Concerned citizens request Health Impact Assessment for PAPA
Ozone at 140 PPB in Jonah Field
On Tuesday, March 11th, ozone levels in the Jonah Field reached a high of 140 ppb during the one-hour readings at the DEQ air quality monitoring station. Chart by Pinedale Online, derived from data from the WYDEQ Jonah Air Quality Monitoring station. The county was under an Ozone Health Adivisory from the DEQ that day.
Repeated Ozone health alerts by DEQ causing heightened public concern about air pollution from natural gas drilling activity near Pinedale
by Dawn Ballou, Pinedale Online!
March 27, 2008 | Updated March 28, 2008
A number of citizens are taking it upon themselves to address health issues related to the recent wave of ozone advisory air pollution alerts issued by the Wyoming Department of Environmental Quality for Sublette County.
In the last month, WY DEQ has issued five Ozone Advisories for the county. On March 11th, during the third Ozone Advisory, ozone levels reached 140 ppb (one-hour reading) at the DEQ Jonah air quality monitor. Federal standards for ozone are currently 84 ppb. New tightened standards will soon make the lower limit 75 ppb over an eight-hour period.
There has been a growing public outcry in response to the ozone alerts, and frustration that local, state and federal government appear to be unresponsive to public concerns and doing little more than paying lip service by saying “we’re working on it.” To date, industry has been deafeningly silent on the subject. The major natural gas company players operating in the Jonah Field and Pinedale Anticline have not come out with public statements regarding the recent ozone alerts and the efforts their companies are taking to address the issue.
A group of concerned citizens is now circulating a Community/Public letter which asks that a comprehensive Health Impact Assessment (HIA) be completed in conjunction with the on-going BLM Pinedale Anticline Project Area (PAPA) Supplemental Environmental Impact Statement process. “The latest Draft SEIS (BLM-PFO, December 2007) did nothing to address the potential human health consequences of on-going and proposed federally permitted natural gas development activities in our county,” the letter states.
It will ultimately be sent to Wyoming Governor Dave Freudenthal, BLM State Director Bob Bennett, Centers for Disease Control Associate Directory for Science Andrew Dannenberg, EPA Region 8 Regional Administrator Robert Roberts, Wyoming Department of Health Director Dr. Brent Sherard, Wyoming DEQ Director John Corra, Shell Oil Company CEO Jeroen van der Veer, Ultra Petroleum CEO Michael Watford, EnCana Corp CEO Randy Eresman, Questar Corp CEO Keith Rattie, and BP Amoco CEO Tony Hayward.
The Sublette County Commissioners asked the Wyoming DEQ air and water quality representatives to come and speak to them at their March 18 meeting in Pinedale, however neither the Commissioners or DEQ informed the local newspapers, radio or Pinedale Online of the meeting to allow the public to be notified so they could attend. At that meeting, DEQ representatives told the Commissioners they hoped to schedule some kind of a public meeting at a future date.
(Editor's Update 3/27/08 11:00 PM: We received an explanation from the Sublette County Clerk on what happened regarding the DEQ meeting with the Commissioners. Apparently the Commissioners were in Cheyenne the week of February 18 and at that time invited DEQ head John Corra to make a presentation to them on water quality. That meeting was scheduled for the March 18 Commissioner meeting. All of that was prior to the ozone advisories, which started on February 27th. The time for the DEQ presentation changed several times due to scheduling conflicts. “It was unfortunate that the public didn’t know, but this was a presentation to the Commissioners, not DEQ holding a public hearing,” said County Clerk Mary Lankford. She said she will start sending us the Commissioner’s tentative meeting agendas ahead of time so we can post them online.)
We have asked the local BLM office twice, in writing, if they have any plans for a public meeting to give people an opportunity to ask BLM questions about local air quality issues and the five recent Ozone Advisories. To date, we have not received an acknowledgement of our inquiry or an answer from BLM to the question about any plans for a public meeting.
(Editor's Note, 3/27/08 11:00PM: The BLM told us today they will get back with us either tomorrow or next week on whether or not they will do a public meeting to answer questions about the ozone concerns.)
(Another Editor’s Note, 3/28/08: We’ve been working with the BLM trying to determine why our two messages asking for an official comment about the ozone issue were met with silence. We have determined that the person we sent the written request to was out of the office between March 7th through 24th. We sent our requests on March 9th & 11th, having always received prompt replies from e-mails in the past. So I want to make a public apology to Caleb Hiner and the Pinedale BLM for saying they failed to respond to our written requests for official comment. We/I should have followed through better in getting a response from them on this. – Dawn Ballou, Editor, Pinedale Online!)
We have also asked Wyoming DEQ for an answer to the question of how DEQ’s actions and regulatory authority might be different in handling the local ozone air pollution concerns if the Pinedale Anticline and Jonah Field were all being done on private land owned by a single private company contracting out the identical natural gas drilling activity, rather than under federal land ownership as it is now. We have asked DEQ twice for an answer to this question, in writing, but to date have not received a response from them.
