Category Archives: AQCC

Air Quality Control Commission, the Colorado state level agency charged with developing programs about air quality standards. See
https://www.colorado.gov/pacific/cdphe/aqcc and https://www.colorado.gov/pacific/cdphe/aqcc-about-commission

Not to be confused with the Air Pollution Control Division, which does the actual permitting, monitoring and enforcement: see https://www.colorado.gov/pacific/cdphe/apcd

Air quality monitoring, AQCC, CO state level politics, Environmental damage from O&G, Ozone pollution in Front Range

I EXPRESS MY COMMENTS/OUTRAGE TO THE AQCC

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The following are my humble comments to the AQCC about the review of Colorado’s SIP (State Implementation Plan) about our air quality before their public meeting on August 18, 2022:

Dear Colorado Air Quality Control Commission:

I would like to submit these written comments as an individual, but I wish the record to show that: 

…I have been teaching environmental economics at Front Range Community College since 2009, and continue to teach it

…I have been the webmaster for the following environmental activism organizations for the past several years:

> Larimer Alliance 

> Fort Collins Sustainability Group

>Colorado Coalition for a Livable Climate

>Northern Colorado Alliance for a Livable Future

I am sure you will hear many in-depth stories and analysis at today’s hearing from others who will want to persuade you with the overwhelming scientific evidence of just how bad the air quality is in the Front Range due to ozone; and that the majority of the evidence points more to oil and gas (read: fracking) activity than to vehicular exhaust. 

Two Personal Stories

I agree with that conclusion, but want to share with you two personal stories that illustrate just how destructive this lightly regulated industry is. I personally knew each of the persons in these videos that I made myself. 

The first video is an interview with Wendy Leonard made Janurary 1, 2013:

Wendy Leonard speaking on her family’s experience with fracking

Wendy is a professional nutrutionist. In her interview, she tells the story of how her four young kids starting get sick with untreatable gastro-intestinal disorders, which started after fracking operations began near their residence in Erie. No doctor could diagnose them well enough to cure the disorder. So she and her husband decided to move to Louisville. Her kids immediately recovered. Despite this, they have since decided to move out of state, where there is no fracking, to remove her family from its harm. 

Next is Rod Bruske, a brief video I made of him in the Boulder County Courthouse, just before he was going to testify at a public meeting about fracking, made in December 2012. He lives, still, with his family on rural property on the Boulder-Weld county border: 

Rod Breuske speaks out

Rod describes how the health of his family had deteriorated, and their quality of life essentially destroyed, by fracking operations near his property, from the heavy truck traffic, loud, constant noise, and air pollution bad enough to sicken his family and his livestock. I don’t know how Rod is doing these days, but I imagine he is toughing it out still on his property, like the tough farmer that he is.

The morale of these stories is this: the VOCs (volatile organic compounds) produced from fracking, coming from prehistoric geological formations deep under the earth and never meant for contact with living human beings, are poorly understood in medical science; but can have an immediate reaction in people by reacting with their nervous system from immediate skin contact. There are many anecdotal stories like this; again, few of which are systematically recorded in this lightly regulated industry. But each story is a testament how this industry should have been more closely regulated from the start (were it not for the Halliburton Loophole).

It is not difficult to find many such stories in the Front Range. There is no definitive record, but they must surely register in the hundreds, if not thousands. All of which is nearly completely unaccounted for by regulatory agencies such as yours. 

What should be done? 

In my opinion, the AQCC needs to support the creation of regional network of air quality monitors that are continuously sampling the air, analyzing it in real time, and creating an official data of record that can be used in a robust array of regulatory needs — and defensible in court if necessary. And then using this data for robust enforcement action to stop the pollution at its source. That is the only real solution. All the public notices exclaiming about ‘bad ozone days’ are not doing us one bit of good about reducing the sources of harm.

Such monitors are the only way that we are going to learn about the true sources of our ozone precursors, what is causing them, and where they are located. The only company with such technology at the moment is Boulder AIR. I’m sure you must have heard of them, as they have at least five, maybe six, monitors, which I believe are in Boulder, Longmont, Erie, Broomfield, and perhaps Commerce City. 

What is really unbelievable is that the state of Colorado does not consider the data being collected by Boulder AIR to be “real” data! I find this simply preposterous, and am really outraged as a tax-paying, concerned citizen that the air quality regulators in my state are so blind as to make such statements, and expect the public to be ok with this. We are NOT ok with this! The data collected by Boulder AIR monitors is vastly superior to anything that the state is collecting; because the number of monitors that the state has to detect ozone precursors is precisely ZERO! They not only collect readings on ppb per billion of over a dozen chemicals, they do it in real time, and they publish their results on a public website within minutes of collection (subject, of course, to later possible data corrections, which seem rare and minor). And then the data are kept in storage indefinitely in the cloud for future research or reference.

