Submitting & Adopting a

Tribal Implementation Plan

Angela BenedictSRMT Environment Division

Air Quality ProgramSt. Regis Mohawk Tribe

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Outline TIP Development TIP–Table of Contents TIP Review TAS–Treatment as State

Letter to EPA Tribal Council approval Public Comment Period

Tribal Tribal/nontribal

MOA Develop Approval

SRMT/EPA/CID

TIP Submittal Approval

Outreach and Education

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Map of Reservation Boundaries

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Reynolds Before

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Reynolds After

2001

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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)

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TIP Development Timeline Draft TIP 2001 Final draft 2001 Public comment

Tribal community public comment Surrounding areas and tribal community public

comment Council approval 2002 MOA with CID 2003–(not in original timeline) EPA review and approval 2007

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TIP 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

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TIP Section 13.0……Synthetic Minor Facilities Section 14.0……Source Surveillance Section 15.0……Open Burning Section 16.0……Reserved Section 17.0……Reserved Section 18.0……Enforcement Section 19.0……Review of State Permits Section 20.0……Regional Haze Planning Section 21.0……Reports

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Appendices Appendix A-Notice of Public Comment Appendix B- TCR99-43 Appendix C- TCR89-19 Appendix D-TCR89-34 Appendix E-TCR2002-183 Appendix F-Eligibility Determination September 19, 2000 Appendix G-Eligibility Determination May 25, 2001 Appendix H-Eligibility Determination March 5, 2003 Appendix I-TCR2002-59 Appendix J-Burn Regulation Appendix K-TCR2003-06 Appendix L-TCR2001-04 Appendix M-TCR2001-26 Appendix N-Safety and Civil Obedience Plan Appendix O-Press Release Announcement of Formation of MANE-VU

11Truckstop on Reservation

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

Website Public repositories Newspapers article

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TAS–Treatment as State Letter to EPA Treatment as State letter to EPA Receive comments from state

State can only comment on jurisdictional boundaries approved

Concerned about boundaries

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

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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

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Alcoa West

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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

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Formal Public Comment Period(cont.) At end of period, all comments addressed If any comment is significant, public hearing will

be held to address After comments addressed, all material will be

given to EPA for review R2 EPA continued to informally review. TIP sent

to EPA HQ for formal review All comments must be documented and submitted

with TIP

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TIP Approval

Tribal approval and tribal resolution in order MOA on Enforcement/Compliance must be in

place before TIP can be approved EPA approval Community must be given notice of effective

date Community/affected entity outreach and

education

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General Motors

Closed Dec 2008

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Outreach and Education Local radio station CKON call-in talk show

“Tetewataron”-Let’s All Talk

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

IEN-Iroquois Environmental Newsletter Published every spring & fall

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Domtar

Closed 2006

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Map of Reservation Boundaries and Industries

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Summary TIP Development TIP Development Timeline TIP–Table of Contents TIP Review TAS–Treatment as State Letter to EPA Tribal Council approval Formal Public Comment Period MOA Approval TIP Approval Outreach and Education

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SRMT Environment Division

Phone: 518-358-5937

website: www.srmtenv.org