance initiatives, the agency
does so in accordance with the
existing laws and regulations.
Accordingly, if something is not
considered a violation under the
statute or regulations, the agency
does not change that designation
via the NCI.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4j. The Lead and Copper Rule () is specifically
called out for rule-based file reviews aimed at
increasing timely and tangible benefits for
communities. The exceedance of the lead or
copper AL is not a violation of the NPDWRs;
however, noncompliance with the deadlines
and requirements stemming from an ALE
would result in a violation. If a system is in
compliance with the deadlines & requirements
within the LCR, does OECA plan to require a
system to complete actions beyond what is in
rule in order to achieve these EJ benefits of
timeliness? This question merits additional
discussions with ASDWA's members.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 14

OECA has a range of tools to
help primacy states and
communities sustain compliance
with the lead and copper rule.
Generally, EPA, in coordination
with our coregulators, makes
case-specific decisions about
what actions are needed to protect
public health.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4k. Over what time period is OECA planning
to conduct compliance evaluations of half of
the large community systems? It is important
for EPA to consider the significant time burden
this places on states who are required to
coordinate with and provide documentation for
these evaluations. ASDWA recommends
coordinating with states on developing a better,
more streamlined, approach to identifying the
necessary information without placing added
burden onto the state enforcement staff.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 14

OECA is currently considering
the appropriate timeline for
evaluation of large Community
Water Systems. Each Region, in
collaboration with primacy
agencies, will be developing a
drinking water NCI action plan to
ensure the efficient allocation of
scarce resources.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

41. Outreach efforts to communities should
focus not only on the general public, but also
on local government entities that have control
and decision-making power over community
drinking water systems. Recalcitrance of these
entities may be the source of non-compliance,
or the entities may not fully appreciate the
situation and fail to address compliance
concerns.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 14

EPA agrees that local government
participation is important to our
communication efforts. Your
comment raises an important
issue that we will make sure to
consider as part of our
compliance and enforcement
activities.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4m. OECA and OW need to coordinate efforts
regarding data reporting and the critical need to
update SDWIS. The lack of accurate and
timely data and information hinders everyone's
efforts to increase compliance.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 18

OECA and OW are coordinating
on modernizing the Safe Drinking
Water Information System which
is expected to reduce state data
management work and enhance
the timeliness and accuracy of
drinking water data transferred
among drinking water systems,
primacy agencies, and EPA.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4n. It should be clarified that in most cases
EPA does not directly enforce the SDWA, as
indicated by item 2 under EPA Activities.
Additionally, because SDWA has not
historically been a part of the "State Review
Framework", actions 3-9 do not necessarily
align with OECA's actions regarding SDWA.
ASDWA suggests clarifying with a separate
sub-section to highlight the differences of
OECA's involvement with SDWA and include
coordination efforts with OW and Regions.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 19-20

Revisions have been made to
section IV.A.5 to distinguish
between activities under SRF for
C A A, CWA, and RCRA and the
pilot SDWA enforcement
reviews.

Edits made to section IV.A.5
to clarify.

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Comment

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Location in

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Guidance

National Program Offices
Response

Action Taken in Final
Guidance

4o. OECA and OW should collaborate on
SDWA inspector training and development.

J. Alan

Roberson, P.E.,
ASDWA
Executive
Director

Page 20

Input from OW is an essential
component of OECA SDWA
inspector training.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4p.OECA should provide support and guidance
to co-regulators to address concerns regarding
contamination of drinking water by
unregulated, emerging contaminants, including
PFAS, especially at federally-owned PWSs
(e.g. military bases).

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 21

OECA made edits to the final
National Program Guidance to
include collaboration with co-
regulators to address PFAS
chemicals, including PFOA and
PFOS, as appropriate.

Added a bullet on page 8 on
collaboration with co-
regulators to address PFAS
contamination, as appropriate

4q.Items 1 and 2 under EPA activities are
conducted by state primacy agencies, and
while EPA has oversight of these activities, it
should be clarified EPA's activity consists of
ensuring states complete these activities, as
denoted in item 3.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 30

EPA maintains independent
authority to monitor compliance
with the SDWA, conduct
inspections, and to initiate
enforcement responses if
violations are found.

No revision to the National
Program Guidance is
necessary in response to this
comment.

