Current through Register Vol. 35, No. 18, September 24, 2024
This procedures manual, developed by the emergency management
task force, is a guide for use by responsible state emergency response
personnel in managing, coordinating, and controlling a hazardous materials
accident. It defines procedures to be followed for central and on-scene
coordination by all state emergency response agencies. It is organized largely
by function and includes sections for carrier representatives and the first
responder.
A.
Notification: Notification procedures are outlined in the Emergency
Management Act and detailed here. They rely heavily on the two statewide
communications systems operated by the New Mexico state police and the
communications division of the general services department. Procedures:
(1) Driver shall notify nearest New Mexico
state police district office.
(2)
First responder shall notify nearest New Mexico state police district emergency
response officer or Santa Fe control, communications division of the general
services department.
(3) State
police district emergency response officer or Santa Fe control shall notify
state police emergency response officer in Santa Fe.
(4) State police emergency response officer
shall notify for: agency, telephone, 24-hour:
(a) radioactive materials; radiation
protection bureau.
(b) other
hazardous materials; ground water quality and hazardous waste bureau.
(c) fire or flammable materials; state fire
marshal.
(d) injuries or
casualties; emergency medical services bureau.
(e) further identification of materials
involved in accident; carrier, shipper.
(5) When other emergency functions are
required, the state police emergency response officer shall notify:
(a) air transportation (types of aircraft
listed under resources); agency: aviation division; state corporation
commission; eastern New Mexico university; energy and minerals department;
forestry division; game and fish department; highway department; New Mexico
state university; state police;
(b)
evacuation of residents; agency: civil emergency preparedness division;
national guard; state school superintendent;
(c) evacuation of bedridden persons; agency:
emergency medical services bureau;
(d) warning, traffic and crowd control, and
law enforcement; agency: New Mexico state police;
(e) sanitation, public works, road closure,
and alternate routes; agency: highway department;
(f) public health, environment monitoring,
decontamination, and cleanup supervision; agency: radiation protection bureau;
ground water quality and hazardous waste bureau;
(g) social services; agency: civil emergency
preparedness division;
(h) backup
support; agency: federal emergency management agency (region VI, Denton, TX);
joint nuclear accident coordinating center (Albuquerque); U.S. environmental
protection agency (national response center).
B.
Carrier representative: The
driver or carrier representative shall notify the nearest state police
headquarters and perform protective actions only to the extent that his/her
knowledge and capability permit.
(1)
Notification: Notify the nearest state police headquarters; advise them of the
accident; provide as much information as possible.
(2) Protective actions:
(a) Set out reflective warning
devices.
(b) If instrumentation or
other monitoring devices are provided by carrier, take readings/measurements to
determine if there is a possibility of a release of materials.
(c) If there is a manageable fire, attempt to
extinguish it.
(d) Isolate accident
scene as much as possible to avoid possible exposure to general public and
others involved in the accident.
(e) Aid first responder and emergency
response personnel as requested.
(f) If a release of materials has occurred,
request contamination check from personnel on-scene.
(g) Provide appropriate resources for the
resolution of the incident, including cleanup. If a release of hazardous
materials has occurred, repackage and dispose of the spilled material and any
contaminated material.
C.
First responder: "First
responder" means the first law enforcement officer or other public service
provider with a radio-equipped vehicle to arrive at the scene of a hazardous
materials accident.
(1) Notification:
(a) Notify and maintain communication with
the nearest state police district office or communications division.
(b) If applicable, follow all notification
procedures required by your departmental procedures.
(2) Protective actions:
(a) render any life saving assistance
necessary;
(b) wear protective
clothing, if available;
(c)
establish 2,000 ft hazard perimeter to avoid possible exposure to general
public;
(d) identify all persons
who may have been exposed to a possible release of hazardous
materials;
(e) obtain shipping
papers, manifest, and any other information available from the
driver;
(f) provide all information
requested through the communications channel;
(g) follow all instructions received through
the communications channel;
(h) aid
emergency response expertise as they arrive on the scene;
(i) if a release of material has occurred,
request a contamination check from the experts on site for yourself and all
persons who may have been exposed to the hazardous material.
D.
Accident
assessment: The Emergency Management Act directs the state police
emergency response center to evaluate and determine the scope of the accident
based on information provided by the first responder. Responsible state
agencies advise state police and travel to scene as needed.
