Spoiler alert: there is a better way to monitor our air pollution than modeling it…

A rather alarming announcement was made recently by the top agency that monitors our air quality for the state:

Corrected ozone data estimate fracking and drilling produce more emissions than every Front Range vehicle

Aside from the misleading title (“every Front Range vehicle”?), the article zeroed in on the foremost burning issue about air quality in the Front Range: what is causing our severe ozone pollution, and how can it be corrected?

Published January 5, 2023, by Colorado Public Radio, the article states that the Air Pollution Control Division (APCD) underestimated the projected pollution in 2023 that will be produced by the O&G industry by no small amount: about 100%, more or less. The extreme number resulted in some extreme reactions from actual people: the director of the APCD, with egg on his face, nonetheless put his best face forward, saying they will “make lemons out of this lemonade,” though I think he was either misquoted or meant that the other way around. “We will get a stronger implementation plan because of this,” he solemnly vowed.

The other extreme reaction, which swiftly came from the industry side, as if dancing together in rhythm, came from the Colorado Oil & Gas Association (COGA). Their director pounced on the news, questioning the accuracy of the data. “We need accuracy, not double-counting!” was the shrill accusation. Whatever…

The data correction was severe enough, however, to justify that the CDPHE, the state department within which the APCD is located, file a formal request to change their recommendation to the Air Quality Control Commission (AQCC), the governor-appointed panel to which the CDPHE reports to about our air quality, and that they be allowed to modify their recommendations for their State Implementation Plan (SIP). These data are also required to be filed with the EPA, lending yet more weight to the issue.

Though somewhat difficult for my layman mind to decipher, the formal language in that request seems to say they underestimated emissions from the O&G industry, and they’re going to take another crack at it. The upshot is that the new estimates show the O&G industry producing significantly more GHG, and the ozone precursors, than vehicles…which is why COGA, the trade organization representing the O&G industry in Colorado, is so upset. No one likes being the bad guy.

However, the request did not discuss what might be done as a consequence; but that might be what the APCD director meant about making lemonade out of lemons. Or something like that….it’s all pretty vague and nebulous to the average layperson I should think, as it amounts to two traditionally opposed organizations pointing fingers and squabbling over numbers that none of the public really has access to anyway.

But there is a better way: it’s called direct measurement.

A model, of course, is simply an estimate of something. In this case, the APCD uses models to estimate our projected air pollution (as in, just how many severe ozone warning days are we going to get this summer?) The tempest-in-a-teacup squabbling is over the data that gets fed into the models; but, again, these data are themselves estimates, as none of these state agencies have the resources to go out and keep tabs on all the O&G operations throughout the state. In effect, the APCD is dependent on the industry to give them an honest answer about the number of their operations; which has been, of course, the long term strategy of the O&G industry in this county since the beginning: to be self-regulating, and to never allow even a hint of legislative encroachment into their dealings. Notwithstanding that the first blow to that attitude took the form of the US vs Standard Oil, when Teddy Roosevelt broke up the trusts that were dominating all major industries during the Gilded Age. Ever since, the O&G industry has waged legal and political battle to prevent regulation to affect their bottom line. And, as we have seen, the major oil companies have even been waging a disinformation campaign about the need to take action on climate change for decades…but I digress.

With the passage of SB-181 in Colorado in 2019, that battle has been slowly shifting more power to local authorities to regulate O&G operations in their jurisdictions, and thereby loosening the grip the industry previously held over centralized regulation such as by the COGCC. Now, COGA must not only contend with the COGCC, but with the CDPHE and APCD as well, which is a battlefront that COGA is not as adept at confronting. Because now the issue is the health and well being of people and their environmental quality. And the more that this health and well being can quantified by direct measurement, the sooner we can get to the bottom of the issue — and stop the pointless ping pong match of watching one side blaming the other over whose data is accurate.

The direct measurement of our air quality is what is needed; and the only technology that is capable of discriminating between the ozone precursors that originate from vehicles and those that originate from O&G activity — because they are distinctly different chemicals — are the monitors made by Boulder AIR (see bouldair.com)

Currently operating in eight sites scattered from Commerce City to Erie, in a combination of fixed and mobile stations, the data from this technology has no comparison to anything operated by the CDPHE. The ozone monitoring stations maintained by the state can only detect ozone after it is ozone; they are useless for detecting the sources of the ozone precursors. But this is precisely what is needed; because how in the world can an effective policy for reducing our ozone pollution be conducted if the real cause of the ozone is not identified?

