Weld County Opposes Clean Air in Denver Metro Area

Strangely and unfortunately, Weld County is opposing the state's proposal to ratchet down on emissions of smog forming compounds from oil and gas developments north of Denver. In their request for party status, the County stated:

"The Board of Commissioners of Weld County desires to challenge the Air Quality Control Commission’s position that the recent increased levels of volatile organic compounds (VOCs) are due primarily to the operation of oil and gas production equipment. The Commission’s proposed regulations, which would increase the number of emission control devices at a high cost to the industry, are misdirected in that they ignore other sources of ozone, such as automobile emissions. It is the belief of the Board that the oil and gas industry has done as much as it should do to reduce or eliminate VOCs and should not be forced through the Commission’s regulations to do more."

The amazing thing about Weld County's opposition, is that even industry is not as opposed to state efforts to ratchet down on smog forming compounds. At a meeting today, the Colorado Oil and Gas Association itself stated that more should be done to limit emissions of smog forming compounds from oil and gas developments north of Denver.

What's more, Weld County's opposition to clean air puts communities north of Denver at great risk. The town of Greeley suffered five exceedances of the federal health standard for ozone this last summer, which is due to a massive increase in volatile organic compound emissions from the oil and gas industry. How massive?

According to current requirements, controlled emissions of smog forming compounds were not to exceed 91.3 tons/day in the Denver area by the year 2007. However, as of 2004, controlled emissions already reached 150 tons/day, over 60% higher than projected 2007 levels.

Weld County apparently believes that mobile sources, like cars, are responsible. However, data from the state shows that in Weld County, mobile sources, like highway vehicles, release only 5% of total smog forming compounds, while stationary sources, which include oil and gas, release 84% of total smog forming compounds.


Weld County's opposition to clean air seems very misplaced.

If We Adopted Scientifically Recommended Ozone Standards...

In August, the U.S. Environmental Protection Agency's Clean Air Scientific Advisory Committee recommended the agency consider lowering the ozone pollution to 55 parts per billion, measured over an 8-hour period, to fully protect human health.

The health standard currently in place is 80 parts per billion, which the Denver metro area has exceeded 66 times so far this year. If the health standard was 55 parts per billion, the Denver area would have exceeded the standard 1,321 times. The table below shows how many times peak 8-hour ozone levels met or exceeded 55 parts per billion as of September 26 at monitors in the Denver area:

Monitoring Station	# Times 8-hour Ozone Met or Exceeded 55 ppb
Welby	61
Highland	129
South Boulder Creek	124
CAMP	18
Carriage	82
Chatfield State Park	138
Arvada	114
Welch	102
Rocky Flats North	142
NREL	124
Ft. Collins West	84
Ft. Collins	75
Greeley	128

From the standpoint of our health, we have a ways to go before we can say our air is clean.

Rocky Mountain Clean Air Action Files for Party Status

Rocky Mountain Clean Air Action today filed for party status in the state's rulemaking to ratchet down on emissoins of ozone forming compounds from oil and gas developments north of Denver. The proposal would require condensate tanks that release 6 tons per year or more of ozone forming compounds to reduce emissions by 95%. 2,237 condensate tanks will be cleaned up because of the rule. As a party to the rulemaking, Rocky Mountain Clean Air Action can more effectively advocate for the proposed ozone reductions.

Summer Ozone in Review

The summer is coming to an end, meaning ozone levels too are coming down to less unhealthy levels. Although ozone pollution can be a problem any time of the year, summer is definitely the season with the greatest pollution problems.

With that said, it's time to count the toll that this last summer's ozone had on Denver area communities and to review where we're at. Let's take a look:

• According to state monitoring, maximum 8-hour ozone levels reached or exceeded the health standard of 80 parts per billion 66 times at the various monitors from Chatfield to Greeley.

