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Community Comments Archive


Posted August 2, 2016

Donald Dayton
Carlsbad, New Mexico

Thank you for a copy of your Community Relations Plan. I am retired in Carlsbad after 30 years of federal employment in Environmental Management work with the U.S. Dept. of the Interior and the U.S. Department of Agriculture at various locations around the country. My last assignment was in Santa Fe, New Mexico.

After retirement, I volunteered to serve on the “Northern New Mexico Citizens’ Advisory Board to “Advise the DOE through a federally chartered formal recommendation process on environmental restoration (cleanup) and waste management activities at Los Alamos National Laboratory (LANL)  and the northern New Mexico communities impacted by LANL activities, (see attached). The Board was also provided with a trip to the WIPP site, a tour underground and discussion with the WIPP environmental management. I found my two year assignment on this Committee to be very successful in providing community input from the various communities impacted by LANL activities.

I urge that you set up a similar Citizen’s Advisory Board with members representing local communities surrounding and impacted by WIPP. In the long run, it can prove to be very valuable and provide a positive impact on your community relations program.

I agree to having my comments and suggestions posted on the WIPP Community Relations Plan Web Page.

Attachment:

               

Posted August 2, 2016

            Permittees Response to Comments from
            Donald Dayton
            Carlsbad, New Mexico

 Dear Mr. Dayton,

Thank you for your interest in the Waste Isolation Pilot Plant (WIPP) and for providing comments to the WIPP Hazardous Waste Facility Permit Community Relations Plan. The        purpose of the Community Relations Plan is to offer background information about the WIPP Permit, updates on Permit actions and opportunities for public participation in the Permit process.

With regard to your interest in establishing a WIPP Citizens Advisory Board (CAB), the Permittees will certainly consider how a CAB might add value to WIPP. Through the    years the WIPP Project has developed valued relations with state and local stakeholders and actively supports public participation opportunities. In addition to regulators, the   New Mexico Environment Department and the U.S. Environmental Protection Agency, there are numerous autonomous agencies and organizations that review WIPP   operations for safety and compliance. 

We welcome your participation in the WIPP Hazardous Waste Facility Permit process and encourage you to sign up for the WIPP facility mailing list to receive notifications of  Permit actions and public meetings. You may also call the toll-free Community Relations number at 1-866-271-9640 for more information.   

Thank you for taking the time to provide comments. 

 

Posted May 24, 2015

Lisa Chappa

I saw in yesterday's paper that you are accepting ideas on how to improve the community relations for WIPP. I would suggest that it should be a goal for the NWP to have everyone in the community have a basic understanding of what WIPP is and how it works. This will avoid any spreading of rumors and reduce any fears.

Perhaps a WIPP month would work, or you could spread it out over the year. But concentrating efforts in one month would encourage families and friends to talk about it at dinner tables and around town. get WIPP people out into the community in a united effort in one month of the year.

For students I suggest a WIPP week. Similar to Engineer's week or Math awareness month, WIPP would visit local schools and offer a hands-on curriculum for students that week. Engineer's week also has a girl day which I think is a nice component. No need to rebuild the wheel, just use their model.

You could also work with local scout groups, after school science programs, and the Boys and Girls club to offer curriculum like games which relate to nuclear power and waste which could just be incorporated into their activities. Bring in people from the National Museum of Nuclear Science to do assemblies or run an evening family science night for the community. You could even sponsor or lead a summer camp!

Some possible curriculum is here:
Exothermic Reactions:
http://www.inquiryinaction.org/classroomactivities/activity.php?id=26
What to do with Waste:
http://www.kineticcity.com/controlcar/activity_print.php?activity=2&bid=51
Model a nuclear Plant:
http://www.charlesedisonfund.org/Experiments/Edison-pdf/edison_ch8.pdf

In this same month, also attend adult groups like Rotary, Lions, Christian Women's Club, and clubs at the college. Bring activities, show power points about how things work, and be available to answer questions. Maybe you could even host a movie at the end of the month. Perhaps this could be done in collaboration with the college or the Cave and Karst institute.

I believe that if you make educating the community a goal, you will find many opportunities to do that in a fun and positive manner. This will certainly improve the community relations and benefit the community in the process. Kids will be proud that their parents work at WIPP, young people will look for education that will allow them to find jobs there, and the community in general will be more likely to embrace WIPP, even in hard times.

