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Summary
Pages 1-8

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From page 1...
... oil and gas resources and is required to help manage air quality in the GOMR to comply with the NAAQS. BOEM meets these requirements in part by conducting air pollution dispersion and photochemical modeling, and analyzing the results to estimate the individual and cumulative impacts of offshore oil and gas exploration, development, and production activities.
From page 2...
... Accurate representation of the diurnal cycle in land-sea breeze circulation is key to model development in the GOMR. The Study's WRF data evaluation does not include key meteorological metrics (e.g., planetary boundary layer height, time series of the wind conditions and temperature, diurnal patterns, errors in vertical profile, and averaging over hourly, daily, monthly time periods)
From page 3...
... This analysis should be used to identify conditions when the land-based measurements are most sensitive to offshore emissions, and how modeling biases and errors during those periods influence air quality modeling. The Study should also evaluate the results from the meteorological (and photochemical)
From page 4...
... Having results from two different years with different meteorological conditions would allow the Study authors to more comprehensively assess impacts of emissions now and in the future under climate change. The BOEM modeling of future impacts of OCS emissions includes the potential impacts of emissions from potential lease sales up to 2022.
From page 5...
... The committee's understanding of the EET formulas as screening tools is that they should be conservative and not subject to any false negatives,6 while minimizing false positives7 to the extent possible. From its public discussions with both BOEM and industry representatives, the committee's understanding is that the typical lessee/operator response to an exceeded EET limit is to reduce planned oil and gas throughput (and thus projected emissions)
From page 6...
... Using both air quality modeling and statistical methods, the Study developed several new versions of EETs, but none of these are shown to be fully protective of all NAAQS because of the continued existence of false negatives for several pollutants. It is more appropriate to eliminate false negatives, based on EPA guidance and the need to preserve air quality and public health.
From page 7...
... Recommendation: The Study should develop EET formulas and methods based on meteorological conditions that are most conducive to elevated levels of ozone, PM2.5, and PM10, and the EET methods developed for the criteria pollutants should eliminate false negatives. Finding: The cumulative effect of biases and uncertainties across the meteorological and emission datasets, and from the air quality models themselves, could be quite large and result in EET estimates that are higher than they should be, or lower than they need to be.
From page 8...
... Furthermore, the EET methods developed are not fully protective of future emissions, leading to increased high pollutant levels and potential exceedances of the NAAQS. The overall utility of the Study could be improved if the Study authors build off of the extensive modeling and analyses that were already conducted and address the shortcomings outlined in this report's findings and recommendations.


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