(1) The first responder shall establish
communication with the New Mexico state police in Santa Fe through the New
Mexico state police district emergency response officer, and maintain this
communication until sufficient information is received to make an initial
assessment:
(a) location of
accident;
(b) type of hazardous
materials involved;
(c) personal
injuries;
(d) accident
description;
(e) package
conditions;
(f) weather conditions;
and
(g) readings taken with carrier
instruments, if available.
(2) The New Mexico state police in Santa Fe
will contact and relay information to appropriate emergency response agencies:
(a) radiation protection bureau: radioactive
materials;
(b) ground water quality
and hazardous waste bureau: hazardous substances;
(c) state fire marshal: fire or flammable
materials; and
(d) emergency
medical services bureau: injuries or casualties.
(3) Responsible state agencies will advise
New Mexico state police in Santa Fe of:
(a)
protective measures to be taken in approaching the accident scene for
lifesaving measures or information gathering;
(b) advisability of moving or separating
various types of hazardous materials;
(c) protection of materials from the
elements;
(d) primary containment
methods;
(e) establishment of the
appropriate perimeter to isolate the scene; and
(f) security of the perimeter until expertise
arrives.
(4) The New
Mexico state police district emergency response officer, will relay all
information from state police headquarters to the first responder.
(5) Responsible state agency will maintain
contact with state police emergency response officer and:
(a) advise as to additional expertise
required at the scene;
(b) advise
as to resources required at the scene; and
(c) estimated time of arrival at the
scene.
(6) Responsible
state agency will prepare to travel to the scene and:
(a) assemble appropriate instrumentation for
the circumstances; and
(b) if
communication en route is not possible, notify alternate to maintain
communication with state police emergency response officer to advise if
conditions change.
E.
Central coordination:
According to the Emergency Management Act, central coordination is the
responsibility of the chief of the New Mexico state police. The chief
designates emergency response officers who are trained in emergency management
and coordination of responsible state agencies during a hazardous material
accident. The emergency response officer on duty at Santa Fe headquarters
serves as central coordinator.
(1) maintain
contact with first responder and instruct first responder on how to proceed at
the accident scene;
(2) record all
initial information and any changes in accident characteristics;
(3) establish and maintain contact with
responsible state agency representative having expertise relevant to accident
characteristics;
(4) report all
information received from first responder to responsible state agency
representative;
(5) relay all
instructions from responsible state agency representative to first responder
and on-scene coordinator;
(6)
maintain communications with the scene at all times to relay requests for
additional expertise, personnel, or equipment;
(7) log all communications;
(8) make arrangements to acquire state-owned
air transportation if circumstances warrant;
(9) collect information or establish contact
with persons who can readily provide information on the area surrounding the
accident:
(a) population affected;
(b) environmental conditions, e.g.,
rural/urban, agricultural, recreational, etc.;
(c) accessibility of site for communications
and emergency response personnel;
(d) accessibility of site to general
public;
(e) alternate routes
available to traveling public; and
(f) canals, storm drains, surface water, and
groundwater sources.
F.
On-scene coordination:
On-scene coordination encompasses the responsibilities of the on-scene
coordinator and the operations officer. The on-scene coordinator is responsible
for the management of the accident and delegation of responsibility to
qualified field personnel. The on-scene coordinator is also responsible for all
protective actions prior to the arrival of experts. The operations officer is
designated by the on-scene coordinator and is the individual with appropriate
expertise to properly handle the immediate threat to health and safety of the
citizen of the state.
(1) Establish and
maintain communication with state police emergency response officer in Santa
Fe.
(2) The New Mexico state police
district emergency response designee will establish an on-scene command post in
a radio-equipped vehicle or facility, and assume the duties of on-scene
coordinator.
(3) Designate trained
command post staff personnel to assume the following duties:
(a) operations officer;
(b) logistics officer;
(c) plans officer;
(d) law enforcement coordinator;
(e) information officer;
(f) communications officer;
(g) any other staff position that may be
required to properly coordinate the operation.
(4) Schedule briefings for all field
personnel as they arrive on-scene.
(5) Direct all representatives of responsible
state agencies to maintain contact with the command post, act as advisors to
the on-scene coordinator, and direct the activities of field
personnel.
