Mountain States

*UPDATE* Something Strange in Erie, Colo.

UPDATE (5/9/2012, 1:17pm ET): The alarmist air-quality claims of the activist group Erie Rising and NOAA scientist Steven Brown continue to unravel, according to the Daily Camera newspaper of Boulder, Colo.:

“A second scientific report in as many weeks will be presented to Erie’s elected officials challenging the notion that natural gas drilling operations in town are spewing unhealthy levels of emissions into the air.” http://goo.gl/OClPQ

This is the second time that Erie town officials have sought independent scientific advice to check the claims made by Brown and Erie Rising in February. It’s also the second time that outside experts have concluded Erie’s citizens are safe, and exposed just how flimsy and irresponsible those claims really are.

According to the Daily Camera, Erie Mayor Joe Wilson believes the town’s Board of Trustees were given distorted information before they voted for a 180-day moratorium on new oil and gas development:

“Wilson said the studies that have been commissioned by the town staff in the last few weeks to interpret and give meaning to the NOAA data indicate the agency’s findings were used by some drilling and fracking opponents ‘politically and inaccurately’ to cast Erie in a bad light. …

‘What we want to do is put this stuff in context, which it wasn’t before,’ he said. ‘As people get more educated, we’re seeing them becoming more accepting of oil and gas operations.’”

Let’s hope the facts will continue to drive the debate in Erie – and elsewhere – over the best ways to develop America’s abundant energy resources.

 —Original post from April 30, 2012—

“One of the basic foundations of modern science … is ‘peer review.’ Peer review means new scientific discoveries, ideas, and implications are not accepted or considered valid until they have been scrutinized, critiqued, and favorably reviewed…”

 National Oceanic and Atmospheric Administration (NOAA)

“…I don’t really have time to take you through the details of an analysis like this. I’m just going to ask you to believe what I tell you…”

Steven Brown, NOAA Employee

The development of homegrown American energy is giving communities across the country a fighting chance to overcome our current economic malaise. By one estimate, oil and natural gas development supports 9 million U.S. jobs and contributes more than $1 trillion to the economy every year. That said, the communities blessed with oil and gas resources often have reasonable questions about how energy production will proceed.

Here’s the good news: the independent companies that develop the vast majority of oil and gas wells are good neighbors with a strong record of responsible development, and interlocking state and federal environmental laws ensure the industry’s operations are tightly regulated. That’s not just the industry’s view – it’s also shared by the energy and environmental experts who enforce those laws.

Still, some communities want to hear from other folks, including scientists. That’s perfectly reasonable, too, as long as anything presented as “science” meets some basic scientific standards. The first and most important of those standards is rigorous and effective peer review. Without it, anything a scientist says is just an opinion, not the kind of hard evidence that’s needed to craft effective environmental laws and regulations.

Unfortunately, that lesson was completely ignored recently in Erie, Colo., a small town nestled in the northern suburbs of Denver. A single government scientist – Steven Brown of the National Oceanic and Atmospheric Administration – appeared before the town’s Board of Trustees at the behest of activist groups that oppose oil and gas development. Armed only with a slide presentation, Brown swayed the board into approving a six-month ban on new oil and gas development in Erie.

Energy in Depth wants to set a few things straight about Brown’s presentation, the way it’s being spun by activists and how it’s been covered by the news media. EID’s concerns are serious, and we hope they’ll be taken seriously by the Town of Erie, NOAA and anyone else with an interest in sound science and the responsible development of America’s abundant oil and gas resources made possible by the combination of horizontal drilling and hydraulic fracturing.

The Town of Erie acted on opinion, not science

Brown’s central claim goes something like this: During a one-month research project in the winter of 2011, a NOAA observation tower in Erie recorded higher levels of propane in the air than are usually seen in Pasadena, Calif., and Houston. Brown surmised that the propane emissions came from oil and gas development in the Denver-Julesburg Basin.

