PINEDALE, Wyo. -- State, federal and company officials admit they don't fully understand how to restore air quality and avoid further exceedences of federal Clean Air Act standards in the once-pristine airshed of the Upper Green River Basin.
Yet the U.S. Bureau of Land Management has already begun analyzing proposals for major natural gas field expansions that will add up to 4,338 new wells in the area.
Despite significant reductions in the volume of emissions from the Pinedale Anticline and Jonah natural gas fields in recent years, the area remains prone to ozone spikes -- a human health risk. Ozone spiked beyond federal thresholds 13 times this past winter, and triggered 10 state-issued alerts, warning people to remain indoors.
Ozone is best known as the main ingredient in urban smog, according to the U.S. Environmental Protection Agency. Naturally occurring ozone in the stratosphere helps protect the earth from the sun's ultraviolet rays. But at ground level, and in high concentrations, ozone is harmful to human health, plants and wildlife.
The federal ozone standard that is not being met today in the Upper Green River Basin is set to become even more stringent this summer. The continuing ozone problem has triggered a process under the Clean Air Act to declare Sublette County a "nonattainment" area, a designation that strictly prohibits any further deterioration of air quality.
Yet industry asserts that the BLM has committed itself to issuing a Record of Decision on EnCana Oil & Gas USA's 3,500-well "Normally Pressured Lance" project (known as NPL) by April 2014. If federal officials attempt to meet that timeline, it would mean the industry, the BLM and Wyoming regulators have just three years to figure out how to expand natural gas development while complying with air quality standards that are not being met at today's higher ozone threshold and slower pace of development.
How can such a feat be accomplished?
"It is a big question, and the answers are equally big," said EnCana spokesman Randy Teeuwen.
EnCana and other natural gas operators say the massive shale gas resource in the Upper Green River Basin is packed into concentrated areas, and that makes it logistically possible to consolidate facilities, and those efficiencies make it economic to employ advanced emission-cutting technology.
"We will ensure that emissions will be below the previous levels in Jonah, for the NPL. ... We are very confident that we can do that," Teeuwen said.
BLM officials are guardedly optimistic. In addition to advanced low-emission technology and consolidating facilities, BLM officials say gains can be made by cutting emissions from existing oil and gas facilities. Such is the case for the proposed 838-well LaBarge Platform infill project, according to the BLM.
Allowing the industry to drill 838 new wells in the LaBarge field presumably would include requirements to modernize the field and plug leaks from older wells and pipelines.
"Through these best management practices, we think we can arrive at a point where we can allow the future development to occur. Depending on results, it could be at a slower pace than they'd like. But they will be allowed to produce those fields," said Bill Hill, Wyoming BLM's deputy state director of Resource Policy and Management.
Others doubt Wyoming can adequately resolve multiple air quality issues while expanding natural gas development.
"Where I come from, if you have a problem you fix the problem before you move on down the road," said Laramie resident Pete Gosar, who is among several Wyoming residents who have advocated a slower pace of development.
Gosar grew up in Pinedale and still has family there. He ran unsuccessfully for the Democratic nomination for Wyoming governor in 2010, and campaigned on a pro-energy stance that included stringent protection of Wyoming's other natural resources.
"This is not something to be played with. These are people's lives," Gosar continued. "It's very sad to watch. In my lifetime -- and I'm only 43 -- we went from celebrating the cleanest air and water to, now, the worst air on occasion in America."
Environmental groups such as the Wyoming Outdoor Council note that spiking ozone isn't the only air quality problem in the area. Regional haze requirements are not being met, and deposition of sulfur and nitrogen compounds is increasing the acidity of some high mountain lakes, according to studies by the U.S. Forest Service.
Wyoming Outdoor Council officials insist that federal law prohibits the BLM -- or the U.S. Forest Service and other federal agencies -- from permitting new activities that would cause violations of Clean Air Act standards, and that agencies are obligated to regulate development of federal leases "as needed" to avoid such violations.
"What's needed most is for people to have a holistic concept of what's going on over there," said Bruce Pendery of the Wyoming Outdoor Council. "It's more than just air. The mule deer population crashed. There's haze in the Class One areas, ozone exceedences. ... Boy, we need to start doing some things differently."
Leslie Rozier, a nurse practitioner at the Pinedale Medical Clinic, recently had to add a new step to her routine in diagnosing patients. She now goes online to check the ozone concentration as monitored by the state of Wyoming.