Thank you for the opportunity to share my opinions, Lisa Chappa

-- “Be the change you want to see in the world.” -Mahatma Gandhi

Posted September 17,2015

Permittees’ Response to Comments from
Lisa Chappa
Carlsbad, NM

Ms. Chappa,

Thank you for taking the time to submit comments to the Waste Isolation Pilot Plant (WIPP) Hazardous Waste Facility Permit Community Relations Plan. Your positive comments and ideas for community outreach have been forwarded to the U.S. Department of Energy’s Carlsbad Field Office Public Affairs representative and Nuclear Waste Partnership’s Communications Department for outreach planning purposes.

The purpose of the WIPP Hazardous Waste Facility Permit Community Relations Plan is to make Permit-related information available to members of the public and to encourage public participation in the Permit process. The Plan (www.wipp.energy.gov/WIPPCommunityRelations/index.html) offers a number of opportunities for the public to become involved in the WIPP Hazardous Waste Facility Permit process.
We encourage your participation in WIPP Hazardous Waste Facility Permit regulatory process.

Again, thank you for your comments and your interest in the Waste Isolation Pilot Plant.


Posted May 28, 2014

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1: Southwest Research and Information Center (SRIC) continues to support the Permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

2. SRIC appreciates that comments and responses are posted under the “Comments” tab.

3. SRIC is concerned that the August 9, 2012 Response to SRIC’s comment about public involvement was not incorporated into the Plan.

The Response was: The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.

However, Plan section 3.7 does not have that language, nor any other discussion of the “meetings that are not required by the Permit.” Nor does the Plan contain the link to drafts of Permit modifications.

SRIC supports including the additional language stated in the August 9, 2012 Response into the Plan. SRIC supports continuing the “meetings that are not required by the Permit” and the posting on the WIPP webpage of review drafts of Permit modifications.

4. SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only
with their consent, which could be given in a similar way to that done with individual comments.

5. SRIC agrees that these comments and the responses should be posted on the Community Relations Plan “Comments” tab.

6. I am glad to discuss any of these comments or other comments

Posted May 28, 2014

Permittees’ Response to Comments from
Don Hancock
Southwest Research and Information Center
Albuquerque, New Mexico

Mr. Hancock,

Thank you for taking the time to provide comments for improvement of the WIPP Hazardous Waste Facility Permit (HWFP) Community Relations Plan. The Permittees have addressed only comments that require a response. Responses for Comments 1, 3 and 4 are as follows:


Comment 1: Southwest Research and Information Center (SRIC) continues to support the Permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

Response 1: No comments were received objecting to Plan changes proposed by the Permittees. The following 2013 proposed changes by the Permittees will be incorporated into the on-line Community Relations Plan:


Comment 3: SRIC is concerned that the August 9, 2012 Response to SRIC’s comment about public involvement was not incorporated into the Plan.

The Response was: The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.

However, Plan section 3.7 does not have that language, nor any other discussion of the “meetings that are not required by the Permit.” Nor does the Plan contain the link to drafts of Permit modifications.
SRIC supports including the additional language stated in the August 9, 2012 Response into the Plan. SRIC supports continuing the “meetings that are not required by the Permit” and the posting on the WIPP webpage of review drafts of Permit modifications.

Response 3: 40 CFR 270.42 requires that public meetings “must be held to the extent practicable in the vicinity of the permitted facility” for Class 2 and Class 3 Permit Modification Requests. The Permittees consistently meet this requirement by holding public meetings both in the vicinity of the facility and in either Albuquerque or Santa Fe. Section 3.3 of the Plan describes--and provides a hyperlink to--the Information Repository where Permit Modification Requests are posted upon submittal to the New Mexico Environment Department .Sections 3.4 to 3.6 of the Plan describe how members of the public are notified regarding Permit Modification Requests and how they can become involved in public meetings.

In the development of a Permit Modification Request, the Permittees may hold pre-submittal meetings, discussions and consultations with a variety of groups, consultants and experts. Such meetings are at the discretion of the Permittees and will not be included in the Plan.

SRIC notes in Comment 3 that the Plan does not contain http://www.wipp.energy.gov/rcradox/ProposedMods.htm, where interested members of the public can review drafts of Permit Modification Requests and check for public meeting dates as stated by the Permittees in the August 9, 2012 response to SRIC.

Thank you for bringing to the Permittees attention that the link identified in the August 9, 2012 response is not posted on the WIPP HWFP Community Relations Plan Web page. The Permittees agree to revise Section 3.7 of the Plan to include the link and the following language:

Interested members of the public can review Permit Modification Requests in draft stage and prior to being
submitted to the New Mexico Environment Department at http://www.wipp.energy.gov/rcradox/ProposedMods.htm, The link provides the opportunity to submit comments on draft Permit Modification Requests to the Permittees.

Comment 4: SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only
with their consent, which could be given in a similar way to that done with individual comments.

