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Home My WebLink About20194270.tiff OFFICE OF BOARD OF COMMISSIONERS r _ PHONE: 970-336-7204 \ 4 � -\i, - FAX: 970-336-7233 � r/A ' = � 1150 O STREET I I P.O. BOX 758 G O u N T Y GREELEY, COLORADO 80632 October 30,2019 Via Email and US. First Class Mail Colorado Governor Jared Polis Colorado State Capitol 200 E. Colfax Denver, CO 80203 Jill Hunsaker Ryan, Executive Director Colorado Department of Public Health and the Environment 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Dan Gibbs,Executive Director Colorado Department of Natural Resources 1313 Sherman Street, Suite 718 Denver, CO 80203 Jeff Robbins, Director Colorado Oil and Gas Conservation Commission 1120 Lincoln Street, Suite 801 Denver, CO 80203 RE: Weld County's Offer to Partner With COGCC and CDPHE to Implement Additional Monitoring and Modeling of Pre-Production Oil and Gas Activities in Weld County Dear Governor Polis, Executive Director Ryan, Executive Director Gibbs, and Director Robbins, As expressed by Commissioner Kirkmeyer at the Colorado Oil and Gas Conservation Commission(COGCC)meeting this morning,the Board of Commissioners of Weld County supports additional monitoring and modeling of pre-production activities at oil and gas well sites to address the concerns raised in the ICF Study about the potential for acute health effects among individuals exposed to emissions from those activities. The Board offers its active participation and resources to partner with the COGCC and the Colorado Department of Public Health and environment(CDPHE)in the planning for and implementation of such additional monitoring and modeling in Weld County. We wish to ensure that such concerns regarding the health and welfare of our citizens are responsibly addressed through(1) sound scientific and technical C o MM v n; co`4-'ci a S 2-411c1 l /o6/lq Letter,Polis,Ryan, Gibbs and Robbins October 30,2019 Page 2 efforts to (2) gather high quality data for(3) use in appropriate modeling and risk analysis. Weld County is the third largest county in Colorado, being roughly 4,000 square miles in size. It is first in both agricultural production and oil and gas production statewide. We hold special regard for clean air and wide-open spaces, for hard and productive work and respect for the land. Weld County is committed to protecting air quality and to protecting the air quality and health of the individuals who work in the oil and gas industry and our citizens. We have a keen interest in ensuring that the public,our citizens, understand the broader conclusions, as well as the limitations and assumptions of the recent ICF Study. We wish to ensure thoughtful consideration of the most appropriate next steps to address those concerns raised in the study about potential acute health effects. To that end, we are relieved that the study shows no long-term health effects from the hypothetical exposures that it modeled, despite its highly conservative,dated and probabilistic methods used to draw conclusions about potential short-term, acute impacts and the uncertainty inherent in methods. While we strongly support planned monitoring and modeling, based on our current understanding of the proposed protocol, we are concerned why weather conditions and operational information, including types of best management practices being utilized at a monitoring site and off-pad data necessary to ground-truth the model and isolate the monitoring site from other sources, are not proposed for data collection. How the data is gathered will be used for subsequent risk assessment also is not clear and may affect the suitability of those data for such an intended use. These observations are illustrative of Weld County's depth of interest and concern for the conduct of well-conceived and technically sound monitoring, modeling and risk analysis in response to the ICF Study's concerns about potential acute health effects. We are excited about the possibility of partnering with the COGCC and CDPHE to plan for and implement additional monitoring and modeling of pre-production oil and gas activities in Weld County. Please let Commissioner Kirkmeyer know with whom we may discuss Weld County's offer. Commissioner Kirkmeyer may be contacted at(970)400-4200, or by email at bkirktneyer@weldgov.com. Letter,Polis, Ryan, Gibbs and Robbins October 30,2019 Page 3 Sincerely, BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY Barbara K' kmeyer, hair Mike Freeman,Chair Pro-Tern Sean Conway 41/L- °.