June 6, 2024
Colorado regulators will not back off! Every few months they propose more regulations on the oil and gas industry. This time we were commenting on the midstream emissions reduction report (https://cdphe.colorado.gov/midstreamGHGplanning). What is the “midstream” you ask? It’s all the equipment between drilling the well and refining the product. About the only things that use much energy are the heater treaters and the pumping stations. Since both are typically fueled by the product they’re handling, you simply can’t get any more efficient. Not to worry though the “Experts” at Colorado Department of Public Health & Environment know better!
Yes, they really are that arrogant. They call one of their divisions the “Air Quality Control Division”, as if anyone could actually control the smoke from wildfires and the ozone that naturally happens when you’re over a mile above sea level and the UV is always fierce enough to make lots and lots of ozone.
This chart is from folder 081822 in https://drive.google.com/drive/u/0/folders/17vtvBLIVbQpnpAY2UQoQWfyLnnurAT1L and it shows why it is completely ridiculous to regulate the Oil & Gas Industry - the natural ozone contribution is about 5.5 times that of the industry. If there was no oil and gas industry the EPAs rules would say that the front range was a non attainment area!
Here’s our testimony, its rough, since we improv quite a bit:
Martin:
I’m Martin Sandberg, I’m a retired MSEE. I’d like to take you on a bit of a journey today. Many years ago, I purchased the URL theviews.org and started looking for a place to build a house that needed that name! The search started down south in New Mexico and then up here in Colorado, where we found it. You can see Long’s Peak and Mt Meeker to the west, Boulder and Lodo to the south, almost all the way to Kansas to the east and north to Ft. Collins.
This gives you an idea of just how important Colorado’s air quality is to us. But, we also have to live in the real world and these constant attacks on the oil and gas industry are very disturbing. We’ve been recently encouraged by seeing the rest of the world acknowledging reality and backing away from Net Zero. We would like to see Colorado not crash into the Green wall either.
This report, unfortunately, is not encouraging. If anything, it seems to recommend putting a vast number of new regulations onto Colorado’s oil and gas industry, when a large number have just recently been added. I said “seems to” because the report is almost unreadable. I would say that it is a perfect example of bureaucratese and I’m afraid I haven’t found a bureaucratese to English dictionary.
Colorado has seen so many regulatory proposals popping up so constantly that there is no way for these agencies to actually have adequate time to review and analyze the efficacy of the regulations and find if they actually are effective.
(On the fly addition since I had some time left:
For example last summer’s smoke that came from Canada and Alaska was a once in ten year even. We can’t use that year to study these regulations because their effects would have been totally overwhelmed by the smoke from the wild fires. )
I would ask that this report’s recommendations be put on hold until we can remove some of the unneeded regulations that are increasing our energy costs.
Bill:
My name is William Hembree. I’m a retired software engineer who has lived in Colorado for over 2 decades. I’m also an Air Force veteran and now live north of Lyons. I love the natural beauty of Colorado and am privileged to see eagles soaring past my home almost daily.
I am, however, also concerned about Colorado’s economic future and this report does little to allay my concerns. My time is short so I’ll just raise a couple of these concerns.
The disparate impact areas contain only one-third of one percent of Colorado’s 2020 population and there is no quantification of the disparate impact. I can’t evaluate whether the costs of the proposed mitigations will have a reasonable effect on health in the disparate impact areas
I noticed an omission in Section 7.D.5.f, which does not appear to address credit for decommissioning MCFE although a transferable credit would seem appropriate in that circumstance.
The “growth scenario” will cost the estimated 6.5 million 2030 Coloradans an additional $50 for every man, woman and child in the state. This will be in addition to the inevitable upstream and downstream additional costs.
Side note: The OnBase system which contains the report is difficult to use and not easily accessible by the general public. Please make an on-line PDF version available via Google drive so we “commoners” can have reasonable access to the report.