National Tribal Air Association Webinar October 15, 2015.

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Presentation transcript:

National Tribal Air Association Webinar October 15, 2015

Clean Power Plan NTAA Comments Building Blocks Multistate Plans Cap-and-Trade Programs  State and Multistate  National Environmental Justice Tribal Consultation

Federal Plan EPA request for comments No comments about underlying Clean Power Plan Types of plans  Trading Plans  Rate-Based  Federal plan for each state / Model rule for states to adopt  Mass-Based  Federal plan for each state / Model rule for states to adopt  EPA could choose single option for federal plan

Federal Plan EPA request for comments Rate-Based Plan  Emission Rate Credits (ERCs)  Set-Asides  Clean Energy Incentive Program  Renewable Energy projects  Demand-Side Energy Efficiency projects Mass-Based Plan  Allowances  Set-Asides  Output-Based for EGUs  Clean Energy Incentive Program  Renewable Energy Projects

Impactful and Substantive Comments Pre-Comment Letter Development  Establish your Tribal identity  Gather data to support Tribal identity Personalize Comment Letter Initial thoughts about comments  Set-Asides  Vulnerable and/or Overburdened Communities  Plan impacts  Tribal Consultation  Federal Plan for Indian Country

Evaluating Proposed Rule for Tribal Implications Research Table of Contents Preamble Search terms such as “comment” and “tribe” Statutory Executive Orders  Executive Order 13175, Consultation and Coordination with Indian Tribal Governments  Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations  Executive Order 13045, Protection of Children of Environmental Health Risks and Safety Risks