My name is Gayla Maxwell Martinez and I live in Larimer County.
I would like to thank Mr. Sura for his presentation and acknowledge the many improvements that have been added to the Larimer County oil and gas regulations.
Addressing the section concerning Public Conservation Lands.
To say that damage to Public Conservation Land can be adequately compensated by off-site mitigation is euphemistic and ignores the critical importance of maintaining the integrity of contiguous natural ecosystems. Previous plans, such as the Mountains to Plains Energy by Design study, that suggest options to minimize or mitigate impacts were developed pre-SB181 and are now outdated.
There is an interpretive sign up at Soapstone Prairie that refers to these lands as our “Last Best Places.” Their value is immeasurable.
According to The State of Colorado’s Biodiversity report, published by the Colorado Natural Heritage Program, the shortgrass prairie ecosystems of northeastern Colorado, including Larimer County, are some of the least protected and most endangered because of the threat of oil and gas extraction.
I would ask that areas zoned as Open Space should be entirely off-limits to oil and gas development.
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Important points of emphasis regarding Larimer County’s Oil and Gas regulations:
Leak detection and repair inspections and reports should be required monthly, to catch and fix problems reasonably quickly. Annual inspections, as required in the draft regulations, are of very limited use.
Air quality – Larimer County’s air quality is often poor, due in major part to oil and gas industry emissions, and improving air quality is an immediate priority for public health and quality of life:
All oil and gas sites should have continuous emissions monitoring and real-time reporting that informs about harmful emissions when they occur, not long after they occurred.
On Air Quality Alert days, operators should be required to significantly reduce emissions and dust, and to report on actions taken. This should not be voluntary based on operators’ convenience.
All venting and routine flaring should be prohibited. Venting and flaring is damaging to health, environment and climate, wasteful, and enables operators to escape paying taxes and royalties.
While our air remains in non-attainment of EPA ozone standards, there should be no net increase in oil and gas emissions; emissions from new oil and gas development need to be offset by reduced emissions at other oil and gas facilities within the non-attainment zone.
Setbacks and reverse setbacks need to truly protect people’s health and safety. Setbacks of 1,000 feet and less in the draft regulations would not protect public health safety, and against nuisance impacts from oil and gas operations. Reasonably protective setbacks and reverse setbacks include:
2,500 feet from all occupied buildings, recreation areas and conservation areas, with variance allowable to 2,000 feet minimum.
2,500 feet for schools, playgrounds, and facilities for older people, with no exceptions.
1,000 feet from any properly plugged and abandoned oil & gas well.
To protect our water resources:
1,000 feet buffer from rivers and streams, water facilities, and ditches.
2,500 feet buffer for drinking water sources.
No oil & gas facilities within a 100-year floodplain.
No more Class II water disposal wells in the County.
Public Conservation Lands should be for conservation – and fully protected from surface use and inevitable degradation by oil and gas development. The draft regulations would allow surface access and use of County and municipal-owned conserved lands for oil and gas development.
Prior to initiation of oil and gas facility site development, all top soil will be removed to a safe location to be reapplied to the site during reclamation.
Financial Assurance is needed to protect governments and taxpayers from costs arising from oil and gas developments such as major accidents, emergency response, operator bankruptcy, and failure to clean up from oil and gas operations and properly plug old wells. Uncovered costs and liabilities will financially impact all County residents/taxpayers and local governments.
Operators must carry adequate insurance to cover all costs arising from their activities, operations, and facilities
Full cost bonding for all wells.
All conditions of approval survive a change of ownership.
This short article, thanks to the Colorado Sun, illustrates how even the COGCC director, Jeff Robbins, is clearly frustrated with the process of cleaning up abandoned wells. Of course, these rules were created in a previous era of the COGCC when their corporate culture was quite different. This testimony will surely play a part in how the enormous problem of the cleanup of abandoned wells will be addressed: