PINEDALE, WY (October 9, 2006) – The proposed Jonah Field Infill project, which will add 3,100 new wells in the Upper Green River Valley, would violate the Clean Air Act by releasing nearly double the amount of the maximum daily limit for particulate matter, local Wyoming citizens noted today.
Particulate matter, which is a mixture of extremely small particles and liquid droplets, causes serious health problems including asthma and premature death for people with heart and lung disease. Last month the Environmental Protection Agency (EPA) imposed new air quality standards for particulate matter to protect Americans from the health problems associated with this form of pollution.
The new EPA standard for fine particles, those 2.5 micrometers or less in diameter [a micrometer is one one-thousandth of a millimeter], for a 24-hour period is 35. According to the Bureau of Land Management’s (BLM) Jonah Infill Environmental Impact Study (EIS), the predicted 24-hour concentrations for particulate matter would be 44 in the Jonah Field over the life of the project. During early stages of the project there could be concentrations of as high as 49.4 and a cumulative 24-hour concentration of 62.4 including regional sources.
“The Jonah Field Infill project will almost double that amount of daily particulate matter maximum set by the EPA for air quality,” said J. Thomas Johnston, M.D., the Sublette County Health Officer and former community physician for Pinedale. “Our air in the Upper Green is becoming worse and neither the BLM nor industry has an effective solution. Simply put, the Jonah Infill project will violate the Clean Air Act and potentially jeopardize the health and welfare of the adults and children who live, work, play and recreate in the Upper Green River Valley.”
At the time the BLM prepared its air quality analysis, EPA already had proposed the recently finalized particulate matter standard, but the BLM only considered the old standard and failed to acknowledge any health risks associated with the project.
The EPA’s web site states: “The Agency selected the levels for the final standards after reviewing thousands of peer-reviewed scientific studies about the effects of particle pollution on public health and welfare.”
“When I think that we may soon experience red alert days when outdoor activity is not recommended because of air pollution, I am appalled,” says Linda Baker of the Upper Green River Valley Coalition. “Being outside in the mountains is part of our way of life here in the Upper Green. Before we move forward on the Jonah project, we need enforced air quality standards so as not to jeopardize human health."
Given the EPA’s new standards, several conservation groups have filed a request to the Interior Board of Land Appeals (IBLA) that their formal appeal of the Jonah Field Infill decision be reconsidered in light of the new standard and clear public health threats. The groups are urging that the BLM set more definite emissions limits, require industry to provide detailed pollution controls, and disclose any and all future public health threats.
The local residents, joined by the Upper Green River Valley Coalition based in Pinedale, said they are not seeking to end development on the Jonah Field, but they are calling for a common sense balance that allows for energy exploration with a defined upper limit on emissions and adequate protections of public health. By law, the BLM is required to control air pollution by working with Wyoming Department of Environmental Quality, the EPA and the U.S. Forest Service.
Unfortunately, the Jonah project has no certain requirements for Jonah Field operators to use best available technology. Cleaner technology will only be required “at the earliest possible date.” Such technology, such as natural gas-fired drilling rigs, while now being piloted or tested, is not yet widely available and the BLM will not require industry to slow down new drilling until the technology update can happen. Also, if technology fails to achieve BLM’s proposed 80 percent reductions in emissions, there are no requirements from BLM to control air pollution by simply slowing the pace of development to reasonable levels.
Additional Ongoing Air Quality Concerns in the Upper Green
As the EPA and other experts have noted, the Upper Green’s air has historically been some of the finest in the United States. But the rapid, widespread development of drilling and related activities in the Valley has had a visible impact on air quality.
Ozone: Ozone spikes in the Jonah natural gas field exceeded federal levels established to protect human health eight times during 2005 and 2006. The EPA has directly questioned industry’s claim that these were due to unusual weather events, noting that the cause of the high ozone is most likely related to ground-based activities. Ozone causes lung irritation, and reduced lung function, and can aggravate respiratory problems such as asthma, especially in children and the elderly.
NOx: The Pinedale Anticline Record of Decision establishes an “analysis level” for NOx (nitrogen oxide, a major contributor to ozone) emissions. In addition, in April of 2000, the BLM and Wyoming DEQ signed an Amended Letter of Agreement for Tracking Nitrogen Oxide Emissions within the Rock Springs, Pinedale and Kemmerer Field Office Areas. The Amended Letter of Agreement called for the issuance of annual reports, beginning December 1, 2000, to track changes in emissions from existing sources and new sources for the period beginning January 1, 1996. Unfortunately, the BLM submitted their last annual report on December 22, 2000 and the BLM has not tracked NOx emissions from 2000-2004 to determine where “actual on-the-ground calculated” NOx emissions are, or whether emission assumptions and/or impacts exceed those identified in the Pinedale Anticline EIS. Emissions of NOx already are nearly triple the level expected at the nearby Pinedale Anticline gas field with 1,985 tons being released per year rather than the 693 tons projected by the BLM.
Nitrogen Depositions: The BLM’s analysis for additional wells in the Jonah Field predicts that the additional deposition of nitrogen oxides (NOx), which can contribute to irreversible acidification of sensitive, high mountain lakes in the Wind River Range, will exceed a threshold of concern established by the Forest Service and National Park Service. In 2005, the Forest Service monitors in the Wind River Range showed a significant spike in nitrate concentrations.
Visibility: The BLM’s analysis of the Jonah Field expansion emphasizes that at the “early project development stage” there will be 22 days per year of significantly increased haze in the Bridger Wilderness due to the Jonah Infill project. On a cumulative basis, there will be up to 94 days per year [more than three months] of significantly increased haze in the Wind River Range at the early project development stage, and impacts will extend to all “Class 1” (protected) areas in Wyoming, including Grand Teton and Yellowstone National Parks.
For additional information:
http://www.epa.gov/oar/particlepollution/naaqsrev2006.html#what
http://www.uppergreen.org
