Colorado needs your help. So does the planet.
Right now, the Colorado Oil & Gas Conservation Commission (COGCC) is revising its operating rules to reflect a major change in its mission mandated by law: from ‘fostering’ O&G development to ‘regulating’ O&G in a manner that prioritizes the protection of public health, safety, welfare, the environment and wildlife, and minimizing adverse impacts on air, water, soil, and biological resources from O&G development.
This COGCC Mission Change rulemaking will have major consequences for future impacts from O&G development, including climate impacts. The rulemaking offers an important avenue for reducing climate damage by O&G development. Your voice is needed to make it happen.
COGCC has drafted proposed rules and is now receiving comments on the draft rules. COGCC will hold a hearing on August 24.
The draft rules will not adequately reduce climate impact and damage by O&G development. Shortcomings in the draft rules include:
While the new rules require estimation of GHG emissions for new O&G developments, there are no standards, limits, mandated reductions, or consequences for GHG emissions. There are no consequences for getting the estimated emissions wrong—intentionally or not. There is nothing in the draft rules that say if you emit 2 tons per year or 500 tons per year of GHGs, then the permit should be denied.
There are no consequences for cumulative climate impacts from new O&G developments, or cumulative negative impacts to air quality and to public health, and no recognition of the severity of these issues in the Front Range and over the Four Corners. The draft rules do not recognize that cumulative effects of O&G development in or near populated areas is correlated to negative health impacts (nosebleeds, asthma attacks, headaches, sore throats, or other health impacts) and to ozone alert days. The draft rules do not provide that such cumulative impacts should trigger limits or stop new permits for O&G development.
The draft rules ignore that methane traps 86x more heat than CO2, with significant near-term climate impact, and that methane lingers in the atmosphere for about 20 years. The draft rules ignore that methane emissions continue to significantly accelerate climate change, pushing the climate crisis toward a tipping point, after which it becomes nearly impossible to stop the runaway warming.
The draft rules are negligent in failing to protect our climate, public health and air quality, and in failing to uphold the climate goals established by legislation and by the Polis administration.
The draft rules need to be revised to provide much more protection for climate, public health and air quality.
Your voices are needed to persuade COGCC to adopt rules that provide far more climate protection than the current draft rules.
There are two ways for for submitting comments in the rulemaking, regarding how you want to see COGCC handle future O&G permits and operations.
1) Submit a written statement (called a 510 Statement). It can be as little as a page, or as long as you need to make your point(s).
510 Statements are due by Friday August 14 at 5pm.
Send to <DNR_COGCC.Rulemaking@state.co.us>
Subject: Mission Change Rulemaking 510 Statement
The Commission prefers a PDF of your statement, but you can send in a Word doc or just write your statement in the body of the email.
Put the date of the submission just above your signature.
End with: Sincerely, /S/ your name (/S/ is the symbol for an electronic signature)
Provide your complete address, email and phone number under your signature.
Do not indicate you’re a member of any specific group.
Most of the climate/envionmental advocacy groups in Colorado are formal Parties to this rulemaking, and therefore are not allowed to submit 510 Statements because we already submitted a prehearing statement.
2) Provide comment by testifying at the rulemaking hearing (via Zoom) on Monday, August 24th, beginning at 4pm. Testimony will be limited to 2 minutes and those who sign up in advance will be given priority. Prior to August 24, the Commission will allow persons to sign up to make oral statements, but that form hasn’t been posted yet. Those who sign up in advance will be given priority.
Talking points are provided HERE (from 350 Colorado and Climate Reality Project).
If you want to take a look, the proposed rules can be viewed HERE. The rules are daunting to get a handle on – and 510 statements and oral testimony can make general points, not necessarily referencing specific rules.
Thank you for advocating to COGCC to reduce climate damage from oil & gas development – which will make a difference in the fight to save our planet.
