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The Grand Traverse Band of

Ottawa and Chippewa Indians

2605 N.West Bay Shore Drive * Peshawbestown, MI 49682-9275 * (231) 534-7750

Certification of Tribal Council Action

Regular Session of March 21, 2012

| hereby certify as the Tribal Council Secretary that the foregoing

Motion was Approved and Adopted at the Regular Session of the

Grand Traverse Band of Ottawa & Chippewa Indians Tribal Council

Review of Written Management Reports

NREC - Integrated Solid Waste Management Plan

Motion made by Tribal Council Member Rohl and Supported by Tribal Council Member

Napont to approve the Integrated Solid Waste Management Plan.

5 — FOR; 0 —- AGAINST; 1 —- ABSENT (Bailey); 0 - ABSTAINING

Motion Carries

CS. LL LB +

George M. Antoine’ GTB Tribal Council Secretary

cc: Shawnee John, NRD

GRAND TRAVERSE CHARLEVOIX LEELANAU BENZIE MANISTEE ANTRIM

Grand Traverse Band of Ottawa and

Chippewa Indians

2605 NW Bay Shore Drive

Peshawbestown, MI 49682

(231) 534-7500

Natural Resource and Environmental Committee

Regular Session

March 8, 2012

Natural Resources Department

II. Old Business

1. Integrated Solid Waste Management Plan

Motion to support the Integrated Solid Waste Management Plan

9-For; 0-Against; 0-Abstain; 2-Absent (TOM ANTOINE; SANDY WITHERSPOON)

Motion Carries

I, Shawnee John certify that the above motion was made and adopted at the Natural

Resource and Environmental Committee Regular Session, held on March 8, 2012 at the

Natural Resources Fisheries Management Buildmg m Peshawbestown, Michigan.

Oy, Oa 3-20-13,

Shawnee John iG - Date

Administrative Assistant NRD

GRAND TRAVERSE BAND

OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED WASTE MANAGEMENT PLAN

PROJECT #3207

FINAL DRAFT

DECEMBER 2010

Prepared By Kristine L. Petoskey, Environmental Consultant

‘Templates used: EPA Region Draft April 2007 Integrated Waste

Management Planning Method & TSWAN

GTB IWMP i Revised 02-28-11

TABLE OF CONTENTS

1.0 DESCRIPTION OF COMMUNITY SERVICE AREA ..

1.1 POPULATION AND DEMOGRAPHICS

1.2. COMMUNITY ASSETS AND RESOURCES.

1.3. HOUSEHOLDS AND HOUSING.

1d POPULATION PROJECTIONS AND ESTIMATED GROWTH

15

1.6

17

1.8 GEOLOGY AND NATURAL RESOURCE!

2.0 DESCRIPTION OF THE TRIBE’S SOLID WASTE PROGRAM

STRUCTURE AND ADMINISTRATION

2.1 PROGRAM ADMINISTRATION AND MANAGEMENT.

2.2. REGULATORY REQUIREMENTS (CODES & ORDINAN'

2.3. ENFORCEMENT. 1

3.0 DESCRIPTION OF THE TRIBE’S CURRENT AND PROPOSED WASTE

MANAGEMENT PRACTICES.

3.1 CURRENT WASTE MANAGEMENT PRACTICES.

3.1.1 Waste Stream Characterization .

1.1.1 Generators (Residential, Commercial, and Industrial)

3.1.1.2 Weight/Volum

3.1.1.3 Compositions and Waste Stream Analy

«14 Future Generation and Growth Rate..

Open Dumps and Uncontrolled Waste Sites

Waste Collection, Transfer, and Disposal

Special and Hazardous Waste ..

Waste Reduction: Source Reduction, Recycli

Facility Descriptions and Capacities

Regional Infrastructure

3.1.8 Current Partnerships

3.1.9 Pasv/Current Publ

PROPOSED WASTE MANAGEMENT PRACTIC

Special Considerations

‘olvement and Community Education..

3.2.1.1 Limitations and Inefficien

of the Current Program

2 Equipment and Facili

Alternatives Analysis.

Capital, Operational, and M:

Closure Care and Costs

Real Cost of In-Kind. Off-the-Book Transactions

Cost-effective Analysis

i Revised 02-28-11

4.0

awe

3.2.2.5 Overall Feasibi

Selected Alternative. :

Proposed and Future Waste Management Practices.

Proposed Waste Reduction: Source Reduction, Recyclin;

Composting.

3.4 Potential Partnershi

3.2.3.5 Compliance and Enforcement...

3.2.3.6 Proposed Public Involvement and Community Education.

2.4 Implementation

‘Tribal Solid Ws

ste Management Plan Review and Updating

DESCRIPTION OF THE FUNDING AND SUSTAINABILITY/LONG-TERM

GOALS OF THE TRIBE’S SOLID WASTE PROGRAM 72

4.1 FINANCIAL IMPLEMENTATIO?

«I Funding the Plan.

Revenue Generators.

Fee Structur

Financial Sustainability

4.2. LONG-TERM GOALS AND STRATEGIES..

Long-Term Goals and Priorities

Improvements Beyond Basic Compliance ..

Strategies for Implementation and Maintenance

DEMONSTRATI OF APPROVAL OF PLAN BY APPROPRIATE

GOVERNING BODY

5.1. BY WHOM..

5.2. DATE... ai

5.3. DEMONSTRATION OF COMMUNITY INVOLVEMENT IN THE

PLANNING PROCESS . ”

APPENDICES

REGIONAL CONTACTS,

FURTHER RESOURCES

APPROVAL BY THEGOVERNING BODY: GRAND TRAVERSE BAND OF

OTTAWA & CHIPPEWA INDIANS.

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1.0 DESCRIPTION OF COMMUNITY SERVICE AREA

This section discusses the following community and service areas:

* Population and demographics

© Community assets and resources

* Households and housing

© Population projections and estimated growth rate

* Economy

+ Climate

© Geography and land use

‘© Geology and natural resources.