• Peak 8-hour ozone levels reached or exceeded 80 parts per billion at the Chatfield monitor 12 times.
• The highest 8-hour ozone concentration was 97 parts per billion and was reported from the Fort Collins West monitor on July 14.
• Ozone levels exceeded 80 parts per billion at 12 monitors along the Front Range.
• Only one monitor, the CAMP monitor located in downtown Denver, did not show high ozone pollution.
  
• Denver will violate federal ozone standards if the three year average of the fourth highest ozone levels reaches 85 part per billion or higher. Because of this summer's ozone, a fourth highest reading of 84 parts per billion or higher at the Chatfield monitor next year will cause Denver to violate the standard. The fourth highest ozone value has reached or exceeded 84 parts per billion two of the last three years at Chatfield.

But the big question is, what do we do now? Clearly more must be done to reduce ozone pollution in the Denver area. While the state is proposing to ratchet down on emissions of ozone forming compounds from oil and gas developments to help reduce ozone, these rules need our support. The health of our children and our communities is on the line here. We cannot afford to continue to have summers where ozone levels exceed health standards even once, let alone 66 times.

Denver's "Clean Air" Status Called into Question

Supporting clean air, last Friday Rocky Mountain Clean Air Action submitted comments to the U.S. Environmental Protection Agency (EPA) opposing the agency's effort to continue Denver's "clean air" status. Rocky Mountain Clean Air Action, however, left open the option of withdrawing opposition if stronger clean air requirements are emplaced to keep ozone below unhealthy levels.

In August, the EPA proposed to defer proclaiming the Denver area to be in violation of the federal ozone standard, which is set at 80 parts per billion averaged over an 8 hour period. The proposal asserted that Denver's air was healthy, contrary to the fact that over 50 exceedances of the ozone standard were monitored this summer.

At the same time, the state of Colorado has proposed to ratchet down on emissions of ozone forming compounds from oil and gas developments north of Denver. This proposal won't be adopted until November, however, and industry opposition may keep it from being adopted at all.

The EPA cannot claim that Denver's air is healthy while simultaneously the state of Colorado has all but admitted that more must be done to reduce ozone pollution from oil and gas development. For the EPA to proclaim Denver's air to be "clean" before ozone reductions are adopted by the state is simply irresponsible. The EPA's proposal puts the cart before the horse and in the end, may provide more incentive for pollution than clean air.

If anyone would like a copy of Rocky Mountain Clean Air Action's comments on the EPA's proposal, feel free to contact us.

Health Seems Lost on Regional Air Quality Council

Ozone pollution was the focus of the most recent Regional Air Quality Council meeting last Thursday. Unfortunately, discussions did not focus on ways to better protect the health of children and communities from ozone pollution in the Denver area.

This summer's ozone levels, which are measured as 8-hour averages, exceeded the federal health standard of 80 parts per billion over 50 times. Although technically a violation of the federal standard did not occur, this doesn't mean our air was not unhealthy. The Environmental Protection Agency has concluded that any time 8-hour ozone concentrations exceed 80 parts per billion, our health is at risk.

For a violation of the federal ozone standard to occur, the three year average of the fourth highest 8-hour ozone values has to exceed 85 parts per billion (85 because of an outdated rounding scheme). In other words, a violation of the federal ozone standard occurs only when we have suffered three years in a row of excessive pollution. At that point, federal clean air regulations kick in to protect our health.

From a health standpoint, it's not important whether or not a violation of the federal ozone standard occurs. This fact seems lost on the Regional Air Quality Council, a politically appointed planning agency. At the Thursday meeting and even in a recent press release, the health effects of this summer's dangerously high ozone were not even mentioned. The focus instead was on whether the Denver area violated the federal ozone standard and whether federal clean air regulations could be avoided.

Clean air should not be about whether federal pollution standards are or are not met. The health science says that 8-hour ozone levels at 80 parts per billion or higher are a health threat. In light of this, we need to do everything we can to keep ozone levels below this unhealthy threshold, whether or not we're in violation of the federal standard. The Regional Air Quality Council would do better to keep this in mind as it weighs options for further reducing ozone pollution in Denver.

