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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 103 Wyoming.285 The DEIS included model performance evaluations for the 2005 and 2006 base case scenarios based on CD-C project modeling and on previously-conducted modeling for the Hiawatha Regional Energy Development Project EIS (Hiawatha). The results of the base case modeling evaluations suggest it is not unreasonable or inappropriate to include wintertime modeling results in BLM’s analysis. Specifically, model results are presented in the CD-C DEIS and compared with year-round monitoring data at several sites.286 In general, the modeling results appear to underestimate winter ozone concentrations, but not in all cases.287 Generally, the results of the CD-C DEIS performance evaluation indicate that there is a tendency towards underestimation, especially at observed maximum concentrations in winter. Even so, if modeled wintertime ozone concentrations are shown to be a problem and the performance evaluation for the modeling indicates that modeled results likely underestimate impacts in winter then, at a minimum, the BLM would have an obligation under NEPA to reduce emissions from the proposed development in order to ensure there will be no significant impacts to wintertime ozone levels based on the modeling, as evaluated (with an underestimation bias). BLM should have considered a similar approach for the RMP/EIS, but failed to do so. As shown by the high wintertime ozone levels nearby in Rangely, in the Uinta Basin in Utah, as well as in Wyoming’s Sublette County, wintertime ozone near concentrated oil and gas development has simply become far too big of an issue, of tremendous public interest and concern, to be ignored in this long-term planning action. BLM should use the CARPP process to improve upon the analysis and monitoring methods used to evaluate impacts in the area but should not delay any further in completing a winter ozone analysis for the UFO planning area using the best available methods. Ozone has long been recognized to cause adverse health effects. Exposure to ozone can cause or exacerbate respiratory health problems—including shortness of breath, asthma, chest pain and coughing—can decrease lung function, and can even lead to long-term lung damage. See also EPA’s National Ambient Air Quality Standards for Particulates and Ozone, 62 FR 38,856 (July 18, 1997). Short term exposure to ozone causes multiple negative respiratory effects, from inflammation of airways to more serious respiratory effects that can lead to use of medication, absences from school and work, hospital admissions, emergency room visits, and chronic obstructive pulmonary disease (“COPD”). According to a recent report by the National Research Council (“NRC”), short-term exposure to current levels of ozone in many areas is likely to contribute to premature deaths.288 As described in more detail below, even ozone concentrations as low as 60 ppb can be harmful to human health. Long-term exposure to elevated levels of ozone results in numerous negative harmful effects, such as permanent lung damage and abnormal lung development in children. Long-term exposure may also increase risk of death from respiratory problems. Short- and long-term exposure to elevated levels of ozone can also harm people’s hearts and cardiovascular systems. See 79 Fed. Reg. 75234-311. 285 See BLM Continental Divide-Creston (CD-C) AQTSD Appendix A. 286 BLM CD-C AQTSD Appendix A at 68. 287 See, e.g., BLM CD-C AQTSD Appendix A at 68 (Close to the project area, the performance of the CD-C and Hiawatha modeling appears to be reasonably good “with the exception of a few days, the two base case simulations reproduce the observed ozone at [the OCI monitor] reasonably well.”). 288 National Research Council, Link Between Ozone Air Pollution and Premature Death Confirmed, (April 2008), available at: http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=12198.