1.1 POPULATION AND DEMOGRAPHICS

‘The Grand Traverse Band was federally-recognized under the authority of the Indian

Reorganization Act of June 18, 1934. (48 Stat, 984). as amended. They were federally-restored

to a previous status as an Indian Tribe on May 27. 1980. The Tribe is located in the northern

lower peninsula of Michigan in the counties of Antrim, Benzie, Charlevoix. Grand traverse.

Leelanau, and Manistee. The acreage includes 2,562 square miles. The Natural Resources and

local economy include: treaty-based hunting. fishing, tourism, recreation, casinos, resort, hotels.

golf courses, freshwater lakes, streams. rivers. wetlands, forests, native plants, environmentallysensitive areas, and culturally-preserved areas. There are 4.102 total members of which 686

members live on the reservation lands. The income sources include casinos, restaurants, hotels.

gas station, golf courses, resort, small retail shops, and rental housing. Further information can

be accessed at hitp://gtbindians.org/.

‘The total population of the Grand Traverse Band is 4,102 members. based on data from the

Grand Traverse Band Membership office, per data received on October 25. 2010. The table

below indicates the breakdown of the current population of the reservation, including total

Tribal enrollment, members living on the reservation, and non:

reservation.

Grand Traverse Band Reservation Population, 2010

Total Members Living neni Reon

Enrollment | on Reservation ving on servation

Reservation Population

4.102 686 o* 686

Only GTB Tribal members are assigned reservation lots. Any non-native occupants

in these households are not tracked by the Tribe.

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

Measurable Outcomes

The housing populations will be updated every five years afier the one year update to ensure the

projections are on track and the projected solid waste needs are accurate

1.2 COMMUNITY ASSETS AND RESOURCES

Cultural Traditions

‘The Grand Traverse Band has strong cultural and traditional beliefs in regard to environmental

protection and preservation. These beliefs are represented in every action taken by the Tribe

‘The philosophy is to always consider those seven generations ahead and to remember and

respect those seven generations back who did things in a good way for us today. It is with this

in mind, that it is easy to understand that managing the solid wastes needs is integral to the basic

existence of the Tribe and is incorporated into everything that is done.

Educational Ethie

The Grand Traverse Band strongly values education. A culture which embraces education so.

highly is very receptive to continually furthering their knowledge. The Tribe supports

educational outreach especially in the areas of the environment, including solid waste

management practices. Community involvement and support is high, increasing the success of a

solid waste management plan.

Community and Cultural Assets and Resources

There are several community and cultural assets and resources at the Grand Traverse Band,

which contribute to the success of a solid waste management plan. Examples include, but are

not limited to the following (in alphabetical order):

Anishinaabek Family Services Food and Beverage Departments

Anishinaabemowin Program Guest Services

Architeet/Project Planning Program Housing Department

Automotive Department Information Technology Department

Benodjenh Headstart/Early Headstart. Life Long Learn Department

Communications Department Maintenance Departments

Conservation Department Marketing Departments

Elder's Advisory Membership Department

Education Department Natural Resources Department (NRD)

Eyaawing Museum Natural Resources Environment Committee

Facilities Department Public Works Department

Family Health Clinic Tribal Council

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Many community events are good sources for reaching Tribal membership, a few

examples include:

Anishinaabemowin Program Gatherings NRD Fair and Feast (annual)

Elders Advisory (monthly) NREC Meeting

Eyaawing Cultural Events Traditional Pow Wow (annual)

Health Fair (annual) Tribal Council sessions (monthly)

Membership Meeting (annual)

Measurable Outcomes

‘The Environmental Director conduets solid waste educational outreach for the Tribal

community and staff on a regular basis by attending community events and by providing

educational materials (brochures, newsletter articles, and e-mail notices). The Director reports

the outreach in EPA progress reports on a regular basis, in accordance with the grant.

1.3 HOUSEHOLDS AND HOUSING

Housing

‘The existing number of households on Grand Traverse Band reservation land is 254. This

includes 152 rental units and 102 privately owned homes on reservation land in the six county

service area, The largest populations are located on the main reserve in Peshawbestown. ‘The

table below indicates the types and numbers of existing housing units on the Grand Traverse

Band reservation.

Grand Traverse Band Reservation Housing, 2010

TOTAL # UNITS | Rental Units | Owned Homes

Entity | Units of Total | # Units | % of Total

254 | 152 | 60% = | 102 40%

Fee Structure

Renters pay their waste and recycling costs as part of their monthly rent, separate from

water/sewer and heat. Housing is available as single units, 2-4 bedrooms. duplexes, and

apartments, Housing trends are tracked to easily predict waste and reeyeling current and future

needs.

Private homeowners are responsible for contracting with local waste haulers for waste disposal

needs. They have the availability to access county recycling sites in their specific county.

‘There are two options available for county recycling in the six county service area: centrallylocated recycling sites and curbside pickup.

Commercial waste fees are built into each separate budget for each casino and the governmental

operation.

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

Source

Rental information was gathered from the Tribal Housing Department. Private homeowner

information was gathered from the May 2005 plat maps provided by the Land/Road Manager,

Rob Kalbfleisch. The number of members per household for rentals and owned homes is based

upon the numbers of members and number of rental units in Tribal housing.

Measurable Outcomes

‘The status of Tribal housing. in regard to the number of units, number of occupants, and

capacity and assess the number of owned homes will be updated every five years after the one

year update.

14 POPULATION PROJECTIONS AND ESTIMATED GROWTH RATE

Population Projections

The table below utilizes the population projections from Section | and reflects the total waste

generation over the 50-year planning period.

Population and Solid Waste Generation Projections

YEAR MEMBERSHIP | RESERVATION

POPULATION POPULATION

2010 4,102 686

2015 4,128 690

2020 4,154 695

2025 4,180 699

2030 4,206 703

2035 4,232 708

2040 4,258 712

2045 4,284 716

2050 4.310 721

2035 4.336 725

2060 4.362 n9

Over the past three years, the Grand Traverse Band reservation has only increased at an average

annual rate of 0.6%. Based on this rate, the fifty year (2010 to 2060) population projection for

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

members who live on Grand Traverse Band reservation trust land, predicts a growth of

approximately 43 people.

Population and Growth Source

Population data was obtained from the Tribal Membership office. which publishes its population

updates twice annually. Data was available from 2007 to 2010.