How in the world can you expect the public to trust regulatory agencies that don’t know better data when it is so blatantly obvious? Until the state air quality regulators admit this, and starts measuring our ozone precursors, and publicly producing that data, your credibility will continue to be about where your current data are: namely pretty damn worthless and near zero in quality or credibility. The state only collects readings on ozone after it is formed, and does not even have the capability of collecting data on ozone precursors. This is a shameful dereliction of duty that calls out for correction when the technology for doing so has already been proven for years.

Please start investing in some real time, continuous air quality monitors and publicly publishing that data. Then we might start believing in you. 

Sincerely,  

Rick Casey

Fort Collins

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

AQCC, CO state regulatory agencies, GHG Roadmap, Polis administration

Greenhouse gas intensity targets: the new greenwashing?

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In a recent article in the Colorado Sun (A new rule to slash oil and gas emissions.., Sept 15, 2021), a new rule adopted by the Air Quality Control Commission (AQCC) is described by the Polis administration as a way to dramatically cut the GHG emissions by the oil & gas industry.

The rule is based on something that is interestingly called “intensity targets”, which apparently simply means making an effort to reduce your GHG emissions, and then reporting how much GHG your company emits…and hopefully it goes down over time. There are reduction targets for 2025, 2030 and 2050, which have been announced for all the various kinds of O&G activities, from fracking to drilling to transport.

The calculation of the emissions by the companies has been developed by the AQCC, and are intended to be an incentive-based, rather than command-and-control-based, kind of regulation. In other words, the regulator does not specifically instruct the polluter how they are doing to reduce their pollution by using a specific technology; but rather suggests a reduction target, and leaves it up the polluter to reduce their pollution by any means they want.

The proposal has, unsurprisingly, been welcomed by the O&G industry. The industry has always preferred to be self-regulating, which was largely the approach taken by the Colorado legislature in the past, up until the passage of SB-181 in April 2019. That historic legislation, which took away the industry’s ability to self-regulate by specifically instructing the COGCC to stop allowing it, was a watershed in the state approach to regulating the O&G industry.

So it comes as a bit of a surprise, at least to this writer, why the AQCC wants to reverse course, and restore self-regulation to the industry that is primarily complicit in causing global climate change. The proposed rules carry no penalties if a company fails to meet its target, and there are no enforceable measures in the new rule. The big assumption is that each individual O&G operator will do their level best to meet their “intensity target”, i.e. a lower level of GHG emissions.

Gee, what could possibly go wrong?

Also unsurprisingly, the environmental community (i.e. Wildearth Guardians, the EDF, at this point) has denounced the new rule as a mistake which will one day have to be corrected. They make the undeniable point that climate change is happening now, and we no longer have the time to try out untested regulatory policies that could take years to evaluate.

The one benefit of the program, from what I can tell, is that it is the first time that a regulation is taking a wholistic approach, and forcing O&G operators to consider their entire operation, from start to finish, to see where best they can best reduce their emissions to meet their reduction targets. The “intensity” aspect of the regulation comes from the required overall calculation of total CO2-equivalent produced per unit of product processed. (The units used will vary by type of company and what it is producing or processing.) As some O&G operations can involved a complex series of operations, the calculation of their overall “GHG intensity” will be a complex process in itself.

However, if history is any guide, the lack of specific enforceable actions, and especially the lack of any penalty for not meeting their targets, does not auger glad tidings for the outcome of this rule. As the saying goes, the road to hell is littered with good intentions — and while this rule may have the best of intentions, I’m afraid it will just be allowing the fossil fuel companies off the hook, once again, and pushing us all closer to a hellish world where the climate veers more and more out of any sort of equilibrium, creating more and more misery with each passing year.

APCD, AQCC, GHG Roadmap

My question for the O&G GHG Roadmap

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The O&G GHG Roadmap is a major policy objective of the Polis administration, as explained at https://energyoffice.colorado.gov/climate-energy/ghg-pollution-reduction-roadmap.  However, some have questioned the intentions of the administration.  Nonetheless, the CDPHE is charged with soliciting public input  on the issues, as its part in this policy action, which will happen in two meetings, on August 16 and 31, 2021.
I registered to have some public input, and sent the message below as my questions for them.
You can still register to attend the August 31 meeting; see this link.
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Dear CDPHE:
One question I have as a concerned citizen is this: the current air quality monitors maintained by the CDPHE only detect the presence of ozone; but as we all know, ozone can be created from various constituent gasses.
The technology exists to measure not just ozone, but those constituent gasses as well, and it is my understanding that the technology used by BoulderAIR monitoring stations (see https://bouldair.com/) are capable of measuring these constituent gasses. This is especially important in order to determine how much of the ozone is being caused by vehicular traffic and how much is being caused by oil and gas operations.
There are five such stations already in place, operating in a coordinated fashion, providing a comprehensive picture of regional air quality in those areas, and building a legally defensible dataset of pollution sources. Would it not make sense to enlarge this network to cover the entire regions where ozone is a problem? Otherwise, how are you ever going to know the true source of this highly problematic pollution, and therefore manage the problem?
Thank you.
Sincerely,
Rick Casey
Fort Collins, CO