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What is Ozone and Why Does it Matter? Ground-level ozone is formed when nitrogen oxides, volatile organic compounds and sunlight react. Ozone is a lung irritant tied to respiratory ailments, reduced lung capacity, and asthma. It can also be harmful to plants and crops. The contributors of nitrogen oxides and volatile organics are industrial sources and auto emissions in the region.
The Four Corners came close to exceeding the health-based standards on ozone air quality in 2002, and the Four Corners Air Quality Task Force (4CAQTF) was formed to develop strategies to prevent the region from going "out of attainment" on ozone. San Juan County, the cities of Aztec, Blooomfield and Farmington, the New Mexico Environment Department and the U.S. Environmental Protection Agency signed the San Juan County Early Action Compact in 2002. The Compact was designed to develop strategies to analyze pollution sources, and look at mitigation measures to keep San Juan County within the legal limit.
Through many meetings, industries' suggestions and SJCA's suggestions, nothing firm was established. No actual pollution reduction goals were set, nor implemented. The hope was that through voluntary measures the pollutants would be reduced. But there have been no actual reductions, in fact only increases in industrial contributions. The Bureau of Land Management (BLM) has continued to permit thousands of new gas wells and compressors without requiring emission controls, relying on the 4CAQTF documents as a mitigation strategy, yet no strategies were actually implemented; they were only discussed and documented. At the same time, it is apparent that basic inventories of precursor emissions of pollutants that form ozone have not been completed in the San Juan Basin. In fact, the BLM has no idea of how many air pollution sources they have permitted in the Farmington Field Area.
The 4CATF final report was issued in December of 2007 withnumerous potential mitigation options as a guide to regulatory agencies in developing air quality management plans to keep the region from exceeding pollution standards for ground-level ozone. Report is available on www.nmenv.state.nm.us/aqb/4C/documents.html
- Mandatory control measures and enforceable regulatory actions for reducing air pollution will advance quantifiable progress in improving air quality in the Four Corners region. Voluntary approaches to mitigate air quality emissions will not sufficiently improve our air quality. Mandatory measures will help "even the playing field" so all industrial sources are burdened with improving, not just the ones who want "be good."
- Federal agencies in the Four Corners region have emphasized reliance on the 4CAQTF (and the earlier Ozone Task Force) as the means to secure improved air quality through mitigation strategies. For the past four years, the BLM’s Farmington office has avoided implementation of mandatory air pollution control measures while approving new oil and gas facilities that often require wellhead or central compression.
- It is essential that improved monitoring of air pollution emissions occur in the Four Corners region. We need more monitors and properly located monitors to accurately determine ozone levels.
- The 4CAQTF must require specific emission control measures to reduce emissions of precursors of ozone.
- The emphasis on air pollution emissions reduction for coal and natural gas facilities should be on upfront design for pollutant source reduction rather than reliance on uncertain future mitigation measures (including retrofits for pollution control).
- The EPA regions 6 (includes New Mexico), 8 (includes Colorado) and 9 (San Francisco office oversees Navajo Nation) must work together with state and tribal entities to oversee air quality emissions in the Four Corners region, which are fragmented by jurisdictional boundaries.
- SJCA urges that the 4CAQTF assist citizens in acquiring complete public health records for the Four Corners region concerning rates of human respiratory illness (including asthma), strokes, heart attacks and autism in comparison to other communities in the United States. It is particularly important that the historic health records in the tribal areas (including Navajo Nation, Southern Ute, Ute Mountain Ute) be obtained from Indian Health Services since current and future planned emissions in the Four Corners region severely impact tribal lands.
- SJCA believes that modeling of existing and projected air quality pollution and emissions in the Four Corners region has been woefully inadequate, with poor input data, underestimated source emissions, improperly located monitors, and inappropriate application of models. The result is that Federal agencies in the Four Corners are using faulty modeling and deficient planning documents to approve thousands of air pollution sources (including natural gas wells and compressors) that are marginally analyzed for air quality impacts, individually and cumulatively.
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• The Clean Air Act requires that any area contributing to ambient air quality in an area violating ambient air quality standards must be designated as nonattainment (see, Clean Air Act section 107(d)(1)(A)(i))). • La Plata County and likely Montezuma County contribute to ambient air quality in San Juan County. Oil and gas activity is prevalent in the region (these counties are part of the San Juan Basin), increases in motor vehicle traffic, and other industrial activity all release emissions that contribute to regional ambient air quality. • High ozone readings at Mesa Verde and at one La Plata Co. monitor over the years attest (as well as at Navajo Lake), ozone concentrations have exceeded the current standard of 75 ppb several times.
• Ozone and impacts to public health are not just a San Juan County issue. Clearly there is reason to be concerned over ozone in La Plata and Montezuma Counties.
• Ozone is a regional problem, it is not local in nature. In the Denver metro region, clean up efforts have focused on 9 counties, even though a violation has been recorded in just one county. • A nonattainment designation provides strong tools to be able to clean up polluted areas. A nonattainment designation would impose reasonable controls on stationary sources, spur smarter transportation planning, and bolster other innovative efforts to reduce harmful emissions.
• Although Montezuma and La Plata Co. are not in violation, there are signs of trouble. It's wise to take action now to curb air pollution, rather than waiting for things to get worse. • We need early action by the EPA, NMED, Colorado Department Public Health and Environment to fully inventory NOx and VOC emissions in the San Juan Basin and develop an action plan to reduce NOx and VOC emissions.
• No new NOx or VOC emission source should be approved in the San Juan Basin without offsets (equal to or greater reduction of NOx and VOC sources taken off-line).
• Recognition that the coal-fired power plants (Four Corners Power Plant, San Juan Generating Station) in the region and the thousands of natural gas facilities in the region contribute to the high levels of ozone being recorded in San Juan County. We have heard from industry at the last meeting of the Four Corners Air Quality Task Force that high levels of ozone in San Juan County are due to biogenics (vegetation) and boat activity on Navajo Reservoir.
• We need an honest dialogue that addresses our air pollution problem in the San Juan Basin and implements mandatory emission control measures.
High levels of ozone in the Four Corners region approximate those of large urban center (such as Denver, Phoenix and Dallas) and threaten public health through increased levels of pollutants (nitrogen oxides and volatile organic compounds) from industrial sources rampantly permitted under the Energy Policy Act of 2005. The BLM Farmington office has stated that 73,565 tons per year (tpy) of nitrogen oxides is to be expected in the year 2023 from natural gas production (over 12,000 wellhead compressors). This is more pollution than PNM San Juan Generating Station and APS Four Corners coal-fired power plants currently emit, combined. APS Four Corners Power Plant ranks as #1 in the United States in 2006 for coal-fired power plants for nitrogen oxide emissions of 44,698 tpy; PNM San Juan Generating Station ranks as #18 in the United States in 2006 for coal-fired power plants for nitrogen oxide emissions of 27,503 tpy (source: Dirty Kilowatts, Environmental Integrity Project). APS Four Corners Power Plant and PNM San Juan Generating Station are approximately 10 miles from each other, approximately 15 miles west and southwest of Farmington. Projects that would emit large, new sources of nitrogen oxides and volatile organic compounds should be precluded from being built without vast emission reductions. Existing sources of nitrogen oxides and volatile organic compounds need to reduce emissions. SJCA is analyzing planning documents in the Four Corners Region and will be involved with air quality impacts and analyses. We are also looking forward to working with the "new" EPA, an agency that should be utiilizing science, first and foremost, in decision making processes that affect public health. We are of the opinion that continued rampant industrial development in the region will lead to ozone nonattainment without proactive action by agencies responsible for accurately permitting projects. |
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