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Oil and Gas WorkgroupSummary October 21-23, 2009 Denver
The Meeting • Participants: Colorado, New Mexico, Alaska, Utah, Wyoming, North Dakota, BLM, National Park Service, WRAP, and EPA Region VIII • Each participating state described current projects, current issues, etc. • Tried to identify common issues / concerns
Issues Identified • Collaboration • NAAQS Protection • Permitting • Technical Assessments • Implementing / Using NEPA
Collaboration • We need a means to work together to share information on the issues dealing with oil and gas development. • Improved collaboration would help states with developing oil and gas fields more effectively manage emissions from these sources. • Additional coordination with federal land management agencies, EPA, and tribes is also important.
NAAQS Protection • There are significant areas of oil and gas development over large portions of the West and the potential for much more in the future, including oil shale development. • We reviewed basin maps of the oil and gas reserves, where development is underway and where it is projected to occur. • All the attendees expressed concern about the ambient air pollution and potential NAAQS violations as a result of oil and gas development (as in Pinedale). • Ozone • Particulate Matter • Increment (PM and NO2)
More NAAQS • A nonattainment designation requires SIP/FIP/TIP development • There is the looming specter of General Conformity • Uncertainty about what it is and isn’t • Uncertainty about how it works (or doesn’t) • Process Questions: • Budget development • Conformity findings
Technical Assessments • Oil and gas development occurring throughout the western U.S. is introducing thousands of sources and substantial air pollution in areas which previously had few emission sources • Areas of concentrated development • Have poor meteorological ventilation conditions • Little (if any) ambient monitoring data • Technically defensible air quality impact analyses can be extremely costly and challenging • Air quality modeling and emission inventory requirements for various regulatory programs (SIPs, NEPA, or NSR Permits) are not the same
There are numerous localized modeling analyses being conducted in areas of the rural West • Little interstate coordination • Sometimes a lack of consensus on modeling protocols • They frequently don’t contain the latest base case and future emission inventories across all source categories • They frequently don’t address multiple NEPA actions, even within the same domain • Therefore, there are several areas conducting regional modeling analyses
Regional Modeling Analyses • Limited ambient monitoring in the rural areas of the region where most of the oil and gas development is occurring • Without adequate monitoring data to ‘ground truth’ the modeling output, the results have little meaning when compared to the NAAQS or other limits and are, at best, limited to relative analyses
Emission inventories are generally limited to evaluation of specific project proposals • Many rely upon regional O&G emissions inventories as a starting point for individual project proposals • Although emission inventories for oil and gas projects, are improving, they often have not accounted for significant source categories: • increased on-road emissions from diesel trucks • non-road emission sources • needed additional power generation • Projected future regional estimations of oil and gas emissions are inconsistent • great variation in operators and equipment • differences in state inventory methodologies
NEPA • What is it? • What could it do? • What should it do?
There is significant variability in how NEPA is applied to oil and gas development projects. • It may be possible to use the NEPA process more broadly to achieve emission reductions • There may be opportunities for more consistency in application of the NEPA process so that air quality impact mitigation is the norm
Recommendations • Developed a table of our recommendations • Affected by current lack of funds generally • Affected by regulatory constraints on different agencies (i.e., model rule)