1. presentation on Waste management and the gap program
2018 Tribal EPA Conference
San Francisco

2. Waste management and the gap program
Michelle Baker, GAP Project Officer, Land Division, Tribal Section 
Deirdre Nurre, Tribal Materials Management Section, US EPA Zero Waste Section
Jenny Stephenson, Tribal Materials Management Section, US EPA Zero Waste Section

3. Outline
1  Building your waste management program: where do you want to go?
2  Integrated Solid Waste Management Plans (ISWMPs): 
            Your program roadmap, key components
3  What is fundable under GAP  
4  Education and Outreach 
5  Ordinances & Enforcement
6  Thinking Big: cleaning up dumps, building transfer stations, and beyond

4. Integrated solid waste management plans
2018 Tribal EPA Conference
San Francisco

5. Integrated solid waste management plans (ISWMP)
ISWMP is the road map for your tribal solid waste program
Comprehensive description of current practices, programs, resources, legal authorities
Comprehensive description of future program
Updates to ISWMP are recommended every 5 years

6. Integrated solid waste management plans (ISWMP)
Preparing for your IWMP requires effort, research, data, because:
It’s Important
It’s Big
It’s Lasting
It’s Hard…..
But There’s Hope!

7. Developing or updating your iSwmp –overcoming basic roadblocks
 Templates are available for ISWMPs upon request
Step back and think about what you want to achieve – what would a successful solid waste program look like for your tribe?
 Based on what it looks like, sketch out goals for your program. Updating ISWMP?  start your goals from scratch.
 Get help from the beginning:  Contact Region 9’s Tribal Materials Management Team and have a conversation
Ask Region 9 for examples of successful ISWMPs and look at what components might work for your tribe – every tribe is different so all ISWMPs are different
Start the writing process by breaking things down into smaller parts – take one at a time

8. GAP Model Language for preparing to develop an ISWMP
Based on GAP Program Guidance on the Award and Management of General Assistance Agreements for Tribes and Intertribal Consortia, May 2013
(See especially Appendix I, Guidebook for Building Tribal Environmental Program Capacity)
R9 developed model language for preparing an ISWMP to assist tribes in identifying what’s fundable and easily approvable by EPA Tribal Section
Why reinvent the wheel for every work plan?
Model Draft Language text is available from EPA

9. Example of Language for preparing iSwmp
Initiate Environmental Team activities - Environmental Program Staff (EPS) will recruit a team of representatives from all Tribal departments and other government organizations, businesses, and other representatives to form a team that will help assess waste management practices, enact improvements to those practices, etc. Specific efforts:
By [date], develop outreach to prospective Environmental Team
By [date], convene an Environmental Team and agree on purpose
By [date], EPA will draft “Environmental Team Operating Plan,” then review and finalize Plan with public input
Outputs/Deliverables:
a. materials used to recruit members-at-large
b. list of Environmental team members
c. Environmental team operating plan

10. Example of Language for preparing iSwmp
Characterize Waste Management Practices - Team will characterize waste management practices and measure waste streams generated by key facilities. Can include:
By [date], EPS will conference to determine how to conduct a waste assessment of Tribal and other key operations on the Reservation and document it in writing.
By [date], the ED and EA will convene team to explain how waste characterizations work, provide necessary trainings, and to schedule and plan upcoming characterizations.
By [date], EPS will coordinate waste characterizations at key facilities/operations (~ 5 total), enter information into appropriate databases, share the data, create a waste management summary.
Deliverables:
a. Draft detailed approach to waste characterization
b. waste characterization schedule, including any staff training that needs to occur
c. waste characterization and management summary; the summary will document (for each facility) waste policies or practices utilized, waste stream data, and waste disposal costs

11. Help for tribes in developing iSwmps:
Contact Tribal Materials Management staff in Region 9’s Zero Waste Team:
Deirdre Nurre (415)
Jenny Stephenson (415)

12. solid waste Capacity building and implementation under GAP
November 2018 – Tribal Conference
San Francisco

13. What’s fundable: A REVIEW OF THE GAP GUIDANCE

14. Review: General Allowability under GAP

15. General Allowability Continued

17. Solid Waste Capacity building under GAP
  Development of ISWMP
Development of staffing plan 
  RCRA and other SW trainings for environmental staff 
Waste characterization assessment 
Development of Solid waste facility/feasibility plan 
Development of waste management/ UST laws, codes & regulations
Development of enforcement plan 

18. Building education and outreach programs
Outreach is a key aspect of all tribal solid waste programs
Presentations to council 
Curriculum development 
Fliers and newsletters
Annual Community clean-ups: 
Only in communal areas; can’t haul waste for individuals 
Must be focused on outreach 
Data should be collected and used for a current waste stream assessment
*Many benefits of outreach: Increased awareness, identifying and preventing environmentally harmful behaviors, and source reduction 

19. more outreach concepts
  Doing recycling demonstrations at schools (especially with youngsters like at Head Start) OR at community events
 Going door-to-door, as a public service, to let people know what is recyclable, and have examples of materials (cans, paper etc.) This can be really effective for folks who are not as mobile.
  Contributing to local newsletter by doing  short write-ups about a solid waste topic, or flyer, or comic

20. Solid waste implementation under GAP
"Once a tribe has established a waste management program consistent with the capacity indicators from E.3, GAP funds may be used for the following implementation activities in order of priority": 
        A) Tribal Waste Management Program Administration
        B) Tribal Compliance and Enforcement Program
        C) Activities to Support Solid Waste Management/RCRA
        D) Cleanup and Closure Activities 

21. Expanded flexibility for SW Implementation
Recent attempt to phase out GAP funding for general costs of government service including trash collection, transportation, backhaul and disposal services.
But restrictions were lifted. Implementation costs remain allowable. However, GAP funding was not increased.
GAP funding for solid waste program development will continue to be a higher priority than funding for solid waste implementation.

22. Solid waste implementation Since the fy16 consolidated appropriations act

23. Enforcement

24. Building enforcement Programs
Many options for enforcement – Police force is not the only option 
 Large tribes have courts, tribal police
Tribes with per capita have had success by withholding payments to violators
Community service in lieu of fines for violators
 Warning letters 

25. Building enforcement Programs, cont’d
For off-Reservation dumpers, build partnerships with counties, neighboring cities
Post signs 
Barricade dumping sites 
Engage youth, create art
Success stories

26. Building beyond base program dump cleanups, transfer stations and more
2017 Tribal EPA Conference
Viejas, CA

27. Implementation: Cleaning up dumps
To fund cleanup of dumps, prerequisites must be met:
Outreach ongoing
Waste Characterization performed
IWMP approved by Tribe
Recycling program underway
Waste minimization program
Compliance monitoring and enforcement program

28. Example: pre-requisites for dump closure funds

30. Example: pre-requisites for dump closure funds, continued

31. Example: pre-requisites for dump closure funds, continued

32. Transfer stations How GAP funds them ? How they assist tribes ?
Prerequisites:
Current waste characterization study
Transfer station feasibility assessment

33. Questions and discussion
Resources/ Google:
“Developing an Abandoned Vehicle Cleanup Program for Tribal Governments”
“How to Design and Conduct a Successful Waste Characterization Assessment”
Tribal Solid Waste Program Costing Tool US EPA 
Questions and discussion
2018 Tribal EPA Conference
San Francisco, CA