(6) Direct all emergency
response personnel at the scene to maintain contact with the representative of
the responsible state agency whose expertise is compatible with their
own.
(7) Establish one to three
perimeters, depending on the circumstances:
(a) hazard perimeter: distance specified by
the on-scene coordinator:
(i) no access
without authorization;
(ii) no
access without appropriate protective clothing;
(iii) no access without proper personnel
monitoring equipment;
(iv) time
records to be kept on all personnel entering the hazard perimeter - time in and
time out;
(v) no personnel will
remain inside this perimeter beyond the time specified by the on-scene
coordinator; and
(vi) personnel not
leaving this perimeter within a specified time will be presumed to be a
casualty and rescue operations will be initiated.
(b) resource perimeter: buffer perimeter and
holding area for personnel and equipment to relieve those within the hazard
perimeter:
(i) safe distance from hazard
perimeter to minimize exposure from released materials;
(ii) backup resources on standby within this
perimeter;
(iii) no eating,
drinking or smoking within this perimeter; and
(iv) decontamination prior to leaving
perimeter.
(c) command
and support perimeter:
(i) clearly marked
command post with expert representatives from all responsible state agencies
required at the scene;
(ii) records
to be kept by all on-scene expertise as to communications between emergency
response personnel in the field, on-scene coordinator and New Mexico state
police emergency response officer in Santa Fe;
(iii) on-scene spokesman for liaison with
media and local government;
(iv)
emergency medical center, if required;
(v) sanitation facilities for extended
response;
(vi) check point for all
personnel to be checked for need for decontamination; and
(vii) law enforcement security of all
accesses into and out of this perimeter. All access must be authorized by the
command post.
(8) Designate record keeper for each
perimeter to check personnel into and out of the perimeter and advise on:
(a) eating, drinking and smoking;
(b) maximum time allowable within each
perimeter;
(c) types of protective
clothing required within each perimeter;
(d) need for exposure check on leaving
perimeter, and;
(e) directions to
decontamination area and systems to be used.
(9) Designate recordkeeper to document how
the accident is proceeding and record what actions are being taken.
(10) Obtain information on surrounding area:
(a) population affected;
(b) environmental conditions;
(c) accessibility of site for communications
and emergency response personnel;
(d) accessibility of site to general
public;
(e) alternate routes
available to traveling public;
(f)
canals, storm drains, surface water, and ground water sources; and
(g) meteorological information.
(11) Monitor any changes in
accident characteristics and evaluate threat to emergency response personnel,
traveling public, and nearby residents.
(12) Relocate perimeters based on evaluation
of changing characteristics.
(13)
Request additional local, state or federal expertise based on evaluation of
changing characteristics.
(14) If
required, set up decontamination station. (see decontamination.)
G.
Operations
officer: The operation officer designated by the on-scene coordinator is
the individual with appropriate expertise to properly handle the immediate
threat to health and safety of the citizens of the state.
(1) Provide instructions to the scene through
established communications channel.
(2) From information received through
communications channel, select appropriate equipment and arrange travel to the
scene.
(3) If communication during
travel is not possible, appoint a representative at the scene to maintain
communications and advise Santa Fe control of changing conditions.
(4) On arriving at scene, wear appropriate
protective clothing if necessary.
(5) Render any lifesaving assistance
necessary.
(6) Obtain all
information available at the scene by personal observation, and from first
responder, driver, etc.
(7)
Determine if there has been a release of hazardous material and if so, take
appropriate actions as follows:
(a) Airborne
release:
(i) evacuate the immediate
vicinity;
(ii) keep all persons
upwind of the release;
(iii) take
air samples for laboratory analysis when possible;
(iv) control all food and drinks in the area
which might have been contaminated; and
(v) use respirators when necessary.
(b) Surface water contamination:
(i) isolate area; do not allow public
access;
(ii) determine if water is
used as a potable water source and prohibit human consumption; and
(iii) obtain appropriate samples for
laboratory analysis.
(c)
Land spill:
(i) isolate the incident area from
public access;
(ii) confine the
spill to as small an area as possible;
(iii) monitor the area; and
(iv) obtain laboratory samples.
(8) Provide technical
assistance to other emergency response personnel on-scene such as law
enforcement, firefighters, medical personnel, and rescue teams.
(9) Conduct exposure and contamination
surveys and record this information.
