Theodore Roosevelt Administrative History

1. The quotations can be found on pp. 9, 14, and 16 of the "NRM Plan." See also "1982 Superintendent's Annual Report," 12.

2. "NRM Plan," 14.

3. Ibid., 14, 15; "Chief Ranger's Monthly Report," 8 August 1974.

4. "1982 Superintendent's Annual Report," 12; Ray Snow, "One Piece of the Research Action: Theodore Roosevelt NP," Park Science 2:3 (Spring 1982), 11.

5. "NRM Plan," 14; R.G. Flocchini et al., "Characterization of Particles in the Arid West," Atmospheric Environment 15:10/11 (1981), 2017-2030; R.G. Flocchini, "A Synoptic Scale Fine Particle Monitoring Network in the Western U.S.," unpublished MS, ca. 1980 (THRO-L), unpaginated.

6. Angelo and Anderson, Western North Dakota Air Quality Study, 12, 27, and 33; Robert T. Angelo and Kurt W. Anderson, The Chemistry of Atmospheric Precipitation in North Dakota: A Preliminary Report With Comments on The Ambient Air Quality and Meteorological Characteristics of Western North Dakota in 1981 (Bismarck: NDSDH, 1982), 86, 88. TSP have exceeded the legal limits in a couple of instances, but only under extraordinary conditions such as a prolonged east wind or after the eruption of the Mount St. Helens volcano in May 1980. See Flocchini et al., 2020-2021.

7. Angelo and Anderson, Chemistry of Atmospheric Precipitation, 86.

8. Angelo and Anderson, Western North Dakota Air Quality Study, 33-35.

9. "NRM Plan," 31.

10. Ibid., 32; Clifford Wetmore, "Lichens and Air Quality in Theodore Roosevelt National Park," unpublished MS, 1983 (THRO-A); L.P. Gough, J.L. Peard, R.C. Severson, L.L. Jackson, B.F. Arbogast, J.M. Motooka, S.W. Snow, E.E. Engleman, and J.P. Bennett, "Baseline Elemental Composition of Selected Plants and Soils, and Assessment of Airborne Element Contamination, Theodore Roosevelt National Park, North Dakota," USGS Open—File Report 85—251, 1985 (THRO-A); John P. Christiano (Chief, NPS Air Quality Division) to Harvey Wickware (Supt., THRO), memorandum, 16 December 1985 (THRO-A), 2-3.

11. As of 1983, North Dakota was the only state in complete compliance with federal clean air standards. Fargo Forum, 8 May 1983.

12. Myron F. Uman, "The PSD Program of the National Park Service," unpublished MS, 1980 (THRO-A), 4.

13. Ibid., 6. See also 40 CFR (a)(13)(i) — (14)(i). For a valuable explanation of the background and effect of the Clean Air Act Amendments of 1977 on the parks, refer to Robert Maynard, "The Clean Air Act Amendments and the National Parklands, " University of Michigan Journal of Law Reform 11:2 (Winter 1978), 290-316, and esp. 295 (for baselines).

14. Martin R. Shock, The Selection of a Complete Modeling Procedure for the Simulation of Mesoscale Ground Level Air Quality Considerations (Bismarck: NDSDH, 1981), 6. North Dakota was one of the first states to adopt PSD regulations (in January 1976). In May 1977, EPA delegated PSD enforcement responsibility to the state; see Final West-Central North Dakota Regional Environmental Impact Study on Energy Development (N.p., BLM and State of North Dakota, 1978), 12. See also Maynard, 296.

15. Uman, 2, quoting the Clean Air Act Amendments of 1977, Section 165 (d)(2)(b). Maynard (p. 303) has this to say about the Federal Land Manager's role in carrying out the Act:

The federal land manager, who is given an "affirmative responsibility to protect the air quality related values" of federal Class I areas under his jurisdiction, is crucial to [the PSD] scheme. Legislative history characterizes this duty as that of a diligent, aggressive advocate for protection of air quality over these lands. The manager is to resolve all doubts about the air quality impacts of new development in favor of continued protection. He is expected to initiate the new source permit review process by notifying the state of expected threats to the air quality related values of Class I lands, as well as reviewing the pollution effects of proposed new sources within the administrative process. . . . Clearly, the federal land management agencies must perform their adversary function if the amendments are to protect national parklands effectively.

16. Air Pollution Control Regulations of the State of North Dakota (ND Administrative Code), Article 33-15, Chapter 33-15-15, paragraphs 4-6 (pp. 13-14); Final West-Central North Dakota EIS, 17. For a full discussion, see Maynard, 306-307.

17. Final West-Central North Dakota EIS, 21-23; Air Quality Effects Analysis and Permit Application of Western Natural Gas Processors, Ltd., Natural Gas Processing and Sulfur Recovery Plant, Billings County, North Dakota (Bismarck: NDSDH, 1979), 48.

18. See for example the Bismarck Tribune, 22 September 1979, 1.

19. "State Coordinator's Monthly Report," 2 October 1979; quotation from Annual Management Review, Theodore Roosevelt National Park, North Dakota: 1980 (Medora: NPS, 1980), unpaginated.

