Submitted to the Colorado Oil and Gas Conservation Commission on November 29th, 2022
The Fort Collins Sustainability Group (FCSG) is affiliated with the Northern Colorado Alliance for a Livable Future, a 501(c)3 non-profit organization based in Fort Collins, Colorado. The mission of the FCSG is to develop and advocate a vision and strategy for becoming a sustainable community, with a principal focus on the need to reduce greenhouse gas (GHG) emissions to levels consistent with a stable climate. We have played a key role in the establishment of and successful achievement of the City of Fort Collins’ GHG emissions reduction goals since 2005.
The FCSG supports the “Petition for Rulemaking to Adopt Rules to Evaluate and Address Cumulative Impacts” developed by WildEarth Guardians, 350 Colorado, Womxn from the Mountain, Physicians for Social Responsibility, the Larimer Alliance, and the Sierra Club of Colorado in its entirety. We wish to highlight three sections of the rules proposed in that petition that we view as particularly important:
Definition of Cumulative Impacts
The petition calls on the COGCC to adopt a definition of cumulative impacts aligned with that used by the U.S. Environmental Protection Agency, i.e. cumulative impact is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. GHG emissions have a clear cumulative impact on Earth’s atmosphere. As the concentration of GHGs in the atmosphere increases, the Earth grows hotter and climate disruption increases, in the absence of countervailing influences. We believe it is important for the COGCC to have a clear definition of cumulative impacts and to account for all cumulative impacts when promulgating its rules.
Denial of Applications Where Local Warming Exceeds 1.5°C
The petition calls for the denial of applications for oil and gas projects or facilities located in areas or watersheds that have already warmed 1.5 degrees Celsius (2.7 degrees Fahrenheit). This is the global average warming threshold that the Intergovernmental Panel of Climate Change (IPCC) has stated must not be crossed. Colorado is warming at approximately twice the global rate, which has resulted in longer and more intense fire seasons, drought, and declining snow packs. Our state government needs to recognize that Colorado is especially vulnerable to increased levels of GHGs in the atmosphere, and to act accordingly by reducing emissions of those gases, especially in areas where warming has already exceeded 1.5 degrees Celsius. The FCSG notes that Larimer County, where we are located, has already warmed by 2.0 degrees Celsius.
Denial of Applications if the State is not Reaching its GHG Reduction Goals
The petition call for the denial of applications for Comprehensive Area Plans, Oil and Gas Development Plans, Form 2A Location Assessments, or Form 2 Applications for Permit to Drill, if the state has determined that it is not reaching statewide greenhouse gas emissions reductions goals. In 2019, the State adopted a goal of 26% GHG emissions reductions by 2025 compared to 2005 levels. The most recent report from the Air Pollution Control Division (APCD) shows that Colorado is not on track to meet the 2025 goal. A little additional math using the APCD’s numbers shows that Colorado will likely only reach about 2/3 (68.7%) of that goal. Until and unless additional actions are taken to reduce Colorado’s GHG emissions to put the State back on track, the FCSG does not believe it is appropriate to approve additional oil and gas projects, which further add to the problem of excessive emissions.
The remaining issues addressed in the petition are also important to protect the health and well-being of Coloradans and the environment. We urge the COGCC to initiate the rulemaking process for cumulative impacts of oil and gas development in our state as requested by the petitioners.
