Pub.1 2019-2020 Issue 1

Ozone Challenges Leading UPA to Team Up B oth our upstream and downstream members have been spending considerable time and energy on ozone nonattainment issues. As a refresher, both the airsheds along the Uintah Basin as well as the Wasatch Front were declared in nonattainment of the 2015 ozone standard (70 ppb for an eight-hour average) effective August 3, 2018. Areas classified as marginal nonattainment must either attain the standard or be bumped up to moderate attainment by the third year after designation (August 2021). Based on current data, both the Wasatch Front and the Uintah Basin are anticipated to bump up to marginal nonattainment. What does that actually mean? The start of an ever escalating series of regula- tions, costs and uncertainty, all without any assurance that those burdens will actually result in the needed air quality improvements. While that may sound like the typical industry skeptic view, there is broad consensus amongst vari- ous stakeholders that unfortunately, the best available models of Uinta Basin air quality are unable to accurately simulate reality. Regulatory emissions reduction plans that rely on flawed models are certain to have an economic cost but are likely to be ineffective at reducing ozone. With the August 2021 deadline getting closer, UPA’s efforts to find solutions have been ramping up. In the spring, we announced a joint effort between UPA and the Utah Mining Association (UMA) focused on the Wasatch Front. We are collaboratively work- ing to demonstrate the impact of exceptional events, such as wildfires, while also evaluating the role of transport of domestic and international background ozone. This work effort will take months of rigorous evaluation before we have confidence if the strategy can support demonstrating attainment of the stan- dard “but for” the combined exceptional events and international emissions (per Section 179B of the Clean Air Act). For updates on this effort, please reach out to Rikki or Rachel Agnew with Chevron, who is currently the Chair of the Refinery Environmental Subcommittee. Looking ahead, this committee is also closely following the work of DEQ and EPA on the Clean Data Determination for the Salt Lake PM 2.5 nonattainment area. Similarly, to better coordinate efforts and resources, our Upstream Committee has partnered with the Western Energy Alliance (The Alliance) to create the Joint Utah Upstream Air Quality Subcommittee. This subcommittee works jointly on all air quality issues impacting the Uintah Basin, from various upcoming Federal Implementation Plans (FIPs) to the looming jump to moder- ate ozone nonattainment. The challenge of being able to defend an attainment demonstration for the basin is significantly greater than along the Wasatch Front. UPA’s goal for the basin is rather to halt the inevitable progression from moderate to serious nonattainment and beyond. Efforts are underway to consider such strategies as well as what further data and modelling will be needed to tackle this issue. In addition to these efforts UPA actively participates in the Uintah Basin Ozone Working Group and is excited to join the steering committee as Dr. Laura Nel- son from the Office of Energy Development steps up to lead the group. Many thanks goes out to Marie Durrant for helping to bring the broad stakeholder group together and her leadership of the group for more than a year. UPA and the Alliance recently jointly commented on the Advanced Notice for Proposed Rulemaking for a Federal Implementation Plan to Establish a Bank for Ozone Precursor Emission Reduction Credits from Existing Sources on Indian Country Lands Within the Uinta Basin Ozone Nonattainment Area, (ANPR). We look for- ward to continuing this collaboration to find proactive solutions to the basin’s air quality challenges. We were also honored to host EPA Region Eight Administrator Gregory Sopkin for a lunch and learn event in Denver on August 9th. Administrator Sopkin talked about his focus on communication and transparency as well as a desire to allow states to come up with locally tailored solutions that meet their needs while also fulfilling EPA requirements. We applaud the Administrator for delivering on those principals in the following productive and engaging conversation. Topics discussed ranged from the current limitations and areas of needed improvement in the air quality model for the basin, to concerns around the emissions inventory, the Wasatch Front Clean Data Determination and forward path on PM 2.5 and various other upstream and downstream air quality issues. UPA is committed to being part of the solution to our air quality challenges both along the Wasatch Front and in the Uintah Basin. We will continue to advocate for smart solutions and look for opportunities to partner to pool resources and leverage expertise. 13 UP DATE