“There is no safe level of air pollution.” (Newsweek) (BusinessInsider) (LATimes)
“Air pollution is still killing people in the United States” (time)
“…a growing body of evidence suggests that exposure can also harm the brain, accelerating cognitive aging, and may even increase risk of Alzheimer’s disease and other forms of dementia.” (Sciencemag)
“Oil and gas extraction is one of the largest industrial polluters in the San Joaquin Valley, emitting dangerous particle pollution, smog-forming volatile gases and toxic air contaminants,” said Genevieve Gale, executive director of the Central Valley Air Quality Coalition. “Additional air pollution from expanded operations adds insult to injury, keeping Valley residents at risk and limiting our ability to achieve clean air.”
“Expanding extraction of dirty fossil fuels on our public lands threatens the health of our communities and the future of our climate,” said Monica Embrey, a senior campaign representative at the Sierra Club. “We will push back every step of the way against this reckless plan to subject more of California’s lands, wildlife, and communities to fracking.” (CBD)
What they say in the EIS…
HOW MANY WELLS ARE WE TALKING ABOUT, ANYWAY?: (pg 2) “The RFDS projected the exploration, drilling, and production activity that would likely occur in the next 10 years, the anticipated life of the 2014 RMP. This was predicted to be approximately 100 to 400 federal wells to be drilled on federal mineral estate per year during the life of the 2014 RMP. This includes 90 to 360 wells per year on existing leases issued and 10 to 40 wells per year on new leases issued subsequent to the 2014 RMP approval date. Some of these wells were expected to be hydraulically fractured.”
First off, it is really hard to know how many will really occur and whether they will be conventional or fracking. The BLM start out with a guiding estimate…
(pg. 44) “The projected emissions included in the 2012 Final EIS are based on conventional well development for 400 wells over the 10-year period of the 2014 RMP, or an average of 40 wells per year on new leases. (Or more…It doesn’t say “maximum”) The analysis in this section projects the emissions of a maximum of four conventional wells that are also hydraulically fractured per year over a 10-year period.” (It projects an arbitrary number of 40 fracked wells out of 400 total over 10 years for the purpose of creating estimate tables. It doesn’t actually limit itself to 40.)
… (Pg. 53) “Emission factors based on per-well analysis are used in conjunction with a maximum new well development of an average of four new hydraulically fractured wells per year over the 10-year life of the plan.” (What is the maximum of an average?)
We disagree with their analysis. In Kern County, California’s major oil-producing county, 50 percent to 60 percent of new oil wells are fracked, according to estimates by Halliburton. And fracking may have been done elsewhere in California, since state officials haven’t monitored or tracked the practice until recently. If 40 wells are “allowed” a year, there could be 20 to 24 fracked wells, and 200 to 240 in 10 years.
(Pg. 52) “…Therefore, the potential impacts from the approximately 40 new hydraulically fractured wells are estimated based on hydraulic fracturing assumptions carried forward throughout this Draft Supplemental EIS. This analysis follows the methods and assumptions used for a similar analysis developed in the Central Coast Field Office Draft RMPA/EIS (BLM 2017)”
LET’S DISCUSS EMISSIONS: We’ll start with their low-ball scenario of an average of four new hydraulically fractured wells per year over the 10-year life of the plan.
According to the EIS (Table ES-2 below), “Emissions from hydraulic fracturing well development are summarized in Table 4.1.1. These emission increases are minimal, with the largest being NOx at 2.74 tons per year. Greenhouse gas emissions from hydraulic fracturing well development are summarized in Tables 4.1.5, 4.1.6, and 4.1.7.”
This language is deceptive, minimizing the damage that any well drilling poses. The emissions number is based on the ADDITIONAL greenhouse gas load over the amount already calculated for a conventional well. (See page 55, Table 4.1.1) As you can see from Table 4.1.2 below, the real story is that emissions from hydraulic fracturing more than doubles the projected NOx emissions from 2.18 tons/year to a project total emissions increase of 4.92 tons/year. This is for an “average” of 4 wells a year, based on “past behavior of drillers”.
