Oil and gas activity in 2022 was heavily focused on the Front Range, which accounted for 72% of the 838 new wells approved and almost two-thirds of the new drill sites in the state, according to an annual report on the industry’s cumulative impacts.
The 2022 number was a sharp increase over 2021 when 48 wells were approved in the Denver-Julesburg Basin and the Eastern Plains.
Estimated air emissions for new projects and water consumption were also up, according to data provided by operators to the Colorado Oil and Gas Conservation Commission.
As part of Senate Bill 181 — the 2019 law that made the COGCC mission protecting public health, welfare, safety and the environment — the commission was directed to evaluate and address potential cumulative impact of oil and gas activity in Colorado.
To meet the requirement the COGCC required operators seeking drilling plans and well permits to estimate the potential impacts of their projects on air, water, land, wildlife and wetlands and rivers.
The first report based on those estimates was released in February 2022, and after a critique by commissioners, this year’s report was refined and includes more detail. Still, environmental groups fault the report for relying on industry projections.
“There is plenty of room for continued growth,” Julie Murphy, the COGCC executive director, said in the report’s preface. “For example, comparisons of actual water use during drilling and completion and actual air emissions to their estimated values.”
The drillers in their cumulative impact assessment offer estimates to the COGCC of what their emissions will be. Once up and running they report their actual emission to another agency, the Air Pollution Control Division.
The data is based on the 47 Oil and Gas Development Plans approved in 2022. A plan can encompass multiple drilling sites and multiple wells.
The bulk of the activity was focused on the Front Range, running from Douglas County in the south to the Wyoming border and from Adams and Arapahoe counties on the east to Clear Creek and Gilpin counties on the west.
Two-thirds of the drilling plans, 31, were on the Front Range. There were nine, or 19%, on the Western Slope. The Front Range also had the most approved drilling locations, 49 sites, equal to 64%, with 13 on the Western Slope, or 17%.
A total of 602 new wells were approved on the Front Range, followed by the Western Slope with 220 wells or 26% of the state total.
The operator reports also showed the demands for water on the Front Range rising and increasing more than in other parts of the state up 12% year-over-year to 425,000 barrels per well – enough water for a year for about 120 average families of four.
“The average estimated planned water use for drilling and completions per well is greatest for the Front Range,” the report said. “Wells in this operating area are typically horizontal wells with long laterals, which require a lot of water to complete the well.”
The most controversial bit
The most contentious element in the report is the air emissions analysis.
The industry estimates show that compared with 2022 there was a projected increase in emissions during Front Range drilling and hydrofracturing.
Emissions of nitrogen oxides, or NOx, increased 30%, to 8.3 tons per well, and volatile organic chemicals rose 40% to 2.1 tons per well.
“The report showed some concerning trends,” said Heidi Leathwood, a climate policy analyst with the environmental group 350 Colorado.
“Even with the lowest per-well figures imaginable, you can’t deal with cumulative impacts without understanding that thousands of new wells piled on top of tens of thousands of existing wells has a detrimental impact,” Leathwood said. “The commission’s actions don’t show an understanding of that.”
NOx and volatile organics are the prime ingredients in the corrosive air pollutant ozone.
The Front Range has been designated by the Environmental Protection Agency as a severe ozone nonattainment area, which requires the state to take steps to cut the pollution. The region repeatedly exceeded the health standard of 70 parts per billion of ozone in the air.
The oil and gas industry through all its activities is responsible for about 8.6 billion parts per billion, with much of that coming from the use of diesel engines used in fracking and for moving oil through pipelines, according to the state Regional Air Quality Council.
The industry questions the council’s analysis. “We disagree with the statement … that the maximum oil and gas contribution to ozone is 8.6 ppb,” the state’s two biggest industry trade associations, the Colorado Oil and Gas Association and API-Colorado, said in a letter to the commission.
“That value inappropriately combines three categories of ozone contributions that occur on different times and places (away from ozone monitors and population centers), and thus cannot be summed in this manner,” the trade groups said.
Environmental groups question all the emissions estimates the industry makes in its cumulative impacts reports to the commission.
“These are all magical numbers made up by a self-reporting industry,” said Kate Merlin, an attorney with WildEarth Guardians. “What we are looking at is under reporting.”
In their letter, API-Colorado and COGA, said “estimates submitted during the early planning stages often err on the side of over-stating impacts to be conservative.”
The trade groups said they agree that “the future ability to compare actuals to estimates could be one of the most powerful tools for the evaluation of cumulative impacts.”
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At a public hearing on the report Monday, a largely pro-industry line of speakers urged the COGCC not to impose any more regulations on the industry. Commissioner John Messner, who chaired the meeting, tried several times to make it clear that there were no proposed regulations or decisions on the table.
That did not stem the warnings of the dire impact of more regulations. “I want to emphasize again, though it looks like a losing battle, we are not considering any regulations today,” Messner said.
In testimony, Broomfield City Councilor Laurie Anderson said that four years after the passage of Senate Bill 181 efforts to address ozone and cumulative impacts are falling short.
In many oil and gas plans, the commission and the Air Pollution Control Division resort to requiring so-called best management practices, BMPs, to reduce pollution and limit impacts, allowing a project to go forward.
“Impact minimization is not the same as establishing enforceable limits on the impacts,” Anderson said.
After the hearing, Anderson said: “They are gathering data but they are not doing anything with it.”