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Rebuttal statement on proposed AQCC revisions

Posted on 08/26/2020
Rebuttal statement on proposed AQCC revisions

The Board of Weld County Commissioners’ concerns regarding the Air Quality Control Commission’s (AQCC) proposed revisions to Regulation Number 7 were formalized in a submitted rebuttal statement sent by the county attorney last night.

Specifically, the county continues to be concerned about three primary items:

1. The lack of monitoring goals and adherence to the Environmental Protection Agency’s (EPA) recommended process in developing Data Quality Objectives when developing a monitoring program, specifically for pre-production.

2. The technical, safety and economic feasibility issues in proposed rules relating to disposal operations and emissions reductions from pre-production flowback vessels

3. The unreasonably short timeline for implementation of all aspects of the rulemaking

In their statement, the county offered again to assist in the air monitoring process by volunteering to oversee a pilot study. The pilot study would evaluate various air monitoring technologies, to help inform the AQCC workgroup and assess the feasibility of program design elements. The rebuttal statement continues, “Specifically, this approach provides a science-based approach that improves the quality and usability of collected data...”

To read the full rebuttal statement to the AQCC, please click here.