Measurable Outcomes

The Tribal membership data and the population growth will be compared to the projected

numbers to make sure it is accurate every five years after the one year update,

15 ECONOMY

Commercial Economy

The Grand Traverse Band Tribe operates two casinos, two hotels, one museum, and one resort

which attract visitors from outside the reservation year round. The year-round population of the

Grand Traverse Band reservation is 685 persons. Additionally. during peak tourist season,

populations increase exponentially. For example, itis estimated that 300.000 visitors attend the

annual National Cherry Festival in Traverse City. alone, According to the Grand Traverse Band

Casino marketing department, 1,052,191 persons visited the Turtle Creek Casino and 303.313

persons visited the Leelanau Sands Casino in 2010 (fiscal year October 2009 - September 2010).

for a total of 1,355,524 visitors in 2010. This is similar to 2009, which had a total of 1,319,912

tors. Further, the Tribe is the largest employer in the northwestern lower peninsula of

Michigan. employing 182 government employees and 876 gaming employees.

Poverty and Unemployment

The Tribe’s historic reservation of Peshawbestown, Michigan is located in an area where the

poverty level for a household of four is $19,100.00 and the national poverty level is $21,200.00.

The poverty level for the Tribe exceeds the national level by 10% or equal to but less than twice

the national poverty rate. This data was derived from the Department of Health and Human

Services reported 2008 national poverty levels and the Department of Housing and Urban

Development’s 2008 adjusted home income limits for Michigan.

These headquarters are located in an area where the local unemployment rate exceeds the

national unemployment rate by 51%. This is twice the national average but less than three times

the national average. This figure was derived from the U.S. Department of Labor's reported

national unemployment rate of 5.0% for April 2008 and the State of Michigan's Department of

Labor and Economics report an unemployment rate for the northwestern lower peninsula of

Michigan for April 2008 of 9.8%.

Industrial Economy

‘There are no industrial sources on reservation lands.

Revised 02-28-11

GTB IWMP.

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Economic Information Resources

Information was collected from the following source:

© Casino visitors and demographics (Marketing Department),

© Gaming staff (Gaming Human Resources), and

* Local economy. demographics. and Government staff data (Grants Department).

Measurable Outcomes

The number of Government and Gaming staff and the unemployment data will be updated every

five years after the one year update.

1.6 CLIMATE

According to the National Water Summary for 1988-89 published by the U.S. Geological

Survey (USGS). approximately 75 percent of Michigan's moisture is derived from the Gulf of

Mexico's tropical maritime air masses. The North Pacific Ocean and the Atlantic Ocean’s polar

maritime air masses lose most of their moisture before they reach the Great Lakes region.

Similarly, the Arctic Ocean and polar continental air masses from northern Canada’s arct

masses contribute very little moisture.

air

The Great Lakes are a regional moisture source. The temperature of the lakes changes very

slowly and this have an affect on climate. It delays the start of summer and winter. affecting

wind, precipitation, and temperature,

On average, Michigan receives an average of 31 inches of precipitation, between 30 (SE

Michigan) and 160 (N Upper Peninsula) inches of snowfall. 8 miles per hour winds

(predominantly westerly), and temperature ranges from 24 to 63 degrees Fahrenheit

The following table presents the seasonal ranges of climate data for the mai

Peshawbestown, Michigan (hitp://www.city-data.com/city/Suttons-Bay-M

reservation in

higan.html)..

Seasonal Climate Data, Peshawbestown, Michigan

Seasons Temperature | Precipitation Wind Snowfall

(F) (in) (MPH) (in)

Spring (March-May) 24 10 58 13 1028 82109 | 010128 |

Summer (June-August) 58 10 63 2.8 10 3.6 7.210 8. 0

Fall (September- 3210 63 2.3103.6 7.21093 | Otwld

November)

Winter (December- 21032 141023 91093 | wie

February)

10-year storm event susceptibility means a ten percent chance of occurrence each year. while a

100-year storm event means a one percent chance. According to the USGS. from 1903 to 1989,

there were no 10-year or 100-year storms in the northwestern lower peninsula of Michigan

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

(htin:/mi,water.uses.gov/{dfloods.php). The significant events typically occur in southern

Michigan and the Upper Peninsula because of the amount of clay. This region is predominantly

sandy, which buffers the effect of severe storms.

Measurable Outcomes

The climate data will be updated to maintain accuracy over the long term every five years after

the one-year update.

1.7 GEOGRAPHY AND LAND USE

The Grand Traverse Band’s reservation is located in the northwest section of the lower

peninsula of Michigan, The Tribe is set within the woodlands of Leelanau County and includes

views of West Grand Traverse Bay and Lake Michigan, The most distinct features of this

region have been formed by glacial activity. Repeated glacial advances and retreats have

created a terrain that is generally level to gently rolling and created a variety of distinct

landform features throughout the region.

The Grand Traverse Band’s service area encompasses six counties: Antrim, Benzie, Charlevoix,

Grand Traverse, Leelanau, and Manistee, with a land area of 2,562 square miles. All six

counties are designated as rural, according to the U.S. Department of Agriculture. The region is

heavily wooded with a diversity of natural resources for hunting, fishing. recreation, agriculture,

and year-round tourism. Table 1-3 contains a breakdown of land use on the Grand Traverse

Band Reservation.

Land use in Grand Traverse Band Reservation

Land use ‘Square Miles

Forest lands 1,537

Agriculture (orchard. crop. hay) | 641

Residential areas 384

Source: Tribal Natural Resources staff

Source

Geological and land use data was obtained from the Tribal Natural Resources Department and

Grants Department.

Measurable Outcomes

The land use data will be updated every five years afier the one year update.

1.8 GEOLOGY AND NATURAL RESOURCES

Landfill Feasibility

GTB IWMP 7 Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Information about the geological and engineering properties of the surface and subsurface is

particularly important when considering landfill site selection. closure of existing dumps. and

economic feasibility studies.

