COGCC response to my complaint

On June 5, I called the COGCC and complained about the bad air quality in Silt. I received an official complaint response report on Saturday (6/23).

COGCC Complaint Response

Really interesting. Note the highlighted areas.

Jump to Antero’s Jason Ryan brief statement:  “Stimulstion operations ended on 6/9”.

Funny how they can’t even get their euphemisms right. “Stimulstion” is not a word – probably a typo. Can I buy a vowel? Substitute the letter “a” for the second “s”. Stimulation? By that I assume he means fracking. Why can’t he just speak English? Anyway I was right. Antero was fracking on 6/5, which means there was also venting. Of course he doesn’t say they were venting. It’s just that I know venting is part of “stimulstion operations”.

Next we have Paul Reaser’s weather report. I guess he’s the new GarCo Public Health Manager replacing Jim Rada. I’ve talked to him on the phone. Nice guy – definitely a weather geek.

Reaser notes: “From 6:00 pm on 6/5 to the early morning hours of 6/6/12, our PM10 levels steadily rose (most likely as a result of the windblown dust) to 118 µg/m3.”

PM10 refers to coarse particulate matter, or dust. Here’s the index for that time period. The light gray line indicates hourly levels. Notice the spikes which correspond to my complaints.**


Take a look at the Ozone index for the same time period, which indicates high PPB levels as well.

Reaser concludes: “At this peak level, air quality is still acceptable, however, for some pollutants there may be a moderate health concern for a very small number of people who are unusually sensitive to air pollution.”

In other words, it’s your fault if you can’t breathe the air.

What Reaser doesn’t say is 118 µg/m3 is most often found in areas where there is commercial industry, like major metropolitan areas. I think it’s safe to say that in rural western Garfield County there is quite possibly a significant portion of the population who moved here to get away from urban air pollution from commercial industry. His statement that those levels affect “a very small number of people” is a broad generalization not based on scientific evidence.  Especially since no studies have ever been conducted as to how many people are actually affected by the bad air quality in western Garfield County. Or how many people moved here because they are “sensitive to air pollution”.

Reaser’s conclusion is baseless. The PM10 index only takes into account dust and not what is in the dust, like hazardous air pollutants – HAPs.

The EPA “calculates the AQI for five major air pollutants regulated by the Clean Air Act: ground-level ozone, particle pollution (also known as particulate matter) [dust], carbon monoxide, sulfur dioxide, and nitrogen dioxide. For each of these pollutants, EPA has established national air quality standards to protect public health.”

Reaser has no way of knowing the chemical contents of the particulate matter – because even though studies were conducted by the Colorado School of Public Health in the Battlement Mesa HIA, that report has disappeared down the memory hole. The BOCC is not interested in the study’s findings or conclusions.

According to the Colorado School of Public Health

As evidenced by ambient air studies in Garfield County, NGD [oil & gas] activities emit several hazardous air pollutants (HAPs), including benzene, toluene, ethylbenzene, and xylenes (BTEX). Toluene and xylene concentrations measured in grab air samples averaged 105 and 138 μg/m3, with maximum concentrations reaching 540 and 1500 μg/m3, respectively. Benzene concentrations averaged 32 μg/m3, reaching a maximum of 80 μg/m3

None of those HAPs are included the EPA standards.

Obviously I’m no scientist. I find all this stuff about PM10 index, µg/m3, and PPB mind-boggling. What I do know is the EPA air quality index Reaser uses to draw his conclusion does not measure the HAPs associated with fracking, which are known to exist in the air in Garfield County. There is no scientific basis to determine “acceptable” air quality in western Garfield County because none exists.

Even though representatives of Garfield County, the COGCC, and the CDPHE declare the air quality is “acceptable” – the sky is pink – that is not based on any accurate scientific data of ambient air studies that include HAPs. It is only their opinion.

When the public – as in actual human beings and not an agency – says the air quality is hazardous because it makes us sick, we draw that conclusion based on experience. Because it’s not based on accurate scientific data of ambient air studies that include HAPs, the response is always that it is only our opinion. They say we don’t have any proof the air quality is hazardous. But they have no proof it’s safe.

Finally, I should point out:  “Jennifer Mattox of the Colorado [Air] Pollution Control Division was on hand on June 5th to accompany and advise COGCC Staff of inspection items pertaining to air emissions.”

No problems were found. But my complaint was not for June 5. I think it’s perfectly reasonable to assume Mattox’s appearance was no surprise and Antero knew she would be in the area on June 5. Her report may be reliable, but it doesn’t pertain to the dates or times in my complaint.

It may or may not be significant that she was in the area at the time. I couldn’t find out anything about normal inspection schedules. Perhaps her annual inspection happened to coincide with my complaint. Or maybe she was responding to a previous complaint from someone else. Whatever the case, I’m glad it worked out that way so she was aware of my complaint. Even though she joined with the others in blowing it off.

** Data from Garfield County air quality monitoring station in Rifle. There is no air quality monitoring station inside Silt city limits. To plot hourly data for any given time period, click on “7-Day Timeline Plots” under the image of downtown Rifle.

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3 Comments on “COGCC response to my complaint”

  1. Todd K. Says:

    I would ask what the wind velocity was, and what direction . What the traffic count on I-70 was and what the traffic on the secondary roads was and what the road construction activity was and why the air quality was varying for other reasons as well as the gas and oil field operations. What was the dust and other contaminates content in the air in PPM. We could do a carbon imprint study for more specific data. Even the humidity and temperature could affect the readings. I would look for a broader overview to analyze. I know that the gas and oil field activity is playing a role in everything but there is way more to it than meets the eye. I remember when the coal was the issue. We hated the coal trucks running the road on Co. 133. This is the energy industry. The Fed is keeping and inforcing so many regulatIons. this is a tight run ship. This has contributed to the local economy and the well being of the country for some time now. I have never seen agriculture with so much money in its hands to invest in equipment, buildings, feed, stock, etc. than at this time in the local history as I know it. I’d like to mention that geo-thermal activity in the area is prevalent. Look at the Glenwood Hot Springs, Penny Hot Springs, South Canyon Hot Springs, etc. This lends to my thinking that any “bubbling” in any creek or vapor caves or whatever could be due to our natural geo-thermal activity in the formation of the earth that we are living on, not “fracking”. Although I’m sure that has an affect. The chemicals they use are derived from the products they produce. I really don’;t think it’s all as bad as the allarmist thinks it is. This and the local climate at this time of this year is enough to drive a person mad. Thanks for the link to the fires. I love this stuff and you.

  2. Peggy Tibbetts Says:

    I don’t agree with a single thing you wrote but that doesn’t mean we can’t still be friends. 🙂

  3. Peggy Tibbetts Says:

    The bottom line is the air and water do make people sick and they bury or ignore the studies that confirm the dangers go here
    http://pennsylvaniaallianceforcleanwaterandair.wordpress.com/the-list/

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