4r. An additional activity should be added to
EPA's general activities: develop and release
guidance for states and regulated entities.
States rely on guidance for implementation of
the SDWA and it should be a priority for EPA
to release implementation guidance in a timely
manner, in collaboration with OW and the
states themselves, as regulations are being
updated or created to ensure effective and
consistent implementation and understanding
of the requirements.

J. Alan

Rob er son, P.E.,
ASDWA
Executive
Director

Page 30

OECA routinely consults with
OW to develop needed guidance.

No revision to the National
Program Guidance is
necessary in response to this
comment

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5. An overall comment for EPA to continue to
consider as the National Program Guidance
(NPG) nears finalization is the notion that over
the past two plus years, the global pandemic
has generated numerous challenges both for
regulated entities as well as for regulators,
from restrictions on inspections due to local
public health orders to supply chain,
transportation, and labor force issues. We
would urge EPA to continue to build as much
flexibility into the NPG as possible to allow
States and other affected partners to adapt to
fluid circumstances in each State or region.

ASTSWMO

Page 5:
Section I. A.
Introduction -
Background
and Context:

Section V of the NPG encourages
the use of several vehicles which
can be used to facilitate
administrative, financial, and
programmatic flexibilities for
states, tribes, and territories.

No revision to the National
Program Guidance is
necessary in response to this
comment.

5a. If EPA's intent is to incorporate specific
requirements related to focusing enforcement
resources on increasing inspections and
enforcement in "overburdened and vulnerable
communities" into Performance Partnership
Agreements (PPAs) commitments, we suggest
building as much flexibility as possible into
guiding documents for authorized States to
account for differing environmental justice
initiatives being implemented at the State level.

ASTSWMO

Page 5:
Section I. A.
Introduction -
Background
and Context:

The EPA is committed to offering
a level of flexibility that accounts
for the unique circumstances
encountered by our co-regulators
while also ensuring compliance
assurance programs are effective.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

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Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5b. What specifically is meant by EPA's intent
to directly implement compliance monitoring
and enforcement programs? Is this true for
authorized RCRA programs where a State's
RCRA program operates in lieu of the Federal
program? It has always been true that EPA
retains its enforcement authority and exercises
that authority if States/Territories/Tribes or
local governments lack the authority,
capability, or resolve to take timely and
appropriate action; is EPA contemplating a
change to its scope of work related to directly
conducting inspections and enforcement in
authorized States?

ASTSWMO

Page 5:
Section I. A.
Introduction -
Background
and Context:

These statements reflect EPA's
ongoing responsibilities for direct
implementation in certain
scenarios and oversight of our co-
regulators on program
implementation. EPA is not
contemplating a fundamental
change in the way that authorized
state RCRA programs operate in
lieu of a federal program.

No revision to the National
Program Guidance is
necessary in response to this
comment.

5c. We encourage EPA to continue to provide
and expand training opportunities to enhance
co-regulator capacity for enforcement,
compliance monitoring and compliance
assurance.

ASTSWMO

Page 5:
Section I. A.
Introduction -
Background
and Context:

EPA will continue to provide and
look for opportunities to expand
training for our co-regulators.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5d. When EPA looks to incorporate
performance measures associated with
environmental justice and climate change into
specific standards that States must implement,
these should be clearly articulated and affected
programs given ample opportunity for input
and collaboration prior to inclusion in the NPG
or other guiding documents, such as the
Compliance Monitoring Strategy (CMS) or
individual PPAs.

ASTSWMO

Pages 7 - 10:
Section II.
Key

Programmatic
Priorities:

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
implement federal environmental
laws.

No revision to the National
Program Guidance is
necessary in response to this
comment.

5e. We suggest that any increase in the number
of RCRA NCI inspections be coordinated and
agreed upon at the Regional level with specific
States and take into account States' differing
programmatic organization/resources and
expertise to conduct organic air emissions
inspections. Additionally, the focus should
prioritize facilities with a high likelihood of
contributing to air pollution from organic air
emissions.

ASTSWMO

Page 11:
Section II. C.2
-Key

Programmatic
Priorities -
FY 2020-
2023 National
Compliance
Initiatives
(NCI) -
Reducing
Hazardous
Air Emissions
from

Hazardous

Waste

Facilities:

We agree that EPA Regions and
states must continue to coordinate
and agree on inspection targets,
including those for the RCRA
NCI. EPA is committed to
supporting states with the training
and technical expertise needed to
fully implement organic air
emission evaluations into their
RCRA inspection and
enforcement programs.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

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Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5f. We support increasing capacity among
Regional and State RCRA inspectors through
continued training and development.

