All posts by Rick Casey

Air quality monitoring, APCD, CO state regulatory agencies, Environmental damage from O&G, General Environmental Reference, Ozone pollution in Front Range

Colorado Sun’s Peak Ozone ‘dog & pony’ show

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Tonight, September 4, 2023, the Colorado Sun digital newspaper, broadcast its much-advertised presentation on “Peak Ozone” with the hopeful tag line of “Looking at Colorado’s ozone season, how it’s going, and at policy changes”.

The presentation was recorded, which you can see at:

WATCH: How Colorado is dealing with Peak Ozone

I commend the Sun reporter, Michael Booth, for interviewing the two top air quality regulators, Michael Ogletree, director of the Air Pollution Control Division, and Mike Silverstein, executive director of the Regional Air Quality Council. This is indeed a public service on a tough public health issue.

However, the reporter never asked the really tough questions about positively identifying the sources of our ozone precursors — which can only be done if you have sensors capable of measuring them, which the state currently does not possess at scale. (It does have a few sensors that can detect some ozone precursors; but they are not powerful enough to identify the chemical source of the precursors, i.e. vehicles vs O&G.) He did attempt to warm up to the topic, asking when are the regulators going to start using “sticks” instead of “carrots” in their policy decisions — but it never really went anywhere.

Poor Mr Ogletree and Mr Silverstein have the unenviable jobs of explaining to the public why our progress in reducing our summer ozone has been so poor. I must say they have learned to become quite adept at every possible euphemism about air quality sources and deflecting the questions to easier topics; but by the end of the presentation, hearing them talk was like eating cotton candy: all air and sweetness, but no substance.

For example: here is a screenshot of one of the main tables of data discussed:

This looks very scientific, doesn’t it? I mean, anytime you mention “ppb — parts per billion — that means this was an actual measurement, right?

Actually….no. Not exactly. These are not measurements at all, but model estimates, based on counts of the sources of emissions in the ‘Ozone Source’ column, like number of cars, number of factories, and number of O&G wells. For the latter, the state has to trust that industry is giving it accurate data, too, since they don’t have the resources to go out and count them themselves. And I have no idea how the ‘Backgrond and Natural’ source is measured or counted, which would be interesting to know; but they made much ado about how much “natural” ozone is out there, which apparently we can’t do much about. Really? Why don’t other areas have this problem? That was not explained.

So, it may just be my cynical nature, but I would rather trust an actual measurement, not take some model’s estimate, of something this serious.

Which is why we need to get a BoulderAIR monitoring station in Larimer County — so we can actually know what’s in our air.

Let’s hope the Colorado Sun gets some constructive criticism about their presentation — and by next year get some real answers to some real questions.

Air quality monitoring, APCD, CDPHE, CO state regulatory agencies, Environmental damage from O&G, General Environmental Reference, Ozone pollution in Front Range, SB-181

The Colorado Sun misses the mark

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or how the public continues to be confused over why our air pollution worsens…

This was a letter I sent to the Colorado Sun today in reaction to a misleading article about our ozone pollution problem..it is self-explanatory:

Re: the 7/9/24 story on “…hunt down one Colorado county’s toxic ozone producers” (by Michael Booth)

Dear Mr. Booth:

I am a subscribing member of the Colorado Sun, and am thankful that we have a reporter like you covering stories about the environment and regulatory enforcement. 

However, the story that was published today “Researchers are surveilling land, air and space to hunt down one Colorado county’s toxic ozone producers” is somewhat misleading. If you are seeking to inform the public about the most effective ways in which to identify the sources of ozone in Weld County, please read on. 

It is all well and good that Coloradoans are getting the assistance of federal agencies like NOAA’s aircraft and NASA’s satellites to help identify the worst sources of ozone precursors from O&G operations in Weld County. I have no doubt they will help…somewhat.

However, they will be one-time operations, which will not be a persistent tool that can be counted on to help us, month in and month out. The FRIPPE study which NOAA conducted back in 2014 was their last effort to assist Colorado in identifying the source of ozone precursors. It proved that O&G and vehicular exhaust both contribute, but did little to pinpoint specific operators in Weld County. Perhaps their efforts this time will do that; we shall see. 

