Adopting & Submitting a Tribal

Implementation Plan

Angela Benedict-DunnSRMT Environment

DivisionAir Quality Program

2

Outline

TIP development TIP – table of contents TIP review TAS-Treatment as State letter to

EPA

3

Outline (cont.)

Tribal council approval Formal public comment period TIP approval Outreach and education

4Map of Reservation

boundaries and Industries

5

Reynolds Before

6

Reynolds

2001

7

Reynolds After 2 redundant

wet scrubbers: some PM, some Fl, SO2

2 redundant dryscrubbers: PM, recycles mix back to plant

8

TIP Development 2 years, included data from emissions

inventory Criteria pollutants, permitting programs

(minor source/burn) Reason for TIP

– Program getting large– Needed way to organize

Set our own standards, need permitting program w/o EPA involvement (sovereignty issue)

9

TIP Development Timeline

Draft TIP 2001 Final draft 2001 Council approval 2002

– Community public comment– Surrounding areas and reservation

public comment EPA review and approval 2003

10

TIP Table of Contents Declaration of Policy Section 1.0…….Organizational Structure Section 2.0……..Legal Authority Section 3.0……..Resources Section 4.0……..Severability Section 5.0……..Definitions Section 6.0……..Public Participation Section 7.0……..Revisions Section 8.0……..Air Quality Control Region Section 9.0……..Air Quality Standards Section 10.0……Emissions Inventory Section 11.0……General Permit Requirements Section 12.0……Permits for Minor Facilities

11

TIP Section 13.0……Synthetic Minor Facilities Section 14.0……Source Surveillance Section 15.0……Open Burning Section 16.0……Reserved Section 17.0……Control of Emissions Section 18.0……Enforcement Section 19.0……Review of State Permits Section 20.0……Regional Haze Planning Section 21.0……Reports Appendix A-TCR99-43 Appendix B-Eligibility Appendix C-Open Burn Code Appendix D-Safety and Civil Obedience Code Appendix E-Press Release Announcement of Formation

of MANE-VU

12Truckstop on Reservation

13

TIP Review

Informal review by R2 office Review by admin, Council, lawyers Informal review by community Avenues for outreach

– Website– Public repositories– Newspapers article

14

TAS-Treatment as State Letter to EPA

Treatment as State letter to EPA Receive comments from state

– State can only comment on jurisdictional boundaries

• Not approved yet– Concerned about boundaries

EPA approval of TAS must precede or coincide with TIP approval– Worse case- letter can be approved

same time as TIP

15

Tribal Council approval Difficulties explaining reasoning for

regulations, technical aspects, not all chiefs formally educated

Difficulties pinning council down for meeting, need lead time to get on schedule

Steps to getting tribal resolution and time frame

16

Alcoa West

17

Formal Public Comment Period TIP open to all (reservation and

surrounding area) for comments Avenues for getting information

out– Website– Public repositories– Newspaper article

30 day time frame from day published in paper

18

Formal Public Comment Period (cont.)

At end of period, all comments will be addressed

If any comment is significant, public hearing will be held to address that concern

After comments addressed, all material to EPA for review

R2 EPA continued to informally review. TIP will be sent to EPA HQ for formal review

19

TIP Approval

Tribal approval and tribal resolution in order

EPA approval Community must be given notice

of effective date Community/affected entity

outreach and education

20

General Motors

21

Outreach and Education Local radio station CKON call-in talk

show• “Tetewataron”-Let’s All Talk

Community education meetings– Had two already: Mold/Mildew & ETS– Burn regulations: Res.2002-59– TIP

IEN-Iroquois Environmental Newsletter– Published every Spring & Fall

22

Domtar

23Map of Reservation boundaries

and Industries

24

Summary

TIP development TIP development timeline TIP table of contents TIP review

25

Summary (cont.)

TAS – Treatment as State letter to EPA

Tribal Council approval Formal public comment period TIP approval Outreach and education

26

SRMT Environment Division

Phone: 518-358-5937

website: www.northnet.org/earth