Groups send letter in support of proposed oil and gas policies

July 12, 2024

Tom Moore
Planning Director
Regional Air Quality Council
1445 Market Street #260
Denver, CO 80202

Re: Proposed oil & gas control measures

Dear Tom:

On behalf of CoPIRG Foundation (the Colorado Public Interest Research Group Foundation), GreenLatinos Colorado and Womxn from the Mountain, we would like to offer support for the measures you are currently considering to cut emissions from oil and gas operations.

As you know, ozone pollution threatens the health of many Coloradans. Rather than being emitted directly, ground-level ozone is formed when nitrogen oxides (NOx) and volatile organic compounds (VOCs) combine chemically in the presence of sunlight; these reactions occur more quickly at higher temperatures. NOx and VOCs come from a variety of sources in our state such as the oil & gas sector, tailpipe emissions from the cars and trucks we drive, industrial sources and gas-powered lawn and garden equipment.

Breathing high levels of ozone can cause harmful health effects including lung damage, worsening of existing respiratory conditions such as asthma, and cardiovascular disease. A 2016 study even found that long-term exposure to elevated levels of ozone – such as those we experience in our region – is associated with decreased life expectancy.

In recent years, the Denver Metro/North Front Range (DM/NFR) region – roughly from Castle Rock up to Fort Collins and Greeley – has suffered from some of the highest ozone pollution in the country. According to the American Lung Association’s most recent State of the Air report, three counties in the region – Jefferson, Douglas and Arapahoe – rank among the top 20 most polluted counties in the nation for ozone levels.

To protect our health, we need to get ozone concentrations in our air down from unsafe levels as quickly as possible – below the EPA’s latest standard of 70 parts per billion (ppb). Of course our best chance for doing this is to reduce the amount of NOx and VOCs entering our air.

We are grateful for the RAQC’s diligent work toward this end, across many fronts, and are heartened that you are currently considering control measures for oil & gas operations.

Specifically, we support the proposed measures to reduce emissions from pneumatic controllers as well as to address episodic emissions during venting and blowdowns.

We support requiring a retrofit of 100% of existing gas pneumatic controllers statewide by 2028 at the latest, starting with a phase-in in 2025. We also support a new measure to limit VOC emissions during blowdown events at operations in the Ozone Nonattainment Area from May through September, when ozone concentrations frequently rise to unhealthy levels; controlling these VOC emissions and routing them to a primary purpose as opposed to simply releasing them uncontrolled into our air just makes sense.

When we are already in severe violation of the Clean Air Act, we should no longer tolerate intentional, preventable releases of ozone-forming pollution into our air – particularly on days when ozone levels are expected to spike – and these two categories stand out as some of the biggest examples of such releases.

Your analysis of operator-reported Oil and Natural Gas Annual Emission Inventory Reporting (ONGAEIR) data that passing and implementing both of these policies can cut 11 tons per day of VOC emissions is impressive and suggests that these two control measures combined can give our region a shot at reaching compliance with National Ambient Air Quality Standards (NAAQS) for ozone during the critical 2024-26 time frame.

We know it has been a lengthy process of developing these policies after being asked to do so by the Air Quality Control Commission, with the support of the RAQC board. We appreciate how you have engaged a broad variety of stakeholders to weigh in on the development of these policies. After many months of work, we believe the policies you have arrived at are necessary for cutting harmful air pollution and bringing our region back into compliance with the health-based standards in the Clean Air Act.

Sincerely,

Kirsten Schatz
Advocate, CoPIRG Foundation

Ean Thomas Tafoya
State Director, GreenLatinos Colorado

Renée M. Chacon
Co Founder, Womxn from the Mountain