What is needed, though, is a permanent, on-going ground-based monitoring effort, which is measuring our air quality on a continuous basis. The instruments need to be reliable enough on which to base a strong regulatory program that includes provisions for regulatory enforcement actions, including cease-&-desist orders. The technology for doing this certainly exists, and has been put into use in Boulder County, Longmont, Erie and Broomfield (Commerce City had one for a year around 2021 but closed it down for reasons discussed below). The state regulatory agency that is in charge of monitoring our air quality, and enforcing regulatory action, is the APCD (Air Pollution Control Division) within the CDPHE (Colorado Department of Public Health and the Environment). 

It should interest us to learn why these four jurisdictions decided to spend hundreds of thousands of dollars to build their own air quality monitoring stations. They did so, starting in 2017, because of the distrust of these state agencies and the sincerity of their efforts; perhaps basic competency may have played a part as well. When the O&G industry had controlled the regulatory environment in this state for over half a century, it tends to have an effect on how well funded such regulatory efforts are. While SB-181, the historic law passed in 2019, did fundamentally change the mission of those regulations, there was nothing in that law that changed how much funding went into those regulatory changes; and certainly nothing about air quality monitoring. It is a problem that still needs to be corrected.

Unfortunately, the investment by these Front Range communities has not resulted in any improvement in our ozone pollution problem over the years. Why not? Shouldn’t this improved monitoring, and an abundance of data, have resulted in changes in state regulatory action? 

Sad to say, it has not. There has not been one iota of reduction in emissions pollution. In fact, dozens of violations of emission permits have been documented by Earthworks, filmed in action by their OGI field operators, all of which were submitted to the APCD, which has seldom taken any action to contact the operators about them. 

This lack of enforcement action by the APCD/CDPHE is slowly being recognized as the real impediment to progress on these environmental crimes. This was why the Green Latinos, who were instrumental in the acquisition of the continuous monitoring station that was in operation in Commerce City for a year around 2021, decided to shut it down. Even though they could have continued to operate it, they decided not to do so because their data was effectively ignored by these state agencies. Their refusal to continue to monitor should be recognized as a sign of protest against injustice: the injustice of these regulatory agencies to do their job, which is to protect our environment against such polluters. 

The Larimer Alliance, with whom I volunteer, has been trying to get a continuous monitoring station here in Larimer County. We want to understand where our ozone precursors are originating, which we strongly suspect are coming mostly from Weld County. If we can get a continuous monitoring station installed, and begin to quantify those precursors, we feel confident we will have the scientific data to prove this. 

But it will be of little avail if the state regulatory agencies do nothing with the data. And that will be our next political barrier to overcome, before we start to make progress on curbing our extreme ozone pollution. 

Sincerely, 

Rick Casey 

——————————-webmaster: larimeralliance.org, larimerallianceblog.org, focosustainability.org, colivableclimate.org, ncalf.org

Air quality monitoring, APCD, AQCC, CDPHE, City of Fort Collins, Larimer County Climate Smart Initiative, Ozone pollution in Front Range

To my local electeds: Why we need to monitor our local air quality

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Dear reader: this is an open letter to the Fort Collins Council and Larimer County Commissioners about the need for a substantive air quality monitoring (AQM) plan for our region — because we cannot depend on the state to provide it. More importantly, the letter addresses the ultimate question of the purpose of air quality monitoring and its ultimate goal: to improve our air quality. Any rational plan for improving air quality would involve two basic steps: identifying the causes of the pollution, and, next, adopting measures to reduce or eliminate the cause. To date, the state’s AQM programs have been a regulatory failure, and the Front Range public is growing increasingly dissatisfied with them.

Because such measures could become contentious, and involve legal disputes, the quality and reliability of AQM data must be sound enough to withstand regulatory and legal scrutiny. This is a foremost requirement, and should be recognized at the outset if the ultimate goal of improving our air quality is to be achieved. Exactly what measures will need to be taken to reduce the sources of our ozone pollution are yet unknown; but identifying the exact sources of the pollution is an undeniable first step towards any effective solution.

I hope this open letter will help to inform, educate and inspire some of you to contact your own electeds as well, and ask them for the same.

Note on acronyms: AQM = Air Quality Monitoring

Dear Fort Collins City Council and Larimer County Commissioners:

We have an urgent need to improve and strength our local air quality monitoring (AQM) programs, because the efforts of the state’s AQM programs have been a regulatory failure.

