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 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
webmaster: larimeralliance.org, larimerallianceblog.org, focosustainability.org, colivableclimate.org, ncalf.org