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The National Association of Clean Air Agencies (“NACAA”) issued a January 15th position paper titled: Improving Our Nation’s Clean Air Program: Recommendations from the National Association of Clean Air Agencies to President-Elect Biden’s and Vice President-Elect Harris’ Administration (“Position Paper”) The Position Paper offers recommendations for consideration for what it describes as “key issues associated with our nation’s clean air and climate programs.” The NACAA describes itself as the: . . . national, non-partisan, nonprofit association of 153 air pollution control agencies in 41 states, including 115 local air agencies, the District of Columbia, and four territories. By way of introduction, the Position Paper notes that the Clean Air Act provides state and local governments the primary role in preventing and addressing air emissions. Nevertheless, the organization states it views itself as a partner in EPA’s efforts to address what it describe

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