Category Archives: CO state regulatory agencies

The quest begins: where is the data on water and fracking?

This is request I made to the Colorado Department of Water Resources today:

Hello DWR:

I have a report from CO DNR (Dept of Natural Resources?) that writes about water and fracking, circa January 2017. Please see attached.

It refers to a “Colorado Water Diversions table”, and shows a line in the report where there is a breakdown of water use, with one line for “hydraulic fracturing.”

I have tried finding this report on your website to no avail. I cannot remember how I found this report, and it is unfortunate that it does not contain any other identifying information, such as who or what office authored the report.

I am basically a concerned citizen that volunteers for a non-profit, and we are trying to find the answer to two simple questions: 1) how much water goes into fracking? (preferably on a county basis), and 2) where does the produced water go?

I am hoping someone in your office might be able to help me.

Rick Casey


Comments on COGCC hearing on financial assurance

These are comments I made during live commentary at the public COGCC meeting on March 31, 2021: 

Good evening Commissioners,

I am Doug Henderson, I live in Larimer County. I am speaking for the Larimer Alliance for Health, Safety and Environment, a coalition that represents thousands of Larimer County residents.

Oil & gas development has many financial costs that are externalized and avoided by the industry –

  • O&G operations collide with residential areas and neighborhood — so people suffer and get sick

from these operations and emissions, with big costs to their lives, families, and communities

  • property values decline, causing losses to homeowners
  • communities become embroiled in fighting against O&G,

costing residents, local governments, and public agencies untold millions

  • air and water get polluted, with huge costs now and into the future
  • billions of gals of toxic waste gets pumped underground –

its false to pretend this won’t have costly consequences

  • many spills, explosions, and fires occur,with costs to emergency services, people’s health, 

and to the environment

  • and the list also includes thousands of old wells and sites left by operators, for taxpayers to pay to clean up.

It is time that O&G operators are required to pay their way, to cover all their costs, from start to finish, to operate when and where it is genuinely profitable, not because it is subsidized by externalizing costs to others, to local communities, to local and state governments, and to taxpayers.

At this point, taxpayers are already facing the cost of plugging and cleaning up thousands of orphaned wells in Colorado, which will run to hundreds of millions. The O&G industry is unwilling to pay to clean up after itself.

It is this Commission’s responsibility to make sure that going forward, the O&G industry acts responsibly, and that operators are capable and responsible for fully covering costs.

COGCC must require full-cost bonding, set at a level that provides real financial incentive to properly shut down, plug, and abandon wells, and to fully reclaim and remediate sites. Every well needs to bonded. Inadequate bonding creates incentive for operators to escape properly shutting down and cleaning up sites.

Allowing blanket bonding must eliminated – in some cases now, the effective bond is under $1000 per well.

COGCC also should get serious about a mechanism for the O&G industry to pay for cleaning up orphaned wells and sites in Colorado – so taxpayers won’t be left with clean-up costs.

The industry claims to be responsible toward the public and the environment.

COGCC needs to be sure the industry and operators walk their talk – from start to finish, including cleaning up after all their operations and all sites, current, future, and past, instead of leaving it to taxpayers.

We thank the Commissioners and staff in COGCC who have genuinely embraced reform in oversight of O&G development in Colorado, including protecting the taxpayers from undue financial risk and cost.

Comment to BOCC 3/16/2021

Dear Commissioners,

Something has come to my attention and I want you to know about it, if you don’t already. I was looking at the wells in Northern Larimer County while on the COGCC website and I found something very concerning. I have added the screen shots below for you. You can see the dotted black line at the border of Larimer County and Weld County and the yellow areas where Fort Collins and Wellington are located on this map. It shows many lakes and ponds located in northeast Larimer County. Many of these lakes, I believe, are used for irrigation. They’re also used by livestock and wildlife and the groundwater supports the huge cottonwoods in this area.

The next screen shot is the same location but this time I selected the “Specified Area CDPHE Regulation 42” option and this is what I saw.

The CDPHE Regulation 42 Specified Area was defined in 1999 by the Colorado Water Quality Control Commission (WQCC) and the Colorado Oil and Gas Commission (COGCC). They ruled that the ground water in this area was, in their words, “a waste” and not expected to be used in the future for domestic or agricultural purposes.  This ruling allows the exclusion of the groundwater throughout this entire area from even basic protection from pollutants associated with the exploration, development, or production of crude oil and natural gas.

According to this ruling, Tables 1- 4 of the Basic Standards for Ground Water, 41.0 do not apply for this area. Additionally, the groundwater organic chemical standards included in Table A of Section 41.5.C.3 of the Basic Standards for Ground Water (5 CCR 1002-41) for benzene, toluene, ethylbenzene, xylenes, and benzo(a)pyrene do not apply to oil and gas producing formations within this specified area. Then, last year during the pandemic the Water Quality Control Commission published the following ruling:


This new ruling is the same old ruling from 1999 but in this one, the Water Quality Control Commission attempts to justify this new ruling by saying this only applies to certain geological formations in the ground and not surface water.

What this ruling did was open this entire area to be used as a dumping ground for toxic produced water that comes out of fracked wells. There is no guarantee that the produced water these companies are injecting into wells in this area are not connected to surface water somewhere. Concrete used in these wells fail often so there is a high potential for aquafers in the area to be contaminated.

Commissioners, I implore you to question these rulings and demand that this polluting of our natural resources is stopped. How can we allow these beautiful lakes, wetlands, and grassland areas to become permanently polluted with toxic hydrocarbons, radioactive materials and other harmful compounds?

Thank you so much for your time and attention.

Lori Brunswig

Fort Collins, CO

(Please see the current ruling on page 175 at the following link.)