Natural Events Action Plan (NEAP) for Luna
County
Michael Baca
Environmental Analyst
Air Quality Bureau
Protecting our Environment, Preserving the Enchantment
PRESENTATION
History/DevelopmentNEAPLocal Ordinances
Why is Wind Blown Dust a Concern in Luna County? RECENTLY
The region has not met the federal standards for particulate matter of 10 microns or less (PM10)
DUST STORMS High winds cause unhealthful levels of
PM10 (dust) in ambient air
Air Quality in Deming & Luna County MOSTLY
Air Quality in Deming & Luna County is Very Good and Considered CLEAN
EXCEPT High Wind Days, DUST Levels May Exceed
Health Standards
HISTORY NONATTAINMENT
Tradition pollution control Designation to non-attainment list Permitting requirements for new sources County wide emission inventory of all
sources Transportation & general conformity Programs are costly
HISTORY NONATTAINMENT
NEGATIVELY VIEWED BY INDUSTRY AND RETIREES LOOKING AT LOCATING IN AREA
DIFFICULT TO BE RE-DESIGNATED INEFFECTIVE FOR DUST CAUSED BY HIGH
WINDS
HISTORY PM10 NAAQS EXCEDENCES SINCE 2003
EPA NATURAL EVENTS POLICY EPA Memo May 30, 1996 Natural High Wind Events Best Available Control Measures (BACM)/Reasonably
Available Control Measures (RACM)
CREATION OF LUNA NEAP Nonattainment vs. NEAP Primary Stakeholders-Citizens, Local Businesses & Govt. Secondary Stakeholders-Federal and State Agencies
Luna County NEAP PURPOSE
Protect Public Health and Welfare
KEY ELEMENTS Analysis & Documentation Public Notification & Education Minimize Public Exposure Abatement & Mitigation Periodic Review-Every Five Years
ANALYSIS & DOCUMENTATION CAUSAL RELATIONSHIP
Measured Exceedance & High Wind Event
MONITORING PM10 Monitor Weather Data Reporting (EPA)
PUBLIC ACCESS/REVIEW
PUBLIC EDUCATION & NOTIFICATION
HEALTH EFFECTS Short & Long Term Susceptible Populations
NATURAL EVENTS Affect Air Quality Imminent
ACTIONS Minimize Health Impacts Brochures, Fact Sheets, NEAP Briefing Document, etc Open Houses/Formal Presentations
MINIMIZE PUBLIC EXPOSURE PUBLIC EDUCATION
Common Sense Approach Windy Season-Late Winter & Early Spring Susceptible Populations & Precautionary
Measures Air Quality Index (AQI) & Perception of
Dustiness Press Releases & PSAs Internet: air.nmenv.state.nm.us
ABATEMENT & MITIGATION COMMON SOURCES/ACTIVITIES
Natural Undisturbed Desert (Highest Winds)
Anthropogenic (Man-Made) Construction Sites Vacant Lots/Recreational Areas Unpaved Roads, Playgrounds, Parking & Equipment
Lots Military Training Exercises
BACM Revegetation and Organic Mulches Erosion Control Mats & Geotextiles Suppressants and Stabilizers Smart Timing-Planning
ABATEMENT & MITIGATION LOCAL ORDINANCES
Stakeholders and Governments Best Equipped for Development & Implementation of
Solutions Deming Ordinance No. 1144 Luna County Ordinance No. 37 Protect and Maintain Natural Environment &
Reduce Negative Health Effects STAKEHOLDER AGREEMENTS
NMDOT State Land Office BLM NRCS Others
PERIODIC REVIEW-2009 ADEQUACY
Overview of Ordinances and Agreements CONCLUSIONS
Successful First Stage? Continued Enforcement Essential
FUTURE PLANS Improved Public Outreach & Education
(Pro-active) State Wide Regulations Improved Emissions Inventories
LOCAL ORDINANCES
Purpose and Intent Protect & Maintain Natural Environment Reduce Health Effects Prevent/Limit Man-made Dust Limit Sources Natural Events Will Happen
LOCAL ORDINANCES APPLICABILITY
Any: Activity, Equipment, Operation &/or Practice Man-made/caused Capable of Generating Fugitive Dust
EXEMPTIONS Agriculture: Regular Cultivating, Tilling,
Harvesting, Growing, etc. Excluding Unpaved Roads Used for Operations
Government Activity During Emergencies Essential Utility Services-Outages and
Emergencies (Electricity, Gas, H2O, Sewer, etc.) Temporary Use of Unpaved Roads (<20 trips/day
for 3 successive days)
LOCAL ORDINANCES CONTROL PLAN SUBMITTAL
Name(s), Address(es), and Phone #(s) of Person(s) Responsible for Plan
Plot Plan or Plat Including: Area of Surface to be Disturbed & Total Area
Operations & Activities Actual & Potential Sources Delivery, Transport, & Storage Areas-Type of
Material & Quantity RACM(s)-Every Source On-site Track Out & Sedimentation Control Contingency Measures
LOCAL ORDINANCES STANDARDS-GENERAL & NON-
CONSTRUCTION ACTIVITIES Ground Cover Removal Prohibited Vacant Land-Weed Eradication & Dust
Suppression Materials-Storage & Transport Parking Time Delay Agreements Unpaved Parking Lots and Roadways Existing Operations
LOCAL ORDINANCES REASONABLY AVAILABLE CONTROL
MEASURES (RACM’S) Utilize Existing, Pre-development Grades Watering: Regular & Minimum Basis Daily Palliatives or Chemical Soil Suppressant/Stabilizer Snow &/or Wind Fences Re-seeding or Re-vegetation Grading (Streets & Utilities)-Part of Subdivision
Construction Only Interior and Perimeter Walls as Part of Overall
Subdivision Construction
LOCAL ORDINANCES REASONABLY AVAILABLE CONTROL
MEASURES (RACM’S) Grade Pad Site, Pond, Driveway, etc. Only Plus
Five Feet Retain Natural Vegetation Utilize Existing or Natural Vegetation for Required
Landscape-Limit Grading, Promote H2O Conservation, & Reduce Dust
Non-natural Landscaping or Vegetation-Installed in Latter Phase of Construction
Any Other Methods Approved by Proper Authority Using Combination of RACM’s
FOR MORE INFORMATION
Michael BacaEnvironmental Analyst
NMED Air Quality Bureau(575) 524-6300
OR
www.nmenv.state.nm.us/aqb
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