WESTERN OIL AND GAS SUSTAINABILITY DEVELOPING AIR QUALITY RISKS

• Jurisdiction: United States

Air Quality Challenges Facing the Natural Resources Industry in the Western United States
(Nov 2007)
CHAPTER 5C
WESTERN OIL AND GAS SUSTAINABILITY DEVELOPING AIR QUALITY RISKS
Gordon "Reid" Smith
BP America Production Company
Houston, Texas

• Ozone (NAAQS and Class I Area Impacts)

• Regional Haze (Class I Area Visibility)

• Climate Change/GHG Regulation

• Risk

-- Precluded Access

-- Significant Delay in Development Approval

-- Controlled & Slower Pace of Development

-- Significant Increase in Costs

• Now =〉 5 years

Summary of Current 8-Hour Ozone Non-Attainment Areas and Additional Areas that Exceed Possible 0.060, 0.070, and 0.075 ppm 4th Highest Standard for 2003 - 2005

[Page 5C-2]

What This Can Mean

• Non-attainment designation:

-- Imposition of retrofit RACT -- existing (economics considered)

-- Imposition of LAER -- new (economics not considered)

-- Emissions offsets for any new sources (NOx & VOC; ˜1.2X)

-- Limit on Growth? -- Where do we get offsets

-- Potentially far larger than immediate county with monitor

• Additional Ozone analysis in EIS's will be needed

-- Expensive and time consuming

-- More to challenge/appeal

• Potentially much tighter regulation and emission limits

• More monitors are being installed = more problems?

Regional Haze

[Page 5C-3]

Regional Haze/Visibility

• Regional Haze Rule

-- Goal is to return visibility in Class I Areas to natural conditions by 2064

• SIP's due this year -- intended to show progress toward this goal -- "glide path"

-- How SIP's deal with new growth from oil and gas NOx and VOC emissions is unknown

-- Demonstrating "reasonable progress" will be difficult

• Huge Current Issue in NEPA Actions

• Business Risk/Impact

-- Higher Costs; Slower Pace; Limits on Growth; EIS Appeals and/or Time Delay; Air Permit Delay

-- Significant EIS Record of Decision Emission Requirements

-- Potential "Regional" NOx Cap & Trade

SULFATE-NITRATE-AMMONIUM AEROSOL IN THE U.S.:
contributions from natural sources and transboundary pollution
Annual regional means from GEOS-CHEM standard and sensitivity simulations
Ammonium sulfate (µg m-3 )	Ammonium nitrate (µg m-3 )
West	East	West	East
Baseline (2001)	1.52	4.11	1.53	3.26
Background (no U.S. anthrop. emissions)	0.43	0.38	0.27	0.37
Natural (no anthrop. emissions globally)	0.11	0.11	0.03	0.03
Transboundary pollution enhancements
Canada and Mexico	0.15	0.14	0.20	0.25
Asia	0.13	0.12

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