ASTSWMO

Page 11:
Section II. C.2
-Key

Programmatic
Priorities -
FY 2020-
2023 National
Compliance
Initiatives -
Reducing
Hazardous
Air Emissions
from

Hazardous

Waste

Facilities:

We agree that prioritization of
training and capacity building for
federal, state and regional
enforcement and compliance
monitoring personnel, including
RCRA inspectors, is important.
We will continue to aim to
develop training and capacity
building efforts to support these
enforcement and compliance
efforts.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5g. It was noted by some members that the
challenges presented by the pandemic required
programs to pivot to alternative strategies for
compliance monitoring and assurance and
would encourage EPA to continue to provide
flexibilities in order to allow State waste
programs to focus efforts in a manner that
optimizes resources. Since the document
memorializes EPA's operational planning
priorities, strategies, and key activities
especially as relates to State waste program
oversight, compliance monitoring initiatives
and grant work planning, flexibilities will
ensure that regional challenges associated with
the Covid-19 pandemic, natural disaster
response or other local concerns can be
addressed while still operating within the
expectations of EPA's priorities.

ASTSWMO

Page 17-
Section IV.
Implementing
Other Core
Work

OECA understands the
flexibilities provided in the July
22, 2020 partner asencv
inspection flexibilities memo and
subsequent extensions through
March 31, 2022 were crucial
during the pandemic. The
experience has shown that certain
offsite compliance monitoring
activities can be used successfully
to augment on-site inspections.
EPA will consider the pandemic
flexibilities in the context of the
compliance learning agenda and
our EPA-State compliance
monitoring strategies. We intend
to use our collective experiences
to inform our policies and
recommendations for when and
how to use different compliance
monitoring approaches while
maintaining a robust compliance
assurance program.

No revision to the National
Program Guidance is
necessary in response to this
comment

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

5h. There is an offer of CCR training
opportunities, both general and subject-specific
for States. Since States are already requesting
program approval and others are working on
their rules/applications, States need such
training now, especially if there are
expectations for CCR rule interpretation.

ASTSWMO

Page 36:

RCRA Coal

Combustion

Residuals

(CCR)

Compliance

Assurance

and

Enforcement
Program:

EPA has provided CCR training
to numerous state partners over
the last several years, and will
continue to seek these
opportunities, including through
engagement with ASTSWMO on
CCR.

No revision to the National
Program Guidance is
necessary in response to this
comment.

5i. There is an expectation of coordination and
collaboration in CCR rule implementation and
facility noncompliance. This seems to be a
departure from approved State Municipal Solid
Waste (MSW) landfill permit programs, where
beyond approving initial regulations/programs,
there has been little EPA interaction with
approved State programs. The EPA authority
derived from the WIIN Act should be made
clear for States seeking CCR program
authority.

ASTSWMO

Page 36:
Under EPA
Activities in
Authorized
Program and
Expectations
for State,
Territory,
Tribal, or
Local

Government
Activities in
Authorized
Programs

EPA plans to maintain its
collaborative relationship with
states as it enforces the CCR Rule
in unapproved states and
coordinates enforcement efforts
in approved states. Unlike the
MSW program, Congress through
the WIIN Act, gave EPA
authority to enforce the CCR
Rule directly in both unapproved
and approved states.

Revision made in the National
Program Guidance on p. 36

#5.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

6. EPA should coordinate with states regarding
federal inspections and enforcement actions.
Effective consultation and coordination with
the states, consistent with Assistant
Administrator Susan Bodine's July 11, 2019
memorandum, when federal inspections or
enforcement actions are planned is essential.
This will assure the best use of limited
compliance resources, minimize friction, and
reduce duplication of effort.

Environmental
Council of the
States (ECOS)

Page5:
Introduction

EPA agrees that cooperative joint
planning and regular
communication with states are
essential to promote shared
accountability between federal
and state enforcement authorities.
That is why EPA regularly
engages with ECOS and its
members to discuss compliance
and enforcement issues.
Additionally, EPA regional
offices meet with their states to
discuss and coordinate
compliance and enforcement
topics. EPA will continue our
collaboration with states,
territories, tribes, and local
agencies, as appropriate, to
implement federal environmental
laws.

No revision to the National
Program Guidance is
necessary in response to this
comment

6a. EPA should continue to prioritize inspector
training. Resources continue to be a challenge
as states take on more work despite flat
budgets. Training continues to be a priority to
ensure inspectors are equipped with the current
information needed to pursue cases to the
fullest.

