NEPA & Air Quality 2008 PLA NEPA Workshop Denver, Colorado June 12, 2008

1. NEPA & Air Quality 2008 PLA NEPA WorkshopDenver, ColoradoJune 12, 2008

2. Air Quality – Game Changes • Pre-History <1996 – Qualitative • 1996 – Moxa Arch – Set Many Precedents • 1997 – 1st Jonah EIS – • 1997 – 1999 – SWWYTAF • 1999 CD & SUIT – 1st to Use CalPuff for Cumulative Analysis • 2000 – FLAG Issued • 2004 – 2006 – Jonah Infill EIS • 2007 – Pinedale Supplemental EIS • 2007-2008 – 4-Corners Interagency AQ Task Force Analysis • 2008 Planned – CDC – Use PGM for Visibility

3. Moxa (1996) Precedents • 1st Cumulative Analytical Approach • Demanded by USFS (Visibility Driver) • 1st Air Quality Related Values (AQRV) • Required Use of “dv” Method – Genesis of 1dv and 0.5 dv Thresholds • Required Acid Deposition Modeling • Scheffe Ozone Method 1st Used • Secondary Organic Aerosols Implicated in Visibility Impacts • BLM Established Cumulative Emissions Cap • Appealed by Project Proponents and Overturned

4. Jonah 1 and SWWTAF • Jonah (1997) • EPA Threatened Unsatisfactory Rating if Engines Not Restricted to 1gr/hp-hr. BLM Agreed • SWWTAF (1997 – 1999) • Examined CALPUFF for Visibility and Deposition Modeling • Conclusions • Over prediction of NO3 by “order of magnitude” • Analysis showed ammonia limiting • Secondary organic aerosols shown to be biogenic

5. CD#1 and SUIT (1999) • First Cumulative Analyses to Use CALPUFF • Configured Using SWWTAF Conclusions • Visibility Analysis Using Hourly Transmissometer Data • Model Showed Significantly Lower Visibility Impacts – However Impacts at All Class 1 Areas Modeled • SUIT Analysis Had Similar Results

6. FLAG (2000) • FEDERAL LAND MANAGERS AIR QUALITY RELATED VALUES WORKGROUP (FLAG) • Developed by USFS and USPS and FWS • Prescribed Detailed Methodology and Became the “Bible” for AQRV Analysis • Mostly Relied on EPA IWAQM Guidelines • Comparison of Model vs Monitoring Indicates Significant Over-prediction

7. Visibility Trends (Bridger IMPROVE)

8. Model to Monitor Comparison

9. CALPUFF (RIVAD) Performance

10. Jonah Infill & Pinedale Supplemental • Jonah Infill (2004-2006) • First Use of “Iterative” Modeling Approach to Set Mitigation Levels (pseudo cap) • Drilling Rigs Considered Significant Sources • Appealed for Scheffe Ozone Methodology • Dr. Scheffe said his method is: “antiquated and useless” • Appeal still underway • Pinedale Supplemental (2005-??) • First Use of Photochemical Grid Model (PGM) • Ozone Only (CALGRID then CAMx) • FLAG/CALPUFF Used for AQRV Analysis • EPA Issued Unsatisfactory Rating on Draft

11. Four Corners Interagency Air Quality Task Force Analysis • Regional Model for AQRV’s and Ozone • Using CAMx (PGM Model) • Baseline Year Run Underway/Done • Very Complete Inventory • Preliminary Model Performance Evaluation Done • Will Develop “Relative Response Factors” • Will Conduct Source Apportionment Analysis • Both Particulate and Ozone

12. CDC (2007-??) • Will Use PGM Model for Both AQRV and Ozone Analysis (CAMx or CMAQ) • Two Years of Baseline Runs Planned • Formal Model Performance Evaluation Planned • Development of “Relative Response Factors” Planned • Very Complete Inventory Developed • Source Apportionment Analysis Planned • Should Yield “Best Science” Information for Decision Making • CDC and 4-Corners Similar to SIP Demonstration Modeling in Detail, Complexity, and Completeness

13. Forward Challenges • “Mega Projects”, Density of Development, Long Term Pad Drilling, Number of Projects • Analysis Requirements • Ozone • Visibility • “Other AQRV’s • Climate Change (GHG Emissions) • Why are Polar Bears Important in the Rockies?

