In their article, Kyoto at the Local Level: Federalism and Translocal Organizations of Government Actors (TOGAS), Judith Resnik, Joshua Civin and Joseph Frueh describe the value of organizations they term "translocal organizations of governmental actors," or TOGAs, which "could be viewed as improving deliberative democracy because they bring in... a particularly interesting set of voices--those of officials structurally embedded in the problems of states and localities and cutting across both." The article then provides examples of how the law could recognize and harness the benefits TOGAs bring to the policymaking table, including through access to federal courts, deference to their decisions and specific roles in rulemaking processes. As a TOGA, we agree that TOGAs should be treated differently than other interest groups and that TOGAs play a unique and important role in our democracy. Below we provide additional examples of how these organizations have enhanced the national policymaking process and include recommendations for actions that Congress, federal agencies, and the courts could take to support and improve the effectiveness of TOGAs as significant actors in that policymaking process.

The organization we represent, the National Association of Clean Air Agencies (NACAA), could be viewed as the archetype of a TOGA. Formed over 30 years ago, NACAA is an association of the air pollution control agencies in 53 states and territories and more than 165 major metropolitan areas throughout the country. We serve to encourage the exchange of information among air pollution control officials, to enhance communication and cooperation among federal, state, and local regulatory agencies, and to promote good management of our air resources. Notably, our members include both state and local officials.