OCS Alarm Bells Are Ringing Today – Please Go To the Library To
Support our Nation and to Save Alaska’s Economy! Our Readers Around the Country Should Send Written Comment. Scroll to the bottom for instructions.
3600 Denali Street, Anchorage, Alaska
Informational meeting: 10 a.m.–11 a.m.
EPA Public hearing: 11 a.m.–2 p.m.
We are seeking public comment on a proposed Clean Air Act permit for Shell Gulf of Mexico Inc. (Shell), 3601 C Street, Suite 1000, Anchorage, Alaska 99503. The proposed permit will allow Shell to operate the Frontier Discoverer drillship and its fleet for a multi-year exploratory oil and gas drilling program within its current lease blocks from lease sale 193 on the Chukchi Sea outer continental shelf (OCS), beyond 25 miles from Alaska’s seaward boundary. Because the drillship operations are a “major” source, the permit must ensure that the operations meet the requirements of the Prevention of Significant Deterioration (PSD) program. The proposed permit is based on non-guideline ISC3-PRIME modeling system used to predict air pollutant concentrations.
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On OCS leasing. Last February, Secretary Ken Salazar (NGP Photo) postponed the comment period on the MMS 2010-2015 draft lease sale program to last Monday, September 21. That was a delay. But get comment he did and when Governor Sean Parnell visited him a few days ago the Secretary did not commit to timely deciding now that the comments are in. By the way, most comments favored moving ahead with leasing of OCS areas around the country. I testified with many NGP readers at the Secretary’s hearing last April.
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On Oceans Policy. A White House Ocean Policy Task Force met here in August charged with recommending to the President an ‘Oceans Policy’–in less than a year! This presidential assignment is either simply bizarre or it could be a pre-engineered strategy. Obviously, the anti-domestic energy crowd was out in force to testify but many ordinary folks were there as well, supporting reasonable energy exploration and production. I testified.… The Task Force is flying to Hawaii for a similar ‘meeting’ next Tuesday and by then the White House should have ‘call in’ instructions available.
- OCS Permitting. Now comes the EPA to Anchorage to ask the ‘public’ about a company that has done more to cooperate with Alaska, Alaskans and a demanding federal permitting system than any company in my memory. The EPA will be inviting us to comment on whether we think Shell’s vessels’ air quality permit should be approved. After spending over $2 billion on Chukchi and Beaufort leases and over a dozen million on the air quality permit alone, the least the company should expect is timely and reasonable regulatory decisions. Shell submitted an air quality permit application late last year and had it rejected, then reapplied, then was rejected again … and again. If that critical permit is not in hand by early 2010, will Shell abandon ship, or simply acquiesce to the reality that it has lost yet another year?
- The Cruise Ship Front. A federal ruling that imposes strict air emission standards on marine traffic in much of Alaska would drive up the cost of living for 90 percent of Alaskans and add another $100 million to the cost of operating cruise ships in the state. If Alaskans dont speak out, this rule will dearly cost all Alaskans as 90 percent of all consumer goods come through the Port of Anchorage, said John Binkley, president of the Alaska Cruise Association (ACA).
- The Congressional Front. Yesterday the Senate democrats blocked consideration of Senator Murkowski’s amendment limiting–for a year–EPA’s regulation of CO2. This amendment addressed an Administration process whereby the EPA is preparing to federally regulate emissions following an April 2007 Supreme Court ruling that carbon dioxide is a pollutant to be regulated under the Clean Air Act. Part of the EPA’s draft rulemaking involves regulation of ‘mobile source emissions’. The Administration and Congressional majority are, in effect, blackmailing holdouts that if they don’t vote on climate change (i.e. ‘tax and trade’) regulation that might treat emissions one way, the EPA big guns will be cocked and ready to fire on all significant carbon emitters from refineries to pipelines to ships and vehicles to farm animals, possibly. Either way, consumers lose. Kudos to Senator Murkowski for trying to keep anti-consumer, energy legislation at bay! See Alaska Standard story by Alex Gimarc and ADN story
- Other. Note that I’ve tried to simplify this by not mentioning how many industries, including oil and gas, could be affected by Administration endangered species initiatives dealing with the Cook Inlet Beluga whales and Arctic polar bears.
The sheer magnitude of regulatory and other requirements will take a toll on the country’s economy and affect the domestic energy industry’s ability and desire to invest in the U.S. OCS. Unless we fulfill our domestic energy potential, America’s consumers will suffer and should wake up while there is still time. In the draft testimony I’m working on for later this morning, I discuss EPA’s rejection of Shell’s air quality permit application:
- …because Shell didn’t provide you with the duration, frequency, hourly emission rates, and potential air quality impacts of an emergency generator on board, “FD-8”. [1]
- …because Shell wasn’t more specific about the number of “ice management vessels”, their direct impact on the modeling analysis, and, “because there is no guarantee by Shell that the same vessels will be used for ice management and oil spill response, what assurances are available that the vessels will have similar stack parameters and emission rates so as not to contribute or violate National Ambient Air Quality Standards (NAAQS), air quality increments, and permit conditions.”
- …because Shell Oil didn’t tell you exactly how many 37-foot long boats would be aboard a management vessel within the Spill Response (OSR) fleet, the number, duration and frequency of the water drill exercises for these boats, and quantifying the emission rates of each boat during each exercise.
"If I were to continue enumerating the volume and depth of minutiae here, I could not guess whether the majority of Alaskans would more likely go to sleep or rise up in frustration to demand that the EPA begin considering the disastrous effects of its decisions."
In the draft, I go on to say that, "As a former regulator, I sympathize with your desire to make sure the public interest is served. One way to serve the public interest is to properly implement regulations in accordance with prevailing law. Another way to serve the public interest is to reasonably interpret regulation requirements and permit application information. I suppose a third way to serve the public interest is to be mindful throughout the process that consumers end up paying many fold for regulations: 1) through taxes funding your operations; 2) through the price of products reflecting cost of the regulatory processes; 3) through lost state and federal revenues that may result from stalled projects; 4) through tens and perhaps hundreds of thousands of American jobs and employment taxation and economic strength that stalled projects could produce; 5) through the increased dependence on foreign energy imports that stalled projects produce, along with 6) associated, harmful impacts on our balance of trade deficit and weakened state of national security.
[1] http://yosemite.epa.gov/R10/airpage.nsf/Permits/chukchiap/$FILE/shell_chukchi_epa_letter1_att_a.pdf, p.6
Alaskans living in Anchorage should come to the Library this morning, or comment by mail as indicated below:
Shell Chukchi OCS Air Permit
EPA Region 10
1200 6th Ave, Ste. 900
Mail Stop: AWT-107
Seattle, Washington 98101
You may submit oral or written comments on the proposed permit at the public hearings. You do not need to attend the public hearings to submit written comments. You may send written comments to the address above, postmarked by October 5, 2009. For more information about these meetings and hearings, contact Suzanne Skadowski, EPA Region 10, Seattle, Washington, 206-553-6689 or 800-424-4372 or skadowski.suzanne@epa.gov. Public comments received on this proposed permit will be posted here as we receive them, through the end of the comment period.
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