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TRIBAL CASE STUDY: Tribal Permits. Angela Benedict SRMT Environment Division Air Quality Program St. Regis Mohawk Tribe. The Winds: Owera ’ shon: a - PowerPoint PPT Presentation
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TRIBAL CASE STUDY:Tribal Permits
Angela BenedictSRMT Environment Division
Air Quality ProgramSt. Regis Mohawk Tribe
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The Winds: Owera’ shon: a
Let us give thanks to the winds of the earth. From the four directions they come, carrying the rains upon their back,
and bringing change to the weather and the seasons. They deliver our words, and can be gentle as a whisper, or have the power of a hurricane. The winds fill us, and connect us to all life, and are the breath of the ancestors of life. The winds are
the sacred breath of the Creator. Let us acknowledge the winds. So be it in your mind.
Now our minds are as one.
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Outline TIP-Permit Section Environmental Assessments Public Comment Period TIP Permit Review
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Map of Reservation Boundaries and Industries
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Reynolds Before
Reynolds After
General Motors
Domtar
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Section 12 –Permits for Minor Facilities
12.1 Purpose 12.2 Applicability 12.3 Construction Permits 12.4 Operating Permits 12.5 Monitoring, Record Keeping,
Reporting
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12.1 Purpose To regulate the operation and modification
of new and existing stationary sources, area sources and devices in order to achieve and maintain the ambient air quality standards established pursuant to Sect. 109 and 112 of the CAA and section 9 (air quality standards) of this code.
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12.2 Applicability May not start or modify without a permit
from the Air Quality Program Sources that are required to register with
AQP DE Minimis Facilities
Still subject to Sect. 15 Open burning Statement allowing change
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12.3 Construction Permits No person shall cause or allow the
construction or installation of any new minor facility without obtaining a construction permit.
Cannot exceed the NAAQS Air quality modeling Production/process-permit condition
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12.3 Construction Permits (cont.) Exceed the NAAQS-issue permit if
AQP determines RACT will be applied Applicant has demonstrated progress toward
attainment of NAAQS Violation means revocation
No permit until violation resolved Termination of permit
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12.4 Operating Permits No authorization for operation of new or
modified minor facility for more than 60 days without applying for minor permit must notify Air Program 30 days in advance
of undertaking modifications Emission limitations become enforceable
limitations of subsequently issued operating permit
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12.5 Monitoring
Monitoring requirements Type, interval, and frequency of monitoring
activities Representative data Compliance Permittee must keep accurate records Reports of monitoring results to AQP
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12.5 Record Keeping
The permittee shall retain the following items for at least five years Copies of all reports Calibration and maintenance records and all
original strip chart recordings for continuous monitoring instrumentation
Records of the date, exact location, and time of monitoring and testing
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12.5 Reporting
(1) The permit shall require the permittee to submit to the Air Quality Program the reports described in 12.5 (1) to 12.5 (4) by March 1 of each year
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Environmental Assessments
Tradition of Mohawk People to look seven generations
ahead in making decisions that affect community
Review process incorporates Thanksgiving Address and
considers all the things for which we are thankful
One recurring theme of Thanksgiving Address: “Now our
minds are one.” If that theme is considered, we will all
benefit
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Public Comment Period Complete applications
30 Days Avenues for outreach
Website Public repositories Newspaper article
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Permit Application
To date, only one possible permit application has come in to the tribe
Animal incineration Owner came in to discuss
Brought information from manufacturer
Developed permit application with help from other permitting agencies
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What does this all mean? Without even filling out a permit
application, process for acquiring information was a lot of work
Burn permit program utilizes time of two people 1 for inspections 1 for enforcement/compliance
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What does this all mean? (cont.)
Who gets regulated depends on how much they emit—some gas stations
may when others may not
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What does this all mean? (cont.) When accepted, any new source must have
permits through the tribe No construction until AQP has approved
work plan Existing sources don’t need permit
Grandfathered Any modification that increases emissions
must get permit
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SRMT Environment Division
Phone: 518-358-5937
website: www.srmtenv.org