-Scott James Steve Moreno pc: Bruce Barker, Weld County Attorney John Jacus,Davis Graham& Stubbs LLP OFFICE OF BOARD OF COMMISSIONERS \ PHONE: 970-336-7204 Tr FAX: 970-336-7233 ! ',,�,�,"�.,,a 1150 O STREET t � P.O. BOX 758 t�U N T GREELEY, COLORADO 80632 r September 23, 2019 Via email to cdphe.commentsapcd@state.co.us Gordon Pierce Program Manager, Technical Services Program Colorado Department of Public Health and the Environment—Air Pollution Control Division 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 RE: Weld County Comments on State of Colorado Enhanced Monitoring Plan for Ozone Dear Mr. Pierce, The Board of Commissioners of Weld County respectfully submits the following comments on the Colorado Department of Public Health and Environment—Air Pollution Control Division (APCD)report entitled: "State of Colorado Enhanced Monitoring Plan for Ozone," published on August 21, 2019 (EMP). The Weld County Board of Commissioners appreciates the opportunity to provide comments to APCD on this important plan and requests the opportunity for Weld County staff and consultants to confer with APCD regarding air quality monitoring for ozone more generally. The draft EMP proposes to add new ozone monitors in Weld County. Specifically, the draft EMP proposes one new ozone monitor in the Platteville area of Weld County; one new nitrogen monoxide (NO)/nitrogen dioxide (NO2)/nitrogen oxides (NOx) monitor in the Platteville area (referred to as the NOx monitor); one new total volatile organic carbon(VOC) monitor in Greeley; and one new meteorological measurement station in Platteville. Based on our understanding of the draft EMP, these monitors are in addition to various proposed monitors that would be deployed separately for special studies. Weld County would appreciate the opportunity to confer with and provide input to APCD whenever it proposes specific air quality monitoring locations within Weld County. While not specifically mentioned in the draft EMP, we are aware that APCD is considering VOC, collocated ozone, and NOx monitoring as well as meteorological measurements at the Weld Count Airport. From the EMP it is unclear if the ozone,NON, and meteorological monitors 2019-4270 Catimtmc)r ►ccitions 09 (30 (19 Letter, Gordon Pierce, CDPHE September 23, 2019 Page 2 proposed for the Weld County Airport would be collocated with the new VOC monitor instead of the existing VOC monitor in Platteville, or if these monitors would be in addition to the ozone, NON, and meteorological monitors the draft EMP proposes in Platteville. It would be helpful to Weld County's understanding if the final EMP was revised to clarify the relationship between these proposed monitoring locations. If APCD is considering collocating the ozone, NOR, and meteorological monitors at the new VOC monitoring site rather than the existing Platteville site, we recommend that the final EMP not specify the location of the ozone,NON, and meteorological monitors to be sited in Weld County in order to increase flexibility during EMP implementation. On the other hand, if APCD is planning to install two ozone, NON, and meteorological monitors in Weld County, we recommend the final EMP be revised to clarify this point, and Weld County would welcome the opportunity to discuss these potential locations with APCD more specifically. It would be helpful if the final EMP elaborated on APCD's rationale for selecting specific areas for additional monitoring, particularly in the context of the recent ozone measurements collected during the 2019 ozone season and the need for additional data to further understand spatial/temporal trends. More specifically, APCD's Chatfield monitor is currently the highest- reading ozone monitor for the Denver Metro and North Front Range (DM/NFR) area, with a three-year average fourth max 8-hour concentration of 78 ppb for the 2017-2019 period. It could be beneficial for APCD to consider additional monitoring and/or special studies at this site or in the vicinity of Chatfield to provide a better understanding of what contributes to these high concentrations. This additional monitoring could be for NOx and VOCs using short-term monitors, long-term monitors, special studies equipment, or the APCD Mobile Lab. It would be helpful to understand if APCD considered Chatfield for deployment of the Photochemical Assessment Monitoring Station(PAMS) system and the rationale for selecting the Rocky Flats site to deploy the PAMS. Information regarding speciated VOCs, which would be measured by the PAMS and not by other VOC monitors being considered by APCD (i.e. summa canisters), could be highly informative in close proximity to the design value monitor. Speciated data could help to provide information about the photochemistry, reactivity, and pollutant aging at the design value monitor. Long-term trends of speciated data could also help inform the efficacy of control strategies. Speciated measurements near Chatfield could be supplemented by