Tribal Minor New Source Review (MNSR) Inventory Overview

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

2. The Tribal Minor NSR • 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 INTER-TRIBAL COUNCIL OF MICHIGAN

3. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

4. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

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

6. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

7. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

8. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

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

10. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

11. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

12. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

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

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

15. 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 INTER-TRIBAL COUNCIL OF MICHIGAN

16. EPA Region 5 DITCA with ITC • Project Outcomes: • Completed(?) Tribal MNSR inventories for Region 5 Tribes • TA for Tribes (serving as 1st 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. INTER-TRIBAL COUNCIL OF MICHIGAN

17. 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 INTER-TRIBAL COUNCIL OF MICHIGAN