ECOS

Page 5:
Introduction

EPA will continue to prioritize
training to ensure inspectors are
adequately equipped. EPA
provides online and in-person
training opportunities for our
inspectors and our co-regulators
to the extent our resources allow.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

6b. EPA's discussion of state and local
collaboration includes mention of "building
state capacity, supporting state actions..." etc.
EPA needs to be more active and effective at
assuring that its state and local partners are
resourced, trained, and have effective
coordination and technical assistance form
EPA in their role as co-regulators.

ECOS

Pages 5-7:
Introduction

EPA remains committed to
supporting our state and local
partners. We provide STAGs that
include funding for training and
other forms of technical
assistance. EPA continually
evaluates how best to support
each program given individual
program needs and resources.
EPA also strives to provides
online and in-person training
opportunities in other areas for
our co-regulators to the extent our
resources allow.

No revision to the National
Program Guidance is
necessary in response to this
comment.

6c. States have identified challenges regarding
Publicly Owned Treatment Works in small or
remote communities, often operated by third
parties. EPA should work closely with states to
achieve improvements in Community Water
Systems (CWSs) compliance.

ECOS

Page 12,13
(Community
Water
Systems)

EPA recognizes the compliance
challenges faced by small
Publicly Owned Treatment
Works and Community Water
Systems. EPA will work with
states to expand the use of the
Compliance Advisors to help
overburdened systems return to
compliance.

Added language to p. 12,
Section 4, on the SNC NCI to
clarify that assistance for
underserved communities
includes Compliance
Advisors. This mirrors
language in the Section 5 on
the CWS NCI.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

6d. EPA should include Off-site Compliance
Monitoring as a critical tool for assessing
noncompliance.

ECOS

Page 17 (A.
Cross-
program
Activities)

EPA's Compliance Monitoring
Strategies will continue to include
flexibilities for states to augment
onsite inspections with offsite
compliance monitoring activities,
as appropriate. An EPA-state
team is currently evaluating the
effectiveness of off-site
compliance monitoring under
OECA's Compliance Learning
Agenda. We intend to use results
from this evaluation, as well as
other information from state and
EPA experiences, to inform our
policies and recommendations for
when and how to use of offsite
compliance monitoring while
maintaining a robust compliance
assurance program.

No revision to the National
Program Guidance is
necessary in response to this
comment.

6e. EPA plays an important role as the liaison
between states and other federal agencies.
EPA's goal to reduce the number of all referred
no complaint filed civil judicial cases more
than 2.5 years old is a good first step.

ECOS

Page 48 (FY
23 National
Program
Measures)

EPA will continue to work on
reducing the number of all
referred no complaint filed civil
judicial cases more than 2.5 years
old.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

7. Office of Enforcement and Compliance
Assurance Draft National Program Guidance,
Fiscal Years 2023-2024 cites in Section VI
(National Program Guidance Measures) a
target of 10.1% or less for permittees in
significant noncompliance with their permit
limits. Since some permittees have multiple
NPDES permits, and only one of those permits
may be in SNC status, Wyoming recommends
changing this target to 10.1% or less "of issued
NPDES permits in significant noncompliance
with their effluent limits." This would provide
a more accurate reflection of compliant vs.
non-compliant facilities and their affected
water bodies.

Water Quality
Division,
Wyoming DEQ

Pg. 48, Draft
National
Enforcement
and

Compliance
Assurance
Program
Guidance

We very much appreciate
Wyoming DEQ's raising an
interesting observation. The SNC
NCI Steering Committee will
discuss this issue and decide on a
path forward.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

7a. Section 4. Safe Drinking Water Act:

SDWA UIC Compliance Assurance and
Enforcement Program. EPA indicates that a
state expectation is to "Coordinate with EPA to
review draft primacy program regulations
throughout the development process including
drafting and finalizing stages." As part of
cooperative federalism, DEQ is committed to
coordinating with EPA when promulgating
rules related to primacy programs. However,
also in the interest of cooperative federalism,
DEQ will follow established state rulemaking
procedures when promulgating rules. On a
case-by-case basis, the DEQ will collaborate
with EPA region staff to determine review
procedures to ensure that EPA, as the oversight
agency, has an appropriate role in the
rulemaking process. EPA's attempt to establish
requirements for state rulemaking procedures
in the NPGs is not appropriate.

