Letter to the Colorado Air Quality Control Commission, Colorado Department of Public Health and Environment - Draft Oil and Gas Rules

Letter

Colorado Air Quality Control Commission
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, EDO-AQCC-A5
Denver, CO 80246

Dear Commissioners:

Thank you for the opportunity to comment on the proposed Air Quality Control Commission Oil and Gas Rulemaking (draft rules). I support the proposed revisions to Regulation Numbers 3, 6, and 7 and I urge you to maintain strong regulations throughout the rulemaking process.

Colorado's oil and gas resources are important to our state's economic future, and developing these resources can and must be done in a way that minimizes health and environmental impacts. I am encouraged that the draft rules will: (1) address methane emissions from oil and gas production activities; (2) require Leak Detection and Repair (LDAR) to control emissions of both methane and volatile organic compounds (VOCs) all wells statewide; (3) adopt a "no venting" standard for storage tanks; and (4) limit venting during well maintenance activities. Importantly, the final rule should not be limited to Front Range nonattainment areas because all of the Colorado's oil and gas wells are contributing to the state's declining air quality and unlike surface disruption, air travels throughout the state.

If the Commission retains these key provisions, Colorado's oil and gas air quality rules will be the strongest in the nation and will serve as a model for other states searching for cleaner oil and gas development methods. After adopting these rules, I urge the Commission to go one step further and promptly determine whether any additional controls will be necessary to attain and maintain compliance with existing federal air quality standards for ozone, and implement those controls as soon as practicable.

I am pleased that the Commission has exercised its broad authority to propose rules that will reduce emissions while benefitting the health of our communities. The methane commonly leaked from natural gas operations is a greenhouse gas thirty times as potent as carbon dioxide. Moreover, the VOCs emitted from oil and gas facilities interact with sunlight to produce ozone or "smog," which has been shown to threaten trigger asthma attacks and aggravate conditions of people with bronchitis and emphysema. These rules will help Colorado ensure cleaner air for Colorado citizens.

These rules are timely because methane emissions in energy producing states like Colorado, Wyoming, and Utah have risen with the increased development of oil and gas. Unchecked methane emissions from oil and gas wells in rural areas in the Upper Green River Basin, Wyoming have caused dangerously high levels of ozone that rival the worst pollution days in Los Angeles, California. Colorado has also seen the effects- nearly 50,000 wells contribute to the state's current non-attainment status for the EPA's 2008 national ambient air quality standard for ozone. The Commission must ensure that the rules are swiftly enacted because we cannot continue to subject our communities to the public health risks associated with high levels of ozone resulting from oil and gas development.

Fortunately, the technology necessary for energy companies to implement these rules is already readily available. Oil and gas developers can easily and cheaply curb emissions by fixing equipment leaks, and installing inexpensive control technology. Capturing methane will also benefit the industry because it is a marketable product that can be sold for a profit rather than being leaked into the air. Reducing leaks creates the incentive for new technology to turn pollution into profits.

In conclusion, the Commission should retain the strong standards set by the proposed rule, and take additional steps to ensure compliance with federal air quality standards. Taken together, these measures will help Colorado successfully and responsibly curb harmful emissions from oil and gas facilities to protect the public good long into the future.

Once again, thank you for the opportunity to comment on the proposed rule.

Sincerely,

Jared Polis
Member of Congress

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