Our air quality problems are a regional problem; no single city or county can effectively do much about it. Until local communities in the Front Range band together to demand, in unison and with a strategic plan, that the state take decisive action against the real source of ozone pollution, I fear it is never going to happen. I fear that Weld County, and in other O&G plays around the state, will continue to encourage the drilling of new oil and gas wells, and continue to worsen our already severe ozone pollution, until I am in my grave — unless there is a unification of the local cities and counties across the Front Range in demanding a dramatic change in state regulatory policy. I have completely lost faith in our politically hamstrung, obsequiously passive, operationally opaque, and publicly unresponsive regulatory agencies to do anything effective about our ozone problem. They have done next to nothing but pass around paper, and issue press releases that congratulate themselves about what a great job they’re doing for years. This is despite the passing of SB-181 in 2019, which supposedly gave local communities the legal authority to regulate the O&G industry.

However, SB-181 did not address air quality at all, and left the existing regulatory agencies largely intact, which have been slow to react to impacted communities. Just ask the Green Latinos organization how much they were helped in their battles with Suncor. These heavily polluted communities in Commerce City had been complaining for years to the state air quality agencies to no effect. Finally, after a dramatic failure at the refinery in 2019, there was a $9 million fine against Suncor, and part of those proceeds were used to fund a mobile Boulder AIR monitoring station there. This collected data for a year, which showed conclusively how much more polluted the air in these communities was. The Green Latinos thought this scientific data would be enough to prove to the CDPHE that more restrictions against Suncor were needed. Did the APCD and CDPHE listen?

No such luck; their requests for additional rules against Suncor’s emissions were rejected. The only change since then has been the creation of a department of Environmental Justice within the CDPHE, which sounds nice but functions little more than window dressing when it comes to tough enforcement decisions. The CDPHE marches merrily along, doing more studies, creating more task forces, and never, ever rejecting emissions permits from O&G operators. They seem to think they are doing a great job, such as the Globeville, Elyria, and Swansea
Community Health Study. The webpage and report look great; but it changed nothing in terms of industry’s ability to get more permits and pollute more air.

If they are doing such a great job, then why are one out of three summer days now ozone alert days? What have they really done to address the “severe” category of EPA bad air quality rating? How much have the precursors that produce this ozone pollution been reduced? Is there even any mention of plan to measure these precursors?

To each of those questions the answer is a resounding “No”. Has there been any change in enforcement actions against known O&G violators? Ask EarthJustice, which has fielded an OGI camera operator in the northern Colorado area for the past several years. I recently profiled their 2023 report in this blog post: Certified Disaster: a powerful report hits home. Seeing is believing, and the OGI videos, recorded at scores of locations scattered across northern Colorado, are inescapable evidence of how O&G operators repeatedly violate their emission permits with impunity from the regulatory agency, the Air Pollution Control Division with the CDPHE.

As for a personal testimony of how just how bad the air quality in Weld Countyis and how it has ruined the quality of life for some citizens there, read this report from a local citizen: A Citizen’s Testimony.

Such powerful evidence shows how this is a regional air quality issue, not confined to a few local O&G operations.

The Existing Effort Is Not Enough

The existing air quality monitors for Fort Collins are shown its Air Quality webpage. There are six monitors inside the city limits, and two more in northern Larimer County, as shown in this screenshot:

All of these stations only monitor for ozone and particulates however:

Why is this not good enough? Because they do not indicate the ozone precursors, only the final result which is ozone. Ozone is not produced directly at the pollution source; the polluting source creates gasses known as ozone precursors, which when combined with sunlight, create surface level ozone.

Ozone precursors have two primary sources: vehicular emissions and O&G activity, which are two very different things. Any effective ozone management plan would need separate policies to address the two separate sources; no single policy can remedy both, as they will require very different approaches to reduce them. And any effective policies will need to know how much each source is responsible for its share of contributing to the ozone problem. The scientific process of identifying the respective sources is called source attribution, which is a well known and tractable problem in atmospheric chemistry. While complex, this is not unknown territory; the methods and procedures to identify these sources are known. What we lack is political will and a unified plan to address it.

In essence, what needs to happen is simple: (1) identify the source of the ozone precursors, and (2) reduce their creation at the source. While step (2) may be problematic, and politically difficult, what is not so difficult is the step (1): identification of the source. One would think this should be a no-brainer.

But this is where the state approach has been so woefully lacking. Because the O&G industry had exerted such strong control over how the state regulated them for so long, in the pre-SB-181 days, they were effectively self-regulating. And they still are, in some important respects. On average, active wells are only inspected by a state inspector every few years, because there are so few of them. All spills or emission events are self-reported by the operators. In nearly all phases of an O&G well after it has been permitted — and they have been rarely refused under the Polis administration — the drilling, the onsite operations, the fracking, and the production of fossil fuels from a well is done under a self-reporting approach.

