Added good info. from the Air Quality mtg. from Lauren Swain - Sierra Club. I am particularly happy that she brought up the issue of regulation enforcement. We can have regulation, but without enforcement, well, people die. I know this from personal experience. Thanks Lauren. AQCC Hearing Comments November 21, 2013 Lauren Swain Communications Coordinator Beyond Oil & Gas Team Sierra Club Rocky Mountain Chapter Thank you, Commissioners, for the opportunity to speak here today. I am speaking on behalf of the Sierra Club Rocky Mountain Chapter, which has over 40,000 members and supporters across Colorado. We have grave concerns about the impact that oil and gas production is having on human health and air quality here in our beautiful state, especially given the additional harm caused by the expanding use of new slickwater high-volume hydraulic fracturing techniques, which were first developed in 1997. We appreciate that Governor Hickenlooper’s administration has vastly improved the draft regulations being submitted to the Colorado Air Quality Control Commission, compared to previous versions they had considered. We share their apparent recognition that it is time for our state government to fulfill its obligation to stop the damage that oil and gas production is causing to human respiratory systems and overall health, through releases of toxic and ozone-inducing agents. And it is heartening to know that our state’s rules may begin to prevent methane emissions from further damaging our climate. With over 3000 new air pollution permits being submitted to the Colorado Department of Public Health and the Environment by the industry each year, this effort could not be more timely. As we recognize the need for better rules, we grimly acknowledge that the current rules are inadequate, and that our government has allowed over 50,000 wells to be drilled in Colorado without applying the standards necessary to protect human health or the health of our climate. Clearly, not one more well should be drilled until the most rigorous standards and enforcement practices are in place to protect citizens from the harm that toxic and ozone-inducing emissions cause. Colorado communities like Longmont, Boulder, Lafayette, Fort Collins and Broomfield are not only within their rights to protect themselves by suspending drilling or fracking under these conditions, they are, in fact, obligated to do so to protect their children from harm. Should our government fail to enact effective rules, or to enforce them in a meaningful way, more communities will, and should, follow suit. Mineral rights are not absolute. The law cannot defend the right to harm others or pollute their air and water to access mineral holdings. Currently, even our inadequate state rules are not effectively enforced. Companies with scores of violations are allowed to drill more and more wells, too often in proximity to residences and schools. One company volunteered to pay almost four times the required fine for a major spill near Windsor, because our state’s fine for spilling 84,000 gallons of toxic fracking flowback water, uncontrolled for a period of over 30 hours, 1500 feet away from homes, was only $9000. Operators will not be comply with the law without a rigorous enforcement program in place. The United States has already established strong air quality standards through the Clean Air Act. The primary reason we must take our time to now to protect Coloradans from damaging oil and gas emissions is because the oil and gas industry is exempt from major provisions of the Clean Air Act, as well as the Resource Conservation and Recovery Act—which governs the management of hazardous waste, and the toxic chemical disclosure requirements of the Community Right to Know Act. The oil and gas industry is also exempt from key provisions of four other major federal laws that we rely on to protect human health and the environment. We should not be reinventing air quality rules on the state level. Our state leaders should urge Congress to pass the BREATHE act and other measures that require the industry to comply with federal law. An industry that is not subject to the federal environmental laws we depend on for our health and safety should not be allowed to operate in proximity to residences and schools. Anything short of full compliance with the Clean Air Act and other federal laws is window dressing for the harm being caused by these exemptions. Nine Front Range counties are failing to meet federal standards for ozone pollution. Studies have proven that oil and gas production is the largest source of the ozone precursors responsible for the problem. However, because this industry is exempt from major provisions of the Clean Air Act itself, it is small wonder that we find ourselves in this predicament. Today, the Sierra Club is asking the State to set forth a clear, deliberate path to full compliance with federal ozone standards. Again, we are encouraged that some of the provisions in the new draft regulations may offer hope for improvement of air quality in Colorado. Despite claims that the administration worked collaboratively with environmental groups to develop these rules, most environmental groups have not been consulted in the process thus far, nor were the community groups that found it necessary to put the brakes on hazardous drilling operations near their homes and schools. Nonetheless, we look forward to working with the Air Quality Control Commission to retain what is valuable in these new proposed rules, to address loopholes and omissions, and to develop a new framework that will better defend Colorado’s air quality, public health, and environmental well-being in the future. Thank you.
Posted on: Sat, 23 Nov 2013 20:44:28 +0000
Trending Topics
Recently Viewed Topics
© 2015