1. Tribal Air Quality Priorities
National Tribal Air Association
Executive Committee
National Tribal Forum on Air Quality
June 2011
Spokane, WA

2. Introduction: NTAA Founded in 2002 72 Principal Member Tribes
Mission: to advance air quality management and policies and programs, consistent with the needs, interests, and unique legal status of American Indian tribes and Alaskan Natives.

3. Principles Sovereignty
Responsibility to future generations
Tribes have the right to know the quality of their air
Tribes as strong partners
Tribes have the legal authority to regulate : Tribal Air Rule

4. National Priorities Consultation RPOs
Improved relations with Office of Radiation and Indoor Air and Office of Atmospheric Programs.
Tribal New Source Review
Regional Disparity issues -

5. There is still room for improvement.
Consultation
Appreciation for the recently finalized EPA Tribal Consultation Policy and increased efforts at tribal consultation
There is still room for improvement.
“Informational” calls should not be confused with true “Consultation”
NTAA sponsored calls should not be used in lieu of consultation
April 29, 2011 notice in the Federal Register regarding “Clarifications to Indian Tribes' Clean Air Act Regulatory Requirements; Direct Final Amendments,” in which the following quote appears:
"F. Executive Order 13175: Consultation and Coordination With Indian Tribal Governments

6. A Recent Example (April 29, 2011)
“This action does not have tribal implications as specified in Executive Order (65 FR 67249, November 6, 2000). These amendments do not impose requirements on tribal governments. This direct final action will not have tribal implications and we received no adverse comments when the proposed changes were presented to the National Tribal Air Association (NTAA) in March Tribes at the meeting supported these proposed changes; thus, Executive Order does not apply to this action."

7. Regional Planning Organizations (RPOs)
Regional air quality planning is essential to Tribal efforts to protect air resources and community health.
What is being done by EPA to preserve and expand the function of the Regional Planning Organizations?
How is EPA planning on ensuring effective Tribal participation in those efforts?

8. Office of Radiation and Indoor Air/Office of Atmospheric Programs.
Why does OAQPS work so effectively with Tribes and these other offices don’t?

9. Implementation of Tribal NSR Rule
Understand that the Tribal NSR Rule has been signed
Questions about implementation remain:
How much funding will be allocated?
Does EPA anticipate Tribal or EPA Inspectors being the primary focus?

10. Regional Disparity issues
Tribes are just as sovereign no matter which Region they happen to be located in.
EPA’s trust responsibility remains the same across the Regions. 

11. Recommendations to encourage consistent treatment of Tribes across EPA Regions
Proper consultation;
Regional budget requests should be developed with tribal input;
Fostering the equal treatment by EPA Regions of Tribes and States that EPA’s trust responsibility requires;
Require that Senior Managers at HQ and Regions take the “Working Effectively with Tribal Governments” training.

12. Consistent Relationship Structure between Regions and Tribes
Open, transparent and timely funding allocation
Consistent reporting requirements
Encourage less turnover among Project Officers
Self-Governance Funding
Each new initiative to include tribal set-aside

13. Region 1
Single-person air programs (data collection, analysis, policy work all done by one person) were told to build capacity under one administration, and then downsized in the next.

14. Region 2 Regional Issues Saint Regis Mohawk Tribe at Akwesasne
Climate Change Adaptation Planning
Wind, solar and geothermal technologies
Saint Regis Mohawk Tribe at Akwesasne
General Motors/Alcoa/other industry
Mobile Sources
On-Road/Non-Road
Emissions from the international shipping industry
Fluoride and Benzene

15. Region 4
More Tribes with air quality programs or projects (capacity building)
Climate change research/adaptation planning incorporating Tribal knowledge (TEK)
Alternative energy & fuel
Regional haze (GSMNP)
Mobile sources
Indoor AQ assessments & implementation plans
Education & outreach to tribal communities (especially youth)

16. Region 5 Mercury Monitoring – air toxics, PM, O3, mercury
Mining impacts
Lack of adequate number of EPA Tribal Air Coordinators
Lack of funding for Indoor Air Quality
Minor Sources
Education/outreach to Tribal community members
Air Modeling
RPOs (not MJOs)
Climate Change

17. Region 6
Continued partnership with the recently formed RTOC Tribal Air Subcommittee
Consider making a self-governance program available to Tribes for Sect. 103 and Sect. 105 funding sources. 
Successfully completing Tribal EIs

18. Region 7 Passive Ammonia Monitoring Network Hyperion Energy Center
NSR – minor sources
CAFOs, gravel pits, mobile sources
Impacts of Coal Fired EGUs 

19. Region 8 Develop Region 8 Tribal Environmental Consortium (RETEC)
EPA/RETEC to conduct baseline air quality assessments where no monitoring has been done
Inter-Tribal Auditing

20. Region 9 Streamline designation process- include Tribes from the start
Always assume Tribes will be affected by EPA standard revisions and rule making
Timely notification
Appropriate consultation
Funding for Tribal Air Programs
Advanced technical training on Air Monitoring Systems including NPAP/PEP audits
Clear/concise information on air monitoring requirements prior to start of monitoring programs

21. Region 10 Smoke Management Program Improvement
Air Toxics and Criteria Pollutant Issues 
Regional Haze Implementation
Indoor Air Quality
Climate Change

22. Alaska Fugitive dust from large-scale mining activities
Dust, road system in rural Alaska is all gravel roads and the majority of the vehicles are ATV's
Funding, again we continue to face "reservations" in RFPs.
Climate Change effects on the northern part of the globe that the villages are facing. Such as, naturally occurring mercury from permafrost melting.
Open Dump Burning, all villages in rural Alaska have this problem. Education and outreach to tribal leaders on the effects of open dump burning is needed.
Lead monitoring in rural Alaska mainly on airport locations.

23. Ondrea Barber, Program Coordinator
For more information
Ondrea Barber, Program Coordinator