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

michael.baca1@state.nm.us

OR

www.nmenv.state.nm.us/aqb