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

2. Air Quality – Game Changes Pre-History <1996 – Qualitative 1996 – Moxa Arch – Set Many Precedents 1997 – 1 st Jonah EIS – 1997 – 1999 – SWWYTAF 1999 CD & SUIT – 1 st 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 1 st Cumulative Analytical Approach −Demanded by USFS (Visibility Driver) −1 st 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 1 st 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