| Virtual Reality From the outset of development of the Jonah field and the Pinedale Anticline, BLM has placed all of its air quality justification for allowing that development to proceed on computer modeling of the anticipated effects upon the local atmosphere in terms of visibility and NOx emissions. This modeling is performed by a contractor, selected and paid by industry, using a code called CALPUFF. I have argued from the beginning that this process is seriously flawed. Garbage in, Garbage Out First, the use of wind history is necessary to the computation process to predict transport of emissions and mixing at levels upward from the surface. The Jonah environmental impact assessment modeling exercise (EIS) and possibly the initial Anticline modeling (attribution of data is uncertain for the latter) drew upon wind data from 1995 and was averaged over the year even though the modeling process was applied to the post-2000 time frame. The current Anticline infill environmental impact statement modeling exercise draws upon an operator's met station wind history from 2004 which again is averaged over the year. It can be demonstrated that climate behavior and wind patterns have altered significantly since the decade of the 90's; also each year of the current decade has presented individual characteristics. Additionally, upper wind behavior was interpolated between measurement stations in Riverton and Salt Lake City, a straight-line distance of 260 miles across three mountain ranges. This should be highly suspect because Sublette County is bordered by two of those mountain ranges. The gas fields in question lie between them. They come to a point in the northern part of the county thus forming a kind of inverted "V." Wind behavior in this "V" is very complex, poorly monitored and therefore poorly characterized. During a year, surface winds can be seen to track from the west-southwest in the lower part of the state when monitors such as the state DOT monitor stations are sampled and yet monitors in the upper regions of the "V" will often come from the north-west at the same time. There is a definite possibility that part of the southwestern winds run up against the southern reaches of the Wind River Range and are turned northward to run parallel to the range. However, the frequent winds traveling down from the top of the "V" toward the southeast surely complicate matters. The outcome could very well be a very much more complex mixing and transport process than BLM modeling has fallen badly short of replicating. Finally, the wind behavior being applied in the modeling exercise draws upon wind input that averages the entire year. I argue that this is inappropriate because such averaging masks significant month-to-month variations of wind directional and speed variation characteristics. Most importantly, the summer months when drilling activity is highest is also the period when winds travel most often toward the Wind River Class I airshed and the other Class I regions further north. Real Reality Evidence that the modeling process is seriously underperforming can be found in the revelation of 2005 that NOx emissions were badly under-predicted. The predicted level, as contained in the Pinedale Anticline EIS, for NOx was 690 tons per year (tpy) but actual DEQ monitoring results revealed a level of 1876 tons per year which represented an under prediction of 2.7 times. However, that revelation has been revised further upward in the draft EIS for the Anticline infill to five times the predicted 690 tpy. Furthermore, although ozone is not modeled, February of 2005 and 2006 have seen an exceedence over EPA allowed levels of ozone which the Agency has formally declared not to have been caused by meteorological influences (click compendium-"Brown Storm Rising"). Ozone is an issue because of its human health impact and because it is formed from NOx and VOCs.(click "visibility chemistry") * * * * * * * * * * * * * * * The tables and charts that follow are presented as evidence that wind behavior is far more complex than is being treated in the modeling process. It must be emphasized that these data are illustrative of surface wind behavior and they are derived from the only measurement station present in the Upper Green River/Sublette County region, namely the Big Piney airport. However, that facility is nicely placed in relation to the Jonah field and should be a close representation. Nevertheless, the data are at best a limited look at what seems to be going on. However, the same can be said about BLM treatment of the subject. Finally, it should be added that many wind measurements in each month are below ten miles per hour and are probably heavily influenced in direction by surface terrain. Thus, it would seem to be difficult to assess meaningful transport of emissions in any long distance direction without quality monitoring of that action. That having been said, there is still a huge proportion of wind data at higher speeds, linked to directional behavior, to demonstrate possible serious transport behavior into the two flanking mountain ranges. Perry Walker |