(10) Supervise hazardous materials recovery;
supply technical support needed by industry or recovery team.
(11) Provide technical information to
appropriate media and authorities as per procedure.
H.
Public information: Accurate
public information is a vital part of any emergency response effort, both to
keep the public informed of a possible danger and to apprise the public of the
need for a possible isolation or evacuation of an area. This section sets forth
procedures for releasing information to the public and also contains some
sample press releases that can be used as a pattern to advise the public of an
accident. Procedures:
(1) A spokesperson will
be designated by the on-scene coordinator. Information will be released by and
through this spokesperson only.
(2)
The spokesperson shall gather information from the various agencies with
expertise on the scene and condense it to a single public
announcement.
(3) Information
released to the public must be approved by the on-scene coordinator.
(4) All information releases will be relayed
to a representative of the governor prior to release.
(5) The command center spokesperson will
request the appointment of a counterpart from the local jurisdiction in which
the accident occurred. This spokesperson may be an elected official, a law
enforcement officer, a civil defense coordinator, etc.
(6) The command center spokesperson shall
periodically give updated material to the media and the local
representative.
(7) Information
releases may be written or oral, at the discretion of the on-scene
coordinator.
(8) Information
regarding a danger to evacuation of citizens in the immediate area of the
accident shall be released immediately to:
(a)
the media;
(b) local government
representative; and
(c) local civil
defense coordinator.
(9)
In the event of evacuation, the local government representative and the civil
defense coordinator shall warn:
(a) all
citizens in the area, by means of the media or house-to-house notification by
law enforcement officers, firefighters, civil defense personnel, volunteers,
etc. not actively engaged in the emergency operation; and
(b) the local civil defense coordinator,
local school superintendent and local national guard unit to provide
transportation and social services for the evacuees.
(10) Sample press release: An accident
involving a_________(truck, train, airplane) carrying ___________(material)
occurred near/at ____________(location) at ______________(time/date).
(a) Option No. 1 The state emergency response
team has been dispatched to the scene. Initial reports from the scene indicate
that no release of material occurred. However, it is advisable for motorists to
avoid this area until a full assessment has been made by the response
team.
(b) Option No. 2 The state
emergency response team has been dispatched to the scene. Initial reports from
the scene indicate that a release of material may have occurred. It is
advisable to remain clear of this area until a more complete assessment has
been made.
(c) Option No. 3 The
accident is accompanied by a fire which could result in a breach of packaging
and a release of materials into the atmosphere. The state emergency response
team has been dispatched to the scene for a more thorough assessment. It is
advisable to remain clear of this area until this assessment has been
completed.
(d) Option No. 4
Officials at the scene have measured the amount of material released and report
an insufficient quantity of material to cause any hazard to the
public.
(e) Option No. 5 Officials
at the scene report a release of___________(material) in the form of
______________ (smoke, dust, runoff, etc.). This material is traveling (N, S,
E, W) and can result in_____________(skin irritation, breathing difficulty,
etc.) on contact. If you have come in contact with this material, officials
advise you to report to___________________________ (location of triage or
emergency room) for observation.
(f) Option # 6 Officials at the scene report
a release of material in sufficient quantity to pose a threat to persons within
a______________ (distance in feet, blocks, miles, etc.) radius of the accident.
Anyone within this area is instructed to report immediately to
______________(location of nearest civil defense shelter or school).
I.
Protective
actions: Protective actions are included in the areas of: emergency
medical services, firefighting, law enforcement, public works and sanitation,
transportation, evacuation, environmental monitoring, decontamination and
exposure control. Protective actions should be executed only after determining
that such actions will not endanger personal life or safety. Do not become a
casualty.
(1) Emergency medical services:
(a) Designate a representative to maintain
communication with the command post to advise the on-scene coordinator and
direct the activities of personnel providing emergency response
services.
(b) Render life saving
assistance as needed.
(c) Wrap the
victim and all clothing and the pillow on the stretcher with a blanket to
prevent spread of contamination.
(d) Provide available contamination
information to the appropriate hospital by radio or telephone.
(e) Save all contaminated and possibly
contaminated materials in plastic containers.
(f) When external contamination is
complicated by a wound, take care not to cross-contaminate the wound from
surrounding surfaces, and vice versa.
(g) All personnel and equipment should be
surveyed by an EID representative for contamination prior to being released
from emergency service.
