Proposed methane rule not necessary or appropriate

Email letters, February 19, 2014

Proposed methane rule not necessary or appropriate
 
The Air Pollution Control division of the Colorado Department of Health and Environment Air has proposed alterations to three regulations that directly affect the oil and gas drilling industry in our state.
The changes in rules 3 and 6 appear to be reasonable for the purpose intended. My only significant concern lies with some of the proposed revisions to Regulation 7.
I do not feel that it is either necessary, nor within the Commissions purview, to regulate methane as a greenhouse gas. The goal of the regulations, and the desire of the people of Colorado, is to control pollutants that contribute to smog, ozone, and other problems, none of which methane contributes to. Basically, the fact there is no scientific evidence to support the inclusion of methane as a pollutant should give the commission pause.
Methane is such a small portion of our atmosphere that it doesn’t warrant the high costs necessary to capture it.
The concern over methane as a global warming gas is blown far out of proportion. All global warming gasses together only make up about 5 percent of the atmosphere and the vast majority of that (95 percent) is plain old water vapor (4.75 percent of the atmosphere). The remaining components are CO2 at 3.62 percent (of global warming gasses) followed by methane at 0.36 percent. This is such a small portion of the atmosphere that it is hardly worth considering.
The issue of scientific justification also comes up when considering the fact that these proposals exceed any that the federal government has come up with. Colorado law requires, properly, that any state regulation that is more stringent than a comparable federal one, must first be properly justified. I do not think that the commission has provided the requisite evidence to justify its creation of regulations that are so much tougher than federal ones. This is one reason I lend so much support to the proposals concerning Regulation 6, which will fully implement federal standards. Let’s see how those do at attaining the desired level of air quality before writing new, stronger ones.
I believe that this regulation change has more to do with a political desire by some of the more radical environmentalists to block all drilling in our state. They will use any avenue available and this and a suggested fracking ban are just two of the most obvious.
Finally, I am also concerned that the costs have not adequately been weighed against the benefits, especially for places such as the Western Slope of the state which does not have the same problems with air quality that exists in the Denver metro area. The costs to achieve these ends will be substantial since the technology does not even exist to achieve the standard.
This will further handicap Colorado in the national energy production market by making our oil and natural gas significantly more expensive than other plays such as the Marcellus and Eagle Ford. Our gas is already a dry gas, which does not contain significant “wets” (butane, ethane and others). It is these “wets” that are currently giving natural gas their value, not the methane portion.
We do not need more handicaps against producing energy in Colorado, let alone western Colorado. These changes are simply not warranted.
Don Pettygrove
Grand Junction