TIP Overview Darrel Harmon U.S. EPA

2 Purpose Provide a broad definition –Explain elements –Describe effect of TAR on CAA requirements –Explore relationship between FIPs and TIPs

3 Relationship Between TIPs and FIPs uPros and cons of using FIPs and TIPs –FIPs don’t require TAS –FIP implementation can be delegated –FIPs developed by EPA, but in consultation with the tribes so don’t require as many tribal resources

4 Relationship Between TIPs and FIPs (cont.) uPros and cons of using FIPs and TIPs (cont.) –TIPs encourage tribes to be seen as the regulatory authority –Allows for tribal decision making to address local concerns. –Allow for tribal implementation with federal backup when needed (gorilla in the closet)

5 What is a TIP? uA plan uA control strategy uA timetable for results

6 A TIP Is a Plan uDefines, assesses problems/ concerns uLays out way to address problems/concerns uProvides schedule and way to measure progress

7 A TIP Is a Control Strategy uApplies pollution controls to sources of concern –Stationary –Mobile –Area uProvides for compliance & enforcement

8 A TIP Is a Timetable for Results uAir quality improvement uAir quality maintenance

9 Why Write A TIP? uManage air quality uLevel the economic playing field uAssert sovereignty

10 TIP Authority under the CAA/TAR uTAR identifies TIP as “appropriate” uTAR provides for authority –Within exterior boundaries of reservation –Over other areas of jurisdiction uTAR assures flexibility

11 Differentiating TIPs from SIPs uVoluntary vs. mandatory uFlexible

12 Relationship between TIPs and FIPs uFIP = Federal plan –Direct implementation –Absence of state or tribal action uDifferent kinds of FIPs –Source-specific –General uTAR approach for FIPs uFIPs can become TIPs