(2) Firefighting:
(a) Designate a representative to maintain
communication with the command post, offer expertise to the on-scene
coordinator, and direct the actions of all firefighters engaged in emergency
response activities.
(b) Render any
life saving assistance necessary.
(c) If appropriate, extinguish the fire as
quickly as possible.
(d) Do not
move or remove any radioactive materials without the consent of the on-scene
coordinator.
(e) Restrict personnel
exposure as much as possible.
(f)
Wear protective clothing designated by the on-scene coordinator.
(g) Work upwind from the fire, keep out of
smoke as much as possible.
(h)
Assure that all personnel and equipment is monitored for possible contamination
prior to leaving the scene.
(3) Law enforcement:
(a) Perform rescue and first aid.
(b) Notify the nearest state police district
headquarters and maintain communication.
(c) Isolate the accident area. A distance of
2000 feet is recommended unless other instructions are received through
communications channel.
(d)
Restrict access to the accident area.
(e) Do not move packages, shipping containers
or wreckage unless it is necessary to rescue people.
(f) Detour vehicles and pedestrians, if
necessary. Move wreckage the shortest distance possible to clear a traffic
path.
(g) In case of fire, keep
everyone upwind of smoke and dust.
(h) A designated law enforcement
representative will remain at the command post to offer expertise to the
on-scene coordinator and direct the actions of all law enforcement personnel
engaged in emergency response activities.
(i) At the direction of the on-scene
coordinator, provide the following:
(i)
radio-equipped vehicle to maintain communication with central
coordinator;
(ii) traffic
control;
(iii) crowd control;
and
(iv) security of perimeter
(established by on-scene coordinator).
(j) If evacuation of residents is required,
provide civil emergency preparedness division with the following:
(i) vehicles with public address capability
to patrol the area to be evacuated.
(ii) personnel to perform house-to-house
notification, and
(iii) security
for the evacuated area.
(4) Public works and sanitation:
(a) The highway department shall be
responsible for providing sanitation services at the scene, road closure, and
designation of alternative routes for the traveling public.
(b) Designate a representative to maintain
communication with the command post to advise the on-scene coordinator and
direct the activities of emergency response personnel.
(c) At the direction of the on-scene
coordinator, move debris to provide access to traffic paths.
(d) At the direction of the on-scene
coordinator, provide heavy equipment and operators to aid in containing runoff
or spills by trenching and diking.
(5) Transportation:
(a) The New Mexico state police and highway
department shall be responsible for transportation of emergency response
personnel to the scene of an accident if necessary.
(b) Locate available state-owned aircraft for
transporting emergency response personnel and equipment to the scene, if
urgency is a factor (through New Mexico state police).
(c) Locate any state-owned or contracted mass
transportation vehicles for evacuation of residents (through civil emergency
preparedness division).
(d)
Designate alternate routes for traveling public (through state highway
department).
(e) Set up road blocks
to divert traffic from the accident area (through state highway
department).
(6)
Evacuation:
(a) The civil emergency
preparedness division of the office of military affairs shall be responsible
for warning nearby residents, evacuation and social services.
(b) Designate a representative to maintain
communication with the command post to advise the on-scene coordinator and
direct the activities of personnel in the field.
(c) Use all available resources and personnel
at the scene and in nearby communities to inform the public of the areas which
are to be evacuated. Resources are as follows:
(i) command post spokesperson;
(ii) media;
(iii) local civil defense
coordinators;
(iv) law enforcement
officers not actively engaged in emergency response activities; and
(v) firefighters not actively engaged in
emergency response.
(d)
Use all equipment available at the scene and nearby communities:
(i) civil defense warning systems;
(ii) law enforcement vehicles equipped with
public address systems; and
(iii)
personnel for house-to-house notification.
(e) Designate specific areas as temporary
shelters and assign representatives to register all people checking into the
following shelters:
(i) civil defense
shelters;
(ii) public buildings;
and
(iii) school gymnasiums and
cafeterias.
(f) Provide
mass transportation:
(i) national guard
vehicles; and
(ii) school
buses.
(g) Designate
gathering areas for mass transportation connections.
(h) Use all available local, state and
federal resources to provide temporary social services, including shelter, food
and medical care.
(7)
Environmental monitoring: The environmental improvement division will conduct
environmental monitoring of:
(a) hazardous
materials, including air, water, soil, livestock and vegetation.
