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.

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