By: Laurie Anderson, Colorado Field Organizer, Moms Clean Air Force
Date: November 27, 2023
About: US Pipeline and Hazardous Materials Safety Administration’s Advanced Leak Detection Standards for Gas Pipelines
To: Gas Pipeline Advisory Committee
My name is Laurie Anderson, and I live in Broomfield, Colorado. I am a councilmember for the City and County of Broomfield representing constituents who are impacted by large-scale oil and gas development in our communities. I am also a Colorado field organizer for Moms Clean Air Force—a community of 1.5 million moms and dads united against air pollution—including the urgent crisis of our changing climate—to protect our children’s health.
I am here to share our broad support for policies that protect safety and the environment, and I call on the Gas Pipeline Advisory Committee to support rapid action by PHMSA to finalize strong Advanced Leak Detection Standards, including expanding the mileage of gas-gathering lines that must be leak surveyed, making more frequent inspections using the best available technology, and ensuring quick repair of identified leaks.
The oil and gas industry is very present in northern Broomfield. In 2017, several of our well-established communities—including a retirement community—were faced with unprecedented residential fracking operations and the supporting gathering and distribution lines. These lines run right past schools and homes in my community. This development rightfully caused much angst and protecting health and safety was clearly the top concern. Strong federal oversight of this infrastructure will ensure the air we breathe is clean, people who live here are safe, and the climate is protected.
Broomfield currently funds and operates an enhanced air quality monitoring program to capture pollution spikes from the large-scale well pads in close proximity to our communities, but these monitors have inadvertently discovered multiple midstream pipeline leaks, which were subsequently repaired once ownership was determined. There are certainly more leaks like these that are just waiting to be discovered. However, time is of the essence, since undetected defects and corrosion pose the potential for catastrophic impacts, such as pipeline explosions, which although rare, are an inherent danger for communities like mine. By expanding reporting requirements to ensure that all gathering pipeline mileage is reported to the National Pipeline Mapping System, decision makers and communities can better understand the physical properties and environments of this infrastructure and assess whether additional oversight is needed.
The Colorado Public Utilities Commission (PUC) is currently considering new rules as we work diligently to meet our statutorily required GHG reductions, including 26% by 2025 and 90% by 2045, below 2005 levels. States like Colorado are following the leadership of PHMSA. For example, in the recent decision by the Colorado PUC, they deferred enacting regulations on the Advance Leak Detection Technology Program until PHMSA finalizes its rules. Regardless of which jurisdiction a pipeline falls under, the concerns remain the same. A strong federal rule that states like Colorado can follow will provide consistency between jurisdictions.
Although there are many examples of the devastation undetected leaks can cause, I want to highlight the story of Mark and Julie Nygren of Weld County, Colorado, who lost their home and livelihood due to contamination from a midstream pipeline leak and—four years later—have not been able to return to their farm. The remediation so far has created a pit 20 feet deep and 3 acres wide to remove the contamination on their property. Rural residents, like the Nygrens, should be afforded the same protections from pipeline leaks as those that live in more urban locations.
Finally, beyond the climate and safety aspects of reduced leaks is another critical matter. The entire Denver Metro and North Front Range area—including my city—remains in severe ozone nonattainment due to our unique topography with mountains that trap the pollution, heavy oil and gas development in this area, and background pollution from out of state sources. We are now facing federal interventions if Colorado does not put forward an approvable State Implementation Plan (SIP) including significant reductions in ozone-forming pollutants. Since these pollutants coexist with methane, the good news is that finding and fixing pipeline leaks will help reduce ozone pollution to safer levels. In fact, a 2022 Carbon Mapper study found that gathering pipelines made up 23% of point source emissions and were the second largest source of emissions, so strong regulations will also help us tackle ozone.
These are just some of the examples of what we are facing, so I thank you for your time and your diligence on developing rules that are effective in protecting health, safety, and the environment.