Water Quality
Division,
Wyoming DEQ

Pg. 32, Draft
National
Enforcement
and

Compliance
Assurance
Program
Guidance

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, to
implement federal environmental
laws.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

8. In its introduction, OECA says that it
"supports EPA's FY 2022-2026 principles of
following the science, following the law, being
transparent, and advancing justice and equity.
OECA's priorities, policies, and practices will
focus on being consistent and systematically
fair, just, and impartial in our treatment of all
individuals." NACAA supports these
underpinning principles, consistent with
NACAA's early input on the FY 22-26 NPGs
and previous comments on earlier guidances
(for example, https://www.4cleanair.org/wp-
content/uDloads/Documents/NACAANPMCo
mments-FY20-21-05022019.odf).

National
Association of
Clean Air
Agencies
(NACAA)

Page 5:
Introduction

Thank you for your continued
support of EPA's principles of
following the science, following
the law, being transparent, and
advancing justice and equity.

No revision to the National
Program Guidance is
necessary in response to this
comment

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8a. Section 1 A also calls for "This work [to]
include targeting and screening to prioritize
inspections and enforcement cases in
overburdened and vulnerable communities."
This aligns with the first recommendation in
NACAA's January 15. 2021 Transition Letter
to the Biden-Harris Administration, that "EPA
should make the consideration of racial justice
and protection of overburdened communities
from the impacts of pollution and climate
change a central focus across all its activities,
as well as exploring ways to involve
overburdened communities in environmental
regulatory decisions that affect their residents.
Environmental Justice (EJ) should not be just a
single program within EPA, it should be
integrated prominently into every program
across EPA." It continues that "EPA's
permitting and enforcement efforts should be
among the first areas of focus for these
activities. When EJ is placed as a central
concern in permitting and enforcement, it
creates immediate opportunities for reducing
harms to the communities most heavily
burdened by pollution impacts. EPA should
consider the permitting and enforcement
models of NACAA member agencies that have
centered disproportionately affected
communities." As a community of agencies,
NACAA continues to be involved in the
modernization of the Integrated Compliance
Information System (ICIS) and OECA should
continue to make NACAA a central partner in

OECA's commitment to EJ
across all media programs is
outlined in the following
memorandums. On April 30,
2021, OECA issued a
memorandum, Strengthening
Enforcement in Communities
with Environmental Justice

, directing an increase in
the number of facility inspections
in overburdened communities,
enhancements to remedies, and an
increase in community
engagement. EPA will focus on
strengthening enforcement and
resolving environmental
noncompliance through remedies
with tangible benefits for the
impacted community. On June
21, 2021, OEC A's Acting
Assistant Administrator, issued a
memorandum, Strengthening
Environmental Justice Through
Criminal Enforcement, directing
strengthened detection of
environmental crimes in
overburdened communities
through effective civil-criminal
coordination on investigations
and cases, improved assistance to
crime victims, and enhanced
remedies sought in environmental
crime cases. Lastly, on July 1,

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

that effort. As OECA develops new tools to
assist in targeting and screening, it should
involve the NACAA community of agencies at
every stage.





2021, OECA issued a
memorandum. Strengthening
Environmental Justice Through
Cleanup Enforcement Actions,
directing cleanup enforcement
staff to require responsible parties
to take early and prompt cleanup
actions, press for more robust
enforcement instruments, and
increase cleanup oversight.



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8b. The draft states that "OECA will address
climate change by establishing a new
hydrocarbon enforcement program..." On July
2, 2021, NACAA supplied comments to the
EPA regarding its American Innovation and
Manufacturing (AIM) Act implementation
rule, (httDs://www.4cleanair.org/wD-
content/uploads/Final-

NACAA 7 2 21 Comments HFC AIM AC

NACAA

Page 5
Introduction

EPA will continue to work
collaboratively with states,
territories, tribes, and local
agencies, as appropriate, as we
move forward with
implementation of regulations
under the AIM Act.

No revision to the National
Program Guidance is
necessary in response to this
comment.