Response 4: There are a number of issues that preclude the creation of such a list of contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. Therelist. There may be Privacy Act considerations in certain instances. The Permittees are not familiar with the charters of these groups or the programs in which they are involved. Therefore, the Permittees would have to provide nonendorsement caveats that, in the long run, may inhibit public involvement. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

A list of involved groups is available on the External Links page on the NMED WIPP Home Page.

Please let us know if you have further comments related to the Permittees responses provided herein. If not, changes described above will be made to the Hazardous Waste Facility Permit Community Relations Plan. Do we have your permission to post your comments and the associated responses to the Community Relations Plan Comment page?

Again, thank you for providing input to the Plan and your interest in the WIPP Hazardous Waste Facility Permit

____________________________________________________________________________________________________

Posted July 19, 2012

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1. Southwest Research and Information Center (SRIC) continues to support the permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

2. SRIC appreciates that the addition suggested in our June 2, 2011 comments in Section 1.0 has been incorporated into the Community Relations Plan.

3. SRIC is concerned that the Plan posted (http://www.wipp.energy.gov/WIPPCommunityRelations/plan.html) does not include Sections 5.1 to 5.6 of the draft plan, including the changes that were agreed to. SRIC believes that the entire Plan must be posted.

4. SRIC continues to believe that the Plan should include the fact that public involvement is encouraged through a pre-submittal meeting on draft permit modification requests and that such requests are posted on the WIPP website link "Hazardous Waste Permit - Information on Proposed Modifications" to allow additional public involvement.

5. SRIC appreciates that the addition suggested in our June 2, 2011 comments for e-mail notification was incorporated into Section 5.3 of the Plan.

6. SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only with their consent, which could be given in a similar way to that done with individual comments.

7. I am glad to discuss any of these comments or other comments.

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

Posted August 9, 2012

Permittees’ Response to Comments from
Don Hancock
Southwest Research and Information Center
Albuquerque, New Mexico

Thank you for taking the time to provide SRIC’s comments for improving the WIPP Hazardous Waste Facility Permit Community Relations Plan. Listed below are SRIC’s comments followed by Permittee responses.

Comment 1: Southwest Research and Information Center (SRIC) continues to support the permit requirement for a Community Relations Plan and for the Plan to be developed and revised with community input. SRIC has no objections to the changes provided in the updated plan.

Response: The Permittees’ suggested changes to the Plan in 2012 have been incorporated. There were no comments objecting to the changes which include wording to clarify that public comments should be specific to the WIPP Hazardous Waste Facility Permit (the Permit) or the Hazardous Waste Facility Permit Community Relations Plan, consistency in capitalization and a contact name change at the New Mexico Environment Department Hazardous Waste Bureau.

Comment 2: SRIC appreciates that the addition suggested in our June 2, 2011 comments in Section 1.0 has been incorporated into the Community Relations Plan.

Response: Thank you for your input.

Comment 3: SRIC is concerned that the Plan posted (http://www.wipp.energy.gov/WIPPCommunityRelations/plan.html) does not include Sections 5.1 to 5.6 of the draft plan, including the changes that were agreed to. SRIC believes that the entire Plan must be posted
.
Response: The Draft Plan provided Sections 5.1 through 5.6 to demonstrate how the Permittees proposed to accomplish each of the objectives listed below:

Following public input to the draft Plan and incorporation of public comments and suggestions, the Plan was formalized and the table of contents reorganized. Sections 5.1 to 5.6 of the draft Plan correlate to Sections 3.2 to 3.9 of the formalized Plan that is currently online. The posted Plan, in fact, contains additional information that was not proposed in the draft Plan. Pleases see Sections 2.0, 2.1, 2.2, 2.3, 4.1, 5.0 and 6.0.

Comment 4
: SRIC continues to believe that the Plan should include the fact that public involvement is encouraged through a pre-submittal meeting on draft permit modification requests and that such requests are posted on the WIPP website link "Hazardous Waste Permit - Information on Proposed Modifications" to allow additional public involvement.

Response: The Permittees agree to add the following statement in Section 3.7 Public meetings:

The Permittees periodically convene meetings that are not required by the Permit in order to provide interested members of the public an opportunity to discuss and give input to the Permittees during the development of a Permit modification request prior to its formal submission to the New Mexico Environment Department. Such meetings will continue provided they add value to the permit modification process and as budget allows. Interested members of the public can find review drafts of Permit modifications and check for meeting dates on the link below: http://www.wipp.energy.gov/rcradox/ProposedMods.htm.


Comment 5
: 5. SRIC appreciates that the addition suggested in our June 2, 2011 comments for e-mail notification was incorporated into Section 5.3 of the Plan.