Below is the letter being circulated in Sublette County by concerned citizens and gathering signatures:
Governor Dave Freudenthal
State Capitol Building
200 West 24th Street
Cheyenne, WY 82002-0010
Mr. Robert A. Bennett
Bureau of Land Management
Wyoming State Office
5353 Yellowstone Road
Cheyenne, WY 82009
Mr. Andrew Dannenberg
Associate Director for Science
Centers for Disease Control
Mail Stop F60
Chamblee, GA 30341
Mr. Robert E. Roberts
EPA Region 8
1595 Wynkoop Street
Denver, CO 80202
Dr. Brent D. Sherard, Director
Wyoming Department of Health
401 Hathaway Building
Cheyenne, WY 82002
Mr. John Corra, Director
Wyoming Department of
122 West 25th St.
Herschler Building-4th Floor Cheyenne, WY 82002
Mr. Jeroen van der Veer, CEO
Shell Oil Company
P.O. Box 2463
Houston, TX 77252
Mr. Michael D. Watford, CEO
Ultra Petroleum Corp.
363 North Sam Houston Pkwy E, Suite 1200
Houston, TX 77060
Mr. Randy Eresman,CEO
1800, 855 - 2nd Street SW
P.O. Box 2850 Calgary, AB T2P 2S5
Mr. Keith Rattie, CEO
180 East 100 South
P.O. Box 45433
Salt Lake City, UT 84145-0433
Tony Hayward, CEO
501 Westlake Park Boulevard
Houston, TX 77079
March 22, 2008
Re: Request for Human Health Impact Assessment
With growing concern surrounding human health issues in Sublette County, Wyoming, the undersigned request that a comprehensive Health Impact Assessment (HIA) be completed in conjunction with the on-going BLM Pinedale Anticline Project Area (PAPA) Supplemental Environmental Impact Statement process. The latest Draft SEIS (BLM-PFO, December 2007) did nothing to address the potential human health consequences of on-going and proposed federally permitted natural gas development activities in our county.
We are aware that the U.S. EPA gave the Pinedale Anticline Oil and Gas Development Project Revised Draft Supplemental EIS its lowest possible environmental rating, EU-3, citing concerns with elevated ozone levels, documented groundwater contamination, and visibility impacts in nearby protected federal wilderness areas. Such low rating is very rare and serves to emphasize the growing health related concerns in this area.
Most recently, the Wyoming Department of Environmental Quality issued three ambient ozone Alerts, with 8 hour averages in our county well exceeding the new 75 parts per billion National Ambient Air Quality Standard and documented at 122 ppb in some areas. It is somewhat fortuitous that this health disclosure occurred but it is also worth noting that these are the first of their kind in the history of Sublette County. Ozone is one of the key pollutants being added to our air from gas development, but only since 2005 has it been subjected to monitoring and then only in connection with Class I airshed visibility issues, i.e., the monitors were not placed for human health reasons. Ozone of course is a significant human health concern, elevating risk to children for asthma development and Chronic Obstructive Pulmonary Disease (COPD) acquisition later in life, among other negative outcomes.
However, of even greater concern than the revealed water and air pollution regulatory breaches are how many potentially un-discovered, and thus un-disclosed, human health risks exist attendant to this continuing local energy development. Health Impacts Assessments are designed to address exactly this critical knowledge gap.
Please be clear that we are not fundamentally opposed to oil and gas development in the Pinedale Anticline gas field. Energy development has flooded our county with revenue and jobs. But revenue alone does not preclude or necessarily remedy the associated impacts and pressures placed on our County and its citizens. It is therefore critical that management decisions be informed, with a full accounting made of all impacts and necessary remedies including those to human health.
We understand that the U.S. Interior Department’s Mineral Management Service last year completed a public health impact assessment regarding oil and gas activities in Alaska. Also, we note and laud that the International Petroleum Industry Environmental Conservation Association has produced A Guide to Health Impact Assessments in the Oil and Gas Industry , recognizing appropriate responsibility for human health in other energy development regions. Further, Shell Oil Company requires health impact assessments “prior to all new projects and major facility developments, as well as prior to the significant modification or abandonment of existing facilities.”
In conclusion, we strongly recommend that the HIA protocol utilized by the World Health Organization and U.S. Centers for Disease Control be adhered to, in order to assure comprehensive and thorough human health impact analysis. With reference to legal interests, such analysis should fulfill the broader human health analysis and disclosure requirements of the National Environmental Protection Act and Community Right to Know Act.
As members of the community we look forward to your prompt reply and to working with you on a comprehensive health impact assessment. For further information, you may contact Carmel Kail at (307) 367-3058.
U.S. Senator John Barrasso, MD
U.S. Senator Mike Enzi
U.S. Centers for Disease Control, Ms. Sarah Heaton
Sublette County Commissioners
Town of Pinedale
BLM Pinedale Field Office, Mr. Chuck Otto
Upper Green River Valley Coalition