Expert John V. Molenar Final EIS Comments

John V. Molenar

February 17, 2003

Director, Bureau of Land Management
Attention: Ms. Brenda Williams, Protest Coordinator
1620 L Street, N.W., Room 1075

Dear Director:

Enclosed is my protest of the "Final Environmental Impact Statement and Proposed Plan Amendment for the Powder River Basin Oil and Gas Project (WY-070-02-065), January 2003", (PRBO&G FEIS). I am an Atmospheric Physicist and owner of Air Resource Specialists, Inc. I have been involved in research, monitoring, modeling, and analysis of visibility and air quality issues for over 25 years. My company is a visibility/air quality/permitting contractor to (among others) the National Park Service, U.S. Forest Service, Bureau of land Management, U.S. Fish and Wildlife Service, the western states of Arizona, Colorado, New Mexico, and Wyoming, and many private business's in the west. During the past 20 years, I have been an active participant in every major visibility studies in the western United States. As well as my work as an atmospheric scientist, I have also been an active participant in western air quality policy organizations. I was a member of the Grand Canyon Visibility Transport Commission's (GCVTC) Aerosol and Visibility and Public Advisory (PAC) Committees. As a member of the GCVTC PAC, I was deeply involved in preparing the GCVTC report: "Recommendations for Improving Western Vistas, Report of the Grand Canyon Visibility Transport Commission (GCVTC) to the United States Environmental Protection Agency". I am currently a member of the Western Regional Air Partnership (WRAP) Aerosol, Monitoring, and Research and Development Forums. The WRAP is the regional planning organization (RPO) that will be developing guidelines for western states to comply with Regional Haze as well as other air quality regulations. I believe that I am highly qualified to offer my opinions on the PRBO&G FEIS.

My protest is based on a comprehensive review of the air quality and visibility analysis sections of the PRBO&G FEIS, BLM's response to comments on the DEIS, and updated Technical Support Documents prepared by Argonne National Laboratory. I believe that while the FEIS and Argonne's updated reports reasonably address some but not all of the issues raised in comments on the DEIS, the significant air quality and visibility impacts predicted in the FEIS still underestimate the magnitude of these impacts. This is due to an underestimation of PRBO&G project and regional cumulative emissions, use of lower ambient air quality levels as a baseline than actually is occurring in the region, an incomplete refined visibility impact analysis, and a failure to examine the visibility degradation of the 20% cleanest days as specified in the National Regional Haze Rule.


John V. Molenar
Vice President