Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />104 <br /> <br />On October 26, 2015, EPA published a final rule to revise the NAAQS for ozone to 70 <br />parts per billion (ppb) from the current 75 ppb. National Ambient Air Quality Standards for <br />Ozone, 80 Fed. Reg. 65292 (Oct. 26, 2015). This decision was driven by significant recent <br />scientific evidence that the standard of 75 ppb was not adequately protecting public health. Id. at <br />136. In fact, recent studies have documented decreased lung functioning and airway <br />inflammation in young, healthy adults at ozone concentrations as low as 60 ppb. Id. at 146. <br /> <br />Additionally, climate change is likely to worsen ozone pollution, offsetting the <br />improvements in air quality and public health that would be expected from reductions in <br />emissions of ozone precursors. As described by the EPA in its recent ozone rulemaking: <br /> <br />In addition to being affected by changing emissions, future O3 concentrations may <br />also be affected by climate change. Modeling studies in the EPA’s Interim <br />Assessment (U.S. EPA, 2009a) that are cited in support of the 2009 <br />Endangerment Finding under CAA section 202(a) (74 FR 66496, Dec. 15, 2009) <br />as well as a recent assessment of potential climate change impacts (Fann et al., <br />2015) project that climate change may lead to future increases in summer O3 concentrations across the contiguous U.S. While the projected impact is not <br />uniform, climate change has the potential to increase average summertime O3 concentrations by as much as 1-5 ppb by 2030, if greenhouse gas emissions are <br />not mitigated. Increases in temperature are expected to be the principal factor in <br />driving any O3 increases, although increases in stagnation frequency may also <br />contribute (Jacob and Winner, 2009). If unchecked, climate change has the <br />potential to offset some of the improvements in O3 air quality, and therefore some <br />of the improvements in public health, that are expected from reductions in <br />emissions of O3 precursors. <br /> <br />80 Fed. Reg. 65292, 65300 (October 26, 2015). For example, climate change impacts include an <br />increase in the area burned by wildfires, which, in turn are sources of O3 precursors. Id. at 65371. <br />While the DEIS acknowledges that climate change can increase the occurrence and severity of <br />wildfires on BLM-administered land, DEIS at 4-18, the DEIS explicitly declines to address this <br />impact of climate change on ozone pollution, DEIS at 4-24. <br /> <br />Venting from methane drainage wells from coal mines in the North Fork Valley may <br />release significant amounts of volatile organic compounds (VOCs). As described in comments <br />on a recent proposal to expand the West Elk mine, VOC emissions at Arch’s West Elk mine are <br />in violation of Colorado air quality regulations, according to data obtained by state regulators.289 <br />BLM must disclose these VOC emissions, address them in any air quality analysis, and <br />acknowledge that any planning decision that permits these mines to continue mining will result <br />in violations of the Clean Air Act due to the mines’ continue refusal to obtain required permits. <br /> <br />289 Letter of E. Zukoski, Earthjustice to S. Armentrout, Supervisor, GMUG National Forest (Apr. <br />12, 2016) at 63-68 (exhibit omitted) (attached as Exhibit 239).