20. Natural Resources Interim Plan (Bismarck: Natural Resources Council, State of North Dakota, 1980), 10.

21. The six projects for which variances were originally sought: Basin Electric Power Cooperative's 500 megawatt addition (AVS #3) to its Antelope Valley electric generating plant; Warren Petroleum's expansion of its Little Knife natural gas processing plant; Nokota's coal-to-methanol plant; a 500 megawatt generating station of Minnesota Power and Light; and gas processing plants of Amoco and Phillips Petroleum. See NPS Air and Water Quality Division's "Technical Review of Six PSD Permit Applications Potentially Affecting Theodore Roosevelt National Park and Lostwood National Wildlife Refuge," unpublished MS, 17 June 1982 (THRO-A), Table 2 (contained in unpaginated appendix).

22. "Technical Review," 4.

23. Ibid.

24. Maynard, 303-305; and Richard A. Dobbins, Atmospheric Motion and Air Pollution (New York: John Wiley & Sons, 1979), 219-249, esp. 243. Shock (p. 4) writes: "The choice of input data, particularly the wind field, is a critical aspect of the air quality modeling process."

25. Air Quality Effects Analysis of Warren Petroleum Natural Gas Processing Plant, Billings County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1978), 44, 46, and 39.

26. Shock, 67.

27. Ibid., 4.

28. Ibid., 58; Maynard, 305; Air Quality Effects Analysis of Basin Electric Power Cooperative Antelope Valley Station Unit 3, Mercer County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1982), 144-145. See also "State Coordinator's Monthly Report," 4 March 1980.

29. Dickinson Press, 15 September 1982. "This is not a clear-cut science," said NPS Air Quality Division liaison John Christiano in reference to the difference of opinion.

30. In a later study, the state admitted to the "post-processing of hourly output . . . in order to remove calm wind bias from calculated 3-hour and 24-hour concentrations. . . .", See Air Quality Effects Analysis of Cities Service Company Lignite Gas Plant, Burke County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1983), 38.

31. Air Quality Effects Analysis, Antelope Valley Unit 3, 171.

32. Ibid., 173. This TSP format is also used in the Air Quality Effects Analysis and Permit Application of Amoco Production Company, Whitetail Gas Processing Plant, Billings County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1982), and Air Quality Effects Analysis of Warren Petroleum Natural Gas Processing Plant (Expansion), Billings County, North Dakota (Division of Environmental Engineering, NDSDH, 1982).

33. "Technical Review," 1. For significance levels, see 40 CFR (b)(23)(i) and 40 CFR (i)(8)(i), and Air Quality Effects Analysis and Permit Application of Koch Hydrocarbon Company Gas Processing and Sulfur Recovery Plant, McKenzie County, North Dakota (Bismarck: Division of Environmental Engineering, NDSDH, 1980), 59.

34. "Technical Review," 2-4.

35. Ibid., 4-7. Quotations from pp. 5 and 6, respectively.

36. Ibid., 7.

37. Ibid., 11-12. None of the cultural resources in the park were thought susceptible to deterioration caused by acid deposition (but cf. "Questionnaire: Threats to the Parks").

38. "Technical Review, " 11.

39. Ibid., 13-14. Quotation from p. 14.

40. "Attack on Clean Air at Teddy Roosevelt NP," National Parks Magazine 56:11/12 (November-December 1982), 30.

41. "Response to Public Comments on the Federal Land Manager's Determination of No Adverse Impact on Theodore Roosevelt National Park and Lostwood National Wildlife Refuge Under Section 165(d)(2)(c)(iii) of the Clean Air Act," unpublished MS, September 1982 (THRO-A), passim.; Duane Sebastian (Chairperson, Dakota Resource Council) to Gene Christianson (Division of Environmental Engineering, NDSDH), 5 June 1982 (THRO-A).

42. "Supplemental Information to the July 1982 Technical Review of Six PSD Permit Applications Potentially Affecting Theodore Roosevelt National Park and the Wilderness Portion of Lostwood National Wildlife Refuge," unpublished MS, August 1982 (THRO-A), 1, 7. The state believed the high sulfur dioxide figures were a temporary increase caused by flaring from a new oil field.

43. "Theodore Roosevelt National Park and Lostwood National Wildlife Refuge; Final Certification of No Adverse Impact," Federal Register 47 FR 41480 (20 September 1982). The certification was made effective as of 15 September 1982. See also Greg Turosak, "Park Service OKs Energy Projects," Bismarck Tribune, 20 September 1982.

44. "North Dakota and the National Park Service," 2.

45. "NRM Plan," 23.

46. Fort Union Coal Regional Environmental Impact Statement; Air Quality Information Supplemental to the Fort Union Coal Region Draft Environmental Impact Statement (Billings: MT State Office, BLM, 1982), 5-11-S-35; Dan Gorham, "Roosevelt Park Air Threatened," High Country News, 13 May 1983.

47. Dickinson Press, 24 February 1983.

48. Ibid., 10 June 1983.

49. "State Coordinator's Monthly Report," 30 March 1983; NDSDH, "Final Report: Sulfur Dioxide Emission Inventory for Sources Near the Theodore Roosevelt National Park (draft)," unpublished MS, February 1983 (THRO A), 19.

50. "Fact Sheet: Hydrogen Sulfide (H₂S) at Theodore Roosevelt National Park (THRO)," 2.

51. "State Coordinator's Monthly Report," 7 June and 8 August 1983.

52. "1976 Superintendent's Annual Report," 10.