Comments to BoCC re Prospect emissions – Doug Henderson – 8 Feb 2022

Good morning Commissioners,

In June and Sept last year, we raised concerns to you about emissions from Prospect Energy’s Krause facility northeast of Fort Collins.

For years this facility has leaked emissions that harm people’s health and quality of life, degrade air quality, and damage the environment.

CDPHE cited Prospect for 3 separate violations at this facility during 2018-19, and issued Prospect a warning. After each violation, Prospect said repairs were made and the leaks had been stopped. But subsequent investigations by APCD found that emissions continued. Repairs were either very inadequate, or weren’t actually made.

Only 2 months after Prospect received the warning, Earthworks documented more illegal emissions from the facility. During the past year, Earthworks documented emissions on 9 separate visits. And several investigations by state and county officials also found leaks, emissions, and odors.

Prospect repeatedly said repairs were made and leaks were stopped. But
subsequent investigations found emissions were continuing.

CDPHE issued another violation notice to Prospect in December. In early January, Prospect replaced two tanks that were known to leak. So finally – after years of leaks and harmful emissions – the facility would no longer be leaking, no longer harming peoples’ health, air quality, and the environment.

Unfortunately, shortly after the tanks were replaced, local residents reported more odors from the facility – the same sickening odors that have made them ill for years.

So in mid-January, Earthworks investigated again – and documented leaks from the replacement tanks. (The imaging from that investigation is here:

https://www.youtube.com/watch?v=db9B9fsErPg&t=67s&ab_channel=Earthworks

It seems Prospect had replaced two old leaky tanks
with other old used tanks, and leaks continued. So Earthworks filed another complaint with APCD.

Ten days ago, a state investigator, accompanied by County Health staff,
documented more leaks, emissions, and odors at the facility.

The Krause facility has a clear record of leaks, emissions, violations. Prospect is responsible for these leaks and failing to stop them, and responsible for toxic and illegal emissions that for years have damaged people’s health and welfare, degraded air quality, and damaged the environment.

Colorado law is clear: protection of public health and the environment holds priority in oil & gas development. Larimer County has legal authority under state law and County regulations to act to protect public health, safety, and the environment.

We urge the County to stop further harm from the Krause facility
and hold Prospect accountable:

• by ordering the facility to cease operation and shut
  until state and local authorities determine the facility can operate without any more illegal emissions.
• and by issuing Prospect a penalty for its chronic illegal leaks,
  and sufficient to deter further illegal conduct.

Not just talk – real action to uphold the law and protect local residents, public health, and the environment.