Category Archives: Ozone pollution in Front Range

WHY CAN’T THE STATE GET ITS FACTS STRAIGHT?

Spoiler alert: there is a better way to monitor our air pollution than modeling it…

A rather alarming announcement was made recently by the top agency that monitors our air quality for the state:

Corrected ozone data estimate fracking and drilling produce more emissions than every Front Range vehicle

Aside from the misleading title (“every Front Range vehicle”?), the article zeroed in on the foremost burning issue about air quality in the Front Range: what is causing our severe ozone pollution, and how can it be corrected?

Published January 5, 2023, by Colorado Public Radio, the article states that the Air Pollution Control Division (APCD) underestimated the projected pollution in 2023 that will be produced by the O&G industry by no small amount: about 100%, more or less. The extreme number resulted in some extreme reactions from actual people: the director of the APCD, with egg on his face, nonetheless put his best face forward, saying they will “make lemons out of this lemonade,” though I think he was either misquoted or meant that the other way around. “We will get a stronger implementation plan because of this,” he solemnly vowed.

The other extreme reaction, which swiftly came from the industry side, as if dancing together in rhythm, came from the Colorado Oil & Gas Association (COGA). Their director pounced on the news, questioning the accuracy of the data. “We need accuracy, not double-counting!” was the shrill accusation. Whatever…

The data correction was severe enough, however, to justify that the CDPHE, the state department within which the APCD is located, file a formal request to change their recommendation to the Air Quality Control Commission (AQCC), the governor-appointed panel to which the CDPHE reports to about our air quality, and that they be allowed to modify their recommendations for their State Implementation Plan (SIP). These data are also required to be filed with the EPA, lending yet more weight to the issue.

Though somewhat difficult for my layman mind to decipher, the formal language in that request seems to say they underestimated emissions from the O&G industry, and they’re going to take another crack at it. The upshot is that the new estimates show the O&G industry producing significantly more GHG, and the ozone precursors, than vehicles…which is why COGA, the trade organization representing the O&G industry in Colorado, is so upset. No one likes being the bad guy.

However, the request did not discuss what might be done as a consequence; but that might be what the APCD director meant about making lemonade out of lemons. Or something like that….it’s all pretty vague and nebulous to the average layperson I should think, as it amounts to two traditionally opposed organizations pointing fingers and squabbling over numbers that none of the public really has access to anyway.

But there is a better way: it’s called direct measurement.

A model, of course, is simply an estimate of something. In this case, the APCD uses models to estimate our projected air pollution (as in, just how many severe ozone warning days are we going to get this summer?) The tempest-in-a-teacup squabbling is over the data that gets fed into the models; but, again, these data are themselves estimates, as none of these state agencies have the resources to go out and keep tabs on all the O&G operations throughout the state. In effect, the APCD is dependent on the industry to give them an honest answer about the number of their operations; which has been, of course, the long term strategy of the O&G industry in this county since the beginning: to be self-regulating, and to never allow even a hint of legislative encroachment into their dealings. Notwithstanding that the first blow to that attitude took the form of the US vs Standard Oil, when Teddy Roosevelt broke up the trusts that were dominating all major industries during the Gilded Age. Ever since, the O&G industry has waged legal and political battle to prevent regulation to affect their bottom line. And, as we have seen, the major oil companies have even been waging a disinformation campaign about the need to take action on climate change for decades…but I digress.

With the passage of SB-181 in Colorado in 2019, that battle has been slowly shifting more power to local authorities to regulate O&G operations in their jurisdictions, and thereby loosening the grip the industry previously held over centralized regulation such as by the COGCC. Now, COGA must not only contend with the COGCC, but with the CDPHE and APCD as well, which is a battlefront that COGA is not as adept at confronting. Because now the issue is the health and well being of people and their environmental quality. And the more that this health and well being can quantified by direct measurement, the sooner we can get to the bottom of the issue — and stop the pointless ping pong match of watching one side blaming the other over whose data is accurate.

The direct measurement of our air quality is what is needed; and the only technology that is capable of discriminating between the ozone precursors that originate from vehicles and those that originate from O&G activity — because they are distinctly different chemicals — are the monitors made by Boulder AIR (see bouldair.com)

Currently operating in eight sites scattered from Commerce City to Erie, in a combination of fixed and mobile stations, the data from this technology has no comparison to anything operated by the CDPHE. The ozone monitoring stations maintained by the state can only detect ozone after it is ozone; they are useless for detecting the sources of the ozone precursors. But this is precisely what is needed; because how in the world can an effective policy for reducing our ozone pollution be conducted if the real cause of the ozone is not identified?

