Publication #440S23001 November 13, 2023 Summary of Input from State, Territory, and Tribal Partners for OAR's FY 2025-2026 National Program Guidance November 13, 2023 Publication #440S23001 In September 2023, the Office of Air and Radiation (OAR) offered the opportunity for national, state, local, and Tribal air, public health, and radiation associations to provide early input to inform the development of the OAR National Program Guidance (NPG) for fiscal year (FY) 2025-2026 via letters of invitation. OAR received four sets of comments and shared that input with its offices and other national program offices, where relevant. Process for Soliciting Early Input Table 1. Process for Soliciting Early Input by Organization Name of Organization Venue Date National Association of Clean Air Agencies (NACAA) Email solicitation 9/5/2023 National Tribal Air Association (NTAA) Email solicitation 9/5/2023 Environmental Council of the States (ECOS) Email solicitation 9/5/2023 Association of Air Pollution Control Agencies (AAPCA) Email solicitation 9/5/2023 Local Government Advisory Committee (LGAC) Email solicitation 9/5/2023 Association of State and Territorial Health Officials (ASTHO) Email solicitation 9/5/2023 Conference of Radiation Control Program Directors (CRCPD) Email solicitation 9/5/2023 Highlights of Early Input from States, Tribes, and Associations NACAA NACAA urges the Environmental Protection Agency (U.S. EPA) and the Administration to do whatever it must to ensure that federal air grants to state and local air pollution control agencies in FY 2025-2026 are increased substantially. NACAA recommended that U.S. EPA propose, and Congress adopt measures that incorporate the following provisions: o $500 million in federal grants to state and local air agencies under Sections 103 and 105 of the Clean Air Act (CAA); o Flexibility for state and local air agencies to use federal grants for the highest- priority needs in their areas; 1 ------- Publication #440S23001 November 13, 2023 o Retention of funding for fine particulate matter (PM2.5) monitoring under Section 103 authority; and o Appropriation of grant increases under authorities of the CAA that do not require matching funds. NAACA recommends that the NPG reflect the importance of U.S. EPA working collaboratively with its co-regulators in state and local agencies. This includes a recommendation that the NPG reflect opportunities for intergovernmental cooperation that include early engagement in regulatory development and implementation and continued cooperation throughout the process. The NPG should continue to recognize the importance of working with state and local air agencies to adjust resources to meet changing priorities, to work collaboratively with state and local air agencies to resolve planning issues, and to provide flexibility in developing workplans. U.S. EPA should focus on spheres in which the agency can do work that best supports its state and local partners, especially for issues that are nationally significant rather than regional. ECOS U.S. EPA program measures should reflect environmental outcomes, as opposed to outputs, and should include metrics for evaluating incremental progress towards these goals. ECOS urges U.S. EPA to commit to early, frequent, and substantive engagement with states as environmental co-regulators. U.S. EPA should support establishment of electronic collaborative forums between regions and states that can be used to develop and negotiate grant workplans such as through MAX.gov and SharePoint. ECOS continues to encourage U.S. EPA to take a holistic approach to data collection, considering potential new information needed alongside what reporting may no longer be needed, what information is not being utilized that could stop being collected, and what information U.S. EPA may already collect that could be shared more broadly so that states are not reporting information more than once. This review should also include expanded ability for information available in one system to more readily be available through and to other systems. Future data modernization efforts should include this holistic approach to data access to further reduce duplicate data entry and increase data transparency. ECOS asks U.S. EPA to use every opportunity to support increased federal funding for states through Categorical Grants, including allowing funding flexibility such as offered 2 ------- Publication #440S23001 November 13, 2023 through PPGs, U.S. EPA's E-Enterprise Workload Trade-offs, and other mechanisms, to carry out delegated/authorized/primacy federal programs. ECOS urges U. S. EPA to follow the principles of the E-Enterprise for the Environmental Digital Strategy. U.S. EPA should provide flexibility in funding, planning processes, regulatory actions and Agency guidance that allows states to determine the most effective ways to meet national standards while accommodating social, geographic, and economic factors that may be jurisdictionally specific. ECOS asks OAR to address exceptional events in the NPG, such as smoke events caused by wildfires that impact states' ability to comply with the NAAQS. Current rules and processes for exceptional events demonstrations should be streamlined and updated to better account for the increased frequency of events that trigger short-term exceedances and nonattainment. ECOS underscores the critical need for additional resources to ensure that states have adequate capacity. ECOS reaffirms the importance of retaining the funding authority for fine particulate matter (PM2.5) monitoring under Section 103 of the CAA. ECOS strongly supports substantive and early engagement with state agencies on OAR's initiative to modernize and unify its monitoring and emissions data infrastructure. OAR should continue to collaborate with states on the Combined Air Emissions Reporting System (CAERS) to ensure that it fully meets the established project goals. ECOS emphasizes the importance of a multi-media approach to addressing emerging contaminants, especially considering the impact of air emissions releases on existing industrial contamination. Saint Louis County Department of Public Health, Air Pollution Control Program (APCP) The next National Program Guidance document should address inconsistencies in who can apply for CAA Section 105 grant funds and clarify funding options for local air agencies. ASTHO (State and Territorial Environmental Health Directors [SEHD]) U.S. EPA should continue to build off of the knowledge for indoor air quality that was developed during the COVID-19 pandemic to assist in creating healthier indoor environments. Next Steps OAR and the U.S. EPA regions will consider the early input received from state, territory, and tribal partners in developing the FY 2025-2026 National Program Guidance. 3 ------- |