Response:
Your input is appreciated.

Comment 6: SRIC continues to believe that a list of involved community groups, including SRIC, and their contact information should be included as resources to facilitate public involvement. Groups should be listed only with their consent, which could be given in a similar way to that done with individual comments.

Response: There are a number of issues that preclude the creation of such a list of contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. There may be Privacy Act considerations in certain instances. The Permittees are not familiar with the charters of these groups or the programs in which they are involved. Therefore, the Permittees would have to provide non-endorsement caveats that, in the long run, may inhibit public involvement. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.


Comment 7
: I am glad to discuss any of these comments or other comments.

Response: We would appreciate your feedback regarding this response. Thank you for your continued interest in the WIPP Hazardous Waste Facility Permit Community Relations Plan.

____________________________________________________________________________________________________

Posted May 29, 2012

Crystal Fletcher
Carlsbad, New Mexico

I am looking for any information available:

My name is Crystal Fletcher and I am an intern at Intrepid Potash in the Environmental Dept. I would like to get a recycling program initiated at the plant and would like any information on the Program that WIPP has in place for recycling in Carlsbad. I am in search of an established plan that can serve as a mentor for research.

Any information would be greatly appreciated.

Thank you,
Crystal Fletcher

Posted May 29, 2012

Permittees’ Response to Comments from
Crystal Fletcher
Carlsbad, New Mexico

Crystal,

To get you started, please access the WIPP Community Relations Plan Web page and click on “Plan” from the menu at the top. Then scroll down to Section 3.3 and there is a link to the WIPP Information Repository. Click on the link and you will see the WIPP Annual Waste Minimization Report for 2011.

I will ask the WIPP program coordinator to give you a call tomorrow.

Best Regards


Posted June 2, 2011

Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

1. Southwest Research and Information Center (SRIC) supports the permit requirement for a Community Relations Plan and for the Plan to be developed with community input. There are many good elements included in the draft Plan. While a concise Community Relations Plan is appropriate, SRIC believes some essential information should be added to the Draft Plan.

2. Section 1.0. SRIC suggests that two important fundamental aspects of WIPP, which are included in Permit Attachment B, should be stated in this section. "During the Disposal Phase of the facility, which is expected to last 25 years, the total amount of waste received from off-site generators and any derived waste will be limited to 175,600 m3 of TRU waste of which up to 7,080 m3 may be remote-handled (RH) TRU mixed waste. For purposes of this application, all TRU waste is managed as though it were mixed."

3. Section 5.1. Over the past several years, an important aspect of public involvement in permit modifications has been the distribution of draft permit modifications and a pre-submittal meeting. That practice should be maintained and included in the Community Relations Plan.

4. Section 5.2. The fact that the Carlsbad Field Office provides financial assistance to some tribes should be included, and the tribes currently with such agreements should be listed.

5. The Community Relations Plan web page should include an e-mail notification system to provide those who sign up with notification when the information changes.

6. The Plan should include a list of involved community groups, including SRIC, and their contact information.

7. The Plan is generally written so that a glossary may not be needed. However, SRIC suggests that the Plan include either a link to Section 1.5 of the Permit for definitions or placing those definitions as a part of the Plan.

8. I am glad to discuss any of these comments or other comments.

Don Hancock

Permitees' Response to Comments from
Don Hancock,
Southwest Research and Information Center (SRIC)
Albuquerque, New Mexico

Mr. Hancock,

Thank you for taking the time to respond with comments to the Draft WIPP Hazardous Waste Facility Permit Community Relations Plan.

SRIC provided several suggestions, which are paraphrased below and followed by the Permittees’ response.

Comment 2: SRIC suggests that a statement from Attachment B of the Permit, addressing authorized WIPP waste capacities, be included in the Plan’s Section 1.0 Introduction and Background.

Response: The Permittees agree to include the Attachment B Permit language regarding authorized waste disposal capacities and transuranic waste management in Section 1 Introduction and Background of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 3: SRIC suggests that the Permittees continue to host pre-submittal meetings. Pre-submittal meetings are informal meetings that provide interested members of the public the opportunity to give input to preparation of proposed Class 2 and 3 permit modification requests prior to the Permittees submitting the request to the New Mexico Environment Department for consideration.

Response: Pre-submittal meetings are a best practice offered by the Permittees that have benefitted both the Permittees and stakeholders. These meetings are not intended to replace or substitute for public meetings required by federal regulation for Class 2 and Class 3 permit modification requests. The Permittees will continue to offer pre-submittal meetings, provided that such meetings continue to add value to the permit modification process. The Permittees will not institutionalize pre-submittal meetings in the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 4: SRIC suggests that a list of the tribal governments with whom the Department of Energy’s Carlsbad Field Office has cooperative agreements should be included in the Plan.

