By: Laurie Anderson, Colorado state coordinator, Moms Clean Air Force
Date: January 11, 2023
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 state coordinator with 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. We live about a half mile from a large-scale oil and gas development site and in an area with many old low-producing and shut-in wells—including orphaned wells.
I support EPA’s updated rule to cut methane and other harmful pollutants from oil and gas operations across the country. This is an important step toward addressing the climate crisis and protecting the health and safety of children and families across the country.
Climate change is already impacting our families and communities in Colorado through extreme weather events, hotter summers, aridification, and decreased snowpack. It was just over one year ago that the Marshall fire ripped through neighboring communities, burning over 1,000 homes in the dead of winter. With each new “Red Flag” day, where high winds and fire danger coincide, our communities relive the very real danger of another destructive scenario.
Broomfield is in the ozone nonattainment area that spans from Denver along the northern Front Range, which was recently downgraded to “severe.” Colorado just approved a state implementation plan that admittedly will not bring us into attainment for the 2015 8-hour standard. Plus, the plan acknowledges that contributions from the oil and gas sector were substantially underestimated requiring even further action. Ongoing heat waves only exacerbates the ground-level ozone pollution problem. These ozone action days and climate impacts will likely intensify if reducing climate changing pollution is not rapidly and effectively addressed.
Most devastating to me is the realization that my oldest daughter who is now in college is facing ongoing respiratory issues. As she undergoes further analysis, the reality is settling in that running cross country in high school was harmful to her lungs. Yet, with 68 days last summer in Broomfield where the ozone was above the level of 60 ppb, where public health experts state impacts can occur, and 15 of those days were above the 70 ppb 8-hour standard, keeping our children indoors is not the answer. Moms like myself envision a healthier Colorado, where our kids are safe to run and play outdoors like we did as children.
Both Colorado and New Mexico have recently adopted rules that eliminate routine venting and flaring—which is a wasteful practice that releases methane and carbon dioxide into the environment—both of which contribute to climate change. Under the new state rules, this excess methane must be put to a beneficial use, which includes routing it to a pipeline. Both states have adopted standards to retrofit old polluting equipment known as pneumatics with zero-emission devices. And both states have adopted comprehensive Leak Detection and Repair standards that include inspections at all well sites—including small well sites. Although these small, low-producing wells produce just 6% of US oil and gas, they are responsible for about half of the methane emissions from all US well sites. Additionally, more frequent inspections are required at well sites in proximity to where people live, work, and play.
While this is just a high-level overview of the benefit of methane regulations, the simple truth is that Colorado and New Mexico cannot go it alone, if we are to address air quality and climate change. Air—and the pollution it carries—knows no boundaries, which results in background ozone and other pollution crossing state boundaries. These same enhanced regulations to reduce methane pollution can be effectively implemented across the country, just as they have been here in Colorado and New Mexico.
Although there is still more work to be done to bring our area into ozone attainment and reduce the impacts of climate change, my family is fortunate to live in Colorado where we are finally taking steps to reduce methane emissions from oil and gas operations. These federal methane rules will help ensure all children across the nation receive these same protections since not all states are proactively implementing much needed changes.
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. Thank you for your time.