The Larimer Alliance has been asking the Larimer County Commissioners and the Fort Collins City Council to please consider installing Boulder AIR monitoring stations here; to no avail so far. However, we are the prime target for the pollution from Weld County, where there are 18,000 plus active wells. The state ozone monitors that are here, one on the CSU main campus and one the west campus out LaPorte Street, have registered some of the highest ozone readings in the state, I’ve been told, which I would like to verify someday. This is due to the fact that the prevailing winds push the polluted air from Weld County up against the foothills to our west. It would be extremely helpful if we could get two such stations, one positioned east and west of Fort Collins, to verify the amount of pollution we are experiencing, and where it is coming from. Longmont has installed two monitors in their city; why can’t Fort Collins do the same?

To add insult to injury, the CDPHE has not even acknowledged the data that Boulder AIR has been collecting — ever since the first station went into operation at the Boulder Reservoir in 2015. These data are made available in near-real time on the Boulder AIR website, and is available for the state to use. But what does one find on the CDPHE website? Here’s a screenshot:

Screenshot from https://cdphe.colorado.gov/ozone-and-your-health, taken 1/29/23

Does anything here tell you what is causing the ozone? Barely: the implication from the left panel is that you, the public, is the primary factor identified as the cause. YOU are the guilty party….indeed. This is partly true, since the precursors coming from vehicles are indeed caused by people and commercial vehicles out driving around; but there is no discussion of how the O&G industry is the other significant caues — only a picture of a pumpjack to indicate their contribution.

So this is what needs to change, at a minimum:

  • the CDPHE needs to give equal time to the O&G industry’s role in our ozone pollution problem on their website and in their regulatory announcements
  • the CDPHE & APCD need to acknowledge the data collected by Boulder AIR stations as superior to anything they have, and start to use it to identify the true sources of ozone precursors by direct measurement

If the COGCC, CDPHE & APCD were really to take the bull by the horns, and fully live up to the spirit of SB-181 — to protect the health and well being of people and the environment over fostering the O&G industry — then they would build an entire array of Boulder AIR monitoring stations all along the Front Range, from Weld County in the north to Pueblo in the south, and start to use their data to maximum effectiveness…and cease this petty squabbling with COGA over models and estimates that is simply not helping.


Good morning, people. My name is Ed Behan and I am with the Larimer Alliance for Health, Safety, & the Environment.

Yesterday there were many celebrations of the life and times of the late, great Martin Luther King, Jr, and his lifelong quest for social justice. And now here we are demanding environmental justice. This is sometimes dismissed as not being a related issue. However I don’t think I need to remind folks that the efforts of Cultivando, the community around the Bella Romero Academy, and tribal groups who resisted the Dakota Access Pipeline and other extractive incursions on native lands, only serve to demonstrate that the issues are intertwined and always have been.

Three years ago, with the passage of Senate Bill 19-181, this State made the remarkable first step of reordering the mission of the Colorado Oil and Gas Conservation Commission to prioritize the protection of our communities’ health, our safety, and our environment.

The Larimer Alliance has advocated for improved local regulation under the mandate of that legislation, as well as lobbied at the State level during rulemaking processes.

We are all here to mark progress made. . . but also to mark that the first step taken has been a stumbling one at best. While new rules have been enacted, and new monitoring standards have been crafted, it is clear that everything from bureaucratic inertia to outright discouragement of effective enforcement has hindered our progress. This legislature has the opportunity and the duty to correct that and keep us moving forward.

Today, as in his inaugural speech last week, the governor is supposed to reaffirm his commitment to Colorado achieving the goal of having its energy needs met by 100 % renewable sources by 2040. But you all have seen the figures, you know the reality of the thousands of oil and gas permits that have been approved since he took office in 2019, and the hundreds more in the permitting pipeline. I’ll take a leap here, give Mr. Polis the benefit of the doubt, and assume we achieve the goal of Colorado’s energy needs being carbon free by the goal date. . . but where is all this oil and gas that is being developed going? I assure you, if it is not being burned here in Colorado, it is being burned somewhere else. And my friends. . . THAT AIN’T CARBON NEUTRAL!




