DENVER – Today 33 environmental groups representing tens of thousands of Coloradans impacted by climate change and air pollution joined together in demanding that the COGCC take immediate action to address the harmful cumulative impacts of the oil and gas industry: a mandate enacted in 2019 by SB 19-181. In the two years since SB19-181 passed into law, the Commission has adopted only a handful of rules which address a small subset of these impacts. 

In 2022 the COGCC produced the first of its required annual reports on cumulative impacts. This report is inadequate. Though it documents the existence of many more categories of potential impacts, it confines its analysis solely to oil and gas operations, although many operations occur in areas already heavily impacted by other pollution sources. For example, Colorado plans to increase oil production significantly in the Denver Metro-North Front Range ozone nonattainment area, further deepening the ozone crisis, despite the already excessive health burden on communities and families. 350 Colorado and the other 30 groups represented ask the Commission to analyze and address a fuller picture of cumulative impacts that includes ozone, air pollution, and climate change. 

In the letter to the COGCC, this coalition of affected groups points to the EPA definition of cumulative impacts, which includes the “total effects on a resource, ecosystem, or human community” and takes into consideration “all other activities affecting that resource no matter what entity… is taking the actions.” The coalition asks the Commission to include data with which to determine the total amount of pollution in a given area and look at the interaction between oil and gas impacts and other impacts.

The request comes at a time when scientists predict a hot, dry summer, with health impacts from ozone, drought that impacts agriculture, and more fires that threaten communities and force disruptive evacuations. According to the Intergovernmental Panel on Climate Change’s most recent August 2021 assessment, there is “high confidence” that human-influenced rising temperatures are a direct cause of the extension of the wildfire season, increased drought, and decreased precipitation in the southwest United States. Multiple recent independent studies have found that the American West is currently experiencing a mega-drought which is the worst in the past 1,200 years, and point to human-caused climate change as much of the cause. Much of Colorado’s cumulative pollution puts an unjust burden on historically marginalized low-income communities and people of color, further amplifying the urgency to address the issue.

Oil and gas operations are the largest contributor (40%) to ozone in Colorado, according to the Regional Air Quality Commission. The oil and gas industry contributes 150% as much to our ozone problem as all of the passenger cars in the state, according to CDPHE data. The 2021 GHG Inventory shows oil and gas operations as one of the largest emitters of greenhouse gasses, as methane leaks into the atmosphere during drilling and production and from unplugged inactive wells, which is before any accounting for end-use combustion. Colorado exports most of its oil and gas,, and as the 5th highest producer of oil and the 7th highest producer of gas in the top producing country in the world, Colorado’s contribution to global climate change is substantial. 

“When people often can’t even safely go outside in areas with high ozone and air toxics, how can the Commission seriously think they are protecting the public and the environment by ignoring these baseline levels of pollution and allowing even one more well in these areas?” says Heidi Leathwood, Climate Policy Analyst for 350 Colorado.   

“The Commission has a legal and a moral duty to act to protect the people of Colorado from the cumulative impacts of oil and gas development, including the millions of Coloradans living with dangerously high ozone levels. Our kids deserve to be able to play outside in the summertime, and all the folks who fix our roads, carry our mail, and do other important outdoor jobs all deserve to breathe healthy air, ” adds Kate Merlin, WildEarth Guardians’ Climate and Energy Program Attorney for Colorado.

This environmental coalition is calling for the Commission to evaluate and address the cumulative impact of oil and gas operations on climate change and on air pollution including ozone. The concept of looking at impacts from other sources in an area or region can also be applied to water, soil, land, wildlife, and other impacts that affect health such as noise, light, dust, traffic, etc.  Members of the public can contact their local representatives, Governor Polis, and the COGCC to demand action to reduce dangerous pollution and protect their families and communities from these harmful impacts.