By: Laurie Anderson, Colorado Field Organizer, Moms Clean Air Force
Date: September 4, 2024
About: Cumulative Impacts Rulemaking
To: Colorado Energy and Carbon Management Commission
Good evening, Commissioners! My name is Laurie Anderson, and I am a Colorado Field Organizer with Moms Clean Air Force—a community of over 1.5 million moms and dads united against air pollution—including the urgent crisis of our changing climate—to protect our children’s health.
For years, residents - like myself - who have been adversely impacted by oil and gas operations have been advocating for the prioritization of public health, safety, and the environment above oil and gas operations. In 2019, the Colorado legislature delivered on these protections - including the requirement to develop rules that evaluate and address the cumulative impacts of oil and gas development, and subsequently followed up with additional legislative requirements. I appreciate the remarks from multiple state legislators indicating that the legislative intent was clear with requirements to protect DI communities, address adverse cumulative impacts, and promulgate rules to advance the state’s pollution reduction goals.
I live about a half mile from the 18-well Livingston Site and speak from lived experience. Several years ago, as oil and gas operations collided with well established communities in Broomfield and neighboring unincorporated Adams County, we felt like guinea pigs. Based on the available health and scientific studies, we raised concerns about the health, safety, and environmental harms that we anticipated as technological advances made large-scale drilling and fracking next to and under our communities a reality. Despite our protests, 84 wells were approved in Broomfield and “residential fracking” began.
Over the years of pre-production and production activities, my community was the subject of health studies while advanced air quality monitoring data was collected and noise studies were undertaken.
A recent cumulative human health risk assessment led by the Environmental Defense Fund confirmed what residents like myself already suspected - that even with the best-in-class BMPs implemented in Broomfield, acute health risks within the community remain above EPA thresholds. The findings from this risk assessment also mirror the results from a 2023 epidemiological study conducted by Weisner et al. in my community. These risks are likely even higher for residents living near multiple oil & gas sites when the risks are aggregated.
Before any enhanced systems & practices (ESPs) are purported to reduce impacts to communities, and before operator’s are allowed to include blanket statements such as “with these BMPs the risks are expected to be near negligible”, the cumulative impacts must first be quantitatively analyzed by an independent third party to ensure they are actually effective. For example, a recent study by Ku et al (2024) found that the use of synthetic-based drilling fluid released more heavy alkanes than petroleum-based fluid, which can contribute to greater ozone formation, which in itself will cause greater respiratory health impacts. However, synthetic drilling fluid is widely accepted as a BMP, but this may not be protective of human health, especially during summer ozone season. More research is needed to understand emissions reductions of BMPs before such practices are widely accepted as solutions.
We cannot undo the impacts to my community which included neurological impacts, eye irritation, nose bleeds, increased asthma, and the yet to be seen long-term impacts, but we can prevent these adverse outcomes going forward.
In closing, I strongly urge the ECMC to enact strong regulations that address the adverse cumulative impacts with the highest priority on avoidance including through increased setbacks and seasonal restrictions on pre-production activities. If, through analysis, an operator’s desired location is determined to not be protective of public health, safety, and the environment through avoiding, minimizing, and mitigating the impacts, the Commission must ensure the rules allow the site to ultimately be denied. The health and safety of families must be prioritized above the bottom line of operators proposing to drill in our communities.
Thank you for this opportunity to provide public comments on the cumulative impacts of oil and gas development.