By David Ludlam
The COGCC pit liner burial rule as proposed by the Colorado Petroleum Association is supported by the West Slope Colorado Oil & Gas Association. West Slope COGA encourages support for the proposal from local governments as some county landfills are not accepting liners, while others charge significant and varied disposal fees. Moreover, in Colorado, state and federal policies towards pit liner disposals are inconsistent. In some cases, federal agencies allow pit liner burial whereas the state rules prohibit the same disposal method. As a result, West Slope COGA supports the rule modification burial allowance in limited circumstances where:
a. written consent is received from surface owners and burial locations are indexed; and
b. all constituents on or surrounding the liner remain at toxicity concentrations
designated by Colorado Oil & Gas Conservation Commission, Table 910-1; and
c. all reclamation standards are followed
The West Slope COGA believes the rule modification proposal represents a regulatory change that encourages reasonable and cost effective natural gas operations in the state of Colorado, while also preserving the stated mission of the COGCC -which includes protecting human health and the environment.
The best public policy results from carefully considered and deliberately conceived policies reflecting science and data driven regulatory practices. The proposed rule modifications (that must conform to COGCC standards) meet that definition. Therefore the proposal deserves consideration and support.