Submitting & Adopting a Tribal Implementation Plan Angela Benedict SRMT Environment Division Air Quality Program St. Regis Mohawk Tribe

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 Outreach and Education

Map of Reservation Boundaries

Reynolds Before

Reynolds After 2001

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)

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

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

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

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

Truckstop on Reservation

TIP Review Informal review by R2 office Review by admin, Council, lawyers Informal review by community Avenues for outreach Website Public repositories Newspapers article

TAS–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

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

Alcoa West

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

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

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

General Motors Closed Dec 2008

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

Domtar Paper Mill-Canada Closed 2006

Map of Reservation Boundaries and Industries

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

SRMT Environment Division website: www.srmtenv.org Phone: 518-358-5937 website: www.srmtenv.org