This is why a robust air quality monitoring program — which collects scientifically valid and legally defensible data — is so needed and could be a key part of a strategic plan to reduce ozone precursors; and thereby our severe ozone pollution. The other advantage? Locally controlled AQM programs will not be under the control of the state agencies that have failed to do their job.

In fact, distrust of the state air regulatory agencies was the reason in the first place that local jurisdictions began building their own AQM stations: so that they could produce and trust their own data. Although there was never a long range plan on how to use the data constructively, there was enough public concern over their air pollution that they were built anyway. The company they contracted to build them was Boulder AIR because they are built with state of the art equipment to collect continuous, real time air quality samples, which are published on a public website within 15 minutes. They are the gold standard of air quality monitoring stations in the state. Despite their exalted reputation within the monitoring community, the CDPHE has never accepted Boulder AIR data as valid for its own policy making decisions. The reason for this has never been made clear, except for the fact that their own sensors did not generate it. In case anyone would like to inform the CDPHE: there is such a thing as learning from experience, and admitting when you are wrong. In reality, the CDPHE simply will not admit that it has no comparable data collection capability, and will continue to stubbornly resist that it would benefit the public if they would do so, but are only likely need to do so when forced by new legislation — which seems to be where this standoff is headed.

The standards and quality of the data which Boulder AIR stations collect exceeds what the state collects with its monitors. The majority of CDPHE monitors collect only ozone data. Only a minority can detect NOx at all, and even these cannot detect the difference between ozone precursors the way that Boulder AIR monitors can; and none of them publish their data automatically within a few minutes on a public-facing website, and store their data in the internet cloud. No other monitoring system’s data has been audited by the EPA and accepted into its repository for Air Quality Data Collected at Outdoor Monitors Across the US (see www.epa.gov/outdoor-air-quality-data)

Our local electeds really need more information on the comparative functionality of the various sensors that are being discussed.

Beyond understanding the differences in the how the equipment in monitoring stations works, and how that affects the quality of the data they collect, what is really lacking is a plan on what to do with this data.

What is needed: a strategic plan

What has become apparent after years of data collection by the state agencies and local jurisdictions is that none of this has been coordinated by any kind of overall strategic plan focused on the real roots of the problem. As so often occurs when the really tough questions need to be asked, there is every incentive to avoid them; or, worse yet, put political and legal roadblocks in the way of even allowing such questions to be asked. And even if they are asked, to deflect them away.

Such has been the evolution of developing legislation — any legislation — that can identify the cause of our ozone pollution, and have the teeth to really address it. This has been the political obstacle, where entrenched interests defending the O&G industry have obstructed any legislation that regulates them. Even the historic passage of SB-181 did nothing to address air pollution.

Local air quality monitoring began with Boulder County’s station at the Boulder Reservoir in 2015. Since then, it has built stations in Longmont (two), Erie and Broomfield. (The last was suspended for 2024, but Broomfield is reconsidering that decision based on recent survey; see Broomfield’s annual focus session puts … air quality in the spotlight, Daily Camera, 3/8/24) This represents a substantial investment by these local jurisdictions to get real-time, high quality data that tells them exactly what is in their air.

But is knowing what is in your air enough? Is it enough just to know to what degree your community is being slowly poisoned? For those who have personally suffered the health effects of such poisoning, the answer is obviously no; the cause should be addressed, not just the symptoms. But up to now, the only actions that have been taken by the state and local jurisdictions is to develop ‘ozone alerts’, and warn people, via text, email and social media, to not go outside.

This approach might be tolerated if the alert days were rare; but when they start to become one out of every three days during the summer months, the situation is no longer tolerable. It is becoming a chronic problem…and some kind of remediative action must be taken. How long will people tolerate inaction by our electeds on this matter? Although there has been an exceptional level of legislative action in the current term, even if all the bills dealing with ozone pollution are passed this year, they will still not get at the real root of the problem: knowing which ozone precursors are causing the problem, where the generation source is located, and which areas are being the most affected. All three of these phases of our ozone pollution problem need to be identified in order for a coherent management plan to develop. This will only be possible if there is a state-level coordinated suite of monitors, operated in a coordinated fashion, that is focused on gathering such data.

There has been some activity among the local cities that have installed Boulder AIR monitors; this deserves more coverage, as the entire region could benefit from their coordinated collaboration. This only makes sense, because the more monitors you can add to a network, it increases the value of the overall data. Just as in social media or economics, there is a “network effect” where the more nodes there are on a network, the more value of the data of each individual node.