Response: The DOE Carlsbad Field Office has established cooperative agreements with tribal governments in New Mexico and other states along WIPP transportation corridors to ensure the safe and uneventful shipment of transuranic wastes to WIPP. The draft WIPP Hazardous Waste Facility Permit Community Relation Plan is universal in its approach to New Mexico residents. The draft Plan offers a web page, toll-free telephone number, dedicated email address and other means for members of the public, communities, special interest groups, government entities and tribes to seek and to receive information about permit actions.

A list of tribal governments who have cooperative agreements with the Carlsbad Field Office is not a component of this WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 5: SRIC suggests that the Community Relations Plan web page should include an email notification system to alert subscribers when changes are made to the Plan.

Response: The Permittees agree to provide sign up capabilities and an email notification system to alert subscribers to changes on the WIPP Hazardous Waste Facility Permit Community Relations Plan web page.

Comment 6: SRIC suggests that the WIPP Hazardous Waste Facility Permit Community Relations Plan should include lists and contact information for involved community groups.

Response: There are a number of issues that preclude the creation of such a list or contact information. The Permittees do not have the permission of the groups and individuals within those groups to publish such a list. There may be Privacy Act considerations in certain instances. The Permittees do not agree to provide lists or contact information for involved community groups or individuals as part of the WIPP Hazardous Waste Facility Permit Community Relations Plan.

Comment 7: SRIC suggests that the Plan include a link to Section 1.5 of the Permit that provides definitions of permit language.

Response: The Permittees agree to include a link to Section 1.5 of the Permit on the WIPP Hazardous Waste Facility Community Relations Plan home page.

The WIPP Hazardous Waste Facility Permit Community Relations Plan web page will be online June 28, 2011 at www.wipp.energy.gov. The web page will offer opportunities to be notified by email or mail about current permit actions. In the interim, if you wish to receive notifications about permit actions, you may do so at the following link: http://www.wipp.energy.gov/Stakeholders/Notice.aspx.

We would appreciate your feedback regarding this response. Again, thank you for your interest in the WIPP Hazardous Waste Facility Community Relations Plan.


Posted June 2, 2011

Cathrynn N. Brown
State Representative

I realize that the WIPP budget has financial constraints and that the community relations staff is overworked, but I believe that WIPP needs to reach out to state legislators. If you haven't already invited each representative and senator on a tour, please make it a point to do so. Keep after them until they "come and see." There is resistance to all things radioactive in the minds of some northern legislators, and we need to assuage their concerns.

I have spoken with the freshman class of legislators, and these individuals would like to go on a tour of the WIPP facility (and then visit LES) in the late summer or fall. Perhaps this tour could be conducted in conjunction with a meeting of the Radioactive and Hazardous Materials Committee. (I have already broached the idea with LES.)

Thank you for inviting comments from the community.

Cathrynn N. Brown
State Representative,
District 55 Carlsbad, Loving, Malaga & Otis

Permitees' Response to Comments from
New Mexico Representative
Cathrynn Brown, District 55
Carlsbad, New Mexico

Representative Brown,

Thank you for taking the time to respond with comments to the draft WIPP Hazardous Waste Facility Permit Community Relations Plan.

In response to your suggestion that WIPP should invite state legislators to tour the WIPP facility, the Department of Energy Carlsbad Field Office (CBFO) encourages the interest of every state legislator in the WIPP project. The CBFO offers a public outreach program with a full range of WIPP informational activities that includes WIPP tours.

The WIPP Hazardous Waste Facility Permit Community Relations Plan is specific in purpose: to offer interested New Mexico residents information about the WIPP Hazardous Waste Facility Permit and to inform members of the public about opportunities for involvement in the WIPP permit process.

The Plan will provide a web page, toll-free telephone number, dedicated email address and other means for members of the public, communities, special interest groups, government entities and tribes to seek and to receive information about permit actions.

The WIPP facility tour program is not specifically part of the permit and therefore it is not included in this plan.

The WIPP Hazardous Waste Facility Permit Community Relations Plan web page will be online June 28, 2011 at www.wipp.energy.gov. The web page will offer opportunities to be notified by email or mail about current permit actions. In the interim, if you wish to receive notifications about permit actions, you may do so at the following link: http://www.wipp.energy.gov/Stakeholders/Notice.aspx.

We would appreciate your feedback regarding this response. Again thank you for your interest in the WIPP Hazardous Waste Facility Permit Community Relations Plan.