14. Projects • Projects are Now 1,000’s of Wells Rather than 100’s • Density of Development Coupled with Long Term Pad Drilling Has “Near Field” NAAQS Implications • SW Wyoming Example • Jonah Infill – 3,100 wells • Pinedale Supplemental – 4,400 wells • CDC – 9,000 wells • Moxa – 1,800 wells • Hiawatha – 4,200 wells (may be less now) • Desolation Flats – 400 wells • Atlantic Rim – 2,000 wells • All of These Exist in Essentially the Same Airshed

16. Analysis Requirements • Photo Chemical Grid Models Likely to be New Standard • Complex, Expensive, Lengthy, Limited Contractor Availability • Better “State of Science” Results • Yields Much More and Better Information for Decisions • Inventories Historically a Problem • Most Analyses Relied on WRAP Inventory (Does not have VOC’s) • More Complete, Accurate, and Speciated Inventories Will be Required • IPAMS Wrap Phase III Will Help • Keeping Inventories Updated Will be Challenge for Both Industry and Agencies

19. Ozone • NAAQS Lowered to 0.075 ppm (75 ppb) • Rural Western “High Background” is Close to Standard • “Winter Ozone” Issues • Several Areas Will Probably Become Non-Attainment • Sublette County Wyoming • San Juan County New Mexico • Other Areas Likely to Be Included As “Transport” Areas. • Analyses Show Modeled Design Value Exceedence of Standard (Pinedale Supplemental) • It is Unclear How to Do a Major Project EIS in a Non-Attainment or Transport Area • It is Unclear if BLM Can or Will Issue a ROD with Predicted Design Value Exceedences • It is Clear that More Appeals Will be Filed With More Substance

20. Pinedale Supplemental Design Values

21. Visibility • Class I area Visibility Impacts • Longstanding Issue – Has Not Diminished • Mostly Nitrate and Sulfate Secondary Particulates • Past Model Predictions Show Significant Impacts • Monitoring Data Shows No Trend • Issues with Modeling System and Application • Extensive Mitigation Driven by Model Output • Wamsutter/Continental Divide II – Impacts Predicted at Bridger and Zirkel • Jonah EIS & ROD – Extensive Mitigation Required • Pinedale Supplemental EIS – Extensive Mitigation – Still Shows Impacts @ Bridger • EPA Issued “Unsatisfactory” Rating • Moxa Draft EIS – Shows Significant Impact @ Bridger

22. Acid and Fertilizer Deposition • Overshadowed by Ozone and Visibility Issues • Still Need to be Mindful of These Parameters • Lake Acidification May Become Problem in Some Highly Sensitive Areas • Fertilizer Deposition Has Been Issue @ Rocky Mountain National Park

23. Climate Change • Emerging Issue • Likely to Be Basis for Appeals • Petition for CEQ Guidance Rule Change is in Washington Now • Rumor That BLM is Working on Guidance • Difficult to Deal With Mitigation • Plan to Develop and Disclose Project GHG Inventory • Highlight Low Emissions Technologies Applied • Stay Tuned for More Developments

24. Forward AQRV and Ozone Analysis Strategy • Past Approaches Will Likely Not Be Successful • Develop Detailed and Agency “Approved” Protocols • Develop Detailed and Agency “Approved” Inventory • Use PGM Model for PM and Visibility in Addition to Ozone • Run Model in “Relative” Sense for PM, Visibility, and Ozone – Output Calibrated to Monitoring Records • Do “Formal” Model Performance Evaluation • Should “Eliminate” Visibility Impact Issues • Conduct Source Apportionment Analysis • Will Bring “Tools” to Understand and Address Ozone Issues • Stay Involved as Much as Allowed

25. Analysis Strategy Goals • Craft an Analysis That is Approvable by BLM • Ensure Agency Support for Analysis and Approval • Avoid EPA “No-Cert” Issue • Avoid Inter Agency Conflict and “Escalation” • Ensure Agency “Buy-in” at Critical Steps in Process • Ensure Analysis will Withstand Appeals • “State of Science” Approach and Tools • Clear, Transparent and Well Documented

26. Project Emissions Strategy • Plan Projects for “Low Emissions” • Condensate and Water Collection Rather than Tanks and Trucks • Controls on Start-up • Contract Low Emission Rigs When Turn-over Occurs • Use Low or Ultra-low Sulfur Diesel • Use Low Bleed Pneumatics, Solar for Chemical and Methanol Pumps • Avoid Pneumatic Pumps (gas) if Possible • Avoid Well Venting for Completion, Unloading or Blowdown • Automation • In a Regional Sense Electrification is Not a Silver Bullet

27. Project Approval Strategies • Be Prepared to Make Emission Mitigation Commitments • It is Better to Plan These for the Most Cost Effective and Largest Effects • Ozone Issues May Require Controls of Existing Equipment • Formal Off-sets in Non-attainment Areas • Model Predicted Impact Reduction Where Analysis Shows Design Value Exceedences • Goal is to Demonstrate No or Very Deminimis Impact