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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />105 <br />4. Hazardous Air Pollutant Impacts <br /> <br />The UFO should look at additional hazardous air pollutant impacts from the proposed <br />development, including the impacts from 1,3-butadiene and secondary formaldehyde that will <br />result from the proposed development. The BLM has completed a more comprehensive analysis <br />of HAPs in other recent NEPA actions which resulted in significant impacts from HAPs. <br />Specifically, the Gasco EIS in Utah evaluated short-term and long-term impacts from numerous <br />HAPs, including methanol, chlorinated solvents and acrolein.290 The Gasco EIS analysis found <br />elevated cancer risks for acetaldehyde, 1,3-butadiene, and ethylene dibromide, none of which are <br />included in the RMP/EIS for the UFO.291 DEIS, Appendix Q at Q-4 (identifying the HAP <br />emissions that were estimated in the UFO RMP/EIS). The Gasco EIS also reported acrolein <br />emissions that exceeded the acute Reference Exposure Level (REL) and the Reference <br />Concentration for Chronic Inhalation (RfC).292 Acrolein is also not included in the RMP/EIS <br />assessment. BLM must include a more comprehensive analysis of HAP impacts and, in addition <br />to the HAPs identified above, the BLM should also assess any HAP impacts associated with <br />volatile emissions from hydraulic fracturing fluids. It is important to continue to improve upon <br />the HAP analyses conducted under NEPA in order to ensure there are no significant health <br />impacts from near-field exposure to HAPs from the proposed development in the planning area. <br />See 40 C.F.R. §1508.27(b)(2). <br />5. Visibility and Ecosystem Impacts <br /> <br />Much of air pollution from oil and gas development and operations also degrades <br />visibility. Section 169A of the Clean Air Act (“CAA”), 42, U.S.C. § 7401 et seq. (1970) sets <br />forth a national goal for visibility, which is the “prevention of any future, and the remedying of <br />any existing, impairment of visibility in Class I areas which impairment results from manmade <br />air pollution.” Congress adopted the visibility provisions in the CAA to protect visibility in <br />“areas of great scenic importance.” H.R. Rep. No. 294, 95th Cong. 1st Sess. at 205 (1977). In <br />promulgating its Regional Haze Regulations, 64 Fed. Reg. 35,714 (July 1, 1999), the U.S. <br />Environmental Protection Agency (“EPA”) provided: <br /> <br />Regional haze is visibility impairment that is produced by a multitude of sources <br />and activities which emit fine particles and their precursors and which are located <br />across a broad geographic area. Twenty years ago, when initially adopting the <br />visibility protection provisions of the CAA, Congress specifically recognized that <br />the “visibility problem is caused primarily by emission into the atmosphere of <br />SO2, oxides of nitrogen, and particulate matter, especially fine particulate matter, <br />from inadequate[ly] controlled sources.” H.R. Rep. No. 95-294 at 204 (1977). The <br />fine particulate matter (PM) (e.g., sulfates, nitrates, organic carbon, elemental <br />carbon, and soil dust) that impairs visibility by scattering and absorbing light can <br />cause serious health effects and mortality in humans, and contribute to <br />environmental effects such as acid deposition and eutrophication. <br /> 290 See BLM Gasco Energy Project FEIS, Table 4-12, Table 4-19 and Appendix H. April 2010. 291 BLM Gasco FEIS Table 4-19. 292 BLM Gasco FEIS Appendix H, at H-45.