Marcellus Shale

Ozone Obfuscation on Shale Gas

Living where I do, near the Delaware Valley, I have accumulated many friends over the years who have somewhat different opinions than me on a host of matters.  They are mostly folks who have “moved up from the city,” as both we and they say.  It’s a culture clash sometimes and often means we end up challenging each other a bit.  That’s, admittedly, a good thing whenever we can keep the debate civil, which is most of the time.  Recently, one of those folks sent around a piece to 300 or so of his closest friends, of which I was privileged to be one, that just cries out for such a challenge.

It’s a post on a website called Mom’s Clean Air Force that focuses on ground-level ozone (that’s the bad stuff, while the ozone up there in the stratosphere is the good stuff) and, in the process, completely obfuscates the facts with respect to shale gas and its impact on air quality.

This post, written by Elena Craft of the Environmental Defense Fund (where the article is also posted), makes a number of assertions that seem very credible on first reading, until you check the sources and the documentation, which present a far different picture.  Let’s take the cited sources and links one by one:

Industry Contributions to Ground-Level Ozone
Not Nearly the Issue Craft Would Make It Out to Be

Ms. Craft starts with a question that she promptly answers herself, although nothing that follows seems to support her conclusion:

Could emissions from natural gas and oil operations significantly contribute to ground-level ozone?  The answer is an unequivocal yes.

Her very first assertion on behalf of her argument is this one:

According to the state of Colorado, natural gas and oil operations were the largest source of ozone-forming pollution, VOCs and NOx in 2008.

The link she provides takes you to a set of regulations by the Colorado Air Quality Control Commission – regulations that apply to a wide range of industries.  While the regulations are accompanied with statements of purpose and limited background information, the statement to which Craft appears to refer actually says “oil and gas industry members are the largest anthropogenic stationary source of precursor pollutants in the State.”

There are, in other words, two hugely important qualifications.  First, the list of sources are limited to anthropogenic or human caused sources, so natural causes such as forest fires (think Colorado Springs) don’t count.  Secondly, we’re only talking stationary sources, so moving vehicles, which dwarf anything from natural gas production don’t count either.  When you take out forest fires, lightning (which can accounted for 36% of NOx produced in July, 2005, for example), soil, strong sunlight, hot weather and anything that moves, is it any wonder oil and gas might be a large source among what’s remaining?  Where’s the perspective here?

We can get some perspective from Environmental Protection Agency (EPA) studies.  There are two precursors to ground-level ozone; nitrogen oxides (NOx) and volatile organic compounds (VOC’s).  The EPA has inventoried both (see Tables 2-1 and 2-2).  Here is what they record for 1970 through 2004 in the way of anthropogenic sources and emissions for these two precursors (data is also available for intervening years):

NOx Sources and Emissions

NOx Sources and Emissions – Source: EPA

VOC Sources and Emissions - Source: EPA

VOC Sources and Emissions – Source: EPA

The tables indicate NOx and VOC emissions have both declined in a major way since 1970, despite economic, population and vehicle growth.  Moreover, the oil and gas industry has contributed to those improvements.  Most importantly, its emissions are minimal in comparison to highway vehicles, and those have dropped considerably as well.  This doesn’t mean there isn’t room for further improvement, particularly with NOx, which has exhibited small periodic upticks.  Natural gas is part of the solution, however, as it burns much cleaner than other fossil fuels.  Oil and gas industry emissions do, and for presumably this reason, receive significant attention in the Colorado report, but of a proactive sort.  Here, in fact, is some of what the Commission states in justification of its regulations:

These revisions constitute a forward-looking approach to deal with a rapidly growing source of air emissions, and are designed to reduce the possibility of future problems with respect to the attainment of National Ambient Air Quality Standards and state and federal Class I Area visibility goals.  Since the requirements are not mandated under federal law and are not currently necessary to meet National Ambient Air Quality Standards, they are being adopted as a state-only requirement in accordance with the Act and as provided for under the Federal Clean Air Act.

How is it that Colorado thinking ahead is evidence of current problems?  Moreover, the adoption of state regulations that are neither mandated, nor necessary, to meet standards hardly makes a compelling case for rampant pollution, does it?  No, this is nothing more than the State of Colorado doing its job.

A Case of Texas Sized Parsing of the Data

The next assertion in the Mom’s Clean Air Force article is this:

The Texas Commission on Environmental Quality has reported that storage tanks used in the exploration and production of natural gas and oil are the largest source of VOCs in the Barnett Shale.  Recently, there have been additional concerns that San Antonio may not meet federal ozone standards due to Eagle Ford Shale development.  Peter Bella, natural resources director at the Alamo Area Council of Governments, told the Houston Chronicle that the city is “right on the edge of non-attainment.”

Curiously, there is no specific source noted for the first statement.  But, we know the source.  It was a paper produced by discredited shale gas opponent and “crucify them” Regional EPA Director Al Armendariz when he worked for the same Environmental Defense Fund from which Ms. Craft hails.  His findings were wrong when he made them and subsequent TCEQ studies indicate VOC emissions from Barnett Shale natural gas sites are less than half of the VOC emissions from non-oil and gas mobile sources.  Perhaps this is why Ms. Craft chose not to cite her source in this instance.

She does provide a source for the Peter Bella quote but, if one goes to that source, they’ll find these quotes (emphasis added):

San Antonio is currently the largest city in the United States in full compliance with all federal air quality standards,” said Peter Bella, natural resources director at the Alamo Area Council of Governments, but the city is “right on the edge of non-attainment.”

