Public Testimonies

May 20, 2020: Testimony by an Alliance volunteer at the Air Quality Control Commission virtual meeting about Regulation 22, an important propose rule that would require tracking of GHG by the oil and gas industry:

The Larimer Alliance for Health Safety and Environment wishes to comment in the rule making for Regulation 22. The Larimer Alliance is a coalition of residents and organizations representing thousands of people in Larimer County.

We ask AQCC to develop regulations that will really meet the reduction goals for greenhouse gases (GHGs) established by SB19-096.

We ask AQCC to proceed without delay because achieving rapid significant reductions in GHGs – sooner rather than later – will have maximum beneficial impact on limiting climate change and protecting life on Earth.

To protect Colorado, AQCC needs to move quickly to reduce all significant GHGs – not only hydrofluorocarbons, also carbon dioxide and methane emissions, which together comprise the vast majority ofColorado’s GHG emissions.

Methane is a major greenhouse gas that must be addressed immediately.Methane also contributes to ozone, which is a serious problem in theFront Range including Larimer County. Methane emissions from oil & gas operations are an especially serious problem for Colorado, including large volumes of emissions from legal and illegal venting, flaring, andleaks. These emissions cause climate damage and contribute significantly to degradation of regional air quality affecting millions of Coloradans and to Colorado’s ongoing failure to meet federal air quality standards.

We urge AQCC to require and to use relevant and current science and best available technologies in all aspects of rulemaking, establishing standards, and procedures for GHG inventory, measurement, and enforcement by state and local agencies.

Reduction targets for GHGs need to be determined in relation to near and intermediate time horizons, especially for GHGs such as methane with significant near-term impacts.

Best technologies include top down atmospheric measurements using aircraft mounted monitoring of GHG emissions from oil and gas sites and other sources, as well as continuous on-site emissions monitoring, real-time reporting, and rapid response requirements for addressing emissions violations. Monitoring and real-time reporting need to be done in a way that is credible and not vulnerable to manipulation or falsification by source emitters.

We believe that producers of GHG emissions – not taxpayers – should bear the full cost of monitoring and enforcement as part of the cost of their operations and business. Major soure emitters should pay for emissions monitoring, real-time reporting, and all costs for addressing violations. These costs should not be externalized onto the public, orto governments, or to taxpayers.

Passage of SB 96, HB 1261, and other laws (such as SB181) marked a major change in Colorado's laws and policies.

We urge AQCC to establish rules that will achieve rapid reduction in all GHGs in Colorado, so as to fulfill the intent and fully comply with Colorado's laws and policies for protecting our climate.