January 12, 2023

Dear Andrea,

Economic growth in the City of Loveland is bound by a Uniform Development Code ( designed to promote public health, safety, and the general welfare.  Allowing hydraulic fracturing in the Centerra Region of Loveland violates this code and the city’s comprehensive plan.  Below are just some of the ways that fracking is NOT compatible with the Uniform Code.

Code: Promote economic opportunity, encourage investment, and promote property values.

Reality: The Oil and Gas Industry provides less than 1% of the states total employment but is projected to cost $1.36 billion annually in damages to the environment. That is 1.5 times the total taxes and fees oil and gas brings to the state. (CO Fiscal Institute, 2022).  Property values decline in areas polluted by  noise, heavy large vehicle traffic, and toxic air caused by invisible fracking gas leaks verified by infrared cameras. (Earthworks, 2022) More and more property owners in Centerra are voicing their concerns and protesting the planned 26 wells that they want stopped. (multiple dates, Loveland Reporter Herald.)

Code: Promote good civic design and site layout.

Reality: Loveland allows reverse setbacks that allow drilling only 300 feet from businesses that employ people such as wholesale nurseries, storage yards, heavy industry, composting facilities, and essential utility facilities. Residential development other than high occupancy buildings is located only 500 feet from an existing oil and gas facility. (City of Loveland Planning Division).  A majority of members of the Colorado Oil and Gas Conservation Commission say “All homes and schools in Colorado should be protected from new oil and gas drilling by a 2,000-foot buffer or setback – four times the current standard for urban areas”. (The Colorado Sun, 9-9-20) In areas with dense oil and gas site layout we see lower birth weights, more children with congenital heart defects, and more childhood cancers. (CU Anschutz Professor Lisa McKenzie). Being close to drilling sites is also dangerous for the elderly and those with breathing issues.

Code: Promote fiscally responsible infrastructure and services.

Reality:  The Oil and Gas industry has tens of thousands of orphaned wells that could cost tax payers billions of dollars to clean up. In addition to the financial burden “all of the science indicates that the dangerous gases that spew from wells are major contributors to climate change.” (Joe Salazar, Colorado Rising, 8-31-21). Climate caused disasters alone have cost the state between $20 billion and $50 billion since 1980. (Colorado Fiscal Institute)

Code: Lessen the risk of flood, fire, panic, and other dangers.

Reality: Fracking poses unique dangers to residential areas by subjecting families to known carcinogens like benzene.  In 2017 fracking gases in Firestone combusted violently in a home causing serious injuries and 2 deaths. “Forced pooling” has allowed gas companies to annex mineral rights and drill beneath homes without the owner’s consent. Climate change caused by greenhouse gas emissions, like methane, contribute to severe weather leading to floods and wildland fires.

Code: Promote the conservation of energy, water, and environmental resources.

Reality: Fracking is a water intensive industrial process. It uses, 1.5 million to 16 million gallons of water per well, according to the United States Geological Survey.<https://urldefense.com/v3/__https://www.usgs.gov/faqs/how-much-water -does-typical-hydraulically-fractured-well-require__;!!HxSnvVm2WdNPEuU!rxwQM 2UytYawcVsFzHuVsPQh0pU4UIuY7unoMMcHMeGLKizQC9rLqOym5M-3MoidYtBPjn1HC7Uy0RVe3fj0kjSXBXEpbnsdgItRO70$>

We don’t get that polluted water back and we’re currently in a 1200 year drought.

Code: Promote the use of renewable energy.

Reality: To curb our climate crisis, we need to end our dependence on fossil fuels. That may have seemed far-fetched a decade ago given the cost of installing wind and solar at the time, but in 10 years, the price of solar electricity dropped 89%, and the price of onshore wind dropped 70%. (Rocky Mountain Institute, 2019). Continued use of fossil fuels is expensive and unnecessary.

Please consider the future of our city and adherence to the Uniform Development Code as you make your decision about allowing fracking in Centerra. For everyone’s health, safety, and the general welfare city leaders owe it to its citizens to not permit fracking within city limits.

Thank you.


Nancy Garcia,

Ward 2 Loveland



Thank you for your email and the thorough, comprehensive and specific information you provided. I appreciate you taking the time to break each issue down and to relate it to code compliance with the examples directly from our code.

I have copied city manager Steve Adams and city attorney Moses Garcia in my response so that your email can be included in any information presented to council and/or planning commission in the event this issue comes before Council.

Thank you again, very much,

Andrea Samson

Loveland City Council

Ward 2