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.
