Statement from 350 Colorado for Rulemaking Concerning State Greenhouse Gas Emissions delivered to the Air Pollution Control Division on January 16, 2020

By Micah Parkin

    • Hello, my name is Micah Parkin, and I’m the executive director of 350 Colorado. 
    • I’m speaking today on behalf of over 18,000 of our members statewide who are extremely concerned about the climate crisis and as a mother of two daughters, one of whom has developed exercise-induced asthma due to our poor air quality.
    • We appreciate the division’s focus on reducing emissions. 
    • As I’m sure we all know, rapid reductions are urgently needed to have any chance of leaving our children a planet capable of sustaining life as we know it.
    • The Intergovernmental Panel on Climate Change tells us that for a 66% chance of avoiding climate catastrophe by limiting global temperature rise to no more than 1.5° C (below pre-industrial levels), the world must achieve net zero GHG emissions by 2040.  
    • Colorado should strive to achieve that goal even sooner – by 2035, considering our historic emissions and access to plentiful affordable renewable energy, and to improve our odds.
    • The 2025 goal set by HB-1261 of reducing emissions by 26% (compared to 2005 levels) aligns with the IPCC’s 66% chance scenario of keeping global temps below a 1.5 degree C rise. 
    • However, the latter two goals don’t align with either the IPCC’s 66% or 50% chance scenarios for staying below 1.5C, and therefore don’t go far enough and will need to be strengthened.  
    • It is essential to begin making deep reductions in all GHGs as soon as possible, since the longer we wait, the steeper the decline curve becomes and the more expensive and difficult achieving these goals becomes, eventually approaching impossibility.


  • So we urge the APCD to move quickly to address all significant GHGs, not just HFCs, and to formally request that the AQCC initiates the Regulation 22 process for GHGs as soon as possible.


    • We also call on State leaders and regulators to use best available technologies, scientific methods and studies to craft truly protective new regulations and plans to meet the climate, health and safety requirements of HB 1261 and SB 181. 
    • For our state GHG Inventory – first, we must start from an accurate baseline – and to do that, a more thorough GHG inventory is needed, using best available technologies including top down atmospheric measurements using aircraft mounted monitoring of methane leaks from the oil and gas sector (rather than relying on bottom-up sector emissions factors), as well as continuous on-site emissions monitoring to quickly address emissions violations.
    • Colorado’s current inventory is severely underestimated according to several studies I’ve noted in my written statement.
    • Research indicates that Colorado’s actual methane and VOC emissions are 2-4 times higher than the current GHG inventory, and benzene was underestimated by at least a factor of 5.
    • Research from NASA, Cornell and Harvard show that the worrying global spike in methane, a potent GHG, over the last decade is largely from US fracking.
    • Methane also contributes to the formation of ground-level ozone, with large adverse consequences for human health and agriculture. 
    • We must also bear in mind that according to Cornell’s Tony Ingraffea, 5% of fracking wells leak immediately and nearly all will leak within 30 years. With already over 80K wells in CO, we are facing a major methane leakage nightmare as well casings deteriorate in the years to come and the financially insolvent fracking companies have long gone bankrupt, leaving communities to clean up the mess. This must be factored into plans to address the climate crisis.
    • We also call on the APCD to develop rules that account for the GHG emissions of oil and gas exports. We must take responsibility for activities within our state’s borders that exacerbate the global climate crisis, regardless of who ultimately burns the fuel. 


  • While new climate and health rules are under consideration, we urge the Air Pollution Control Division (and other state agencies) to stop the issuing of new oil and gas permits.
  • Fracking is contributing significantly to the climate crisis. Colorado must properly study and assess the full impact of the industry and begin to transition away from oil and gas, in order to reduce toxic emissions statewide and to address the full climate footprint of this state.


      • The recent state-funded health study released by CDPHE showed toxics such as benzene and significant negative health impacts up to 2000’ from oil and gas fracking.  
      • Since 2000’ was the maximum distance studied and the study did not follow actual long-term impacts, such as increased cancer risks in high density and close proximity to fracking, we call on the state to urgently launch additional studies to assess these risks. 
      • The NY Health Compendium shows many additional risk at greater distances. 
      • Regarding who should pay for technologies to monitor health studies – the fracking industry should pay for this equipment.
      • In the meantime, until meaningful data can demonstrate that Coloradans’ health and safety are being protected, we must not be exposed like lab rats to continued poisoning from the oil and gas industry. 
      • Health and safety must come first, including clean air and a safe climate.
      • I call for a timeout on new fracking. The precautionary principle must be employed and additional fracking must not be permitted until those tasked with protecting public health and safety can be sure that they are doing their jobs.
      • Several other states and countries around the world, such as the UK, Germany, France have employed the precautionary principle and banned fracking after carefully considering public health and safety data.


  • A baseline study of current toxic emissions in various areas must be ascertained to assess if any additional pollution is permissible or if potential risks to public health and safety are too great. Permitting blindly without this baseline information and a corresponding public health assessment is irresponsible and unethical for those tasked with protecting public health and safety.


      • I call for bold new rules to fully safeguard clean air, climate, and public health from fracking. 
      • Research by CU’s Detlev Helmig has shown dangerous spikes in carcinogenic benzene miles away from the source wells. There is no safe level of benzene exposure. What will the long-term effects be to children in high density fracking locations? They need and deserve your protection.
      • Oil and gas extraction is responsible for as much as 40% of the dangerous levels of ground-level ozone and F-grade air quality along the Front Range. 
      • It is also contributing significantly to the climate crisis through vast methane leaks and oil and gas burning. While better pollution controls are helpful, the reality is, there is simply far too much fracking happening. 


  • Finally, we call for all relevant state agencies and divisions to work together to craft and deploy a bold plan for a rapid and just transition off oil and gas development in CO. Health and safety can only be protected if we have a livable climate and safe air to breath, which is at present incompatible with fracking.


Thank you.