By: Laurie Anderson, Colorado field organizer, Moms Clean Air Force
Date: November 30, 2021
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2021-0317
To: Environmental Protection Agency
Hi! My name is Laurie Anderson, and I am a field organizer for Moms Clean Air Force. I live in Broomfield, Colorado. Thank you for this opportunity to share with you today. I am a mom of five kids living a half mile from a recently fracked 18-well large-scale oil and gas development site. I also serve as a councilmember for the City and County of Broomfield, but am speaking on my own behalf.
Moms support the proposed EPA methane rules and urge the EPA to finalize the strongest and most comprehensive rules to protect children’s health from all sources of oil and gas methane pollution, including small wells and routine flaring.
Air pollution can travel long distances and harm people's health, but the communities, like mine, that live near oil and gas operations are exposed to higher levels of harmful air pollution that put our health at risk—especially our children, pregnant women, older adults, and those with underlying conditions, as well as disproportionately impacted communities, which most often include people of color and low-income communities.
I live in the Denver Metro North Front Range nonattainment zone, which is currently listed in “serious” nonattainment for ground-level ozone and is slated to soon be downgraded to “severe” nonattainment as we contend with ozone originating from oil and gas sector pollution in the DJ basin combined with elevated background ozone originating outside Colorado’s borders. This past summer in Colorado, we had a record-breaking 67 high ozone days with the maximum eight-hour ozone detected at 101 ppb—dangerously above the 70 ppb standard.
As Colorado has experienced the detrimental effects of air pollution and climate change, we have been forced to contend with the negative impacts of oil and gas extraction. As such, Colorado has continued to lead the nation on strict methane regulations, and even with these enhanced regulations, oil and gas production is still viable in our state. We have already increased wellbore integrity, enhanced programs for leak detection and repair, prohibited the practice of routine venting and flaring, begun the process of replacing pneumatic controllers with non-methane emitting alternatives for both new and existing sources, and more. These same enhanced regulations to reduce methane emissions can be effectively implemented across the country, just as they have been here in Colorado.
In response to the EPA’s overview of the proposal to reduce pollution from the oil and gas industry, I offer the following input:
Finding and repairing leaks is essential, and quarterly inspections are a good start. Lower producing and shut-in wells must NOT be exempt since, although they may be less economical, the reality is that this equipment is often older and leaks still occur, which impacts the health of nearby communities and contributes to climate change. If a well is no longer used or useful, it must be properly plugged and abandoned in a timely manner. When wells are finally plugged and abandoned in my area, we repeatedly see reports that a “historic leak” was discovered, which is all the more reason to require routine, quarterly inspections of all well sites.
With new technology rapidly emerging for methane detection, it is beneficial to allow flexibility on the techniques to be utilized for LDAR. However, it is critical that the EPA is prepared to verify and enforce the varied techniques that operators may choose to utilize.
Colorado regulations now require the use of non-emitting pneumatic controllers at new well sites, as well as retrofitting existing well sites. It is imperative that this change happen swiftly at all well sites in the nation since these intentional emissions remain ongoing.
We must not allow operators to justify flaring solely based on economic reasons. It may be most economical to the operator to flare the gas, but it comes at a price to the climate and our air quality.
We must not forget about the significant emissions from the pre-production phase, including emissions from drilling and fracking operations.
In response to public health concerns, Colorado’s Front Range communities have implemented sophisticated air quality monitoring programs that continue to enhance the available technology, including reference grade monitors with a network of TVOC sensors with triggered summa canisters near well sites. The EPA should look to entities like Boulder AIR, Colorado State University, and Ajax Analytics to build upon the work underway.
Even as the EPA enacts and implements these new regulations, communities like mine will still rely on third-party inspectors to help identify leaks. Earthworks spends much time in communities impacted by oil and gas operations—and they seek community input as to sites of concern. Oftentimes, these inspections do uncover leaks. It is imperative that when entities like Earthworks or municipal inspectors find and report leaks that the EPA rules require these leaks to be swiftly repaired. The best thing the EPA can do to empower communities to assist in identifying and stopping emissions is to accept third-party evidence, like VOC spikes from a community monitor or Earthwork’s OGI, as evidence of violation, investigate the findings, and result in substantive action.
And finally, enforcement is critical to ensure that all of these changes that will positively benefit our air quality and help protect our climate are fully implemented so that the full extent of the benefits are realized.
Once again, I support the proposed EPA methane rules and urge you to finalize the strongest and most comprehensive methane rules to protect children’s health from all sources of oil and gas methane pollution, including routine flaring and small wells. Thank you for your time.