"There's something wrong with that," said Rozier, in light of Wyoming's long-held reputation of having clean air.
The Upper Green River Basin commonly experiences temperature inversions during the coldest part of the winter - long periods when cold air is trapped close to the surface and the wind doesn't blow in the valley.
When there's an inversion, volatile organic compounds (VOC) from natural gas facilities and nitrogen oxides (NOx) from tailpipe emissions are suspended low in the valley -- along with smoke from wood-burning stoves and other background pollution. If the valley is blanketed in snow, then the VOCs and NOx are exposed to direct sunlight and light reflected from snow, causing a photochemical reaction that creates ozone.
Working with the Wyoming Department of Environmental Quality, natural gas operators on the Anticline have spent millions of dollars to reduce emissions. Their efforts succeeded in reducing VOC emissions 50 percent and NOx emissions 75 percent compared to 2008 levels. Throughout Sublette County, VOC emissions have dropped 20 percent, and NOx decreased 25 percent, from 2008 levels.
But it still wasn't enough to avoid 13 "high ozone events" this winter.
So far there's not enough scientific evidence available to say whether high ozone concentrations are aggravating respiratory problems in Sublette County. A human health impact study paid for by Sublette County failed to definitively determine the human health effect of spiking ozone in the area, but indicated it likely has not impacted health, according Wyoming Department of Health officials.
Still, residents are concerned.
In March, Rozier sent a newborn back to the hospital in Jackson -- 1,000 feet lower in elevation -- because the baby was hypoxic, which means a dangerously low blood oxygen level. The child was having trouble coming up to high altitude in Pinedale, so Rozier sent the baby back to Jackson. But doctors also had to consider something else: Sublette County was under an ozone advisory that day.
"This kid can't come home because we have 161 parts per billion ozone in the field across from his family's house," Rozier said.
At ground-level, a high ozone concentration can cause nose, throat and eye irritation, and shortness of breath. It can be extremely dangerous -- even deadly -- to the elderly, children and those with respiratory problems.
The federal eight-hour average threshold for ozone is 75 parts per billion (ppb), a standard set under the Clean Air Act to protect human health. The highest eight-hour average in Sublette County was measured on March 2 at 124 ppb -- higher than Los Angeles' worst ozone day during the past year.
The U.S. Environmental Protection Agency is expected to issue a new primary ozone standard of 60 to 70 ppb and establish a secondary seasonal standard. The new standards could be issued as early as July.
Approximately 94 percent of the VOCs and 60 percent of the NOx believed to contribute to the ozone problem come from natural gas development, according to Wyoming DEQ documents. But state and federal regulators failed to collect baseline air quality data before major drilling began some 10 years ago, causing some to speculate about how much of the ozone problem can be attributed to pollutants carried from urban centers of the West.
Nonetheless, industry and regulatory officials say they're focused on cutting emissions from natural gas development.
Pinedale Anticline operators Shell, Ultra Petroleum and QEP Resources Inc. note that the Pinedale Anticline drilling project underwent several public permitting processes during the past six years, and the resulting 2008 "record of decision" acknowledged the potential for unforeseen environmental effects and required that those be "mitigated." Essentially, operators say the 2008 decision allows them the opportunity to resolve the spiking ozone problem without shutting down current operations.
"We all agreed that there was a level of mitigation required to make those impacts acceptable," said Ultra Petroleum spokeswoman Cally McKee, adding that the operators have pitched in a total $13 million to a monitoring and mitigation fund. The companies are committed to eventually contributing up to a total $36 million.
EnCana is committed to contributing $36 million for similar mitigation efforts.
But many area residents say they didn't bargain for the level of air quality degradation that has occurred, or a major decline in mule deer on the mesa as a result of the development. At a public meeting in Pinedale in March, residents spent about two hours airing their frustration and imploring state and industry officials to take serious action.
"Anybody who used to be here in the '70s knew we had the best air in the country," said Rita Donham, who lives in a small community northwest of Pinedale. "Everyone is getting sick of this."
In regard to new permitting actions, such as EnCana's NPL project, some residents and environmental groups say they will ask for very different requirements than current plans. Some Pinedale residents have suggested the upcoming federal decision should include an option or requirement to slow or shut down operations in the proposed new NPL field in winter.
Prone to ozone spikes
"I'm really disappointed that we haven't solved that damned ozone problem," Wyoming DEQ administrator John Corra said.
