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San Juan Citizens Alliance has been actively involved in the Four
Corners Air Quality Task Force (4CAQTF) and the earlier New Mexico
Environment Department Ozone Task Force, since inception in 2002.
As described by the state, the Task Force is a broadly representative
group including government, industry, and citizens formed to look
at air quality issues in the Four Corners region. Increased development
in the area including new power plants, oil and gas wells, and
population growth all are contributing to air quality concerns.
Ozone levels in the region are close to exceeding the health-based
national air quality standards for outdoor air. Many residents
are concerned with potential health impacts from other pollutants.
An overall haze can often be seen in the skies, which impacts visibility.
There are concerns for the ecosystem due to deposition of mercury
and nitrogen. The responsible regulatory agencies will need to
address these issues in order to effectively manage air quality.
These agencies believe input from residents of the area is important
in developing an effective management plan.
The Task Force’s final product will be
a report of potential mitigation options as a guide to regulatory
agencies in developing air quality management plans (a draft
report is available on www.nmenv.state.nm.us/aqb/4C/documents.html). SJCA hopes these options are more than mere recommendations, and include real requirements for action to clean up our air.
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- Mandatory control measures and enforceable regulatory actions for reducing air pollution will advance quantifiable progress in improving air quality in the Four Corners region.
- Federal
agencies in the Four Corners region have emphasized reliance
on the 4CAQTF (and the earlier Ozone Task Force) as the means
to provide air quality mitigation. For the past four years, the
BLM’s
Farmington office has avoided implementation of mandatory air
pollution control measures while approving new oil and gas facilities
that often require wellhead or central compression. The BLM Farmington
office has stated that 73,565 tons per year of nitrogen oxides
is to be expected in the year 2023 from natural gas production
(over 12,000 wellhead compressors). This is more pollution than
PNM San Juan Generating Station and APS Four Corners coal-fired
power plants currently emit, combined.
- It is essential that improved
monitoring of air pollution emissions occur in the Four Corners
region. We need more monitors and properly located monitors to
accurately determine emissions including carbon dioxide, mercury,
ozone and particulate matter that are disproportionately high
in the Four Corners region.
- Ozone readings at Bloomfield ozone
monitoring site are already higher than the recommended limit.
San Juan County, the cities of Aztec, Bloomfield, and Farmington,
the New Mexico Environment Department and the Environmental Protection
Agency signed the San Juan County Early Action Compact in 2002.
The Compact was designed to keep San Juan County from exceeding
pollution standards for ground-level ozone. Since then, EPA’s
Clean Air Scientific Advisory Committee has recommended that
the United States adopt much stronger air quality standards for
ozone. Ozone readings at Bloomfield ozone monitoring site are
already higher than the recommended limit. If San Juan County
cannot remain in attainment for ozone, there would certainly
be significant economic and environmental repercussions. The
4CAQTF must require specific emission control measures to reduce
emissions of precursors of ozone.
- The emphasis on air pollution
emissions reduction for coal and natural gas facilities should
be on upfront design for pollutant source reduction rather than
reliance on uncertain future mitigation measures (including retrofits
for pollution control).
- The EPA regions 6 (includes New Mexico),
8 (includes Colorado) and 9 (San Francisco office oversees Navajo
Nation) must work together to oversee air quality emissions in
the Four Corners region, which are fragmented by jurisdictional
boundaries.
- SJCA urges that the 4CAQTF assist citizens in acquiring
complete public health records for the Four Corners region concerning
rates of human respiratory illness (including asthma), strokes,
heart attacks and autism in comparison to other communities in
the United States. It is particularly important that the historic
health records in the tribal areas (including Navajo Nation,
Southern Ute, Ute Mountain Ute) be obtained from Indian Health
Service since current and future planned emissions in the Four
Corners region severely impact tribal lands.
- SJCA believes that
modeling of existing and projected air quality pollution and
emissions in the Four Corners region has been woefully inadequate,
with poor input data, underestimated source emissions, improperly
located monitors, and inappropriate application of models. The
result is that Federal agencies in the Four Corners are using
faulty modeling and deficient planning documents to approve thousands
of air pollution sources (including natural gas wells and compressors)
that are marginally analyzed for air quality impacts, individually
and cumulatively.
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