T-l .p ) and in those comments identified
areas where EPA should coordinate with state
and local programs on issues such as
enforcement. For example, NACAA's
comments noted that "EPA should coordinate
with those agencies that have programs to
facilitate multijurisdictional consistency
surrounding labelling, recordkeeping, tracking,
reporting, verification, and enforcement.
Tracking programs should allow for
terminological flexibility around issues such as
labeling and disclosure to enable consistency
with, and take advantage of lessons learned
from, the variety of existing local and state
programs. In addition, authorized by statues
and regulations in their jurisdictions some local
and state programs emphasize GHG reductions
over a period that prioritizes some HFCs with
longer or shorter persistence longevity." Also,
NACAA's July 2, 2021 comments noted that
"As it finalizes its proposal, EPA should also
detail how it will coordinate with state and
local recovery, reclamation and reuse
programs."

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

State and local agencies have existing
programs and EPA should make every effort to
coordinate with these agencies and leverage
their experience, widespread presence,
institutional strengths, and expertise.









8c. The sentence referenced in the previous
comment continues "... directing enforcement
resources to ensure effective enforcement
against noncompliant emissions of greenhouse

gases..."

As reflected in NACAA's response to OAR,
EPA should work to assure that state and local
enforcement efforts have sufficient resources
from the federal government to accomplish
their role as enforcement co-regulators. In
addition to grant funding, key areas that EPA
can facilitate are the provision of technical
assistance and training.

NACAA

Page 5:
Introduction

EPA remains committed to
supporting our co-regulators in
regard to training and technical
assistance. EPA continually
evaluates how best to support
each program given individual
program needs and resources.
EPA also strives to provides
online and in-person training
opportunities in other areas for
our co-regulators to the extent our
resources allow.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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8d. EPA's discussion of state and local
collaboration includes mention of "building
state capacity, supporting state actions..etc.
As noted above, EPA needs to be more active
and effective at assuring that its state and local
partners are resourced, trained, and have
effective coordination and technical assistance
form EPA in their role as co-regulators.

Enforcement of new rules will not keep pace
without additional resources to effect data
gathering and action taken to support
compliance and address violations. In
NACAA's January 28, 2022 comments on the
EPA's proposed NSPS for the Oil and Gas
Sector (https://www.4cleanair.org/wp-
content/uploads/NACAA-Oil-and-Gas-NSPS-
Comment-Letter-01 28 2022.pdf). NACAA
noted that "all agencies face inadequate
resources to meet their existing and emerging
Clean Air Act responsibilities. For agencies
that have a daunting number of sources and
already-stretched funding, human resources,
and equipment, the rule will create
implementation challenges if EPA does not
become a more effective advocate for fully
funding these agencies, and matching the
regulatory responsibilities assigned to these
agencies with the resources to carry them out.
"New EPA rules will overburden agencies with
many new sources requiring new inspection
and enforcement actions with unchanged
funding, resources and support. The Agency

EPA remains committed to
supporting our co-regulators in
regard to training and technical
assistance. EPA continually
evaluates how best to support
each program given individual
program needs and resources.
EPA also strives to provides
online and in-person training
opportunities in other areas for
our co-regulators to the extent our
resources allow.

No revision to the National
Program Guidance is
necessary in response to this
comment.

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Comment

Commenter(s)

Location in

Draft
Guidance

National Program Offices
Response

Action Taken in Final
Guidance

has a responsibility to address this issue.









9. When US EPA is to conduct civil or
criminal action, the US EPA should remember
that Tribes are not land owners. In the new
language in RCRA, tribes are defined as land
owners.

Navajo Nation

General
Comment

Please contact Jonathan Binder for
further clarification on the
comment

No revision to the National
Program Guidance is
necessary in response to this
comment.

9a. Are there baseline statistics to show the
number of inspections per tribe for the OITA
office to share?

Navajo Nation

Page 10
(OITANPG)

EPA can provide information on
the number of inspections
conducted in Indian
country. EPA is not currently
able to provide baseline statistics
on the number of inspections
conducted per tribe.

No revision to the National
Program Guidance is
necessary in response to this
comment.

10. The phrase "... and federally recognized
Indian t (tribes),.." needs to be completed to
say "... and federally recognized Indian tribes
(tribes), ...".

Mille Lacs
Band of Ojibwe

Page 5

The sentence has been updated

Edit made to National
Program Guidance.

10a. The document has hotlinks for various
relevant topics and sites. This is good if the
document will be strictly electronic. But
because some may receive the document in a
paper form, all hotlink URLs should be
provided as reference either within the text
itself, or be footnoted, and have then have the
provided URL be hot-linked.

Mille Lacs
Band of Ojibwe

throughout

Endnotes added to the National
Program Guidance with URLs

Edits made to the National
Program Guidance

38


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