There are no plans for constructing a permanent structure, such as a landfill, The basis for this

is that the Grand Traverse Band does not generate the volume which would warrant the need for

their own landfill. they are not remotely located far from viable community’ landfills, there are

no historic and cleanup landfills on the reserve. and. further. they value the natural pristine

quality of the natural resources,

Measurable Outcomes

The landfill feasibility will be updated every five years after the one year update or in the event

the Tribe decides a landfill becomes a viable possibility.

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

2.0 DESCRIPTION OF THE TRIBE’S SOLID WASTE PROGRAM STRUCTURE

AND ADMINISTRATION

This section discusses program administration and management, regulatory requirements (codes

and ordinances), and enforcement.

2.1. PROGRAM ADMINISTRATION AND MANAGEMENT

Administration

Administration includes the planning, development, contracting, legal, technical, record

keeping, staffing, and public education responsibilities that are involved in the management of

the Tribal solid waste system performed by the solid waste managers and/or recycling

coordinators,

‘Tribal Personnel & Responsibilities

The roles and responsibilities involved in the administration of solid waste management is

diverse and complex, and have grown more so within the past ten years. In addition, roles and

responsibilities will grow as programs develop.

Solid Waste Managers/Recycling Coordinators:

* Dan Hughes, Leelanau Sands Casino Maintenance Supervisor (Gaming)

© Jim Gaskin, Turtle Creek Casino Maintenance Supervisor (Gaming)

* Tom Shomin, Facilities Manager (Government)

* Loi Chambers, Division IV Business Manager (Family Health Clinic, Government)

* Steve Ferrenga, Corporate Architect (C&D, Gaming)

* Joan Cotter, Interim Housing Director (Government)

‘© Dwayne Burfield, Automotive Program Director (Government)

* Desmond Berry, Environmental Director (Government)

Their responsibilities in regard to solid waste management generally include:

+ Budgeting: Prepares an annual budget of anticipated capital and operating expenditures,

ipated revenues/losses from disposal fees and available funding.

Conducts any plan development, contracts for outside services (if needed),

assigns staff to the solid waste and recycling committees, represents the Tribe to the

public, presents planning documents and recommendations to the Tribe.

© Financing: Produces projections on needed revenues, and requests available funding, as

needed.

© Implementation/Development: Arranges for development of new facilities and

programs by developing contracts, plans specifications and bid documents, and provides

contract management.

* Liaison: Coordinates with the local Health Department on ordinances related to solid

Waste regulations as necessary to implement the solid waste program. Funetions as the

clearinghouse for all solid waste

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

© Operations: Develops. manages. and monitors the contract for the waste disposal by

private enterprise contractors.

* Record Keeping: Tracks the contractor's operating reports, maintains waste reporting

and other databases and reports, and maintains the overall expenditure records. and

tracks expenditures and revenues. (No database tracking is currently being utilized.)

Education Outreach Coordinator

The Grand Traverse Band Education Outreach Coordinator consists of:

* Desmond Berry. (Government) Environmental Director

His responsibility in regard to solid waste and pollution prevention consists of:

* Public & staff education and outreach: Prepares and provides public information through

Jocal media, workshops and seminars. provides published information on the solid waste

system, and ation center for recycling, hazardous waste, and other waste

management issues within the reservation.

Grand Traverse Band Tribal Council

‘The Grand Traverse Band Tribal Councilors include:

© Derek Bailey. Tribal Chairman

Sandra Witherspoon, Tribal Council Vice-Chairman

Robert Kewaygoshkum, Tribal Council Treasurer

George Antoine, Tribal Council Secretary

David Arroyo, Tribal Councilor

Brian Napont, Tribal Councilor

Jane Rohl, Tribal Councilor

‘Their responsibilities in regard to solid waste management include:

© Review and approve prepared budgets, capital and operating expenditures,

revenues/losses, and grant funding.

* Review and approve prepared implementation plans, plan development updates,

contractual needs. staffing needs. and plans for public educational outreach, planning

documents, and technical staff recommendation:

© Review and approve financing, revenues. and available grant funding. as appropriate.

All Tribal staff members are subject to annual reviews. Note that there are no dedicated “solid

waste” staff or budgets. Solid waste responsibilities are incorporated into other position

responsibilities. Similarly, solid waste budgets are integrated into departmental budgets. All

gaming and governmental entities run separately and do not currently have close

‘communication in regard to an entire Tribal solid waste program. All gaming and government

department are subject to routine audits.

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

FEDERAL, STATE, AND OTHER AGENCIES INVOLVED

‘The United States has a unique legal relationship with Tribal governments based on specific

constitution, treaties, statutes, executive orders, and court decisions. Under the American legal

system, Indian Tribes have sovereign powers separate and independent from the federal and

state governments. This means that Tribal governments have the same powers as the federal

and state governments to regulate their internal affairs. with a few exceptions. For instance,

Tribes have the power to form a government, to decide their own membership, the right to

regulate property, the right to maintain law and order, the right to regulate commerce, and so on.

Because of the unique nature of Tribal sovereignty and specific federal legislation recognition.

various governmental agencies are involved in assisting Indian Tribes. Agencies assisting

Tribes with solid waste management needs and concerns are listed below,

United States Environmental Protection Agency (EPA)

‘The EPA is entrusted with the responsibility to protect human health and the environment.

Working on a government-to-government basis with tribes, the EPA gives special

considerations to Tribal interests in making agency policy. and to insure the close involvement

of Tribal governments in making decisions and managing environmental programs affecting

reservation lands. In 1984, EPA became the first federal agency to adopt a formal Indian Poli

of working with federally recognized Tribes on a government-to-government basis. This poli

is intended to provide guidance to EPA staff and managers in dealing with Tribal governments

and in responding to the problems of environmental management on Indian reservations in order

to protect Tribal health and environments. For further information, go to the website:

American Indian Environmental Office (AIEO)

‘The AIEO coordinates an agency-wide effort to strengthen public health and environmental

protection in Indian Country, AIEO oversees development and implementation of the Agency's

Indian Policy and ensures that the agency-wide implementation of its Indian Program

it tion's policy to work with Tribes on a government-to-government

basis to protect Tribal health and environments. For further information, go to the website:

Uhup://www.epa jeo/index.htmU.