Corra noted that the ozone concentration in the valley typically remained well below the eight-hour 75 ppb threshold this winter -- even on days before and after the 13 high ozone events. This, according to state officials, suggests that the area's geography and atmospheric conditions make the Upper Green River Basin particularly prone to ozone spikes, even as the industry reduces its VOC and NOx emissions.
Yet the state can't simply blame Mother Nature and forget about the problem. Not only are local residents deeply disturbed, but Wyoming has some federal requirements to meet.
With primacy over the Clean Air Act, Wyoming DEQ is required to address not only the spiking ozone problem, but also regional haze in the Bridger-Teton National Forest, and nitrogen and sulfur deposition that scientists believe is causing some high mountain lakes to become more acidic and prone to algae blooms.
"So the state will continue to have primary authority in regulating pollution in the Upper Green River valley and elsewhere. But EPA sets the standards, not the state," said Bruce Pendery of the Wyoming Outdoor Council.
"We have to find ways to reduce pollution. If not, then they have to regulate how quickly they're drilling those wells," Pendery continued. "What gets (into) my craw is when an agency says ‘We're going to do more monitoring and more studies.' Boy, I don't think that works any more."
Scant baseline data on air quality was collected before major drilling began in the Upper Green River Basin, but the quality was generally considered very good.
The general strategy to address ozone so far has been to reduce the volumes of VOCs and NOx -- precursors to ozone -- from the Pinedale Anticline and Jonah gas fields. But ozone spikes may depend more on the ratio of VOCs and NOx rather than the volume, according to state and industry officials.
"It's really complicated, because if you bring down VOCs and NOx, it doesn't necessarily mean there won't be high ozone (events)," said Wyoming Department of Environmental Quality spokesman Keith Guille.
And much of what is known in the U.S about ozone has been drawn from work to address broader ozone problems in California, making it difficult to apply models to the Upper Green River Basin.
"That's where we have the modeling effort and where we're having difficulties," said Guille.
Gas operators have helped the state expand its air quality monitoring system in the region in recent years, and the state has assembled a team to analyze spiking ozone and the broader spectrum of air quality concerns in the region.
In order to write emission parameters for new natural gas projects, state and federal regulatory agencies must look for the best emissions inventory data they can find. But the inventory over a broad, multistate region comes in piecemeal fashion.
Still, industry officials insist they can continue the recent trend of drilling more wells with fewer emissions.
"It's important to note, you're right, we don't know what it's going to take to be enough. But we do believe that continuing to reduce the emissions will help address the problem," said Shell spokeswoman Darci Sinclair. "When you talk about slowing the pace of development, technology is essentially doing that for us."
Intent on development
A recent report by Headwaters Economics suggests Wyoming's revenue rides high and low based on the energy commodities it's tied to: coal, natural gas and oil. Revenue from mineral extraction contributed more than $3.5 billion to state coffers in 2008, then slipped to $2.9 billion in 2010. Yet the industry continues to contribute between 60 percent and 65 percent of all state revenue, which has leaders here determined to keep coal, oil and gas exports flowing.
In April, Gov. Matt Mead underscored Wyoming's reliance on energy extraction and warned that if it becomes too expensive or onerous to produce energy in Wyoming, companies may leave.
"In order for them to continue to want to work in Wyoming, it has to be profitable," Mead said. "For those on the extreme side who say ‘Listen, we think Wyoming could be more pristine without energy,' ... It's also true it could be more pristine without roads and more pristine without people. But I'm not going there as governor."
Mead has qualified his push for more energy development by insisting that environmental impacts will be limited to an acceptable level. Others argue that that line has already been crossed.
"I think we're increasingly at a point where unfettered development is really hard to justify. It's leading to public health hazards and that's really not acceptable," said Pendery.
Sublette County Commission chairman Joel Bousman said some of his constituents feel that the environmental damage from natural gas drilling was more than they bargained for, while others believe the impacts are exaggerated and the community should be thankful for the revenue it's brought to the region.
"It depends on who you talk to," said Bousman.
Bousman said despite the differing views, everyone seems to agree that the ozone problem is priority No. 1 in Sublette County.
"The expectation of people, generally, is that they want to get on top of the problem," said Bousman. "Everybody realizes if they don't make significant progress, at some point, there's going to be a great restriction. EPA could come in, theoretically, and shut down activity."
WyoFile is a Wyoming-based, nonprofit news service.