$6,845,786 a Year

This is the estimated cost of further reducing emissions of smog forming compounds from oil and gas developments north of Denver under the state's proposed rule. Does this seem like a lot? Let's put this into context:

• This is only 1.65% what asthma costs of the state of Colorado annually.
• This is only 1.06% of Noble Energy's Net Income for 2005, which was $645,720,000 according to the company's annual report. Noble Energy is one of the largest oil and gas producers north of Denver.
• This is only 3.93% of Weld County's 2006 budget of $174,164,568.
• This is less than 1% of what it is costing the Valero Refining Company to install pollution controls at its Commerce City oil refinery north of Denver.
• This is 0.83% of the Colorado Department of Transportation's 2006 budget.
  
• This is 1.3% of what the state spends to cover Medicaid costs for over 249,000 low income children in the state of Colorado.
  

And on and on and on. The bottomline is that the cost of reducing air pollution in the Denver area is really insignificant in the grand scheme of things. When the oil and gas industry says they can't afford to do more to reduce smog in the Denver area, it may be helpful for us to remind them just how little they'll be spending.

Ozone Reminders

Just a reminder on a couple of important public involvement opportunities coming up:

• Today there will be a Regional Air Quality Council meeting from 3:00-5:30 P.M. at 1445 Market St. in the Second Floor JA Conference Room. Check out our September 3 post for more information.
• Tomorrow, September 8th, comments on the Environmental Protection Agency's proposal to defer Denver's nonattainment designation for the 8-hour ozone standard are due. Check out our August 9 post for more information.

Come to the meeting, submit comments, or do both. Weigh in and help make a difference for clean air in Denver!

Smog Levels "Technically" Low, but Remain Unhealthy

Many probably noticed the hazy and smoggy conditions today in the Denver metro area, especially in the morning. The picture below, from 9 in the morning, shows the dirty sky. Smog levels have technically been low so far in August, although new recommendations from scientists suggests that smog levels have remained unhealthy. In fact, scientists have recommended the U.S. Environmental Protection Agency set a smog, or ozone, standard as low as 55 parts per billion, over 30% stronger than the current standard of 80 parts per billion. Ozone levels at several monitors in the Denver area exceeded 60 parts per billion today.

Although smog levels were technically low, levels of nitrogen oxides appear to have approached dangerous concentrations today. Not only are nitrogen oxides dangerous on their own, they also contribute to smog pollution and acid rain.


Under the Clean Air Act, annual concentrations of nitrogen oxides cannot exceed 0.053 parts per million anywhere. Nitrogen oxide levels at the air monitor at 2105 Broadway reached 0.061 parts per million today. Although this may not indicate a violation of the yearly standard, it does show that nitrogen oxide levels today contributed to unhealthy air in Denver. But again, this was likely obvious to any of us that ventured outside.

Regional Air Quality Council Meeting on the 7th

The Regional Air Quality Council, an appointed body that oversees air quality in the Denver metro area, is meeting on September 7th, from 3:00-5:30 P.M. at 1445 Market Street in the 2nd Floor JA Conference Room. This meeting will give citizens the opportunity to voice support for smog reductions in the Denver metro area and get the RAQC behind clean air.

The September 7th meeting agenda is online. The RAQC is slated to discuss the state's proposal to ratchet down on emissions of ozone forming compounds from oil and gas development north of Denver.

If you have time, it's crucial to attend this meeting. There will be an opportunity for public comment, giving us a chance to get the RAQC behind the state's proposed smog reductions in Denver. We need to hold the RAQC accountable to communities and human health in the Denver metro area. Please attend the September 7th meeting and simply tell the RAQC to support the state's proposal to reduce emissions of ozone forming compounds from oil and gas development and reduce smog in the Denver metro area.