1. Oil and Gas Workgroup Summary October 21-23, 2009 Denver

2. 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

3. Issues Identified Collaboration NAAQS Protection Permitting Technical Assessments Implementing / Using NEPA

4. 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.

5. 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)

6. 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

7. 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

8. 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

9. 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

10. 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

11. NEPA What is it? What could it do? What should it do?

12. 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

13. 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)

14. RecommendationActivity/TopicOutcome/Product Timeframe/ frequency Who Priority (low, medium, high) NAAQS Compile mitigation tools Identify strategies for protecting and improving air quality. Might include source-specific controls, budgets, etc requires periodic updating WESTARMedium-high General Conformity Analyze general conformity in the context of oil and gas development and prepare white paper one time WESTAR Planning Committee Low-medium Technical Assessments Ambient Monitoring Inventory sites regionally requires periodic updating States, Feds, Industry High Recommend new sites requires periodic updating WESTAR states Medium-high Emission Inventory Improved emission factors and activity data for both SIP and NEPA analyses requires periodic updating TBD*Medium-high Modeling Better regional scale modeling for both SIP analyses and controls as neededTBD*High NEPA WorkshopNEPA workshop for oil & gas regulatorsone time WESTAR, WRAP, FLM, EPA Low-medium Clearinghouse Identify and make available successful NEPA related air pollution mitigation actions requires periodic updating WESTARLow-medium Modeling & Assessments Better regional scale modeling and cumulative assessments. TBD*High

15. RecommendationActivity/TopicOutcome/Product Timeframe/ frequency Who Priority (low, medium, high) Collaboration Clearinghouse List of control techniques, fees, BMPs, emerging issues, agency contacts requires periodic updating WRAP and/or WESTAR Low-medium HandbookEmissions calculation handbook/workbook requires periodic updating contractorLow Conference Periodic specialty conferences to exchange information as needed WESTAR, WRAP, industry Low-medium Conference callsWork group(s)ongoing WRAP, WESTAR as needed Low-medium