The CCC and Eco-Justice Ministries, our affiliate partner, have contacted the Air Quality Control Commission to push for strong air quality standards. These commissioners have come under intense pressure to weaken the strong standards that they have developed during the agency rulemaking process. While Colorado enjoys a boom in oil and gas development, we believe that our state can find a good balance and regulate air pollution in a way that reasonably protects the environment, safeguards the health of our communities and gives the oil and gas industry room to develop. For more information on Eco-Justice Ministries, please visit www.eco-justice.org.
Here is the text of what Eco-Justice Ministries submitted to the Air Quality Control Commission during the public comment process:
TO: Colorado Air Quality Control Commission
FROM: Eco-Justice Ministries, Denver, CO
DATE: February 19, 2014
RE: Proposed Air Quality Rules
Eco-Justice Ministries affirms the good work of Colorado’s Departments of Public Health and Environment (CDPHE) and Natural Resources (DNR) in developing proposed air quality rules. We appreciate the strong standards that have been proposed for many kinds of air pollution related to oil and gas development, and we call on the Air Quality Control Commission to adopt the rules in their entirety.
Eco-Justice Ministries is a faith-based organization, working with churches in Colorado and around the country on issues of environmental justice and ecological health. The dramatic increase in oil and gas drilling seen in Colorado is a matter of primary concern for us and our constituents.
The moral principles that inform us when addressing these issues highlight the long-term health of local communities (both humans and other parts of creation), and whether the costs and benefits of oil and gas extraction and transportation are allocated fairly. We are deeply concerned about the high impact of air pollution on vulnerable populations, including children and the elderly, and those with existing health conditions. We are also concerned about the historic questions of environmental justice, and the disproportionate impact of pollution on communities of color and low-income populations.
With the pollutants that can be released in these oil and gas operations, health impacts can be spread across a very wide region, and there are global impacts from strong greenhouse gasses such as methane. Compassion and justice for all of our neighbors — locally and globally, now and in the future, and of all species — call us to demand strong environmental protection.
In the presence of newer technologies such as fracking, and with the lack of extensive research on the health impacts of long-term exposure to pollutants, we advocate a precautionary approach which avoids or minimizes risk whenever there is any doubt. Research published since the release of the proposed rules (“Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado”, published by the National Institute of Environmental Health Sciences, January 2014) makes it clear that there are many unanswered questions about the types and scale of risks from oil and gas pollution. Holding all operations to very strong standards is the least we can do while such uncertainty remains.
We strongly support aspects of the proposed rules which require “green completion” of all wells, a reasonable procedure which can lead to a dramatic reduction in pollution. We also strongly support the regulation of methane — an inclusion in the rules that puts Colorado at the forefront of appropriate regulation.
We are convinced that these rules must be applied to all areas of Colorado, and to all oil and gas operations. The reduction and monitoring of pollution is essential across the state, in areas of high-intensity drilling as well as areas where such operations are less pervasive. All businesses doing oil and gas extraction must be held to the same standards, regardless of the size and resources of the business, or the infrastructure in place for extracting and transporting the product.
The proposed rules will provide responsible and reasonable guidance for a rapidly expanding industry in Colorado, with tighter monitoring and greater protections. We see these new rules as a good expression of what should be the minimum standards in Colorado and across the country. We hope, and expect, that the rules will be tightened in coming years as new technologies become available, and as more research provides better information on the risks from this kind of pollution on human health and environmental vitality.
I was privileged to meet last fall with the directors of CDPHE and DNR, to share these moral principles from faith communities in Colorado. I was pleased to hear from them that the rules — which were about to be released — would take seriously our concerns about the well-being of all Colorado communities. I heard from them about the hard work done by their staff to develop rules that would provide for very strong protection.
Eco-Justice Ministries urges the Colorado Air Quality Control Commission to honor the good work of CDPHE and DNR, and to respect the need of all Colorado communities to clean air and healthy environments, by approving all of the proposed rules.
Rev. Peter S. Sawtell, executive director
Eco-Justice Ministries
400 S. Williams St, Denver, CO 80209
