Submitting Comments on EPA’s Clean Power Plan National Tribal Air Association’s Project Director Andy Bessler

The National Tribal Air Association  NTAA was founded in 2002  NTAA’s mission is to advance air quality management, policies and programs, consistent with the needs, interests and unique legal status of American Indian Tribes and Alaskan Natives.  NTAA is administered by NAU’s ITEP staff through a cooperative grant from U.S. EPA.  NTAA has 97 Member Tribes and is governed by Executive Committee Members from EPA regions and Alaska govern NTAA with by-laws approved by member Tribes.

NTAA provides Policy Response Kits for Tribes that include:  NTAA official comments to on air quality and climate change policies  Tribal Template Letters Tribes and Tribal communities can use to submit their own comments  Fact Sheet and other resources to help understand how these policies will impact Tribal communities  NTAA’s work is public and available online at  NTAA provides additional information on Tribal Air Quality issues at

The NTAA and the Clean Power Plan (CPP)  The NTAA submitted comments on the draft CPP in October,  NTAA just published a White Paper that lays out how EPA’s Final CPP addressed NTAA comments on the draft CPP.  EPA is not accepting comments on the Final CPP but NTAA is preparing comments on EPA’s Clean Energy Incentive Program and Federal Plan.

When Providing Your Own Comments on the Clean Power Plan:  Research the Clean Power Plan  Review the Table of Contents  Read the Preamble  Search the Clean Power Plan for terms such as “comment” and “tribe”  Pay attention to Statutory Executive Orders like:  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 from Environmental Health Risks and Safety Risks

When Providing Your Own Comments on the Clean Power Plan:  Establish your Tribal identity  Gather data to support Tribal identity  Personalize the Comment Letter

NTAA’s Specific Concerns with the Final Clean Power Plan’s Proposed Federal Plan will address:  Rate-Based vs. Mass-Based Goals  Federal plan for each state vs. model rule for states to adopt  EPA could choose single option for federal plan  Environmental Justice  Tribal Consultation

NTAA’s Specific Comments with the Final Clean Power Plan’s Clean Energy Incentive Program (CEIP) will address:  Tribal Impacts from an Allowance Trading Program  Clarity how Tribes can be involved in the CEIP  Remove barriers for Tribes to participate, e.g. Tribes allowed to trade allowances/ERC with other Tribes  The proposals needs to include more details about how EPA will be consulting with Tribes as EPA prepares the federal plan for Indian Country as the CEIP does not meet the requirements of EPA’s Policy on Consultation and Coordination with Indian Tribes, May  Involvement of Regional Planning Organizations

How to Submit Comments

  Include docket ID No. EPA-HQ-OAR in the subject line of the message  Fax: Fax your comments to:  Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 28221T, Attention Docket ID No. OAR– , 1200 Pennsylvania Avenue, NW., Washington, DC

Any Questions or Need Help?  Call NTAA at  NTAA at  Visit NTAA at or  THANK YOU!