Category Archives: CO state regulatory agencies

Comments by Doug Henderson to COGCC, June 16, 2021

I am Doug Henderson, a resident of Larimer County, speaking for the Larimer Alliance for Health Safety and Environment, a coalition of residents and organizations in Larimer County.

Larimer County’s air quality is terrible, due largely to oil and gas industry emissions.

The American Lung Association gives Larimer County a grade F for air quality. In 2019, Fort Collins was ranked #24 worst in ozone pollution of over 200 cities in the US. In 2020, Fort Collins ranked lower: #19 worst in the US.

The NCAR FRAPPÉ study found conclusively that oil & gas industry emissions are the major driver of unhealthy air quality in the northern Front Range including Larimer County. Improving our air quality depends on reducing emissions from oil and gas facilities.

We in Larimer also face the mega problem of climate change and all its ramifications. The impacts are not in some distant future, they are immediate and close to home. Last summer, the biggest wildfire in Colorado’s history was directly west of where I live near Ft Collins, wreaking both immediate and lasting impacts. It’s only mid-June now, but this week we are sweltering, and almost every day is an air alert, very bad air day.

What kind of canary in the coalmine does Colorado’s officialdom need to wake up, get serious, and take meaningful action to rapidly reduce harmful emissions and greenhouse gases such as methane?

It is time – past time – that COGCC takes serious action to stop harmful, often illegal, emissions from O&G facilities and sites.

These emissions happen at virtually all O&G facilities, causing damage to people’s health, ruining our air quality, and doing grave harm to our environment and climate. Colorado expects operators to self-report and be honest about emissions. But the real honest truth is that the industry lies about its emissions. And in spite of this open secret, there has been very little monitoring, investigation, and enforcement by state or local authorities.

One example here in Larimer County –

Investigators with the organization Earthworks recently documented emissions at an O&G facility just NE of Ft Collins, in Larimer County. The investigation was triggered by a report from a nearby local resident, who has experienced health problems for years from this facility – headaches, nausea, nosebleeds, possibly long-term damage.

The facility has been leaking harmful and illegal emissions for many years – harming local people, air quality and our environment. Although the operator was cited for violations a number of times over years, the leaks continued, and local residents suffered health effects. It took repeated imaging documentation by Earthworks and reports to the state in the first months of this year before the operator finally made repairs that stopped the leaks.

Without that, the facility would be leaking now, with the operator denying there was a problem, and authorities replying on self-reporting and trusting the operator to fix leaks.

Unfortunately this is typical O&G business as usual, how the industry has operated for decades.

COGCC needs to get serious about stopping harmful emissions.

Every O&G site needs monitoring adequate to identify harmful emissions and to report in real time, to be useful for addressing problems when they occur. Technology is readily available to do this. But of course the industry prefers monitoring and reporting that provides results weeks or months later, and is not public, because its useless for really ending leaks and holding polluters responsible.

Local residents and emergency responders have a right to know what is being emitted, available on a public website with alert options so that people can know when a dangerous emission occurs near them and take precautions.

The problem of emissions isn’t only with active wells and facilities it is also inactive wells, including properly plugged and abandoned wells and wells simply  abandoned.

Mechanical Integrity Tests are needed and necessary to ensure that inactive wells are not a danger to public health and safety, not harming the environment, and not causing climate damage, possibly huge damage.

Credible research points to idle inactive wells and abandoned wells as significant sources of methane emissions.

But without integrity tests of these wells, there is no way to ensure that they aren’t leaking methane and other harmful pollutants. And no way to know if some may be “super emitters” that are contributing disproportionately to climate change.

We ask COGCC to put more attention and effort to
• emissions monitoring and reporting,
• to enforcement that serves as effective deterrent,
• and to ensuring that mechanical integrity tests are conducted to
identify emissions and to stop them.

We encourage that this happens sooner rather than later – for protection of public health, safety and environment, and because rapid reduction of GHGs – sooner, not later – is crucial to maintaining a livable climate and planet.

Thank you for your attention to and action on rapid reduction of emissions.

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.