American Oil and Gas Reporter - April 2016 - 34

BOEM Proposes New Air Quality Rules
WASHINGTON-The Bureau of Ocean
Energy Management has proposed updates
to its air quality regulations for Outer Continental Shelf oil and gas regulations in a
manner the National Ocean Industries Association calls "ominous, to say the least."
"Ultimately," NOIA worries, "BOEM's
proposed changes could result in the
agency disapproving an operator's exploration plan, development and production
plan, or development operations coordination document that would have been
approved under the existing regulations."
BOEM says the proposed amendments,
released March 17, update 36-year-old
regulations and incorporate its Arctic
OCS jurisdiction over air quality. The
proposed rules, which target emissions
of volatile organic compounds, oxides of
nitrogen, sulfur oxide, carbon monoxide
and particulate matter, would apply to
operations in the Western and Central
Gulf of Mexico, and the Arctic.
The agency says the proposed modernizations include addressing all relevant
criteria and major precursor air pollutants,
and cross-reference BOEM's pollution
standards with those of the Environmental

Protection Agency.
According to NOIA, some of the more
significant changes are:
* Broadening the definition of a facility to include transportation activities,
pipelines, man-made islands, dynamically
positioned drill ships, and vessels engaged
in installing subsea tiebacks and pipelines
connected to the seabed;
* Requiring a lessee or operator to
aggregate emissions generated by proximate activities from multiple facilities
within one nautical mile, regardless whether
they are described in a single plan;
* Accounting for supply vessel emissions over their entire transit, rather than
only within 25 miles of a facility, as at
present; and
* Requiring previously approved plans
to be compliant with the updated regulations.
BLM adds that under the new program,
it would measure impacts landward from
the state-seaward boundary, as opposed
to only at the coastline.
Other significant changes mentioned
in the summary portion of the 349-page
proposed rule include:

* Providing a process by which exemption thresholds are established and
updated;
* Changing the circumstances when
emission reduction measures (ERMs),
including best available control technology,
are required, and establishing new criteria
for applying ERMs; and
* Including an air quality component
in the submission of right-of-use easements, pipeline rights of way, and lease
term pipeline applications.
The proposed OCS air quality rule may
be viewed at http://www.boem.gov/AirQuality-Proposed-Rule/.
Industry Objections
American Petroleum Institute Group
Director of Upstream and Industry Operations Erik Milito, who calls the proposed rule "the latest example of an
agency advancing regulation outside of
its authority," notes that BOEM air modeling studies, which were commissioned
to inform the rule, are not expected to be
completed until next year.
"BOEM should not get ahead of the
science," he contends, adding: "The agency
American Oil and Gas Reporter - April 2016

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