Bureau of Indian Affairs (BLA)

‘The BIA is responsible for the administration and management of 55.7 million acres of land

held in trust by the United States for American Indians, Indian tribes, and Alaska Natives.

‘There are 562 federally recognized ,1, Tribal governments in the United States. Developing

forestlands, leasing assets on these lands, directing agricultural programs, protecting water and

means these Tribes have a special legal relationship with the United

nvernment-to-government rel

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

land rights, developing and maintaining infrastructure and economic development are all part of

the agency's responsibility. For further information, go to the website: Untip://www.bia.govU,

Indian Health Services (IHS)

An ageney within the Department of Health and Human Services, the IHS is responsible for

providing federal health services to American Indians and Alaska Natives. The IHS is the

principal federal health care provider and health advocate for Indian people. and its goal is to

raise their health status to the highest possible level. The Sanitation Facilities Construction

Program (SFC) within the IHS, provides assistance for the cooperative development and

continued operation of safe water. wastewater, and solid waste systems, and related support

facilities for American Indian and Alaska Native homes and communities. For further

information, go to the website: Uhitp:/svww.ihs. gov.

Measurable Outcomes

‘The staff and Tribal Council positions will be updated every three years after the one year

update.

2.2. REGULATORY REQUIREMENTS (CODES AND ORDINANCES)

Pertinent Laws & Regulations

Federal and State

Native American Tribes play an increasingly critical role in regulating the environment on

Indian lands. Although Tribes are increasing their own regulatory authority, the EPA ret

jurisdiction over all pollution sources until a program has been delegated to the Tribe. Indian

Tribes must qualify for the "delegation" of a program under the various environmental

inistered by the EPA. A list of Federal laws and regulations concerning

protection laws adm

solid waste management issues is included in Appendix B-1.

State power over activities on Indian reservations generally is narrow, Although Tribes are

required to follow federal laws and regulations, Tribes may incorporate state laws and

regulations (when applicable) when addressing environmental issues. There is potential for

overlap and conflict among Tribal, state, and federal regulations.

The Michigan Department of Natural Resources and Environment (DNRE) is the regulatory

agency which is responsible for waste issues. These waste programs include: groundwater

discharge, hazardous waste, hazardous and liquid industrial waste, medical waste, radiological

protection, recycling, scrap tires, and solid waste. The DNRE also provides permiv/license

application forms: guidance documents; state, federal and local statutory and regulatory

information; and grant and loan information. A list of state laws and regulations in Michigan is

included in Appendix B-2.

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Tribal Codes

‘The Grand Traverse Band Tribe has established its own codes relative to solid waste

management, which are enforceable by the Tribal Game Wardens, A description of the Grand

Traverse Band's Tribal solid waste management codes and regulations is included in Table |

Grand Traverse Band Tribal Laws and Codes for Solid Waste Management

Law and Code Number Description

9GTBC. § 107G)2) Littering and Burning of Trash

9GTBC. § 10703) Dumping of Hazardous Material

T4GTBC § 801-810 Hazardous Material Releases

Deficiencies of Codes and Ordinances

There are no deficiencies in the existing Tribal ordinances and codes. however, new ordinances

and codes are developed and approved when plans or existing conditions exist. ‘Therefore, there

are no contingency health and safety plans. no codes or ordinances for permanent structures not

planned, such as landfills, transfer stations, etc. There is also not enough waste and recycling

generated to warrant the planning of permanent structures.

As the Tribe has grown, the solid waste and recycling needs and capacities have been added to

existing programs and assigned in addition to other staff responsibilities. Because of the lack of

dedicated staff and budget, it is more difficult to ensure consistency and track data. Each casino

and the governmental operation are run under separate budgets, staff, and have individual needs.

Measurable Outcomes

‘The Environmental Director will report any enforcement issues or collaborative measures in the

PPG progress report, under solid waste management. Any additions or deletions to the codes

and ordinanees pertaining to solid waste will be updated every five years after the one year

update.

2.3. ENFORCEMENT

The Tribal Conservation Department is responsible for enforcement of all Tribal codes and

ordinances. The Game Wardens have the responsibility to monitor. inspect, and enforce. Game

Wardens most commonly deal with environmental violations to the burn ban, incidences of

illegal dumping, and accidental hazardous spills. There is no laboratory budget, so instances

where sampling is warranted, funds need to be allocated from other sources.

Game Wardens work in conjunction with many other Tribal (Maintenance staff. Fire

Department staff, Architect, Facilities staff, and Natural Resources staff) and non-Tribal staff

(DNRE staff, EPA staff. and local official:

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Measurable Outcomes

The Environmental Director will report the number of code or ordinance violations, number of

illegal dumping incidences. and the associated fines enforced in the PPG progress report. under

waste management.

GTB IWMP 14 Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

3.0 DESCRIPTION OF THE TRIBE’S CURRENT AND PROPOSED WASTE

MANAGEMENT PRACTICES

This section discussed the current and proposed waste management practices.

3.1 CURRENT WASTE MANAGEMENT PRACTICES

This section discusses the following topics regarding current waste management prac

© Waste Stream Characterization

* Open dumps and uncontrolled waste sites

* Waste collection, transfer, and disposal

‘© Special and hazardous waste

‘© Waste reduction: source reduction, recycling, and composting

© Facility descriptions and capacities

© Regional infrastructure

© Current partnerships

© Public involvement and community education.

3.1.1 Waste Stream Characterization

This section discusses the following elements of waste stream characterization:

Generators (residential, commercial, and industrial)

Weight/volume

Compositions and waste stream analysis

Future generation and growth rate

3.1.1.1 Generators (Residential, Commercial, and Industrial)

Residential Generators

‘The cost and choice of contractor for residential solid waste is the responsibility of home

owners. The solid waste needs of families in Tribal housing are the responsibility of the

Housing Department. The cost is factored into their monthly rent

Commercial Generators

Commercial generators (solid waste) include the followi

* Governmental Operations (aiso special wastes:

waste, and white good waste)

© Gaming Operations (also special wastes:

white good waste)

© Leelanau Sands Casino

© The Lodge Hotel

re waste, vehicle fluid waste, medical

-waste, C&D waste, cooking oil waste, and

GTB IWMP 15 Revised 02-28-11

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INTEGRATED SOLID WASTE MANAGEMENT PLAN

© Eagletown Market

© Double Eagle Restaurant

© Turtle Creek Casino

© Turtle Creek Hotel (and restaurants)

Industrial Generators

There are no current or future industrial generators on Tribal lands and none locally which

would contribute to the Tribal solid wastes.

