Day 2 & 3 of the 900 Series Rulemaking

Thanks again to Andrew of LOGIC for providing this. The proceedings on these day seemed preliminary, laying the groundwork for future decisions to be made by this new COGCC about very substantive issues regarding venting, flaring, open pit storage of produced water and, last but least, cumulative impact studies.


LARIMER ALLIANCE ENDORSES State senator Joann Ginal and Representatives Jeni arndt and Cathy Kipp for Re-election

     The Larimer Alliance for Health, Safety & the Environment is a coalition of Northern Colorado citizens and groups committed to protecting Larimer County from harm by oil and gas development.  We aim to educate the public about this issue and ensure that local and state governments develop and implement policies that prioritize the protection of public health and safety, environmental quality, wildlife resources, and the integrity of public lands, in accordance with Colorado law.  

     Since our founding in 2019, the Alliance has been focused on oil and gas issues in Larimer County and greater Northern Colorado. Particular attention was given to new regulations enacted at the County level under the mandate of Senate Bill 19-181, a state reform which called for more protection of health, safety, and the environment by the Colorado Oil and Gas Conservation Commission (COGCC), and allows more local control. 

    The current Board of County Commissioners enacted local regulations that were not in the spirit of SB-181. Both before and after the passage of those local rules, the Alliance provided input at the State level as new regulations on oil and gas were being drafted by the COGCC and the Air Quality Control Commission (AQCC). This frequently includes consultation and collaboration with Larimer County’s representatives in the State Legislature.  

Our experience throughout this process has led us to endorse State Senator Joann Ginal in Senate District 14, Representative Jeni Arndt in House District 53, and Cathy Kipp in House District 52 for re-election in 2020. 

     With a 20- year career in bio-sciences specializing in reproductive endocrinology prior to her entering the Colorado legislature, Senator Ginal has long been concerned about the effects of oil and gas development on public health and the environment, and co-sponsored SB-181. She ran bills on the epidemiological effects of oil and gas development on nearby communities, as well as on the potential earthquake hazards presented by fracking.

     Representative Kipp serves on the House Energy and Environment Committee, closely tracking the new regulatory processes of both the COGCC and the AQCC. Representative Arndt serves on many committees. Her knowledge of water law is the reason why she has been appointed Vice-Chair of the Western Council of State Governments’ Agriculture and Water Committee. She is keenly aware of issues centered on the vast amount of water utilized in fracking processes. 

     Representatives Arndt and Kipp were both co-sponsors of SB-181 in the House. As new regulations were being formulated this year by the COGCC, all three of our Larimer County legislators signed a letter to support greater setbacks of oil and gas projects from homes, schools, and other sensitive locations. 

     We feel these public servants are paying quite appropriate attention to environmental issues in general and oil and gas regulatory issues in particular. It is our hope that they can continue their advocacy on behalf of Larimer County on these and other issues as they are re-elected to their seats in 2020. As ever, the Larimer Alliance stands ready to assist in educating and informing our representatives and the community at large as these issues march forward.

alliance Points out Serious Concerns about state’s Draft Ghg Reduction Plan to aqcc member tom gonzales

As previously noted in this blog, the Larimer Alliance had been tracking numerous processes at the state and local level relevant to oil and gas development and general environmental issues. We recently posted, and registered our agreement with, a press release from 350 Colorado about the recently publicized Greenhouse Gas Reduction Roadmap from the Colorado Energy Office. This plan came up short in terms of monitoring and regulatory requirements , as specified in HB19-1261, as well as failing to come into compliance with Federal air quality standards. The plan also fails to keep us on track to meet the goals established by the International Panel on Climate Change of keeping global temperature rise below 1.5℃, which requires 100% GHG emissions by 2036.

One of the volunteer commissioners at the Air Quality Control Commission (AQCC) is Tom Gonzales, who is the Larimer County Director of Public Health and Environment. The AQCC is in the process of rewriting air quality standards. This will provide critical guidance as the state prepares to move forward with energy planning that affects the air we breathe, as well as the overall goal of mitigating if not reversing the effects of climate change caused by a rise in greenhouse gas emissions. With that in mind, the Larimer Alliance recently sent this letter to Mr. Gonzales in his capacity on the AQCC:

October 19, 2020

Larimer County

Commissioner Gonzales,

We are the Larimer Alliance for Health, Safety & the Environment. We represent thousands of Larimer County residents with 11 partner organizations. A description of our members and mission are here

We’d like to thank you for your skill in choosing best practices for our county during this pandemic. We appreciate the stress it represents! 

We also appreciate your work in sitting on Colorado’s Air Quality Control Commission. Improving our terrible air quality is a role made all the more important while our lungs are not only threatened by COVID-19, but also assaulted by wildfire smoke so intense it blocks the sun and covers our town in ash. 

Times being what they are, we hope you will be sympathetic to our concerns about Colorado’s Greenhouse Gas Reduction plan. At this moment in negotiation, we believe the plan is not enough to put us on a fast trajectory toward breathable air, or to retreat from most catastrophic predictions for climate change. The fires now burning may be just the beginning.  

Leaders of Larimer Alliance are watching the COGCC rulemaking alongside the AQCC’s milestone agenda. While rules moving forward at COGCC will be helpful, we question if progress is real without a look back at current fugitive emissions. How can we approve new wells and reduce methane by 50% without serious regulation on the leaks that contribute greatly to the poor air quality we have today? 

According to the Natural Resources Defense Council, a speedier electric energy transition could achieve the same overall emissions goals more reliably and at a reduced cost. Waiting for residents to bear the cost of upgraded hot water heaters and replacement of gas appliances for electric appliances is a slow boat. Government has far more control with a single decision to diminish emissions from coal and gas plants. We agree with NRDC that this all represents opportunities for the utilities going forward. We also hope that 80% reductions of carbon emissions for the state’s electric utilities is the minimum for utilities, and not a cap on progress. 

The Journal of the American Medical Association states: “We found that an increase of about three parts per billion [of ground-level ozone] outside your home was equivalent to smoking a pack of cigarettes a day…”

Understanding that it is your professional study to recognize and protect us from public health risks, we invite you to a medical symposium by Physicians for Social Responsibility on the Health Effects of Oil and Gas Development on Dec. 5. The all-day workshop has 12 well-credentialed speakers and the National Environmental Health Association offers credit for public health officials for $75. There’s no fee for non-credit seeking participants

Commissioner Gonzales, we appreciate the gravity of your milestone task with AQCC. Please know that you hold our hope in building the strongest plan for our state, as well as our county. We will continue to witness and educate at both levels and we welcome any dialog you may offer. 

With Respect,

Ed Behan 

on behalf of The Larimer Alliance for Health, Safety & the Environment

We will continue to keep the community advised of our communications with relevant officials in our efforts to enact meaningful and effective environmental regulation in the State of Colorado.