Versions of these comments were delivered to the Board of County Commissioners and the Planning Department’s Virtual Open House on the Consolidated Draft Regulations for oil and gas development.

I am repeating information I have previously shared with you all by email, but I want these remarks to be part of the public record. I know as one of the spokespeople for the Larimer Alliance I have repeatedly raised concerns about air quality in the context of the pending revision of the County’s oil and gas regulations. I know that regional monitoring technology is not necessarily something that would be established by regulation in the land use code, although that remains a critical issue to be addressed if for no other reason than we are downwind from Weld County.

But the issue of monitoring on the individual well pads and other facilities is something that is being dealt with in the draft regulations. I know that canister monitoring systems have been designated as required in the revised air quality segment of the rules. One concern is those canister systems may monitor continually, but their intake is only checked periodically. . . a period of a week or once a month. The problem with that sort of system is that something that needs to be dealt with may be happening, but unless crew happens to be onsite, it may not be caught. This could include leaks that affect air quality or something possibly indicative of a potential catastrophic failure.

I was recently made aware of a Colorado based company named Project Canary. They provide technology and systems for continuous air quality monitoring with fenceline sensors that are connected to a network so alarms might be received and responded to 24/7. One would think this would be in the interest of the operator as well as the first responders who may have to come online in the event of any serious failure. This company apparently works with a range of energy developers, utilities, and regulatory entities.

I will place a link in the question section of tonight’s Zoom to the YouTube video of a presentation at an air quality symposium at the University of California Davis by a co-founder of Project Canary. If I am understanding her discussion correctly, the company has also worked in conjunction with CSU and the CDPHE. I will include a link to the company’s website as well.

I am not suggesting this is the only technology of this type available, but it is the first serious leap I have seen for site specific monitors beyond the periodically checked canister systems. I hope you all will make appropriate inquiries and consider this as a standard for required monitoring by oil and gas developers operating in Larimer County. Thank you for your continued dedicated work on the County’s oil and gas regulations, and for your attention in this matter.

Ed Behan

https://www.youtube.com/watch?v=5ObwlzJPpks&ab_channel=UCDavisAirQualityResearchCenter

https://www.projectcanary.com/