What Numbers Can’t Capture: Life on the Reservation Next to a Compressor Station

The Fort Berthold Indian Reservation sits in the heart of the Bakken oil and gas formation in North Dakota. The Three Affiliated Tribes — the Mandan, Hidatsa, and Arikara Nation — have lived on this land since long before any pipeline company existed. They did not choose to have Arrow Pipeline’s Station #7 built in their backyard. They did not choose to breathe the exhaust from engines rated at up to 7,000 combined horsepower, running around the clock, compressing natural gas for transmission to a central delivery point somewhere off-reservation where the profits flow.

What gets permitted on paper rarely matches what gets breathed in the body. Nitrogen oxides irritate the lungs and react in sunlight to form ground-level ozone. Volatile organic compounds are a class of chemicals that includes benzene, toluene, and formaldehyde. Benzene is a known cause of leukemia. Formaldehyde is a known carcinogen. The permit authorizes Arrow to emit up to 9.8 tons of any individual hazardous air pollutant per year, including formaldehyde, from this one station alone. These are not abstract policy numbers. They describe chemicals that enter the respiratory systems of children who play outside, elders who sit on their porches, and adults who work land that has been in their families for generations.

The betrayal here is structural. When Arrow Pipeline decided in October 2017 that its existing permit was too restrictive for its future equipment plans, it filed a request with the EPA to revise it. The EPA agreed that the changes qualified as “administrative revisions” under federal regulations. That classification is the machinery of erasure. It means the revision is not subject to public participation. No community meeting. No comment period. No chance for a tribal elder, a mother, a farmer, or a student to stand up and say: wait, explain to us what you’re changing and why. The Three Affiliated Tribes’ Environmental Director received a carbon copy of the decision letter after it was already signed and sealed.

That is what dispossession looks like in the regulatory era. It does not always arrive with bulldozers. Sometimes it arrives as a letter dated January 10, 2018, with a cc: line at the bottom.

Those words appear in the cover letter from EPA Region 8 Director Monica S. Morales. They are bureaucratic in tone and catastrophic in consequence. They translate plainly to: the people who live here do not get a say. Arrow Pipeline asked for flexibility. The EPA provided it. The community was notified after the fact, if at all.

Straight from the Document: What the Permit Actually Says

These are verbatim quotes from EPA Permit #SMNSR-TAT-000661-2017.003, issued January 10, 2018. Nothing is paraphrased.

“Administrative permit revisions are not subject to the permit application, public participation, issuance or administrative and judicial review requirements of the MNSR Permit Program.”

EPA Region 8 Cover Letter, January 10, 2018, Director Monica S. Morales

“Arrow requested to administratively revise the permit in order to better accommodate future equipment changes at Station #7. The request also updated the corporate office location, removed language describing installation limits, specific engine-type, and individual engine limits by horsepower.”

EPA Region 8 Cover Letter, January 10, 2018

“It is not a defense, for the Permittee, in an enforcement action, to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.”

Permit #SMNSR-TAT-000661-2017.003, General Provisions, Section II.A.8

“The EPA has verified that the requested revisions qualify as administrative revisions under 40 CFR 49.159(f).”

EPA Region 8 Cover Letter, January 10, 2018

“VOC emissions shall not exceed 92 tons during any consecutive 12 months. NOx emissions shall not exceed 92 tons during any consecutive 12 months. CO emissions shall not exceed 92 tons during any consecutive 12 months. Individual HAP emissions shall not exceed 9.8 tons during any consecutive 12 months. Total HAP emissions shall not exceed 24.5 tons during any consecutive 12 months.”

Permit #SMNSR-TAT-000661-2017.003, Section I.C.1

Three Ways This Permit Damages the World Beyond Arrow’s Balance Sheet

Environmental Degradation

The permitted operations at Station #7 generate multiple categories of atmospheric pollution on tribal land that cannot be reversed once released.

• The permit authorizes up to 92 tons per year of volatile organic compounds, which react with sunlight and nitrogen oxides to form ground-level ozone. Ozone damages crops, grasslands, and native plant ecosystems in the surrounding area.
• The permit authorizes up to 92 tons per year of nitrogen oxide emissions. NOx is a precursor to acid rain, which acidifies soil and surface water, degrading habitat for fish, birds, and native plant communities across the Fort Berthold area.
• The permit allows compressor blowdowns, meaning deliberate venting of pressurized natural gas directly into the atmosphere during maintenance and emergency operations. The volume of methane released during these events is required to be estimated by Arrow using “representative emission factors,” a method that routinely understates actual releases.
• Up to 80,500 barrels per year of combined produced water and natural gas condensate pass through the station. Produced water from Bakken oil and gas operations contains naturally occurring radioactive materials (NORM), salts, and hydrocarbons. The permit governs vapor emissions from this material but places no limits on spill risk during truck loading operations.
• The permit requires only weekly visual surveys for fugitive dust during construction and operation. Visual inspection cannot detect submicron particulates or hydrocarbon vapor plumes that drift beyond the station boundary.

Public Health

The communities nearest Station #7 are the members of the Three Affiliated Tribes, a population with documented health disparities and limited access to specialized medical care in rural North Dakota.

