Brandy Toft Air Quality Specialist Minor NSR Workshop

Leech Lake Reservation rural area located in North Central Minnesota 864,158 acres, over half is water/wetlands 260 miles of rivers/streams 270 fishable lakes 40 Wildrice lakes Serving 12,000 in 17 communities Part of the 1855 Ceded Territory

Wood Products Waste incinerator 2 Largest MN Coal EGU Waste EGU 2 3 Wood products Leech Lake Title V Permits and area sources of Concern Great Lakes Compression Station Paper mill Coal EGU Area of concern 19 Title V’s Title V facilities of concern to the LLAP19 clustered Title V facilities of concern Over 250 area sources within the Reservation Boundaries

LL attained 2007 Wanted concrete input and involvement in permit commenting Wanted lower percentage on 105 funding Wanted to build capacity for Leech Lake It was the “next” step for LL Air

Did not talk with State before hand… sovereignty State had opportunity to comment during comment period – tried to nit pick EPA backed up Tribe State not “pleased” to see Tribes receive TAS, concerned on their role and responsibilities State dropped main comments, LL has indisputable boundaries

Tribes asked for advance permit commenting – 30 days not enough and at end of process Tribes with TAS had a greater voice Discussions with State continued – year plus State of Minnesota felt it would be easier to treat all Tribes equally Negotiated timeframes and notification process Minnesota Pollution Control Agency Guidance On Air Quality Permit Consultation with Indian Tribal Governments

Early notification by State engineer via /phone when permit application is submitted to State Continued conversations as new info is presented – dependent on engineer Conf calls with multiple Tribes if needed Early viewing and involvement: – Permit application, – draft permit, – EIS, – EAW

WI Tribes have sent representatives to our MNTECH meetings to gain insight to our process and relationship with State of MN Shared guidance documents with WI & MI Tribes

With precedence set in MN – want equal notification from R5 Formulated a list for R5 for air, water, mining, and environmental contacts Updated every six months Have yet to be contacted by EPA for a state permit in review… yet…

2003 went through full 3 course training EPA didn’t know how to credential LL Currently stalled, Tribe in need of more info Potential process at EPA now, Just need time to retake the courses

Discussion??? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Brandy Toft Air Quality Specialist Leech Lake Band of Ojibwe