A big unknown is how Eagle Ford Shale drilling will affect ozone levels in the San Antonio area. Federal standards look at a three-year average of ozone levels using area monitors set up by the Texas Commission on Environmental Quality.

We don’t have the data we need,” Bella said, “but we’re working hard to get it.” That will require looking at a range of equipment, from diesel trucks to pumps, compressors, rigs and pipelines, he said.

Computer modeling shows that ozone can be present in areas far from the emission source, Bella said. Prevailing winds could carry pollutants from the shale into the San Antonio area.

At the same time, though, the ozone-causing pollutants are falling in metro San Antonio, Bella said. That’s because many vehicles are burning cleaner fuels and a number of industries, along with the city and CPS Energy, have adopted policies that have helped reduce overall pollution.

So far this year, San Antonio remains below the ozone standard, “but we still have the toughest months to come, August and September,” Bella said.

Railroad Commissioner David Porter said the commission and some oil and gas companies may launch a program to use natural gas to power on-site generators to power operations in the shale.

Ms. Craft, obviously, chose to leave out all the good parts.  She didn’t mention San Antonio is the biggest urban air quality success story in the U.S., that her source acknowledged a lack of data, that he was relying upon computer modeling (speculation), that ozone causing pollutants were falling because of cleaner fuels (natural gas, maybe?), that the city meets standards or that the solution to further reducing ozone is MORE use of natural gas.  Talk about parsing of the data!

Broken Links – Broken Data

Next, Ms. Craft says this:

In 2010, air quality exceeded national health standards for ozone nearly seventy times in Utah’s Uintah Basin.  Concentrated natural gas and oil development in the Uintah Basin has been identified by the Bureau of Land Management (BLM) as the primary cause of the ozone pollution.

The first link she cites is a broken one.  What she doesn’t say with regard to the second link cited, is that it was an analysis conducted by the BLM for the specific purpose of entertaining natural gas development on its lands.  Moreover, the report says the following about existing air quality (emphasis added) and the reader will need no explanation of how this varies from what Craft has said:

Based on the emission inventories developed for Uintah County, the likely dominant source of ozone precursors at the Ouray and Redwash monitoring sites are oil and gas operations near the monitors. The monitors are located in remote areas  where impacts from other human activities are unlikely to be significantly contributing to this ozone formation.  Although ozone precursors can be transported large distances, the meteorological conditions under which this cold pool ozone formation is occurring tend to preclude any significant transport.  Currently, ozone exceedences in this area are confined to the winter months during periods of intense surface inversions and low mixing heightsSignificant work remains to definitively identify the sources of ozone precursors contributing to the observed ozone concentrations.  Speciation of gaseous air samples collected during periods of high ozone is needed to determine which VOCs are present and what their likely sources are.

So, we have still another instance of Ms. Craft obfuscating the facts, stretching the truth and embellishing the story.  Additionally, Appendix J of the report notes even the proposed new natural gas development should not “exceed the 75 ppb ozone standard with either the 2005 or 2006 meteorologies for any of the project alternatives.”

Finally, there is this paragraph:

Residents of Wyoming’s Upper Green River Basin suffered thirteen unhealthy ozone days in 2011. Air quality in the Basin had declined so much due to emissions from natural gas activities that former governor Dave Freudenthal requested it be designated an ozone nonattainment area, which the Environmental Protection Agency (EPA) confirmed.

What do we find when we check out these sources.  Well, once again, the first link is a broken one.  The second one leads to another EDF post with similar claims as Craft offers.  It does include a supposed link to the former Wyoming Governor’s statement, but that link is broken, meaning the entire paragraph is effectively unsourced.  The State of Wyoming includes a site with background information, however, and it indicates the following (emphasis added):

Based on monitoring results from 2006 through 2008, the entire state of Wyoming is in compliance with this standard except for at a single monitor, the Boulder monitor, in Sublette County.  The Wyoming Department of Environmental Quality, Air Quality Division (AQD) evaluated whether a non-attainment area should be designated due to the monitored results at the Boulder monitor.  The AQD recommended that the Upper Green River Basin (UGRB) be designated as non-attainment for the 2008 ozone National Ambient Air Quality Standard (NAAQS).  The AQD based this recommendation on a careful review of the circumstances surrounding the incidence of elevated ozone events.  Elevated ozone in the UGRB is associated with distinct meteorological conditions.  These conditions have occurred in February and March in some (but not all) of the years since monitoring stations began operation in the UGRB in 2005.

Once again, the reality much less than what Craft and EDF would have one believe.  We can also find the former Governor’s letter at this site and it says:

Many local gas producers, working in cooperation with our DEQ, have aggressively reduced air emissions and those reductions will continue even as our natural gas resources continue to be developed.  These air emission reductions have occurred because of the application of Wyoming’s stringent air pollution permitting requirements; because of industry response to our calls for voluntary emission reductions…

This is indication that whatever is going in the Upper Green River Basin, it is both unique and being addressed cooperatively by the government and industry working together – as it should be.  Ozone, despite the scare tactics of shale gas opponents, is a declining problem, as the following chart from the EPA illustrates:

Ground Level Ozone Declines

Ground Level Ozone Declines

There you have it.  Mom’s Clean Air Force is hyping a problem.  The facts are clear.  Ozone is less and less of a problem nationwide, natural gas has little to do with it and is part of the solution.  No amount of obfuscation can change those facts, despite what Ms. Craft and others may offer.  I hope my friend will share this information in the same way he shared the original.  It’s the price of civility, after all.



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