FARR on the Nez Perce Reservation

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FARR on the Nez Perce Reservation

• Johna Boulafentis, Environmental Outreach
  Specialist
• Nez Perce Tribe
• Environmental Restoration Waste Management
• Air Quality Program
• Lapwai, Idaho

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Overview

• The Nez Perce Reservation
• Sources of Air Pollution
• History of Smoke Management Program
• Federal Air Rules for Indian Reservations
• Delegation Agreement Nez Perce FIP
• Other FARR Elements-Title V Inspections,
  Registering Sources

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The 1863 Nez Perce Reservation
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Some of our Sources
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NPT Smoke Management Program

• Operating on the Reservation since 2002
• Voluntary prior to the FARR
• Coordination with EPA State of Idaho
• Clearwater Airshed MOA (EPA, NPT, IDEQ)
• Ag Burning MOA (EPA, NPT, IDEQ, ISDA)

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Delegation Agreement

• Nez Perce Tribes Delegation Agreement effective
  June 27, 2005
• Delegates day-to-day FARR activities
• Tribe acts as EPA representative on Reservation
• Coordinate with surrounding agencies and with EPA
• Collect, store, analyze, and report data

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Nez Perce FIP

• Rule for Limiting Visible Emissions
• General Rule for Open Burning
• Rules for General Open, Agricultural and Forestry
  Burning Permits
• Rule for Air Pollution Episodes
• Complaint Response
• Inspections and Investigations
• Annual Review and Evaluation

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Nez Perce FIP Open Burning Burn Permit Rules

• Day-to-day FARR activities
• Twice-daily forecasts for agricultural, forestry
  and open burning
• Outreach
• Complaint response and investigations
• Burning is permitted and burned only during
  approved burn durations
• Recreational, traditional and cultural burns are
  exempt
• FARR does not exempt/excuse compliance with other
  applicable laws and ordinances

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Permit Holders
As of June 2008
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Nez Perce FIP Burn Bans

• Three monitoring sites Kamiah, Lapwai, Reubens
• Levels have exceeded or are expected to exceed
  75 of NAAQS
• 26.25 ug/m3, PM 2.5 24-hour
• average
• Levels are projected to continue
• or reoccur over at least the next
• 24 hours
• Cultural and traditional burns
• are exempt

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Burn Bans

• 3 days in 2005
• 7 days in 2006
• 9 days in 2007
• 1 day in 2008

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Nez Perce FIP Air Pollution Episodes

• Prevent occurrence of air pollution emergency
• Air stagnation advisory
• Air pollution alert
• PM2.5 _at_ Unhealthy (65-150)
• Air pollution warning
• Very unhealthy (150-250)
• Air pollution emergency
• Hazardous (over 250)

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Outreach Venues

• Office
• Answer Qs Share Information
• Field
• Events Presentations
• Meetings Workshops
• Media
• Articles, info notices, posters, newsletters,
  mailings, website
• Inter/Intra-agency coordination

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Office Field Coordinator Outreach
As of June 2008
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As of June 2008
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Outreach to Community

• Open House Public Listening Session
• Nez Perce Tribe Events
• Community Civic Organizations
• Community Events
• Classroom School Events
• Grower Meetings
• Elder Centers, Nursing Homes

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Levels of Coordination

• Tribal
• Federal
• State
• Local
• Regional

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Nez Perce FIP Compliance

• EPA retains authority for enforcement
• Tribe conducts compliance assistance
• Tribe conducts investigations
• Sends reports to EPA
• EPA determines enforcement action
• EPA Inspector Credentials
• 2 staff members, June 2007

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Complaints

• 49 in 2005
• 152 in 2006
• 89 in 2007

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Other FARR Elements

• Title V Inspections
• 3 lumber mills
• 2008 conducted inspection and permit review
• Registering Sources
• 10-12 gas stations and petroleum distribution
• 12 grain elevators
• 4 concrete/ gravel pit / crusher operations
• 2 auto-body paint
• 1 asphalt
• 1 lumber mill

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Program Evaluation and Annual Review

• Annual analysis
• Scrutinize causal relationships between burns
  conducted, forecasted vs. actual meteorological
  conditions, and impacts from wildfires
• Staff in constant learning mode
• Adjustments in decision-making may occur on a
  day-to-day basis

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Challenges

• Increasing competition for airshed
• Anti-Indian sentiment
• Resistance to government regulation
• Contentiousness of agricultural burning
• Change in burn practices
• Obtaining multiple permits and approvals
• Continued program funding

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Successes

• First tribe to take delegation of FARR Burn
  Permit Program
• Capacity building
• Partnerships with various agencies and groups
• Overall awareness of air quality issues
• Protecting air quality and human health

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Contact Information

• Nez Perce Tribe
• ERWM Air Quality Program
• 109 Lolo Street
• PO Box 365
• Lapwai, ID 83540
• [phone] or 1-800-720-4089
• fax [phone]