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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />106 <br /> <br />The visibility protection program under sections 169A, 169B, and 110(a)(2)(J) of the <br />CAA is designed to protect Class I areas from impairment due to man-made air pollution. The <br />current regulatory program addresses visibility impairment in these areas that is “reasonably <br />attributable” to a specific source or small group of sources, such as, here, air pollution resulting <br />from oil and gas development and operations authorized by the RMP. See 64 Fed. Reg. 35,714. <br /> <br />Moreover, EPA finds the visibility protection provisions of the CAA to be quite broad. <br />Although EPA is addressing visibility protection in phases, the national visibility goal in section <br />169A calls for addressing visibility impairment generally, including regional haze. See e.g., State <br />of Maine v. Thomas, 874 F.2d 883, 885 (1st Cir. 1989) (“EPA’s mandate to control the vexing <br />problem of regional haze emanates directly from the CAA, which ‘declares as a national goal the <br />prevention of any future, and the remedying of any existing, impairment of visibility in Class I <br />areas which impairment results from manmade air pollution.’ ”) (citation omitted). <br /> <br /> Here, there are at least 10 Class I areas in or near the planning area that may be impacted <br />by the proposed development, including: the Black Canyon of the Gunnison National Park <br />(inside the planning area); Arches National Park; Canyonlands National Park; Flat Tops <br />Wilderness Area; Eagles Nest Wilderness; Maroon Bells – Snowmass Wilderness Area; West <br />Elk Wilderness; Raggeds Wilderness; La Garita Wilderness; Weminuche Wilderness; and Mesa <br />Verde National Park. See DEIS at 4-25. <br /> <br />The UFO provides visibility modeling based on the “projected federal and nonfederal oil <br />and gas emissions throughout the 2.5 mile (4-kilometer) CARMMS domain plus mining on <br />federal lands in Colorado,” but provides no information about the contribution of the specific <br />development contemplated by the UFO RMP/EIS. Yet the BLM acknowledges: “For all of the <br />alternatives, the magnitude of emissions from oil and gas and coal and uranium mining <br />development has the potential to impact air quality and air quality-related values (i.e., visibility <br />and atmospheric deposition) within these areas.” DEIS at 4-25. The nature and extent of these <br />impacts must be considered and specifically analyzed in the UFO RMP/EIS. <br />6. Air Quality Impacts on Human Health <br /> <br />Entirely absent from the agency’s discussion of air quality impacts is the relationship to <br />human health. Although adherence to air quality mitigation and NAAQS standards will have a <br />positive relationship to human health, poor baseline air quality conditions due to direct, indirect <br />and cumulative impacts in the planning area warrants an independent hard look analysis at <br />human health; and, moreover, such analysis is required by NEPA and CEQ implementing <br />regulations. As the Endocrine Disruption Exchange has noted: <br /> <br />In addition to the land and water contamination issues, at each stage of production <br />and delivery tons of toxic volatile compounds (VOCs), including BETX, other <br />hydrocarbons, and fugitive natural gas (methane), can escape and mix with <br />nitrogen oxides (NOx) from the exhaust of diesel-driven, mobile and stationary <br />equipment, to produce ground-level ozone. One highly reactive molecule of <br />ground level ozone can burn the deep aveolar tissue in the lungs, causing it to age