studies of the speciated VOC emissions closer to emissions sources. A short-term deployment of the Mobile Lab during a typical period for high ozone in 2020 might provide insights into the roles of urban, rural and industrial emissions from the DM/NFR area. It would also be helpful if APCD included more information about its special studies monitoring plans in the final EMP or indicated that such plans will be the subject of future draft monitoring plans and therefore will afford Weld County and other stakeholders with an opportunity for review and comment prior to their implementation. It is difficult for Weld County to comment meaningfully on this aspect of the draft EMP without examples of the types of special studies being considered or discussed, the types of questions that special study monitors could help answer, and an understanding of APCD's past performance of special studies of the type being contemplated. Letter, Gordon Pierce, CDPHE September 23, 2019 Page 3 Additionally, it appears that the draft EMP deviates from both the"2015 Ambient Air Monitoring Network Assessment" (5-year network assessment last finalized in 2015) and the 2019 Ambient Air Network Monitoring Plan in some respects. This is understandable given the rate of change in regulations and advancements in our understanding of the science of Denver Basin air quality. Given the rapid rate of change in both regulations and the state of the science, it could be beneficial for APCD, as part of finalizing the draft EMP, to consider an out-of-cycle update of the 5-year network assessment to ensure that the final EMP is aligned with the 5-year plan and vice versa. In addition to submission of these and possibly other comments, Weld County would like to work with APCD to explore possible monitoring sites in Weld County that meet both scientific objectives and logistical requirements. Though we generally support site selection for certain additional monitoring in the greater Greeley area, we would like APCD be mindful that the Weld County Airport might not be an optimal monitoring site for a number of reasons. First, the airport will likely not be able to restrict access to the monitoring equipment, while other sites could control access more readily. Second,monitoring NOx and ozone would provide better and diverse data if located in areas other than near Greeley(as other monitors are currently in the area). Though collocation of monitors can useful and efficient, in this case, siting monitors for different pollutants in separate locations would lead to a better understanding of air quality and emissions in the County and the relationships with air quality and emissions in other areas of the Northern Front Range area. Weld County has a number of county-owned parcels that may be superior to the Weld County Airport locations being considered by APCD. Separately, we wanted APCD to be aware that Weld County is actively considering conducting an assessment of the County's additional ozone and other air quality monitoring needs to guide development of a possible County monitoring network intended to complement the APCD's network of monitors. Specific types of information that may be considered as part of this assessment include emissions source location, topography, meteorological factors, inflow of pollutants into the County, and the fate of emissions and pollutants transported away from the County. As Weld County continues to evaluate whether and how to conduct this assessment it would welcome feedback from APCD and opportunities to collaborate with APCD to achieve joint monitoring objectives. We believe that our work might be particularly valuable to APCD as it decides on the specific location of ozone monitors proposed in the draft EMP and in future monitoring plans. We look forward to discussing these issues with APCD and a exploring the coordinated implementation of expanded ambient air monitoring Weld County and the rest of the Denver Basin. Thank you for the opportunity to provide these comments and local government perspectives. If you have any questions or wish to schedule a meeting to discuss the draft EMP in greater detail, please contact Ben Frissell, Waste Program Coordinator with the Weld County Health Department at (970) 400-2220, and Courtney Taylor, Consultant to Weld County with Ramboll at (303) 382-5467. Letter, Gordon Pierce, CDPIIE September 23, 2019 Page 4 Sincerely, BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY Barbara irkmeyer, Chair c Mike "reeman, Chair Pro-Tem Sean Conway A.,_..."''-''''''.----------"-- .,,.‘1, .---, _/92,20,14„...e, Scott James Steve Moreno pc: Bruce Barker, Weld County Attorney Ben Frissell, Weld County Health Department John Jacus, Davis Graham & Stubbs LLP Hello