Final
January
10,
2005
Page
1
of
2
Pages
White
Paper
#
3:
What
Constitutes
a
Good
Natural
Events
Action
Plan
(
NEAP)?

Date/
Status:
January
10,
2005,
Final
Background:
The
Natural
Events
Policy
(
NEP)
was
developed
in
1996
to
establish
EPA
policy
for
protecting
public
health
in
areas
of
the
country
where
PM10
levels
exceed
the
National
Ambient
Air
Quality
Standards
(
NAAQS)
due
to
natural
environmental
conditions.
The
policy
identified
three
categories
of
natural
events:
(
1)
volcanic
and
seismic
activity,
(
2)
wildland
fires,
and
(
3)
high
winds.
These
categories
were
selected
to
address
those
environmental
conditions
that
are
not
controllable
and
have
historically
resulted
in
exceedances
of
the
PM10
standard.
The
NEP
allows
for
the
development
and
implementation
of
a
Natural
Events
Action
Plan
(
NEAP)
to
address
these
issues.
Colorado
has
recently
had
good
success
in
developing
these
NEAPs
and
in
getting
EPA's
concurrence.
This
White
Paper
was
developed
to
give
insight
into
this
process
and
provide
guidance
for
successful
NEAP
development.

Discussion:
Presently,
Colorado
has
in
place
two
NEAPs
for
high
winds
including
a
five­
year
revision
NEAP.
(
Colorado
is
currently
drafting
a
statewide
wildland
fires
NEAP
as
well.)
These
two
NEAPs
have
been
positively
received
by
the
regional
EPA
office
(
has
received
EPA
"
concurrence")
following
extensive
State­
EPA
and
State­
local
negotiations.
Colorado's
success
with
NEAP
development
falls
mainly
into
two
areas:
technical
documentation
and
local
support.

Technical
Documentation
Colorado's
current
success
in
preparing
NEAPs
relies
heavily
on
negotiations
conducted
early
on
with
EPA.
In
these
negotiations,
Colorado
eventually
identified
the
documentation
EPA
was
seeking
to
make
their
(
EPA)
determination
of
a
natural
event.
Today's
Colorado
NEAPs
include:
background
information
on
the
natural
event,
ambient
air
quality
data,
meteorological
data
which
support
the
uncontrollable
nature
of
the
event,
news
accounts
of
the
event,
laboratory
data,
and
other
supporting
materials
deemed
internally
important.
While
these
are
the
traditional
data
which
EPA
seek,
from
time
to
time
EPA
may
request
clarification
or
additional
technical
information.
The
Division
supplies
these
data
as
requested.

Local
Activities
The
support
of
local
agencies
has
also
been
critical
in
the
successful
development
of
Colorado's
NEAPs.
For
example,
the
state
relies
extensively
on
the
local
agencies
for
public
notification
and
public
education/
outreach.
Colorado's
most
recent
PM10
NEAP
included
approximately
twenty
two
separate
outreach
initiatives,
developed
in
concert
with
local
agencies.

In
addition,
local
decision
making
regarding
the
outreach
and
public
notification
has
been
paramount.
This
includes
recognizing
that
the
State
will
not
pose
additional
rules
Final
January
10,
2005
Page
2
of
2
Pages
on
the
local
governments
nor
will
we
"
override"
local
decisions
regarding
notification
(
those
locally
know
best
whether
public
notification
is
necessary
given
ambient
conditions).

Balanced
with
this
desire
to
keep
as
much
control
as
possible
in
the
hands
of
the
local
agencies,
Colorado
reminds
local
agencies
about
their
need/
desire
to
avoid
a
nonattainment
designation.
Often,
this
message
ensures
local
notification
and
outreach
efforts
are
sufficient,
especially
in
light
of
negotiated
State­
local
commitments
within
the
NEAP.
Also
within
this
effort
to
avoid
non­
attainment
and
while
often
not
required,
regular
updates
to
local
agencies
(
e.
g.,
city
councils,
county
commissions,
State­
level
Air
Commissions,
etc.)
better
guarantee
that
local
stakeholders
consistently
and
strongly
support
the
development
of
the
NEAP.

For
the
development
and
implementation
of
local
control
measures
(
BACM,
Best
Available
Control
Measures),
the
State
has
had
its
greatest
success
in
supporting
projects
that
are
already
in
place
or
on
the
near
horizon.
Asking
local
agencies
to
begin
entire
new
programs
or
invest
additional
resources
during
a
period
of
limited
budgets
is
difficult
at
best.
A
robust
NEAP
takes
as
much
credit
as
possible
for
ongoing
local
controls.

Finally,
NEAP
success
at
the
local
level
is
greatest
when
the
State
is
able
to
provide
resources
to
the
community.
Examples
of
such
resources
may
include,
but
are
not
limited
to:
technical
assistance,
"
lessons
learned"/
resources
for
public
education
and
notification
campaigns,
identification
of
potential
control
strategies
(
BACM),
financial
support
(
Colorado
has
a
Community­
Based
Environmental
Protection
grants
program
that
offers
funding
on
an
annual
basis
to
local
air
quality
agencies),
and
other
resources
as
identified
or
requested.

Recommendations:


States'
technical
staff
should
take
the
lead
in
negotiating
simple
and
initially
agreed
upon
processes
for
technical
documentation
of
natural/
uncontrollable
events.
This
would
include
an
agreement
on
the
standard
technical
documentation
that
is
warranted
for
an
event;


States
should
consider,
in
addition
to
the
State­
EPA
relationship,
the
activities
needed
at
the
local
level
including
steps
for
local
"
buy
in,"
needed
resources,
etc.


Public
notification
and
outreach/
education
should
provide
a
variety
of
options
for
local
agencies
to
consider
and
implement.


Treating
public
health
as
the
priority
within
the
NEAP
makes
clear
the
intent
of
the
plan
and
sets
a
path
toward
its
successful
development.

Task
Group
Members:
Mark
McMillan,
Colorado
DPH&
E 
Author
Ray
Mohr,
Colorado
DPH&
E 
Reviewer
