- General Regulatory Practice:
WHEREAS the energy sector employs more than 7.8 million Americans in many fields, including but not limited to; electric power generation, transmission, distribution and storage, energy efficiency and fuels, and
WHEREAS the energy industry operations in Colorado contribute billions of dollars to the state’s economy, and
WHEREAS the western slope, including the Piceance Basin, is home of some of the cleanest and most densely concentrated fields of energy resources, and
WHEREAS Colorado is also home to some of the most spectacular wildlife habitat in the world and it is important to ensure that development of our energy resources is done in a manner that takes other important natural resources into account, and
THEREFORE, BE IT RESOLVED that input from technical and industry experts should be adequately reflected in all regulatory oversight, and
BE IT FURTHER RESOLVED that Club 20 does not support regulations that would be duplicative and unnecessary; and
BE IT FURTHER RESOLVED that Club 20 opposes any attempt to, enact wholesale energy bans or create regulatory chaos by repealing Colorado’s traditional statewide approach to energy regulation.
BE IT FURTHER RESOLVED that Club 20 opposes any ballot initiative, amendment, proposal, or legislation that has not been fully vetted in transparent forums that involve all potentially affected stakeholders (including local governments) and has not considered relevant analyses of the social, economic and environmental impacts of such proposals, particularly as they concern the locally affected communities.
BE IT FUTHER RESOLVED that Club 20 supports that state-level agency officials understand the operations in each basin, regardless of county lines; and
- Oil and Natural Gas:
WHEREAS Colorado has large reserves of oil and natural gas and the development of these reserves is not only an important economic opportunity for our state, but also an important part of reducing our nation’s dependency on foreign energy supplies, and
WHEREAS the Colorado Energy and Carbon Management Commission (CECMC), formerly known as the Oil and Gas Conservation Commission (COGCC),is required to promulgate rules concerning public health and wildlife involving the Colorado Division of Parks and Wildlife (CPW) and the Colorado Department of Public Health and Environment (CDPHE) in the development of appropriate regulations, and
WHEREAS oil and gas development is a capital intensive and high-risk business requiring regulatory consistency and predictability to justify investment, and
WHEREAS the State of Colorado has been regulating drilling activity since 1951. Every aspect is currently overseen (at a minimum) by the CECMC which acts as the lead regulatory agency for oil and gas in the state of Colorado and regulates cradle to grave oil and gas activities from well siting, drilling, completion, and production to reclamation and final plugging and abandonment including, but not limited to:
- Well design, location, spacing, operation, water management and disposal, waste management and disposal, wildlife impacts, surface disturbance, and health and safety.
- Drilling operations including prevention of surface spills, ensuring adequate cementing through cement bond logs and mechanical integrity tests, and monitoring the surface casing and production casing annulus (Bradenhead) during fracturing operations for signs of any fluids migration, and
WHEREAS federal laws that govern environmental aspects of natural gas and oil drilling include:
- The Clean Water Act (CWA)– regulates discharges of pollutants to surface water and storm -water runoff.
- The Safe Drinking Water Act (SDWA)- regulates specifically the injection of fluid wastes (produced water) under the ground.
- The Clean Air Act (CAA)– sets rules for air emissions from engines, gas processing equipment, tanks and other sources associated with production and drilling activities.
- The National Environmental Policy Act (NEPA)–requires environmental impact assessments for development of federal lands.
- Occupational Safety and Health Act– administered through OSHA, sets safety standards with which employers must comply to protect their employees. Also requires Material Safety Data Sheets (MSDS’s) to be maintained and readily available for chemicals used on locations for employee use.
- Emergency Planning & Community Right-to-Know Act (EPCRA) – requires storage of regulated chemicals above certain quantities be reported to local and state emergency responders on an annual basis.
WHEREAS by law, state regulations must be at least as protective as federal standards. The oil and gas industry and the agencies that regulate them are committed to protecting groundwater, and environmental health and safety are priorities for both the industry and the regulatory agencies; and
WHEREAS, there are counties/municipalities that attempt to ban hydraulic fracturing at a local level by resolution or by the public voting process based on incomplete or misleading information; and
WHEREAS, over the years hydraulic fracturing has been studied a multitude of times and on separate occasions the Environmental Protection Agency (EPA), the Department of Energy, and academia have determined that hydraulic fracturing does not pose a threat to groundwater and studies have found no significant environmental risks as a result of proper hydraulic fracturing; and
NOW, THEREFORE, BE IT RESOLVED that Club 20 supports utilizing our domestic energy supply to achieve energy independence, both nationally and to assist our geopolitical allies, and
BE IT FURTHER RESOLVED that Club 20 believes that rules regarding the development of Colorado’s Oil and Gas reserves should:
- Support and encourage the responsible development of Colorado’s oil and gas reserves, and
- Provide an efficient and timely process for the regulation, application and issuance of permits to drill, avoiding unnecessary or conflicting regulation, and
- Provide appropriate protections for public health, wildlife and the environment, and
- Secure the rights of private landowners to possess, control, and enjoy their property without additional restrictions on private land and
- Secure the rights of mineral owners to possess, control, and enjoy those mineral resources
- Be analyzed to assess their cumulative economic effects on industry and the State and local governments, and
- Consider any changes to the industry’s tax and/or regulatory burden, and
- Where possible, be implemented at the state level with local government input
- Anticipate the unintended consequences of the imposed regulations
- Allow for inclusive stakeholder input and time for analysis, to evaluate the impacts of proposed regulations on industries, businesses, and communities, and
BE IT FURTHER RESOLVED that, concerning the enforcement of oil and gas regulations, the Colorado Division of Parks and Wildlife should ensure consistency with local wildlife management plans and maps where such plans exist.
BE IT FURTHER RESOLVED that Club 20 supports the use of the best available technology by the oil and gas industry to minimize the possibility of accidental leakage of methane into the atmosphere or contamination of water in the hydraulic fracturing process.
BE IT FURTHER RESOLVED that Club 20:
- Supports the use of hydraulic fracturing.
- Believes banning hydraulic fracturing would further harm the economy of Western Colorado and hinder progress toward American energy independence.
Incorporates the Following Resolutions:
- EN-08-1: Rules Concerning the Development of Colorado’s Oil & Gas Reserves
- EN-09-3: Hydraulic Fracturing, Supporting Exemption for in Safe Water Drinking Act
- EN-14-02: Hydraulic Fracturing Policy
Adopted 04/12/2024