Guidance- Use of Air Emissions Estimating Tools
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
November 24, 2014
In Reply Refer To:
7300 (280) P
EMS TRANSMISSION 11/26/2014
Instruction Memorandum No. 2015-020
Expires: 09/30/2018
To: All Washington Office and Field Office Officials
From: Director
Subject: Guidance – Use of Air Emissions Estimating Tools
Program Areas: All Resource Programs, National Environmental Policy Act and Planning
Purpose: This Instruction Memorandum (IM) provides national guidance for the Bureau of Land Management (BLM) on the use of air emissions estimating tools. The purpose of this IM is to help BLM employees determine which estimating tool is appropriate to use when calculating emissions.
Policy/Action: The Federal Land Policy and Management Act (FLPMA) requires the BLM to consider air resources in making land management decisions. In some cases, quantifying air emissions is necessary to make informed decisions. The BLM has developed the Greenhouse Gas & Climate Change - National Environmental Policy Act (GHGCC-NEPA) toolkit, the Medford District toolkit and the BLM Planning Stage Emissions Inventory toolkit to estimate air emissions. Many other commercial products are also available.
For some actions, it may be necessary for BLM staff to use more than one estimating tool, or may choose to compare the results among tools. Therefore, all offices are instructed to include with the action’s documentation, the estimating tool(s) used, the rationale for using the tool(s), the limitations of the tool(s), the assumptions made, and the uncertainties involved when estimating emissions.
Timeframe: This IM is effective immediately.
Budget Impact: This IM does not have any impact on the budget. The guidance and tools identified in this IM are available to support the BLM in estimating emissions for NEPA analysis and other regulatory requirements and therefore create the potential for efficiencies.
Background: In some instances, it is useful for the BLM to estimate air emissions from resource management activities in order to prepare NEPA documents for planning or project decisions or to comply with applicable reporting requirements. Various tools are available to the BLM staff, but the choice of which tool to use depends on the application and the intended users’ expertise in the air resource area. This IM describes three toolkits that are available at the BLM. Each toolkit described was developed using the latest emissions factors models, and estimates emissions using accepted equations and methodologies including API Compendium of GHG Emissions Estimation Methodologies and EPA AP-42. The inputs, calculations, and emissions results are summarized in a Microsoft Excel spreadsheet.
Greenhouse Gas & Climate Change NEPA Toolkit
The Greenhouse Gas & Climate Change NEPA (GHGCC-NEPA) toolkit is an internal, web-based tool featuring a climate change reference library, a guidance and policy page, and a suite of greenhouse gas (GHG) calculators. The climate change reference library and the guidance and policy page offer a one-stop destination for current guidance, policy, and reference material related to climate change that the BLM can use in developing NEPA documents. Users can narrow their search in the reference library to specific states, landscape conservation cooperative regions, rapid ecoregional assessment (REA) areas, and topics. The GHG calculators are designed for use by field staff, including planners and interdisciplinary team members, to estimate GHG emissions (carbon dioxide, methane, nitrous oxide, and carbon dioxide equivalent) for project or management activities that would not require complex, comprehensive air emissions analyses. The activities addressed in the GHG calculators include fluid and solid mineral production, rangeland and forestry management, recreation and trails, wildland fire and fuels management, manufacturing and wastewater treatment. The BLM staff may need to use an additional tool to estimate air emissions for pollutants other than GHG, if necessary.
Use of the GHGCC-NEPA toolkit’s fluid minerals GHG calculators may be appropriate, for example, when a NEPA Environmental Assessment is being prepared for an application for permit to drill involving only one or two well pads in an area designated as attainment for national ambient air quality standards (NAAQS) and where air pollutants other than greenhouse gases are not an issue requiring detailed analysis such as air quality modeling. Another example of appropriate use of the GHGCC-NEPA toolkit’s GHG calculators may be during the development of an Environmental Impact Statement (EIS) associated with a new national monument management plan. If the newly-proclaimed national monument has little existing mining activity and is withdrawn from future mining activity, if continued livestock grazing is permitted, and if the monument is located in an area designated as attainment for NAAQS, then the GHGCC-NEPA rangeland emissions calculator may be an appropriate tool to estimate GHG emissions from livestock grazing in the monument.
Medford District Toolkit
The Medford District toolkit, developed by the Medford District is a GHG estimation toolkit, for use in forest management, livestock grazing, mining, and campground development. This toolkit is similar in scope to the GHGCC-NEPA toolkit since it only calculates GHG. As with the GHCC-NEPA toolkit, BLM staff may need to use an additional tool to estimate emissions for pollutants other than GHG, if necessary. The Medford District toolkit is posted in the BLM Oregon/Washington Climate Change Library under Assessment Methods on the internal website.
BLM Planning Stage Emissions Inventory Toolkit
The BLM Planning Stage Emissions Inventory (BLM-PSEI) toolkit calculates air emissions of criteria and hazardous air pollutants, volatile organic compounds, and GHGs (carbon dioxide, methane, nitrous oxide, and carbon dioxide equivalent) of the resources (e.g., fluid and solid mineral production, rangeland and forestry management, recreation and trails, wildland fire, etc.). The BLM-PSEI toolkit is more robust than the other two toolkits and is designed to be used by experienced air resource specialists to estimate emissions from complex projects, including NEPA project alternative actions and to meet local, state and federal reporting requirements. It allows user flexibility for choosing planning assumptions, geographic-specific emissions factors and representative region datasets.
The BLM-PSEI toolkit was used to quantify air emissions for the Four Rivers, ID project, a development which required analysis of multi-pollutants for multiple gas wells and other activities. This analysis was done instead of performing air modeling.
The toolkit is currently available for internal BLM use. It is posted on the Air Resources E-Library at: https://sites.google.com/a/blm.gov/air-resources/home.
Manual/Handbook Sections Affected: None.
Coordination: The Division of Environmental Quality and Protection (WO-280) coordinated preparation of this IM with the Division of Decision Support, Planning and NEPA (WO-210), the Directorates of Resources and Planning (WO-200) and Energy, Minerals and Realty Management (WO-300), the Division of Resource Services, National Operations Center (OC-500), the Department of the Interior (DOI) Office of the Solicitor, and the DOI Office of Environmental Policy and Compliance (OEPC).
Contact: Please direct any questions concerning this IM to Nancy Dean, Division Chief, Environmental Quality & Protection, BLM Washington Office (WO-280), at 202-912-7136.
Signed by: Authenticated by:
Edwin L. Roberson Robert M. Williams
Assistant Director Division of IRM Governance,WO-860
Resources and Planning