Projected emissions from hydraulic fracturing typically increase above inventory, by pollutant, as follows:
- Nitrogen oxide – 2.18 + 2.74 = 4.92 tons/year
- Sulfur oxide – 0.41 + 0.004 = 0.41 tons year
- Reactive organic gases – 7.35 + 0.21 = 7.56 tons/year
- Particulate matter less than 10 microns in diameter – 0.35 + 0.08 = 0.43 tons/year•
- Particulate matter less than 2.5 microns in diameter – 0.35 + 0.08 = 0.43 tons/year
Table 4.1.3 (Pg. 57) states that the estimated greenhouse gas (GHG) emissions during development over the 10 years (of new wells construction and hydraulic fracking of four wells per year) = 779.2 MTCO2e per year
Table 4.1.4 (Pg. 57) states that the (GHG) during the “production phase” of the wells for an estimate for 40 wells over the life of the 2014 RMP” (It doesn’t specify conventional or fracked) = 20,779.2 MTCO2e per year
Table 4.1.5. (pg. 58) describes estimated “production phase + end use of GHG emissions for 40 hydraulically fractured wells = 221,119 MTCO2e per year. Just for comparison, Santa Barbara County’s threshold of significance for GHG emissions is 1,000 metric tonnes (MT) per year.
We believe it easily could be 5-6x more, due to Halliburton’s actual % used. 1,105,595 – 1,326,714 MTCO2e
SO WHAT’S THE LIFETIME EMISSIONS FOR THE ESTIMATED 400 WELLS?
It specifically doesn’t quantify GHG for conventional well development in the 2012 Final EIS. Why not?
Table 4.1.6 (pg. 60) shows that ozone levels from this proposal fail every county’s Air Pollution Control Distric Attainment Status with their applicable control plans except Santa Barbara..
Table 4.1.7 (pg. 62) compares the projected total emission increase per year to the ozone maximums allowable under each County’s Air Pollution Control District.
- San Joaquin: Extreme nonattainment for 8-hour ozone and moderate nonattainment for PM.
- Ventura: Serious nonattainment for 8-hour ozone.
- San Luis Obispo: Marginal non attainment for 8-hour ozone.
BLM’S ESTIMATES OF GHG MAY BE LOW…
- A new study by the Environmental Defense Fund finds that methane escaping from fracking operations in Pennsylvania “causes the same near term climate pollution as 11 coal fired power plants” and is “five times higher than what oil and gas companies report” to the state.
- A previous assessment by EDF last November found methane emissions escaping from oil and gas wells in New Mexico are “equivalent to the climate impact of approximately 12 coal fired power plants.”
What we say…
Report card of California air quality by district already: here (based on high ozone days). California is rated as having the “highest ozone levels” and “worst smog levels” in the country.
Grades for affected regions: Eastern Fresno (F), Western Kern (F), Kings (F), Madera (F), San Luis Obispo (F), Santa Barbara (D), Tulare (F) and Ventura (F).
According to the ARB, 80,000 deaths that occur each year in California may be attributed to illnesses aggravated by air pollution. While air pollution affects everyone, some people are more susceptible to its effects than others. Research has established that air pollution:
- Aggravates heart and lung illnesses.
- Adds stress to the cardiovascular system, forcing the heart and lungs to work harder to provide oxygen to the body.
- Speeds the aging process of the lungs, accelerating the loss of lung capacity.
- Damages respiratory system cells even after symptoms of minor irritation disappear.
- May cause immunological changes.
- Causes lung inflammation.
- Increases health care utilization (hospitalization, physician, and emergency room visits).
- May contribute to the development of diseases such as asthma, bronchitis, emphysema, and cancer.
- May cause a reduction in life span.