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Comments on Draft NACAA RPO Letter

July 10, 2009

Bruce Andersen

I think that some of the points in this letter need to be more thoroughly discussed by our board before this letter, or a version of this letter, is sent out. Unfortunately, we did not have enough time at our last board meeting to discuss these RPO issues and come to a consensus among our directors. The value of and the services provided by the RPO’s may vary from one region of the country to another and I’m not sure the majority of all of our members would support this letter, especially the locals, which benefit less from the RPO’s. Before NACAA asks EPA to expand the charter of the RPO’s, the boards should discuss it more and determine if consensus can be reached. Some of our members may not realize that this funding comes out of our 105 pot. I agree that there is still more work to complete on haze but am not sure of widespread support for having the RPO’s expand into other areas, especially if it takes away from our budgets at home. A charter expansion could end up putting the RPO’s in competition with us for limited funds.

Joyce Epps

Great letter, Mary. Please adda sentence in the second paragraph which specifically states that EPA's FY 2010 budget does not provide any RPO funding.

Bill O’Sullivan

Best letter I've read in a long time

Cheryl Heying

Well done Mary, thanks.

Anne Gobin

Anne: Is the intent of this to say that we want funding for the RPOs to come off the top of our grants or that we need more $ for the RPO work b/c it is critical to do?

Mary: We want more money.

Anne: It should say that and it should say multi-pollutant.

Stu Clark

One potential concern. Did the board discuss a want or need to specify that funding RPOs shouldn’t reduce STAG grants below current levels that states/locals/tribes receive? I’m concerned that whatever the amount, it could be a zero sum so if RPO dollars go up then state etc funding goes down commensurately. Otherwise letter looks good to me

Larry Greene

I support this letter. Initially I was ambivalent regarding the RPOs, but I’ve been educated over the past couple of years. For me the fact that the RPOs receive substantial funding from the states and locals was important. I also know the money we are requesting is needed to support federal requirements, especially those that are best quantified on a regional basis. Lastly, there is a good management philosophy going on here where we gain an “economies of scale” benefit by doing some work through the RPOs. EPA benefits from that work and should share in the funding.

Eddie Terrill

My comments are as follows:

  1. While I support EPA funding the RPO’s and the expansion of the mandate to include issues other than regional haze, I think we need to discuss further the ramifications of extending the RPO process to ozone and PM, specifically the role that industry and even the tribal entities would play in this process.
  2. If EPA decides not to fund these organizations and the states decide to continue the work through voluntary payments to the regional consortiums, I would be opposed to allowing any organization to participate that does not contribute monetarily to the work of the group. This would mean that tribes would not participate. While a collaborative effort has been beneficial for both the states and tribes, if EPA doesn’t see the benefit in funding this effort to foster a continuation of the collaborative process then I see no need to continue the process either. If we let them, I believe EPA would let us fund this just like they have shifted the burden of the funding of training to the states.
  3. I don’t know that I would put the RPO funding at a higher level of importance than we do anything else. I think we need to discuss further the possibility that we send the message that this is the most important thing we are doing if we single out this one area above others.

I may come up with something later but this is all for now.

Vince Hellwig

Thanks for sharing the draft letter. I like the tone and content of the letter. For our Region this is timely as we had a meeting yesterday, July 9, in Chicago and discussed this subject. The LADCO states support continued funding of the RPO. Although MN is in Region V, but not a member of LADCO, in the past David Thornton has supported LADCO activities. In fact MN is a financial contributor through 105 funds to LADCO, and is supportive of the RPO activities. Therefore this is a position of the Region V states.

Jim Kavanaugh

Region 7 states support strongly encouraging EPA to continue funding the RPOs, but with EPA dollars NOT with the State's 103/105 funding.