Measurable Outcomes

3.1.1.2 Weight/Volume

‘The table below utilizes the population projections from section 1.4 and reflects the total waste

generation over the 50-year planning period,

Population and Solid Waste Generation Projections

year Reservation Solid Waste

Population Generated (tons)

2010 686 1.856

2015 690 1.867

2020 695 1,880

2025 699 1.391

2030 703 1,902

2035 708 1.916

2040 112 1,926

2045 716 1,937

2050 721 1,951

2055 725 1.962

2060 729 1.972

Over the past three years, the Grand Traverse Band reservation has increased at an average

annual rate of 0.6%. Based on this rate, the fifty year (2010 to 2060) population projection for

members who live on Grand Traverse Band reservation trust land, predicts a growth of

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

approximately 43 people. In order to maintain current levels of service. the Grand Traverse

Band and its members would need to provide waste management programs for an additional 116

tons generated by 2060.

Measurable Outcomes

The waste generation rate will be updated to accurately predict the 50-year projected needs

every five years after the one year update.

3.1.1.3 Compositions and Waste Stream Analysis

Commercial Solid Waste

The commercial solid waste is not documented (tracked) year to year by either of the

‘government or gaming entities. The Maintenance Supervisor for the Turtle Creek C

reported that waste volumes are continuing to gradually decrease as he is able to introduce

additional recycling programs. The Leelanau Sands Casino reports that volumes have and will

remain to be fairly steady. As with the nature of a tourism business, waste volumes fluctuate

with the economy. Both supervisors confidently predict that the casino tourism and solid waste

volumes will remain fairly consistent over the next three to five years.

Residential Solid Waste

‘The residential waste is the responsibility of each household and is generally disposed of by

local waste haulers via curbside service. Because the waste haulers vary per location and

because they vary per the choice of each household, the residential solid waste volume has been

based on the number of households and an average household volume according to EPA data.

Another service the Grand Traverse Band offers is an annual spring clean-up event. Tribal

households are encouraged to take advantage of the opportunity to dispose of most bulky

household furniture and miscellaneous items free of charge. They are asked to pile items at the

end of their driveway for pick up. The date is announced in the newsletter and via staff e-mail

as to the scheduled dates for each road. Individual Tribal members also take advantage of this

opportunity to gather scrap metal, appliances, and other materials for their own profit prior to

the scheduled Tribal pick up days. At 57 tons per year. this service is well-utilized by the

membership.

Industrial Solid Waste

There is no current and expected future industrial solid waste generated on Tribal lands.

Disposed Solid Waste

The majority of solid waste from the Grand Traverse Band reservation is generated by the main

reservation in Peshawbestown and transported for disposal to the Glen’s Landfill in Leelanau

County.

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

In 2010, the amount of commercial waste generated on the Grand Traverse Band reservation

was 1.493 tons. which consisted of 917 loose tons per year and 576 compacted tons per year. In

2010, the amount of residential waste generated was 363 tons per year. The total amount of

residential and commercial solid waste generated on Grand Traverse Band reservation land in

2010 was 1.856 tons per year.

Diverted Waste Volumes

Commercial recycling consists of medical waste, automotive oil, automotive coolant,

automotive tires, cardboard, and computer equipment. A total of 444 tons of material was

diverted in 2010. Residential recycling consists of fiber. tin, plastic, and glass. A total of 188

tons of material was diverted in 2010. Because Tribal Members utilize publically accessible

county recyeling sources, an independent Tribal volume is not known, so instead, an average per

person volume is used, based on EPA data averages. The total amount of commercial and

residential materials diverted in 2010 was 632 tons

Waste Generated, by Sector

Tons generated

Sector Tons Disposed Tons diverted (Disposed +

Residential 363 188

‘Commercial 1493 444 1.937

1.856 632 2.488

‘otal ee

Measurable Outcomes

‘The diverted and disposed wastes will be updated every five years after the one year update.

3.1.1.4 Future Generation and Growth Rate

Solid Waste Generation Rate

‘The generation rate for the year 2010 was 2.7 tons per person per year (Upp/yr) and is calculated

using the following formula:

Generation jeer caeaia 1.856 __2.7055392

(ions) ss

lapis

a Population (persons) 686 vpp/yr

No off reservation sources current or predicted are expected to impact reservation waste

volumes.

GTB IWMP 18 Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Measurable Outcomes

The waste volumes, population data, and potential outside contributors will be updated every

five years after the one year update.

ncontrolled Waste Sites

3.1.2 Open Dumps and

‘Types of Illegal Dumping

s¢ Band reservation include the following:

Sources of illegal dumping on the Grand Trav

Occasional Problems with [legal Dumping: Although not a common occurrence. the

reservation does experience illegal dumping along roadsides and in rural areas, ‘These dumping

areas are cleaned up soon afier reporting and signage is posted to prevent future occurrences.

People observing illegal dumping of solid waste (the action, the presence of improper materials

in collection containers, or waste materials dumped in inappropriate locations) on the

reservation’s property are to notify the Tribal Game Wardens, who, in turn enforce t

ordinance.

Tribal

Existing Conditions

‘There are currently no known illegal dumps on the Grand Traverse Band reservation. All

former dumps have been cleaned up to date.

Historical Megal Dumping Sites

Historical sites were identified, posted. and cleaned-up. These sites included: in an open field

behind the Strongheart Center (household dumping) and behind Automotive building (vehicles

and parts). No burning at open dumps has been reported or discovered. Any burning on Tribal

land must be under a burn permit.

Junk Vehicles/Bulky Items

Junk vehicles/bulky items consist of furniture, mattresses/box springs. large appliances, and

other large items not contained in waste bags. Typically. these wastes are generated through

discarding old furniture, appliances, or vehicles with the replacement of new items.

