Good morning, commissioners, and welcome back to the Winter Wonderland that is Springtime on the Front Range. My name is Ed Behan, with the Larimer Alliance for Health, Safety, and the Environment, and I live in Fort Collins. 

First, I would like to acknowledge a change that has been made in the release dates for the next two segments of draft oil and gas regulations, and the subsequent public meetings for citizen input. The dates for draft release have been pushed back a few days, and more generous study periods before the Planning Department’s Virtual Public Meetings on those drafts have been scheduled. Knowing the complicated nature of establishing these timelines, let me state my own gratitude for expanding that framework to allow sufficient time for study and preparation of discussion points as part of the County’s rules revision process. It does help, and it builds a good deal more confidence in the transparency of the proceedings. 

Secondly, let me address a relevant topic for the upcoming draft regulations dealing with public health, welfare, and environmental standards. Section 17.3/T of the current county regulations touch lightly on the subject of gathering lines. I am aware we helped facilitate a presentation on this matter last Spring by Josh Joswick, a former La Plata County Commissioner. You may recall, John, specifically asking him to speak to the Board of County Commissioners last March. 

Gathering lines are sort of the orphaned children of our oil and gas distribution network. Flowlines take produced oil and gas from a regional storage point, feeding them to Transmission lines that ultimately get the product to refinery and market. Flowlines are regulated by the Colorado Oil and Gas Conservation Commission, and Transmission lines by a Federal agency. But gathering lines are very local, drawing the product from individual well sites to feed it into the production line network. They actually fall between the other two in size and pressure, and at present, there is no state or federal oversight of gathering lines. It behooves the County to look carefully at their location, maintenance, and potential for failure, both during production, and following any intended end of a well’s active operation. As a reminder, the tragedy that took two lives in Firestone just a few short years ago, involved a supposedly capped gathering line on a recently reactivated well. Even the industry would be quick to admit this should never have happened. 

It is critical to establish clear standards in the county for locating, monitoring, and properly shutting down such lines. This would also include protocols for collaboration with the industry to hopefully prevent such an accident in the future, and to have quick and effective responses if, God forbid, something should go wrong. We will be gathering more material on this to share with you and County staff, but I would refer you to the excellent presentation Mr. Joswick made to you last spring. Thank you.

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