• The permit allows up to 9.8 tons per year of any individual hazardous air pollutant. Formaldehyde, explicitly named as a controlled pollutant in the engine emission limits, is classified by the International Agency for Research on Cancer as a Group 1 carcinogen, meaning it causes cancer in humans.
• Engines at Station #7 are permitted to emit formaldehyde at up to 0.2 grams per horsepower-hour (lean-burn) or 0.1 grams per horsepower-hour (rich-burn). With a total facility capacity of 7,000 horsepower running continuously, the math on potential formaldehyde output over a year is significant.
• Carbon monoxide, permitted at up to 92 tons annually, is an odorless gas that causes headaches, dizziness, confusion, and death at sufficient exposure levels. CO accumulates indoors and in low-lying areas, posing risks to residents in homes near the station.
• Nitrogen oxide exposure causes airway inflammation and worsens asthma and other respiratory conditions. Children and elders are the most vulnerable populations. The permit places no proximity restrictions on residential areas.
• The permit’s monitoring system relies largely on Arrow’s own calculations and self-reported data, submitted annually by April 1st. There is no continuous ambient air quality monitoring required in the surrounding community to verify whether these permitted emissions are actually making people sick.

Economic Inequality

The structure of this permitting process concentrates benefit in Fort Worth, Texas and concentrates risk on the Fort Berthold Indian Reservation in North Dakota.

• Arrow Pipeline, LLC maintains its corporate office at 1200 Summit Avenue, Suite 320, Fort Worth, Texas 76102. The profits from the natural gas gathered and compressed at Station #7 flow to Texas. The air quality consequences stay in North Dakota.
• The Three Affiliated Tribes received only a carbon-copy notification of the permit revision. Arrow’s corporate team submitted the revision request and corresponded directly with EPA Region 8. The Tribes had no equivalent seat at the table under the administrative revision process.
• The natural gas condensate and produced water transported off-site by truck generate revenue for Arrow. The truck loading operations also generate VOC and HAP emissions, the costs of which are externalized onto the surrounding community, with no compensation mechanism built into the permit.
• The permit explicitly states that Arrow bears no responsibility for the EPA’s “risk of loss” if permit conditions are not met. All financial liability is structured to flow back to Arrow only through enforcement actions, which are rare and resource-intensive for an agency with a limited inspection budget covering tribal lands across the entire Rocky Mountain and Great Plains region.
• Tribal communities often lack the legal and technical resources to challenge EPA permit decisions, even when those decisions directly affect their air, land, and health. The administrative revision classification ensures that even if those resources existed, they would have no formal entry point into this process.

What Arrow’s Operational “Flexibility” Looks Like in Real Units

Who to Pressure and Where to Push

The permit belongs to Arrow Pipeline, LLC. The authority to revoke or modify it belongs to the EPA. The people who have the most at stake are the Three Affiliated Tribes, and they are the ones with the least institutional power in this process. That is the gap where organizing matters.

Key Decision-Makers (as identified in the permit)

• Jeff Stovall, Arrow Pipeline, LLC, 1200 Summit Avenue, Suite 320, Fort Worth, TX 76102. The permit is addressed to him as the company representative.
• Monica S. Morales, Director, Air Program, Office of Partnerships and Regulatory Assistance, EPA Region 8. She signed the permit revision approval on January 10, 2018.
• Colin Schwartz, EPA Region 8 staff contact for this permit, reachable at (303) 312-6043. He is the point person for permit questions.
• Edmund Baker, Environmental Director, Three Affiliated Tribes. He received only a carbon copy of the final decision. He should be receiving far more than that.

Watchlist: Regulatory Bodies with Jurisdiction or Overlap

• EPA Region 8 (Denver): Primary permitting authority under the Tribal Minor New Source Review program at 40 CFR part 49. All complaints and deviation reports go to r8airreportenforcement@epa.gov.
• EPA Office of Enforcement, Compliance and Environmental Justice: Responsible for enforcement actions if Arrow violates permit conditions. Address: 1595 Wynkoop Street, Denver, CO 80202.
• Bureau of Land Management (BLM): The permit references BLM Onshore Order No. 4 for produced water measurement. BLM has concurrent authority over oil and gas operations on Federal and Indian oil and gas leases.
• Three Affiliated Tribes Environmental Department: Has been notified of permit decisions as a cc recipient. Deserves formal consultation rights, not afterthought notification. Contact through the Mandan, Hidatsa, and Arikara Nation tribal government.
• EPA Office of Environmental Justice: Exists specifically to address disproportionate environmental burdens on minority and low-income communities, including tribal nations.

Specific Actions You Can Take

• Contact EPA Region 8 at r8AirPermitting@epa.gov and demand that all future permit revisions affecting Fort Berthold include a formal tribal consultation period, not a cc: notification after the fact.
• Send written comments to the EPA Office of Environmental Justice requesting a cumulative impact review of all air pollution sources permitted on or near the Fort Berthold Indian Reservation. Multiple synthetic minor sources operating in close proximity can collectively exceed major source thresholds.
• Support the Three Affiliated Tribes Environmental Department directly. They are the on-the-ground watchdogs with the least resources and the most skin in the game. Find their public contact information through the MHA Nation official website and ask what technical or advocacy support they need.
• Connect with Indigenous-led environmental justice organizations working in the Bakken region, including but not limited to those affiliated with the Indigenous Environmental Network. Grassroots monitoring of air quality near compressor stations on tribal lands creates an independent record that counterbalances Arrow’s self-reported emissions data.
• Demand your federal representatives require the EPA to mandate continuous ambient air monitoring near industrial facilities on Indian reservations, rather than relying exclusively on the permit-holder’s own calculations and annual self-reports.