In response to a significant joint letter submitted earlier in the year by six environmental groups active in the Front Range, the COGCC at last responded to repeated requests for rules about the cumulative impacts of pollution from O&G activities. See here:
In the last paragraph you will notice that the Larimer Alliance is mentioned among the other five groups: 350 Colorado, WildEarth Guardians, Womxn from the Mountain, Physicians for Social Responsibility, and the Sierra Club of Colorado.
Today the Larimer Alliance learned that the Larimer County Community Director sent a letter to the COGCC regarding Prospect Energy, requesting that Prospect submit a Form 2A (location application for oil and gas operations) because the recompletions (redrilling the wells to a different formation) of 3 wells Prospect applied for last year are considered to be a significant change to the current operations. Prospect had originally applied only for drilling permits to drill to a different formation for the 3 existing wells.
A letter was also sent to Prospect Energy asking Prospect to comply with County oil and gas regulations.
The two letters are attached to this post.
The 41 page letter to the COGCC begins by stressing the proximity of the Prospect wells to residences (290 feet to the closest, and 22 homes within 1,000 feet), how this is in an Urban Mitigation Area, and is a “disproportionately impacted community”…and goes on from there, requesting the COGCC grant the request for a “Form 2A” review. The upshot seems to be, if granted, this will result in a delay and extra cost to Prospect…but a greater emphasis on proceeding safely, thereby increasing the chances that residents are not going to get exposed to more harmful pollution from unsafe operations — which Prospect has been known to do in the recent past.
The following is an email I sent on 12/14/2021 in response to an EPA Grant Competition offered to local communities to improve their air quality monitoring capabilities; I found out about it on the listserv for CCLC ( Colorado Coalition for a Livable Climate). Ms Archuleta is Cassie Archuleta, the head of the Air Quality Department in Fort Collins:
Dear Larimer County Commissioners and Ms. Archuleta:
I would like to bring to your attention, if you were not already aware, of this EPA Notification of a grant competition for $20 million for Community Air Pollution Monitoring; please find attached. The public meeting for it will be on January 11, 2022. It is targeted at “communities with health outcome disparities.”
I think if the data on respiratory illnesses in Larimer County were summarized, I believe it would have communities that qualify. The bad ozone conditions here in the summer must certainly be having its effect. Just publishing that data would be useful in and of itself.
If the state air quality regulators were serious about discovering the sources of what’s causing all this ozone — instead of just installing ozone monitors to tell us how bad it is, and what days to stay indoors — they would have installed an array of BoulderAIR monitors from Wellington to Pueblo by now. Instead, the cities and counties have had to take on this job in piecemeal fashion, as you well know. It is no way to manage a regional air pollution issue.
If Larimer County were to coordinate with the five other BoulderAIR monitoring stations from Boulder to Erie, we would be able to find the real causes of our air pollution. And then, and only then, will we be able to start to managing this pollution problem with data driven results. I hope some staff can be directed to evaluate this opportunity; and hopefully take advantage of it.
Best regards, Rick Casey
PS — This is the positive response from Commissioners Kefalas and Stephens in reply: