February 11, Regulation 7 Revision

MEMORANDUM

February 10, 2017

TO:      Leah Martland
Regulatory Development
Planning & Policy Program
Colorado Department of Public Health and Environment
4300 Cherry Creek South Drive
Denver, Colorado 80246-1530
www.colorado.gov/cdphe/apcd

FROM: Larimer County League of Women Voters

Re: Regulation 7 Revision

On January 30, 2017, members of our Larimer County League of Women Voters participated in the Webinar sponsored by the Colorado Department of Public Health and Environment regarding revision of Regulation 7. A participant from the oil and gas industry commented, “Colorado was one of the first states to have regulations on oil and gas drilling and is ahead of the country in this respect. Therefore we are in good shape and don’t need to worry about changing what we have.”

We respectfully disagree.  We believe that the need for updating Regulation 7 is evidenced by the fact that Colorado continues to be out of compliance with the previous Federal Ozone Standard of 75 ppb, and is not expected to achieve the current Federal Ozone Standard of 70 ppb in the near future. Along the Front Range we have ozone readings that exceed 80 ppb at times.

The Colorado Department of Public Health and Environment must take corrective action now to protect the health of our state and its people, as well as our region and country. To achieve the Federal ozone standard of 70 ppb, we urge the Department to take the following actions:

  1. Hire more inspectors so that all wells are checked not less than once a year. Data show that to accomplish this goal, the Department needs at least one inspector for every 900 to 1,000 wells. This means you need to double the number of inspectors we presently have.
  2. When water is used in the process of hydraulic fracturing, require on-site treatment of water for reuse. This would reduce significantly the need for new water and would greatly reduce air emissions from numerous trips to take out used/ bring in new water.
  3. Create incentives for using sources other than water in the process of hydraulic fracturing, such as liquid nitrogen, propane gel, and carbon dioxide foam.
  4. Do not allow flaring of methane gas at the site. Rather, require companies to collect all gas for future use during the process of drilling and collecting of natural gas.
  5. Require closed storage of all used process water. Do not permit storage of this water in open “ponds;” evaporation of process water releases volatile organic chemicals (VOCs) and produces air pollution.

The League of Women Voters of Larimer County supports the State’s current effort to revise Regulation 7 and appreciates the opportunity to participate as a stakeholder in the revision process as it goes forward.

We thank the Colorado Department of Public Health and Environment for its efforts to protect Coloradans and Colorado’s environment from pollution, and we appreciate your consideration of our comments regarding Regulation 7.

League of Women Voters of Larimer County
By: Georgia Locker and Patricia Miller
Chairs of the Environmental Action Team on Fracking