Air Quality
Large-Scale Natural Gas Projects
Regional Haze
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Large-Scale Oil and Gas Projects Have Implications for Air Quality
The Pinedale Anticline Oil and Gas Project
In September 2008, with some 600 wells already in existence, the Bureau of Land Management approved drilling 4,399 additional wells in the Pinedale Anticline Field near Pinedale, Wyoming. The Wyoming Outdoor Council submitted extensive comments and the technical opinions of several experts to the BLM in response to its environmental impact statement. The impacts to air quality from increased levels of drilling were among our primary concerns. The BLM’s own conclusions in the EIS showed that approval of the project would result in a violation of the national standards for ground-level ozone pollution. Moreover, the project would cause the allowable limits on nitrogen dioxide and coarse particulate matter to be exceeded. Lastly, the project would contribute to significant degradation of visibility in the Class I Bridger and Fitzpatrick Wilderness Areas.
In February 2008, the EPA rated the EIS “environmentally unsatisfactory” with “insufficient information” (an “EU-3” rating), the EPA’s lowest possible rating. The rating was issued partly due to concerns over ozone pollution, but also impacts on visibility in Class I areas and water pollution concerns. You can see the EPA’s EU-3 letter here.
Fortunately, after consultation with the State of Wyoming and the EPA, the BLM acknowledged these problems and made several important changes between its release of the EIS and its record of decision. The BLM added significant mitigation measures that we are hopeful will be sufficient to prevent the legal violations anticipated in the initial EIS. We will monitor this project closely, however, to ensure ozone limits are not violated, that other air and water quality problems do not continue, and that public health is safeguarded.
To read the four sets of comments we submitted to the BLM on the Pinedale Anticline infill project, click the links below:
PAPA SEIS scoping comments.pdf
Revised PAPA SEIS Comments.pdf
You can look at BLM’s environmental impact statement for the Pinedale Anticline Project Area (PAPA) oil and gas project here.
Ozone in Pinedale
The ongoing oil and gas boom west of the Wind River Mountains has brought economic benefits to the sparsely populated Upper Green River Valley. But it has also brought environmental and socioeconomic costs. One of the most unexpected harms has been severe, big-city-like smog in Pinedale, Wyoming—a town that doesn't even have a stoplight.
Pinedale-area residents have had to deal with dangerous spikes of ground-level ozone pollution in recent winters. Ozone is a type of pollution that is especially harmful to developing children and the elderly.
In 2009 we leant our legal and technical capabilities to a grassroots Pinedale-area movement called CURED, or Citizens United for Responsible Energy Development, which was working to protect residents in the region from this dangerous form of air pollution. In May 2009 we petitioned the Wyoming Environmental Quality Council to establish a standard for ozone in Sublette County that would have been stricter than the national standard. We represented CURED in the case.
The EQC rejected ultimately our petition, but it did not deny our argument that the current federal standard was inadequate for protecting the public health. Nearly all independent scientists, public health experts, and public health organizations agree that the Bush-era standard—which set a ceiling of 75 parts per billion for ozone—was inadequate. Even the scientific advisory board that made recommendations to the Bush administration agreed that 75 ppb would be too high, and that the level recommended in our petition was in the range necessary to protect the public health. Because of limited resources, among other things, the Wyoming EQC decided the issue would be best corrected at the federal level.
On January 7, 2010, the Environmental Protection Agency did in fact propose a new standard of 60 to 70 parts per billion (we and CURED had asked for 65 ppb in our petition). We believe our collaborative advocacy efforts helped influence the EPA to propose this stricter standard sooner rather than later. In addition to our role in the ozone petition, we engaged with the EPA during the transition in presidential administrations, had frequent communications with regional EPA staff, as well as ongoing communications with EPA personnel in Washington, D.C.
If you would like to see the comments we submitted in support of the EPA's most recent effort to make the ozone standard more protective of the public health, click here.
Background and Details on the Ozone Standard
Ground-level ozone, caused by the combination of nitrogen oxides (NOx) and volatile organic compounds (VOCs) in the presence of sunlight, is the primary constituent of smog. Ozone can cause severe respiratory problems, putting children, adults who work or exercise outdoors, and people with respiratory illnesses (such as asthma or emphysema) particularly at risk.
Ozone is one of the air pollutants the Environmental Protection Agency regulates under its National Ambient Air Quality Standards program. In May 2008, the EPA set a new, stricter national standard for ozone making it a violation of the Clean Air Act when ozone measures 75 parts per billion or more. The prior standard was 80 ppb. More information on the EPA’s ozone standard can be found here.
In the winter of 2008 and again in winter 2009, air quality monitors in the Pinedale area revealed several exceedances of the national standard for ozone pollution. Ozone levels reached as high as 122 ppb, far in excess of the legal limit of 75 ppb. As a result, the Wyoming Department of Environmental Quality was forced to issue a series of public health advisories.
The high ozone levels in the winters of 2008 and 2009 followed high levels also seen in the winters of 2005 and 2006.
Such high levels of ozone pollution are largely unprecedented in rural communities; national ozone standards are normally only exceeded in large metropolitan areas. It is recognized by the state that drilling and maintenance of the natural gas fields in the area, activities that emit NOx and VOCs, are responsible for the problem. It is particularly troubling that the Pinedale area is experiencing such severe pollution because prior to the onset of large-scale natural gas development, it had some of the cleanest documented air quality in the country, if not the world.
It is not surprising that community members responded to this change with tremendous outrage and concern. As a result, the DEQ has been forced to play a much more active role in attempting to control this pollution. The DEQ adopted an interim policy in July 2008 that requires “offsets” (i.e., actual pollution reductions) of NOX and VOC emissions before a permit for a new source of pollution will be granted, and it is also moving to improve its best available control technology (BACT) requirements for oil and gas operations. To view this interim offsets policy, click here. You can view the Wyoming DEQ's oil and gas BACT requirements by clicking here.
Because the data from local monitoring stations support the conclusion that the Pinedale area is out of compliance with the existing standard of 75 ppb, the state and has recommended that the EPA designate the area in non-attainment with the existing ozone standard. That recommendation is pending. You can view the state's request to designate Sublette County and portions of Sweetwater and Lincoln Counties as a non-attainment area for ozone by clicking here.
If the Pinedale area is designated in non-attainment, this will precipitate the need to revise the State Implementation Plan for ozone pollution, a lengthy and complex process, and it will almost certainly increase the amount of regulation in the area. Non-attainment areas are regulated more heavily under the Clean Air Act than are attainment areas. The Wyoming Outdoor Council will be closely involved in any revision of the SIP and its implementation.