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Important points of emphasis regarding Larimer County’s Oil and Gas regulations:

• Leak detection and repair inspections and reports should be required monthly, to catch and fix problems reasonably quickly. Annual inspections, as required in the draft regulations, are of very limited use.

• Air quality – Larimer County’s air quality is often poor, due in major part to oil and gas industry emissions, and improving air quality is an immediate priority for public health and quality of life:
• • All oil and gas sites should have continuous emissions monitoring and real-time reporting that informs about harmful emissions when they occur, not long after they occurred.
  • On Air Quality Alert days, operators should be required to significantly reduce emissions and dust, and to report on actions taken. This should not be voluntary based on operators’ convenience.
  • All venting and routine flaring should be prohibited. Venting and flaring is damaging to health, environment and climate, wasteful, and enables operators to escape paying taxes and royalties.
  • While our air remains in non-attainment of EPA ozone standards, there should be no net increase in oil and gas emissions; emissions from new oil and gas development need to be offset by reduced emissions at other oil and gas facilities within the non-attainment zone.

• Setbacks and reverse setbacks need to truly protect people’s health and safety. Setbacks of 1,000 feet and less in the draft regulations would not protect public health safety, and against nuisance impacts from oil and gas operations. Reasonably protective setbacks and reverse setbacks include:
  • 2,500 feet from all occupied buildings, recreation areas and conservation areas, with variance allowable to 2,000 feet minimum.
  • 2,500 feet for schools, playgrounds, and facilities for older people, with no exceptions.
  • 1,000 feet from any properly plugged and abandoned oil & gas well.

• To protect our water resources:
  • 1,000 feet buffer from rivers and streams, water facilities, and ditches.
  • 2,500 feet buffer for drinking water sources.
  • No oil & gas facilities within a 100-year floodplain.
  • No more Class II water disposal wells in the County.

• Public Conservation Lands should be for conservation – and fully protected from surface use and inevitable degradation by oil and gas development. The draft regulations would allow surface access and use of County and municipal-owned conserved lands for oil and gas development.

• Prior to initiation of oil and gas facility site development, all top soil will be removed to a safe location to be reapplied to the site during reclamation.

• Financial Assurance is needed to protect governments and taxpayers from costs arising from oil and gas developments such as major accidents, emergency response, operator bankruptcy, and failure to clean up from oil and gas operations and properly plug old wells. Uncovered costs and liabilities will financially impact all County residents/taxpayers and local governments.
  • Operators must carry adequate insurance to cover all costs arising from their activities, operations, and facilities
  • Full cost bonding for all wells.
  • All conditions of approval survive a change of ownership.

A comprehensive detailing of our critiques and suggested changes to the draft regulations can be found in this letter to the County Commissioners and Planning Department staff: Larimer Alliance comments on public hearing draft Oil and Gas Regulations Revised