By: Laurie Anderson, Colorado Field Organizer, Moms Clean Air Force
Date: January 10, 2024
About: Greenhouse Gas Intensity Verification Protocol
To: Colorado Air Pollution Control Division (APCD)
Thank you for this opportunity to provide comments. My name is Laurie Anderson and I have been engaging in this rulemaking as an impacted resident, a Broomfield City Councilmember, and also as a field organizer with Moms Clean Air Force, as we strive to protect the air our children breathe and the climate they will inherit.
First and foremost, I appreciate the technical expertise of the division as the Protocol progresses. Most essential, is that the final Protocol ensures that the principles and parameters outlined in the newly adopted GHG Intensity Verification Rule are achievable and result in real, verifiable emissions reductions.
Of critical importance is going beyond simply monitoring the air we breathe.
Early on, Broomfield recognized the importance of deploying a robust air quality monitoring program, even though some technology was still, in a sense, in the research and development phase at the time. This program, as well as similar programs in other municipalities, have been funded by our local governments - so by the people - as they strive to protect the health of our communities.
It was, and still is, important to us to have reference grade measurements that were scientifically robust and reliable. There are many monitoring options available, but many do not meet this requirement. Just as it was for our local municipalities, of which there are now several, this same rigor and requirement of accurate measurement in the Protocol will ensure we have the reliable data we need to know whether or not we are on track to meet Colorado’s statutorily mandated GHG targets for both the oil and gas sector and overall statewide goals, and better understand the progress we are making.
There is now advanced technology that can do even more. The industry must move forward with this same diligence to ensure the air our children breathe is protected with innovative technologies that will go further to directly measure the amount of air pollution they are creating and improve air quality for years to come. It is essential that operators do not simply use any technology they want, but make use of those proven to be most effective and appropriate at measuring emissions for their specific types of facilities.
We have learned so much over the years regarding the impacts of oil and gas development, and so many lives have been impacted because we lacked accurate emissions data. The Protocol finally gives APCD the opportunity to change this trajectory through a scientifically robust Protocol - one that the public can place their trust in.
Thank you for your continued diligence.