NACAA Provides Input on EPA’s FY 2018-19 NPM Guidance

October 12, 2016 – NACAA has submitted comments in response to EPA’s request for early input on the development of the FY 2018-19 National Program Manager (NPM) Guidances.  The NPM Guidances outline the strategies and actions EPA and state, local and tribal agencies will undertake over the next two years to implement their programs and work toward the goals contained in EPA’s Strategic Plan.  The guidance documents will be issued next spring in draft form and open to public comment.  However, at this point, EPA sought early input before the agency began developing the guidance.  NACAA emphasized in its comments that state and local air quality agencies are severely underfunded and it is essential that federal grants for these programs be increased significantly.  Additionally, state and local agencies should be given as much flexibility as possible with respect to how these resources are spent.  NACAA rearticulated points it has included in comments for previous years’ NPM guidance documents, including supporting EPA’s intention to work with state and local agencies to adjust resources to meet changing priorities and encouraging the agency to use the guidance as the basis for negotiations among federal, state and local air agencies.  Finally, NACAA reiterated the recommendation that funding for fine particulate matter monitors remain under the authority of Section 103, where matching funds are not required, rather than shifting it to Section 105.