And here is another unique advantage of the Boulder AIR data: its ability to combine its live data stream with wind vector data to construct images that can show the intensity a pollutant over a region over certain period of time. The exact interpretation of these images requires expert interpretation; but what is undeniable, is that these images are based on science-based data collected by calibrated instruments.

Here are a couple of images to suggest what is possible:

The above images suggest what is possible with Boulder AIR data: realistic two dimensional maps of pollution intensity over the nearby region of the monitoring station over a specific time period. Such information could be extremely valuable, I would think, to the jurisdictions interested in their

One caveat to the above images: they require a certain amount of highly customized work effort to produce by Boulder AIR, at the present time. However, in my opinion, these trial versions, like any trial version in a production process, could be improved upon. In my experience with software, I would see no reason why such data could not be transformed into animated images, like weather radar, given sufficient resources to accomplish the task. This is the power of combining the Boulder AIR stations data into a concerted effort: joint efforts could result in amplified benefits to all involved due to the combined nature of the data covering a wider region.

And, in the final analysis, this is what is needed for a regional approach to a regional problem: a linked network of monitoring stations capable of gathering uniformly calibrated data to produce a comprehensive picture of the problem. No other AQM technology comes even close to providing this type of comprehensive coverage for a regional area.

But asking the various local jurisdictions to continue to voluntarily coordinate efforts to share data seems wholly insufficient; which begs the question: to what end? No matter how much data we gather on how much our environment and people are being poisoned, this will never solve the problem. The only action that will solve the problem is to reduce the generation of the ozone precursors at their source.

Air quality monitoring, CDPHE, Colorado Rising, Conservation Colorado, Environmental damage from O&G, General Environmental Reference, Ozone pollution in Front Range

Patagonia sponsors local activists fighting ozone pollution by…running?

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Fighting air pollution by running? Yes, there is such a thing…and I and Ed Behan attended this event that proved it is happening.

Ed & I at Patagonia Boulder…where we didn’t realize we were being photo-bombed!

On Friday night, February 9, 2024, Ed Behan and I drove down from Fort Collins to the Patagonia store in Boulder. ‘Step Up for Air’ was sponsored Colorado Rising, Suffer Better and the Colorado Regional Air Quality Council. It was billed as the “RUFA Pre-Race Event this year!” on their Facebook page. (RUFA, if you couldn’t guess, is Run Up For Air — of course!)

Neither I nor Ed are runners, of course; we were there for the free food and drink, and the chance to meet other activists in person.

The event was slow to get started…because some of the participants were still out on a run!

Talked with Christiaan van Hooteberg and Brent Goodlet, both local activists. Christiaan is with the Erie Protectors, and actually was on Erie’s city council for 4 years recently. He’s an IT guy, and informed me he has downloaded the ENTIRE ECMC database, and is using the information to good effect! He showed me a cool map he had made recently of all the wells, included the underground horizontal well bores, that are in the Erie vicinity — an alarming graphic which looks a crowded pincushion. I hope to work with him in the future.

The main organizer of the event, Patrick, with Run Up for Air, encouraged people to sign up for a local running event, coming up soon — this group seems to prefer running in the winter! — which would raise money for this environmental cause.

Patrick’s introduction was followed by an excellent film made by Patagonia about the origins and continuing winter running event in Salt Lake City by a 24 hr run up and down Grandeur Mountain. Started about 10 years ago, the type of event has spread to a few other cities scattered across the West, for the same purpose: calling attention to air pollution and raising money to help develop legislation to change it.

Next were several presentations by local representatives who are working on this. I did not get a picture of the presentation by the representative from the Regional Air Quality Council, but who vouched that the issue if of real concern to local governments; however, her presentation lacked information about what can be done to remedy the situation.

The next two presenters did address this question:

This is Jared Bynum of Colorado Rising, who gave quite an animated delievery of why the impacts of fracking so harmful, but which has been allowed to affect so many residential communities in the Front Range.

Helena Gonzalez of Conservation Colorado gave a quite thorough walkthrough of current analysis they use in their lobbying of the Colorado legislature. They are tackling the O&G industry head-on, and presenting the strong case for why they are the primary cause of our ozone pollution problem — and helping to develop the necessary legislation to correct it.

Poster of why surface level ozone is not good for you! Very good to see this detailed information getting out to the public.

The evening ended in a raffle, where a lucky few won some good gear.

And with that, Ed and I drove home in a snowstorm back up the Fort Collins. It was worth it!