Tuesday, March 20 2012
Statement by David Ludlam, Executive Director of the West Slope Colorado Oil & Gas Association, Affiliate Chapter of the Colorado Oil & Gas Association
The McKenzie Report -Regarding Human Health Risk Assessment of Air Emissions from Development of Unconventional Natural Gas Resources
Member companies of the West Slope Colorado Oil & Gas Association (WSCOGA) are committed to conducting oil and gas operations in compliance with applicable rules and regulations, including those related to air quality. These operators have reduced air emissions through improved operating practices and emission controls, and both funded and participated in studies to characterize and monitor air emissions. WSCOGA agrees that oil and gas operations must be protective of public health and the environment.
The West Slope Colorado Oil & Gas Association and our member companies are very concerned about the assumed health impacts of the McKenzie report (“the report”). This report lacks the necessary supportive data and proper context and represents a basic restatement of the Battlement Mesa Health Impact Assessment—a project that was suspended, in part, due to the State of Colorado’s criticism of the project.
As noted by McKenzie, the “EPA standards are designed to be public health proactive and may overestimate risks.” (CSPH media release, March 19 2012) This statement is important. The McKenzie report lacks contextual comparisons to other, potentially higher, everyday risk factors. Colorado Department of Public Health and Environment authored comments extremely critical of data used for the McKenzie report. (CDPHE comments on the “Health Impact Assessment for Battlement Mesa, Garfield County Colorado, and November 15, 2010). Again, the report is basically a restatement of data already proven to be weak on supportive data and void of critical proper context.
WSCOGA strongly urges members of the public and media to review CDPHE’s comments as well as Energy In Depth’s response related to the Colorado School of Public Health’s data interpretation. We believe these comments will assist in properly framing follow-up references to, and stories about, the report.
For nearly a decade, operators in western Colorado have conducted green completions to capture the natural gas emissions that result from flowing back a well after hydraulic fracturing treatments. This is and has been a best management practice. Except for an initial period when gas pressures are insufficient, the flowback gas is connected to a gathering line for sale. The relatively small volume of gas produced during initial flowback is flared or vented. In Colorado, the successful practice of green completions became a rule in 2008, to ensure that emissions during hydraulic fracturing flowback were being minimized. EPA has now proposed that green completions (aka reduced emission completion) be established as a nationwide rule for oil and gas operations. This new rule is expected to be finalized in April 2012.
In the coming days WSCOGA will join our statewide parent organization in expanding our analysis and will provide a formal response to the report. Efforts will focus on a sample of examples below that help place the purported increased risk factors in proper context: use of limited, antiquated data that fails to consider new, stricter regulations, inaccurate assumptions regarding operational timeframes, and health risks.
Interpretation of data for the purposes of influencing public policy must be led by good science, particularly considering the complexity of atmospheric studies. To this end, WSCOGA supports studies that are founded in sound science and is working with Colorado State University’s School of Atmospheric Studies to employ a first-of-its-kind air emissions study to characterize air emissions from natural gas well drilling and completion operations in Garfield County, CO using state-of-the-art technology, scientific methodology, and interagency cooperation. Specialists from the oil and gas industry, Garfield County’s Environmental Health Department, the Environmental Protection Agency, the Colorado Department of Public Health & Environment and numerous local partners are working collaboratively in this groundbreaking effort. This study will provide reliable data to depict emission profiles for these operations.
The West Slope Colorado Oil & Gas Association takes pride in the progress made by our member companies in not just reducing air emissions during the previous decade, but also in reducing the impacts related to all aspects of operations in Western Colorado. And while our organization remains critical of the McKenzie report we look forward to working with Colorado State University and our county, state and federal partners to provide the quality data needed to address public concern related to air quality in Western Colorado.