Often times, Tribal members or area residents do not know how to properly dispose of these

items, and ofien abandon them along a roadside or in a rural area. If not disposed of properly.

junk vehicles/bulky items can easily become eyesores around the reservation.

Occasional Problems with Junk Vehicles/Bulky Items: Although not a common occurrence,

the reservation does experience large items along roadsides and in rural areas, These dumping

areas are cleaned up soon after reporting,

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GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Actions for Cleanup

To successfully deal with illegal dumping problems, the Grand Traverse Band Tribe enacted an

ordinance against illegal dumping and has implemented a comprehensive approach that

includes:

Site Cleanup and Monitoring

Site cleanup and monitoring includes planning, budgeting, and implementing cleanup projects at

current sites and the monitoring of these sites to prevent future illegal dumping. Proper

planning is a key element in the success of cleanup efforts. The Grand Traverse Band Tribe

does not have funding available for transportation and disposal of the removed waste: however.

they have staff to monitor and address illegal dumping on a case-by-case basis. When a site is

identified the Environmental Director, supported by Federal grant EPA General Assistance

Program funding. works in conjunction with local and federal staff to address site assessment

and cleanup. Although no funding is set aside for this purpose, existing funds may be able to be

redirected, if approved by the Tribe and EPA.

Community Outreach for Illegal Dumping

Educating Tribal members. visitors, and the surrounding community members about proper

waste disposal will help limit future illegal dumping incidents. Tribal members are more likely

to support solid waste management programs if they understand the new waste disposal options

and the dangers of open and illegal dumping.

Although limited funding is available to actively target this type of education and outreach,

Grand Traverse Band environmental staff members are readily available to the community

during annual Tribal events, through periodic newsletter articles, and daily in the office. In

addition, staff members monitor and distribute environmental information from the media and

meetings, as appropriate. The following measures are currently being implemented by the

Grand Traverse Band Tribe to educate Tribal members on new waste disposal options and the

dangers of open and illegal dumping:

© Participate in annual Tribal events, such as Heritage Days. Health Fair, Pow Wow. and

Fair & Feast. which promotes communication, education, and the availability of staff to

membershi

* Attend meetings and forward information to other Tribal staff and tribal members

through e-mail and Tribal newsletter media.

* Make educational publications available in the Natural Resources office. at Tribal

events, and in Tribal buildings,

© Utilize Tribal staff during spring cleanup events to remove trash from identified dump

sites.

Another deterrent to illegal dumping is the opportunity to participate in the annual spring

cleanup offered free of charge to Grand Traverse Band members. As stated earlier, this service

is well-utilized by the membership.

Further information on education and outreach efforts are included in Section 3.1.9.

GTB IWMP 20 Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

Surveillance & Control Program for Illegal Dumping

Policies regarding illegal dumping and littering are in place. which supports monitoring actions,

program enforcement, and program measurement. With these components in place. the

efficiency of the program is evident in the status of the low incident and infrequeney of

‘occurrence of open and illegal dumping sites.

Enforcement for Ilegal Dumping

The establishment of solid waste Tribal codes, ordinances, and regulations are the foundati

for enforcement actions against illegal dumping and set the stage for strong support from T

Council members. Beyond that, support is needed to remind Tribal members, visitors, and the

local community that illegal dumping is prohibited.

‘The Grand Traverse Band Tribe has implemented the following enforcement measures as

deterrents for illegal dumping:

© Post signs prohibiting illegal dumping at rural locations frequented in the past,

* Investigate reported or discovered dump sites by Tribal Game Wardens.

¢ Issue tickets for violators by Tribal Game Wardens, and

* Work with local and federal staff, as needed.

Community Survey

Information in regard to any known open dumps was requested in a community survey as part

of this report. Survey was conducted at the annual tribal Health Fair. August 2010. Of the

forty-seven completed surveys, no known open dumps on reservation land were reported.

Measurable Outcomes

‘The Grand Traverse Band Tribe utilizes the following methods to measure the effectiveness of

deterrents to illegal dumping:

© The lack of existing open or illegal dump sites

© The frequency of members reporting possible sites.

© The increase in annual Spring Clean up utilization,

* The increase in Tribal members routinely collecting metal serap, and

© The infrequency of new dump sites.

The Environmental Director will report the number of illegal dumping violations as well as any

illegal dump sites as well as the plan, budget, financing, and implementation of its subsequent

clean up in the EPA PPG progress report, under solid waste management.

3.1.3 Waste Collection, Transfer, and Disposal

GTB IWMP 21

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS.

EGRATED SOLID WASTE MANAGEMENT PLAN

Current Collection Systems

Residential Curbside Collection Is Provided Through Contracted Services: Home-owners

are responsible for placing their trash at curbside for waste collection on their assigned waste

collection days. Housing renters are responsible for placing their waste and recyclables in the

bins adjacent to their housing units. A contracted waste hauler (Kalchik’s Disposal Services)

collects and transports the waste to an appropriate disposal facility (Glen's Landfill) located off”

the reservation (in Traverse City, Michigan).

Commercial Collection Is Provided Through Contracted Services: Tribal governmental and

gaming entities (includes casinos, hotel, and the gas station) are responsible for disposing of

their waste in a waste collection containers. typically located adjacent to their building.

Contracted waste haulers (American Waste and Kalchik’s Disposal) collect and transport the

waste to an appropriate disposal facility (Glen’s Landfill) located off the reservation (in

Traverse City, Michigan).

Special Waste Collection

See s

ion 3.1.4 below.

Measurable Outcomes

As long as contractor fees remain acceptable, this is an acceptable and effective practice.

Current and predicted waste volumes do not warrant the construction of permanent structures,

such as Tribal transfer stations and landfills. ‘This status will be assessed and updated every five

years after the one year update.

3.1.4 Special and Hazardous Waste

Introduction

Wastes that require special handling or consideration when it enters the solid waste management

system are labeled special waste. These wastes may include, but are not limited to:

© Construction and Demolition (C&D) Debris

* Household Hazardous Waste (HHW)

* Electronic Wastes (E-Waste)

* Scrap Tires

* Medical/Infectious Wastes

Any other special wastes encountered on the Grand Traverse Band reservation are dealt with on

a case-by-case basis.

