A Report by the
National Association of Clean Air Agencies (NACAA)

May 22, 2017

Executive Summary

President Trump will release his FY 2018 federal budget on May 23, 2017, which calls for huge cuts in funding for the U.S. Environmental Protection Agency (EPA). According to a document obtained by the National Association of Clean Air Agencies (NACAA),1 the budget will include a 31-percent reduction in EPA’s overall funding (from $8.2 billion in FY 2017 to $5.7 billion in FY 2018), the elimination of many important environmental programs, and – the focus of this report – a 30-percent decrease in federal grants to state and local air pollution control agencies (from $227.8 million in FY 2017 to $159.5 million in FY 2018).

Based on advance information about what the proposed budget would include,2 NACAA surveyed its members to learn what a reduction of approximately 30-percent in federal grants would mean to state and local air quality programs. The results revealed a very disturbing picture: cuts of the magnitude proposed would likely have a devastating impact on the efforts of state and local air pollution control agencies to provide healthful air quality for the American public. Indeed, if cuts of this magnitude are sustained by Congress, we fear more people will die prematurely and get sick unnecessarily.

State and local air quality agencies have faced inadequate funding for years and have already taken many steps to address their budget shortfalls. Additional cuts of 30 percent would severely impede the ability of many agencies to continue essential programs and, in the most extreme cases, some smaller local agencies could conceivably have to close their doors entirely. If such cuts are enacted, many state and local air pollution control agencies will have trouble fully implementing the Clean Air Act’s health-based air quality standards and delivering the clean and healthful air quality that the public deserves.

Additionally, these agencies could be subject to harsh sanctions under the Clean Air Act, including the withholding of millions of dollars in federal highway funds, severe emissions “off-set” limits that could interfere with economic development, and the possibility of EPA imposing Federal Implementation Plans on states.

In their responses, agency after agency painted a similar picture of severe curtailments to their programs in the face of the steep cuts being proposed: loss of staff, cancellation of programs and a diminished capacity to obtain and maintain healthful air quality. Nearly every respondent reported that cuts of this magnitude would severely reduce the benefits the agencies can provide. These include not only to the general public, with respect to decreasing air pollution, maintaining clean air and generally protecting public health, but also to the regulated community, in terms of permitting, compliance assistance and other services.

The respondents provided a long and varied list of ways in which a 30-percent reduction would impact state and local air pollution control programs, affecting nearly every function they perform. State and local agencies identified many activities to be reduced and/or eliminated, including staffing levels, monitoring, inspections, enforcement, permit issuance, compliance assistance, data analysis, equipment maintenance and complaint response, among others.

The impacts of these reductions are far reaching. Numerous agencies reported that they would be operating at a bare minimum level and that the services they provide the public would be limited or even eliminated. Perhaps most importantly, efforts to obtain healthful air quality and maintain clean air would suffer as a result of these resource constraints on their programs.

Agencies also reported that their state or local governments, which already provide the lion’s share of funding for clean air programs, would not be able to make up for the reductions in federal grants through additional state or local appropriations, general funds, grants or other contributions. Additionally, several agencies noted that they could consider increasing fees to address the shortfall, but that gaining approval for additional fees is unlikely as well.

Finally, state and local air quality agencies reported that a 30-percent cut in grants could force them to turn some of their important Clean Air Act implementation work back to the federal government. As local communities, including many regulated entities, generally prefer working with their local and state agencies (as opposed to EPA), the return of responsibilities to the federal government would be a tremendous loss. Additionally, since the proposed budget calls for sharp cuts to EPA’s operating budget as well, the agency would not be in a good position to take on the tasks that the state and local agencies can no longer carry out.

State and Local Air Agencies – In Their Own Words:

“A cut in our federal grant of 30 percent would impose serious and adverse impacts on our individual state and collective ability to effectively run our air pollution control programs. There would very likely be many more people in our state getting sick and possibly dying as a result of these budget cuts.”

“[We are] insufficiently staffed to assure citizens are protected from asbestos. Asbestos is a carcinogen and was widely used in buildings for fireproofing, thermal and acoustical insulation, condensation control, and decoration. Our current staffing of 5 FTEs is only able to inspect 8% of the structures. This inability to verify compliance places the public directly at risk.”

“If you cut back on enforcement programs, such as inspections and compliance assistance, your regulated community tends to be out of compliance more of the time. This can result in increased emissions which affect the health of your citizens.”

“We have been forced to cut programs—sunset Stage 2 vapor recovery, returned delegation of asbestos NESHAP, air toxics, downsized monitoring to federal minimum allowed. Permits are slower, enforcement is down.”

“If there are further reductions in federal funding, there will be a corresponding reduction in services. It is unreasonable to ask States to further supplement their programs with additional State funds.”

“Because we are at the federal minimum for our air monitoring network and unable to fully meet our planning, inventory, and asbestos compliance requirements, a reduction of 31% would be devastating. We clearly would be unable to meet the federally- mandated responsibilities.”

“Our current level of service will be significantly reduced… The level of public health protection currently provided will definitely be reduced to reflect the impacts of the budget cuts.”

“Without question, a cut of 31 percent to the already-reduced funding levels would devastate our program. Under the requested funding reductions, we would be forced to cut our staffing by at least one-third… a reduction in staffing along the proposed lines would significantly delay the issuance of permits for new construction.”

“The state and local funding cuts combined with the proposed 30% federal funding cut will result in about a 72% reduction in [our] overall budget. This will significantly impact [our] ability to be here at all, and if we are still here, it will be at a 60-70% decreased staffing level leaving us with 7-10 FTEs to manage a 6 county area. At this level, we will not be able to meet the core requirements of the state contract and federal grants.

“Enforcement would be reduced to only the most serious cases – Violations may not be detected early because there will be less report reviews, inspections, stack tests, and complaint response.”

“A reduction of federal funds may result in an air quality monitoring network that does not meet federal requirements.”

“These cuts ignore reality; because we still have to meet all the existing federal requirements, even the ones the new administration doesn’t like. When we fail, due to a lack of resources, it will be local taxpayers who bear the burden of paying environmental groups’ legal fees.”

“We’d no longer do any air toxics work.”

Who is NACAA?

The National Association of Clean Air Agencies (NACAA) is a national, non- partisan, non-profit association of state and local air pollution control agencies in 45 states, the District of Columbia and four territories. The air quality professionals in its member agencies have vast experience dedicated to improving air quality in the United States.

State and local air pollution control agencies (e.g., NACAA members) have primary responsibility for implementing our nation’s air pollution control laws and regulations. The associations serve to encourage the exchange of information and experience among air pollution control officials; enhance communication and cooperation among federal, state and local regulatory agencies; and facilitate air pollution control activities that will result in clean, healthful air across the country.

NACAA’s headquarters office is located in Washington, DC. For further information, including contact information for state and local air quality agencies, visit NACAA’s web site at http://www.4cleanair.org or call (202) 624-7864.

1 http://www.4cleanair.org/sites/default/files/Documents/EPA_FY18_Budget.pdf
2 On March 21, 2017, information regarding the Administration’s proposed FY 2018 budget for the U.S. Environmental Protection Agency (EPA) was released. While it did not include all the details of the proposal, it indicated that state and local grants under Sections 103 and 105 of the Clean Air Act would be reduced by 31 percent. The memorandum is available here: http://www.4cleanair.org/sites/default/files/Documents/EP A_Memo_FY_2018_Budget_March_21_2017.p df

A copy of the complete NACAA report can be found at: http://www.4cleanair.org/sites/default/files/Documents/NACAAFundingReport-FY2018.pdf