1. INTER-TRIBAL COUNCIL OF MICHIGAN Tribal Minor New Source Review (MNSR) Inventory Overview Inter-Tribal Council of Michigan, Inc. Environmental Services Division Travis Maki ITCMI ESD ES 6/12/131

2. INTER-TRIBAL COUNCIL OF MICHIGAN Federal Implementation Plan under CAA Pre-construction permitting program for major and minor sources on Tribal land Existing and new facilities, or facility modifications, with emissions at or above major or minor threshold levels Implemented by: EPA, Delegate Tribal Agency, or EPA- approved Tribal Implementation Plan The Tribal Minor NSR 6/12/132

3. INTER-TRIBAL COUNCIL OF MICHIGAN EPA Region 5 DITCA with ITCMI Goals: Assist in planning FIP implementation Provide information to help direct Region 5 efforts for permitting, enforcement, and outreach Provide Tribes with more information about emissions on Tribal lands Objectives: Develop an inventory of existing potential minor sources on Tribal lands across Region 5 Facilitate registration of minor sources 6/12/133

4. INTER-TRIBAL COUNCIL OF MICHIGAN Why ITCMI? Project was set up to be a success: ITC had previous experience with EI’s as well as working in many of the Tribal communities that were to be inventoried ITC has previously worked on and is currently apart of DITCA’s that have similar tasks involved with the Tribal Minor NSR DITCA. Region 5 has “only” 35 Tribes, workload did not appear painstaking/exhaustive at onset of project 6/12/134

5. INTER-TRIBAL COUNCIL OF MICHIGAN Tribal Minor New Source Review ITC staff developed a process for completion of the proposed DITCA goals/outcomes. The Steps of the Inventory: 1)Information Gathering 2)GIS 3)Surveys 4)Tonnage Information/Calculations/Estimations 5)Compare information from Step 4 to Minor NSR regulations (Reporting!!!) 6)Continually Develop the Database 6/12/135

6. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step One Defined Reservation boundaries; zip codes, counties, and city names located wholly or partially within the exterior boundaries of each Reservation Use online public data sources to generate a preliminary inventory of potential sources on tribal lands www.manta.com www.yellowpages.com www.michiganbusiness.us Began with specific source codes and expanded to review all potential sources in the identified Reservation zip codes INTER-TRIBAL COUNCIL OF MICHIGAN 6/12/136

7. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step Two Using GIS, geocode emission source addresses from draft inventory Create maps of potential minor sources for each Reservation Eliminate sources that are not on Tribal land from the inventory 6/12/137

8. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step Three Share lists and maps with each Tribe Ask tribal staff to review the documents and provide comments, corrections, and perspective on the data Revise data and maps as needed 6/12/138

9. INTER-TRIBAL COUNCIL OF MICHIGAN Tribal Input (comments/concerns from participating Tribes) -Jurisdictional Example: xxx -Requests, Refusals, Rebuttals example xxx 6/12/139

10. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step Four Sample a selection of potential minor sources: Verify correct SIC code and potential for emissions Obtain process information for emission estimation Estimate tonnage of NSR pollutants emitted – Tribal Emissions Inventory Software Solution 6/12/1310

11. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step Five Develop final reports for each Tribe with summary of potential minor source inventory Develop final report for EPA Region 5 on the inventory development process and inventory results Continue editing the inventory as Tribes share data/revisions 6/12/1311

12. INTER-TRIBAL COUNCIL OF MICHIGAN Tribal Minor New Source Review Output Examples Fond du Lac Band of Lake Superior Chippewa and the Leech Lake Band of Ojibwe: Written Report on MNSR sources Excel Spreadsheet with MNSR source information Map (jpeg) of MNSR sources 6/12/1312

13. INTER-TRIBAL COUNCIL OF MICHIGAN LLBO Tribal Minor New Source Review Inventory Packet 6/12/1313

14. INTER-TRIBAL COUNCIL OF MICHIGAN FDL Tribal Minor New Source Review Inventory Packet 6/12/1314

15. INTER-TRIBAL COUNCIL OF MICHIGAN The Inventory… Step 6 Develop GIS database with minor NSR sources – Geographic Coordinates – Facility Information – Estimated tonnage of pollutants emitted INTER-TRIBAL COUNCIL OF MICHIGAN 6/12/1315

16. INTER-TRIBAL COUNCIL OF MICHIGAN EPA Region 5 DITCA with ITC Project Outcomes: Completed(?) Tribal MNSR inventories for Region 5 Tribes TA for Tribes (serving as 1 st stage in FIP implementation) Project Outputs: Tribal MNSR inventory in Excel spreadsheet format(sources within the exterior boundaries of every Region 5 Tribes’ reservation and/or trust lands) GIS maps including each facility within the Tribal MNSR inventory Inventory reports for each Tribe in Region 5. 6/12/1316

17. INTER-TRIBAL COUNCIL OF MICHIGAN Lessons Learned Identifying minor sources from afar SIC code discrepancies; limited-no ground truthing High number of businesses and/or areas Saginaw Chippewa Indian Tribe (750+ businesses filtered to 151); Ho-Chunk (24 zip codes) Paperwork Reduction Act ITCMI could not survey the sources; research stalled and changed Making determinations without clear knowledge of emissions, facility processes, or guidelines Reservation/trust land boundaries in flux or dispute 6/12/1317