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Implementation of an Interagency MOU to
Safeguard Air Quality and Improve Coordination for Federal Oil & Gas NEPA
DecisionsBureau of Land ManagementU.S. Forest Service
Environmental Protection AgencyNational Park ServiceFish & Wildlife Service
WESTAR MeetingApril 16, 2012
Catherine Collins Branch of Air Quality FWS 1
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Overview MOU Purpose, Concepts &
Goals MOU Implementation
NEPA Air Quality MOU Basics:
Signed on June 23, 2011, by USDA, DOI and EPA officials
Five participating agencies
EPA BLM FWS NPS FS
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Purpose of the MOU Collaboration: Improve collaboration and respect in
conducting analyses of air quality and AQRV impacts and mitigating those impacts;
Certainty: Provide greater certainty and transparency for agencies, project proponents, and the public regarding the conduct and review of air quality and AQRV analyses in the NEPA process, and the application of mitigation;
Regional Perspective: Promote and support a regional perspective on air resources, and collaborative development of appropriate regional air quality assessments; and
Mitigation: Encourage both integration of design features that reduce emissions and application of cost-effective mitigation measures in projects covered by this MOU.
What Does the MOU Mean for Federal Decision Makers & Planners? Managers’ decision space for Federal oil &
gas decisions remains the same under the MOU.
The process Agencies use to gather and disclose information is different.
The new process emphasizes collaboration. The MOU does not change the roles or
responsibilities of states or other partners, or interfere with states’ regulatory authority.
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Air Quality and Oil & Gas DevelopmentMOU Premise
The agencies: “acknowledge that air resources are important and
merit protection within their respective legal authorities. Accordingly, the Agencies will strive to ensure, to the maximum extent practicable,
that Federal decisions relating to oil and gas will not cause or contribute to exceedances of the
NAAQS, nor adversely impact AQRVs . . .”
MOU Section I., page 3
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Air Quality and Oil & Gas DevelopmentMOU Premise
"recognize that Federal land management agencies must consider multiple
resources when authorizing activities, and, therefore, acknowledge that air
quality and AQRVs are among the many resources that must be considered in
the decision making process." MOU Section I., page 3
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MOU Benefits and Desired Outcomes
Early collaboration will ensure all agencies are informed, have opportunity to participate and reduce disagreements and resulting project delays.
Procedures will ensure air quality and AQRV analyses follow a consistent approach
Encourages consistent consideration and protection of air quality and AQRVs
Air Analyses The MOU outlines steps that all 5 Agencies
will use to decide when modeling is appropriate, including:
- Reasonably foreseeable number of wells;- Emissions Inventory; and- Application of modeling criteria that consider
a plan or project’s emissions/impacts and location.
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Land Use Planning Stage
Project Stage
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Specific Procedures: Air Analyses
MOU requires air quality modeling when specified criteria are met – criteria include:
Emissions/Impacts Geographic location
MOU Mitigation Measures
The Lead Agency will identify mitigation in collaboration with Agencies.
The Lead Agency will:- determine appropriate mitigation to
eliminate or reduce adverse impacts to air quality & AQRVs;
- ensure its implementation;- consider a monitoring and enforcement
program; and- take appropriate action if mitigation is
not effective.
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MOU Benefits and Desired Outcomes
Encourages efficiencies through reusable data, reducing cost and analysis completion time.
Provides a resolution process, with specified timelines and hierarchy of decision makers, if a dispute arises.
If the Lead Agency follows the procedures in the MOU, then EPA agrees it will deem the AQ and AQRV analysis as adequate;
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Accomplishments since signing the MOU on June 23, 2011
The Joint Agency Implementation Team focused on: disseminating information
about the MOU, planning implementation, and developing and providing
trainings.
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Accomplishments since signing the MOU on June 23, 2011
Briefings and Coordination
Stakeholders were briefed upon signature of the
MOU All agencies have briefed their staff AQ MOU Basics: What, Why and How AQ MOU Procedures and Decisions Questions &Answers Session on the MOU Technical Training for Air Specialists & NEPA
Specialist
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Accomplishments since signing the MOU on June 23, 2011Future Implementation Activities
The I-Team will continue to: provide outreach and resources look for opportunities to share
information about the MOU with interested states and other stakeholders
Take-Away Messages The MOU’s collaborative approach preserves managers’
decision space for Federal oil & gas decisions, but; New procedures will be used for the NEPA air quality &
AQRVs analyses and mitigation determinations. The MOU guides Federal Agencies’ working
relationships and does not change States’ regulatory authority or NEPA participation.
Focus on increased efficiencies through more effective interagency collaboration & dispute resolution.
The MOU recommends methods to increase efficiencies through reuse of modeling data.
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Where can I get the MOU & Additional Information?
DOI Press Release: http://www.blm.gov/wo/st/en/info/newsroom/2011/june/NR_06_27_2011.html
White House: http://www.whitehouse.gov/the-press-office/2011/08/31/white-house-announces-steps-expedite-high-impact-infrastructure-projects
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Agency Web Pages:
NPS: http://www.nature.nps.gov/air/ FWS: http://www.fws.gov/refuges/AirQuality/index.html FS: http://www.fs.fed.us/air/ EPA: http://www.epa.gov/compliance/nepa/index.html
& http://www.epa.gov/gateway/learn/airpollution.html BLM: http://www.blm.gov/wo/st/en.html
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Who Can Answer Questions?Implementation Team members
FS: Ann Acheson, National Air Program FS: Jeff Sorkin, Rocky Mountain Regional Office BLM: Kerry Rodgers, BLM-WO BLM: Dave Maxwell, NOC FWS: Catherine Collins, Branch of Air Quality NPS: Andrea Stacy, Air Resources Division EPA: Jessica Trice, HQ NEPA Compliance EPA: Ken Distler, Region 8
The Joint Agency Implementation Plan lists other contacts.
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Questions
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