(b) firefighting, washdowns, or runoffs,
including natural water paths, culverts, storm drains and surface
waters.
(8)
Decontamination:
(a) The on-scene coordinator
shall be responsible for establishing a decontamination station with the
assistance of EID.
(b) If required,
set up decontamination station. A decontamination station consists of the
following:
(i) change room;
(ii) wash-down procedures;
(iii) paper clothes;
(iv) plastic bags for contaminated
clothing;
(v) decontamination
equipment required;
(vi) personal
showers;
(vii) scrub-down shuffle
boxes;
(viii) changing of SCBA
tanks;
(ix) location of monitoring
equipment;
(x) street
clothes;
(xi) replacements for
damaged or contaminated clothing;
(xii) respirator replacement
cartridges;
(xiii) backup
personnel;
(xiv) communication with
personnel on-scene;
(xv) garbage
cans; and
(xvi) rest area, with
stool for those in protective clothing.
(9) Exposure control:
(a) Keep all persons a safe distance from the
accident area until the extent of the hazard is determined. Suggested distance
is 2,000 feet.
(b) After initial
notification, environmental improvement division (EID) designee will maintain
constant communication with the scene and provide technical expertise to all
responsible state agencies at the scene and to the on-scene coordinator. In
addition, the EID designee will carry out or assist with accident assessment,
protective actions, and exposure control procedures.
(c) Prior to entering an accident area where
there is a release or suspected release of hazardous material, EID will provide
safety requirements for performing:
(i)
accident assessment;
(ii) control
and containment;
(iii)
decontamination; and
(iv)
cleanup.
(d) Avoid
exposure to smoke, dust, mists, liquids, or any other suspicious
material.
(e) All emergency
response personnel will leave the scene through designated checkpoints. This
will assure appropriate monitoring and decontamination of all
personnel.
(f) If the situation
warrants, all personnel leaving the scene will be instructed on decontamination
procedures and location of equipment available for decontamination.
(i) clothing: remove and place in plastic
bags;
(ii) equipment: do not remove
beyond resource perimeter;
(iii)
skin and hair: wash thoroughly with water and soap or detergent;
(iv) eyes, ears, mouth and nose: flush with
large amounts of water - distilled water if available.
(g) Logs will be maintained at the hazardous
perimeter check point an all personnel entering and leaving the hazard
area.
(h) Logs will be maintained
at the decontamination center on all emergency response personnel and
procedures used.
(i) Logs will be
maintained at the medical facility of all persons treated, reason for
treatment, and disposition.
(j) If
radioactive materials are involved, personal dosimeters will be made available
through the RPB personnel on scene.
(k) Designated personnel from responsible
state agencies will provide HMER administrator with current medical examination
results. Medical records will be updated annually.
(l) Until assessment has been made, the
following protective clothing is recommended inside the hazard area:
(i) pressure-demand, self-contained breathing
apparatus;
(ii) chemical resistant
clothing (overalls and long-sleeved jackets; coveralls; hooded, one or two
piece chemical splash suit; disposable chemical resistant coveralls);
(iii) chemical resistant gloves;
(iv) chemical resistant boots (steel toe and
shank);
(v) hard hat or face
shield;
(vi) 2-way radio
(intrinsically safe).
J. Postaccident: In addition to supervision
of cleanup, a responsibility of the environmental improvement division, the
Emergency Management Act places postaccident responsibility with industry and
the safety board.
(1) Cleanup:
(a) Hazardous materials owners, shippers and
carriers shall be responsible for cleanup of a spill of hazardous
materials.
(b) The environmental
improvement division shall supervise industry cleanup operations and determine
at what point the accident scene is restored to the satisfaction of the
state.
(2) Accident
Review:
(a) Safety board reviews all hazardous
materials accidents in which the state emergency response plan is
used.
(b) The review:
(i) assesses the performance of emergency
response personnel; and
(ii)
determines cause of accident.
(c) The accident review process includes:
(i) assessing performance of all responsible
state agencies;
(ii) documenting
all agencies' activities; and
(iii)
completing summary review report.
(d) The results of the review shall be sent
to:
(i) responsible state agencies;
(ii) state corporation commission;
(iii) EID legal counsel; and
(iv) affected local jurisdiction.