Construction and Demolition Waste

GTB IWMP.

Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS.

‘EGRATED SOLID WASTE MANAGEMENT PLAN

Introduction

Construction and demolition (C&D) debris is generated by the construction, demolition, and

renovation of existing structures, clearing of land, removal or construction of roads and utilities,

and other activities that produce bulky wastes. General characteristics, regulatory requirements,

landfill management options. and recycling opportunities for C&D debris differ from those for

MSW, and therefore, should be managed differently.

Some C&D debris may be classified as hazardous waste because it contains hazardous

materials, such as lead or chromium, or has been contaminated by other hazardous waste.

Hazardous C&D debris must be disposed of in a hazardous waste landfill. Other toxic

materials, such as asbestos and polychlorinated biphenyls (PCBs), must also be managed in

accordance with federal regulations, as spelled out by the Toxic Substances Control Act

(TSCA).

Sources and Composition

C&D debris is generated from a variety of construction and demolition activities. Sources and

representative composition are discussed in this subsection:

* Demolition Debris: Demolition debris is generated from demolishing buildings. other

structures, and roadways. Demolition material composition is similar to that of

construction debris. except that wall and other structural materials, such as concrete.

steel. and masonry. are present in larger quantities. Additional sources include materials

from foundations and other substructures when buildings are completely removed.

* Renovation Debris: Renovations generate a combination of materials from demolition

and removal activities and shipping cartons, scrap. and excess materials from

construction sites. Recycling of renovation debris has additional challenges because the

waste may be a combination of old materials and new scrap and waste materials that

require different recovery approaches. For example, painted lumber removed during

renovation may have to be managed differently than scrap from uncoated lumber used

for the construction phase.

* Construction Debris: Construction debris is discarded material generated from exterior

and interior construction. This waste includes packaging and containers that

‘manufacturers use to ship building materials, wood scraps, drywall, masonry. paint and

other coatings. roofing scrap, and numerous other materials. Table 5-1 presents a list of

typical construction debris materials.

Revised 02.

GTB IWMP.

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

‘Typical Construction Debris Materials

MATERIALS | CONTENT EXAMPLES

Wood Forming and framing lumber, stumps, plywood, and laminate

scraps

Gypsum Sheetrock, drywall. plaster

Metals Pipe, rebar, flashing, steel, aluminum, copper, brass, stainless

steel

Plasties Vinyl siding, doors, windows, floor tile, pipes

Roofing Asphalt and wood shingles, slate. tile, roofing felt

Inert Asphalt, concrete, cinder blocks, rock, earth

Brick Bricks and decorative blocks

Glass Windows, mirrors. lights

Mise, Carpeting, fixtures, insulation, ceramic tile, and paper

Source: http:/www.epa.gov website, 2004.

© Land Clearing Debris: Land clearing waste is generated by site clearing activities prior

to site work and construction of structures. ‘Trees, stumps, brush, soil, and rock, as well

as litter (i.e., tires, metal, and paper) may be on the site.

* Road Materials: Road demolition materials include asphalt, concrete. rock. and soil

generated by removal of roadways, curbs. gutters, and sidewalks, or waste generated by

construction of similar improvements. Materials generated by these types of projects are

fewer in number but they are heavier.

C&D Existing Practices

Factors affecting quantities of debris generated, collected, and disposed of include the type of

nstruction (i... office buildings. recreational facilities. and housing) and the type of project

(.c., new construction, remodeling, renovation, road repair).

Generation

C&D debris is generated from a variety of construction and demolition activities. Sources and

representative composition are discussed in this subsection. Depending on the type and amount

of activities occurring on a reservation. the amount of C&D debris generated can vary greatly

Small quantities of C&D debris are generated on the reservation. Small quantities of C&D

debris are generated on the reservation, All C&D debris are generated by contractors. The

Tribal Corporate Architect provides direction and oversight of the contractors’ methods and

efficiency. It is Tribal policy to protect the environment and at the same time minimize costs

associated with C&D activities, so itis policy to meticulously liquidate everything, from

furnishings, materials, to serap.

Projects that have occurred over the last few years include a new casino, new hotel, hotel

renovations, hotel demolition, and a casino demolition. There are on average four projects a

GTB IWMP 24 Revised 02-28-11

GRAND TRAVERSE BAND OF OTTAWA & CHIPPEWA INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN

year, Future projects under consideration include new Tribal Member housing development,

new Natural Resources storage and work facility, and Tribal Member housing renovations.

Collection

A Variety of practices exist for the collection of C&D debris. In general, contractors perform

the majority of construction, demolition, and renovation activities.

Contractors are responsible for providing their own containers. In general, construction

contractors generating C&D debris provide their own containers. The material is typically

collected in open-top roll-off containers. Normally, roll-off containers are 20-, 30-, and 40-

cubic yard units.

Disposal

Managing C&D debris is the responsibility of the Corporate Architect.

All C&D debris is taken off the reservation: Tribal members and contractors must transport

all C&D debris off the reservation for disposal at area landfills.

Contracted Services

Many Tribes choose to use private contractors for the disposal C&D debris due to the materials’

size and weight. Other Tribes having proper equipment and facilities often use their own Tribal

members for disposal services. The Grand Traverse Band utilizes private contractors.

On-Call Services and Agreements: Various haulers perform C&D debris collection on the

reservation. Contracts are set up on an as-needed basis. The cost for the service varies and is

competitive. Terms of the contract vary based on the complexity and size of the job.

Contract Surveillance

Contract surveillance is crucial to making sure the contractor is adhering to the contracts for

services preformed.

Have Contract Surveillance: The Tribal Corporate Architect oversees and monitors the

performance and adherence of the contractor to the C&D debris contract.

DIVERSION STRATEGIES

Diversion strategies vary depending on the method of recovery (manual or mechanized) and the

level of sorting of the material.

The Contractor is Responsible for the Method of the Diversion Activities: The Tribal

Corporate Architect oversees and directs the efficiency and safety of the contractor.

GTB IWMP 25 Revised 02-28-11

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