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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />100 <br />State of Colorado and EPA to establish a more comprehensive monitoring network in the <br />planning area and it is vitally important that the data collected from monitoring efforts <br />throughout the planning area are quality assured and made publicly available through the State <br />and/or EPA websites. <br /> The CARPP states that BLM will participate in a cooperative effort to establish a <br />comprehensive monitoring network in the planning area and share collected data with other <br />agencies and the public, “as appropriate” and “contingent upon available funding” (Section <br />III.A.1). This is an important provision of the CARPP and BLM should work with the State and <br />EPA to expand monitoring in the area. Establishment of a more comprehensive monitoring <br />network will help serve as a backstop to track and ensure air quality protection throughout the <br />planning area and to help identify areas of concern with regard to air impacts. But the adaptive <br />management process must require frequent and specific actions are taken in order to prevent <br />significant impacts throughout the planning area – as opposed to taking corrective action after a <br />significant impact is identified, as the current management plan proposes. <br /> For the BLM’s Greater Natural Buttes adaptive management plan, the National Park <br />Service advocated for the establishment of specific monitored ozone “trigger points” set at levels <br />below the NAAQS and tied to immediate implementation of enhanced mitigation measures, <br />including phased development.281 Similarly, for the Gasco adaptive management plan, EPA <br />provided the following input to BLM to ensure the adaptive management strategy would help <br />prevent significant adverse impacts to air quality: <br />First, the draft EIS does not make clear what would constitute a “significant <br />increase” in the emissions inventory, triggering the need for a new modeling <br />analysis. Second, the strategy should include monitoring that conforms to 40 CFR <br />Parts 50 and 58, with an emphasis on obtaining measurements that contribute to <br />the formation of secondarily formed pollutants such as PM2.5 and ozone. The EIS <br />should identify how monitoring results may trigger a need for additional <br />modeling. Finally, the adaptive management strategy should address how BLM <br />and Gasco will address the proposed lowering of the ozone standard.282 <br />BLM must establish specific triggers, as outlined by NPS and EPA. Without these <br />specific triggers for further specific action, the CARPP cannot function as an adaptive tool to <br />ensure mitigation measures are appropriate to prevent significant impacts to air quality. <br />Section III of the CARPP is titled “Actions to Analyze & Protect Air Quality” yet it is <br />almost entirely made up of discretionary and non-specific actions; e.g., BLM may require pre- <br />construction monitoring, may require life-of-project monitoring, may require project-specific <br />modeling, may participate in future regional modeling studies, may require mitigation measures <br />and best management practices, etc. BLM must establish a specific meaning for what is meant by <br />“a substantial increase in emissions” in Section III.C.1, and must establish specific, numeric <br /> <br />281 See BLM Greater Natural Buttes FEIS at P-68. 282 Letter from EPA to BLM, Re: Comments on the Gasco Uinta Basin Natural Gas <br />Development Project Draft EIS CEQ # 20100386 (January 7, 2011) [hereinafter “EPA 2011 <br />Letter”] (attached as Exhibit 194).