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Tribal Benefits from State Implementation Plan (SIP)
Process InvolvementRosanne Sanchez
New Mexico Environment DepartmentAir Quality Bureau
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Why should a tribe care about SIPs? Why tribal input is important Types of SIP actions Review public notification process Participating in the SIP process Important SIP elements
Topics
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Testimony Future opportunities for SIP participation Other opportunities for tribal participation
NM tribal notification Tribal participation example Summary/Conclusion Contact information
Topics (cont.)
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Air pollution is regional, transported to Indian communities
To better protect health of citizens To not be disadvantaged by area planning
efforts To remain competitive and enhance
opportunities for economic growth
Why Should a Tribe Care About SIPs?
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SIPs outline… how sources will be regulated how states plan to address local non-
attainment problems how future SIPs will address regional and
transported pollution
Why Should a Tribe Care About SIPs? (cont.)
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Can incorporate major policy judgments of state agency
Limited opportunity to participate once state-level process complete
Helps agency make balanced decisions Ensures tribe’s voice is heard in decision
making
Why Tribal Input is Important
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Initial SIPs – new plans Attainment redesignation Approve new state rules Amend emission limit at a particular source Amend monitoring requirement at SIP source Process is the same – difference is
complexity of plan development and supporting documents
Types of SIP Actions
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New rule, plan, or amendment to existing part of SIP
Major newspaper statewide or regional notice for affected area (NM 60 day comment period)
Published in NM Register Posted on website Anticipate a lot of comments outreach prior to 60
day comment period During 60 day comment period open house or
public meeting
Public Notification Process
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Develop relationship with state or local air authority (SIP writer or manager)
Attend hearing, see how system works for state or local authority
Document your contacts and how hearing process works for others to view and learn (SIP protocol checklist)
Participating in the SIP Process
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Get involved early Participate at development stage (i.e.,
workgroup) for the experience and for best impact
Better understanding of the issue will improve quality of your comments
Possess knowledge that state may not have leads to better outcome
Participating in the Process (cont.)
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Know your subject matter Each a little different depending on project
Example regulation development, nonattainment area, etc.
Comments should be relevant to subject
Important SIP Elements
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Hearing with Environmental Improvement Board (EIB)
Public may Provide oral comments at hearing (general) Cross-examine witnesses ask questions If tribe comments on technical info they must submit
as a notice of intent (see next slide) Written non-technical statement may be submitted Record of hearing is made; transcript copy
available at requester’s cost
Public Testimony
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Technical testimony – scientific, engineering, economic, other specialized testimony
Notice of intent to present technical testimony 20 days before hearing
Will include qualifications of witness education and work background
Other Testimony
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Very difficult to make a change at a hearing Request to meet with state air program Participate in workgroup Attend public meetings
Engage Early in the Process
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New federal ozone standard may affect areas of the West currently in attainment
Includes many rural areas influenced by power plant and oil and gas emissions transport from major metropolitan areas
Look out for lower NAAQS
Future Opportunities for SIP Participation
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General Permit development General Permit revisions Permit review
All written comments added to permit application record and considered in permit review process
Work groups Hearings
Other Opportunities for Tribal Participation
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NM has incorporated into it’s rules notification Construction Permits (within 10 miles) Operating Permits (within 50 miles) Prevention of Significant Deterioration (PSD) Nonattainment Areas
Contact air program and get on a mailing list
NM Tribal Notification is Required for Permits
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New Mexico Air Quality Bureau proposes General Construction Permits (GCP)
Volunteered to be a member Attended several meetings Exposed to several new terms Gained valuable experience on how state
develops general permit
Tribal Participation Example (non-SIP)
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Attended administrative hearing (non EIB) Concerned about language in permit
application Testified at hearing my concerns Hearing officer did not object, so change was
made
Tribal Participation Example (non-SIP)
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Amended Permit Language3
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Amended Language (cont.)
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Amended Language (cont.)
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Air issues becoming increasingly complex – ozone, PM2.5 formed by precursor emissions that travel significant distances
Increasing need for national coordination, interstate and tribal cooperation (Regional Haze Rule 40 CFR Part 51.308 and 51.309)
Need for more tribal comments
Summary/Conclusion
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Rosanne SanchezEnvironmental AnalystAir Quality BureauNew Mexico Environment Department5500 San Antonio Dr. NEAlbuquerque, NM 87109(505) [email protected]://www.nmenv.state.nm.us/aqb
Contact Information