The Larimer Alliance has been asking the Larimer County Commissioners and the Fort Collins City Council to please consider installing Boulder AIR monitoring stations here; to no avail so far. However, we are the prime target for the pollution from Weld County, where there are 18,000 plus active wells. The state ozone monitors that are here, one on the CSU main campus and one the west campus out LaPorte Street, have registered some of the highest ozone readings in the state, I’ve been told, which I would like to verify someday. This is due to the fact that the prevailing winds push the polluted air from Weld County up against the foothills to our west. It would be extremely helpful if we could get two such stations, one positioned east and west of Fort Collins, to verify the amount of pollution we are experiencing, and where it is coming from. Longmont has installed two monitors in their city; why can’t Fort Collins do the same?

To add insult to injury, the CDPHE has not even acknowledged the data that Boulder AIR has been collecting — ever since the first station went into operation at the Boulder Reservoir in 2015. These data are made available in near-real time on the Boulder AIR website, and is available for the state to use. But what does one find on the CDPHE website? Here’s a screenshot:

Screenshot from https://cdphe.colorado.gov/ozone-and-your-health, taken 1/29/23

Does anything here tell you what is causing the ozone? Barely: the implication from the left panel is that you, the public, is the primary factor identified as the cause. YOU are the guilty party….indeed. This is partly true, since the precursors coming from vehicles are indeed caused by people and commercial vehicles out driving around; but there is no discussion of how the O&G industry is the other significant caues — only a picture of a pumpjack to indicate their contribution.

So this is what needs to change, at a minimum:

  • the CDPHE needs to give equal time to the O&G industry’s role in our ozone pollution problem on their website and in their regulatory announcements
  • the CDPHE & APCD need to acknowledge the data collected by Boulder AIR stations as superior to anything they have, and start to use it to identify the true sources of ozone precursors by direct measurement

If the COGCC, CDPHE & APCD were really to take the bull by the horns, and fully live up to the spirit of SB-181 — to protect the health and well being of people and the environment over fostering the O&G industry — then they would build an entire array of Boulder AIR monitoring stations all along the Front Range, from Weld County in the north to Pueblo in the south, and start to use their data to maximum effectiveness…and cease this petty squabbling with COGA over models and estimates that is simply not helping.

BROOMFIELD STAFF WANTS TO REDUCE MONITORING — WHY?

It has come to my attention that the city staff for Broomfield City and County Council is going to be proposing a dramatic cutback in their real-time air quality monitoring station, the Soaring Eagle station. This would be a big mistake, in my opinion, and deserves more public input. This is going to be discussed at the 6pm meeting on Tuesday, December 13, 2022.

I attended a tour this state-of-the art monitoring station on September 23, 2021, given by Detlev Helmig, and wrote this blog post about it: THE BOULDERAIR TOUR ROCKED! The tour was organized by Broomfield Councilperson Laurie Anderson, and was attended other members of the Larimer Alliance, LOGIC, and other local activists and volunteers. It was an in-depth explanation of the sophisticated technology employed, and how it provides vastly better data than other comparable monitoring stations because 1) it is continuous, real-time data, recorded and published literally within minutes of measurement, and 2) it can simultaneously monitor a panel of targeted chemicals at levels far more sensitive than other comparable monitoring technology.

Other canister-based monitors are not real-time, and rely on periodic manual collection — like your neighborhood garbage trucks — to come by and pick up the canisters…which then get shipped to a lab…which then get sampled and processed…and eventually the results are sent back. This means the measurements can be DAYS OLD before they are analyzed; besides which, a canister grabs one, brief, isolated sniff of air out of the constantly blowing and shifting wind. How reliable is such an approach to air quality monitoring? Answer: Not much!

What the Front Range really needs is to have the state offices of CDPHE and its subdepartment, the AQCD, (see their website here) to create an entire array of such monitoring stations for the Front Range, from Fort Collins down to Pueblo, so that we can really know what is in our air. For without precise measurements, we are just flying blind — and policy makers cannot know what air quality policies should be developed and enforced, and where.

What percentage of our ozone precursors are due to vehicles and what percentage are due to O&G operations? Our current knowledge of this is scant; try and find it on the CDPHE/AQCD website….good luck with that! The closest I think you will find are these “air quality index reports”, which are useless for answering these burning questions needed for an accurate policy response.

I urge you to express your opinions about this to the Broomfield City and County Council prior to their meeting on 12/13/22.

To send your comments to the Council, use this email address: council@broomfieldcitycouncil.org

To watch the Broomfield Council meeting, see here.

I EXPRESS MY COMMENTS/OUTRAGE TO THE AQCC

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

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