Brown’s Feb. 21 presentation, which can be accessed here, was highly technical in nature, especially the section that tied those propane emissions to oil and gas development. But rather than explain it fully, Brown told a group of elected officials who were poised to act on his findings:

“What you can do with a set of data like this is to break it down into what the likely sources are. I don’t really have time to take you through the details of an analysis like this. I’m just going to ask you to believe what I tell you about the ranking of these compounds…”

Brown’s presentation played perfectly into the communications plan of environmental groups, including the local activist organization Erie Rising. Together, they have been trying to frighten Erie’s citizens and elected officials into banning new development with unsubstantiated health and environmental allegations. Here’s a sample of the press coverage generated by Brown’s presentation to the Board of Trustees:

A study showing that Erie exceeds Houston and Los Angeles in the levels of certain air pollutants commonly connected to oil and gas activity became a point of concern for several trustees Tuesday night during a meeting held to formulate local rules for resource extraction.” http://goo.gl/50TgA

A National Oceanic and Atmospheric Administration study said the propane levels in the air in Erie are worse than in Los Angeles and Houston.” http://goo.gl/eyhkz

Air pollution worse than Los Angeles and Houston? That would strike fear into the heart of any elected official in a town where the median age is 33, the median household income is a touch under $100,000 a year, and officials brag about “educated, affluent, diverse and dynamic” residents and their “close proximity to world-class research and academic institutions.” Scarier still, it’s politically perilous for local officials to challenge Brown’s opinion because he works at one of those revered institutions – NOAA’s Earth System Research Laboratory, which is just a few miles west in Boulder, Colo.

So, on March 7, a little more than two weeks after Brown’s presentation, the Erie Board of Trustees voted unanimously for an “emergency ordinance” that imposed a six-month moratorium on new oil and gas development. But nine days later, NOAA revealed that the town had passed a local law based on the opinion of a lone scientist and the alarmist claims of environmental activists. In a March 16 notice on its website, the federal agency said:

“Please note that analysis of the data from this study is in progress. When a peer-reviewed paper is published, we will make it available to the public.” http://goo.gl/zWL6b

Brown didn’t get his conclusions peer-reviewed before presenting them to a local government. No peer review. No hard scientific evidence. Just an opinion. But that opinion, when it’s part of a concerted campaign of fear-mongering from activists, was powerful enough to get a local ordinance passed that was designed to shut down an entire industry within the town’s limits for at least six months. This wasn’t democracy in action. It was a mugging. Not just a mugging of an industry and its workers, but of the town’s elected leaders and the citizens they represent.

Of course, the Town of Erie’s authority to enforce such a ban is questionable, since state governments usually have jurisdiction over oil and natural gas development, not local governments. But that’s a discussion for another day.

The Denver area has better air quality, not worse, than Los Angeles and Houston

Brown’s presentation focused on propane and other volatile organic compounds, or VOCs, which can contribute to the formation of ground-level ozone, which causes smog. Other sources of smog-forming pollution include factories, power plants, car and truck exhaust fumes, gasoline vapors from vehicle refueling and chemical solvents, according to the EPA.

Both state and federal environmental regulators monitor ozone levels very closely, so it’s possible to make comparisons between different metropolitan areas.

According to EPA data, ozone levels in the Denver metropolitan area – which includes Erie – are 34 percent lower than those in Los Angeles and 15 percent lower than the levels in Houston. The same EPA ozone statistics show Denver and Erie have better air quality than 37 other major metropolitan areas.

Erie’s air quality has improved as natural gas development has expanded

When natural gas starts flowing from a newly developed well, VOCs can develop. And if they aren’t captured or flared, they can combine with other ozone-forming emissions from cars, trucks, power plants and factories and make an existing smog problem worse.

But that’s not happening in Erie. Colorado’s Air Pollution Control Division has a statewide network of monitoring stations that continuously measure air quality. These long-term monitors provide a much clearer picture of air quality than the month-long snapshot in Brown’s research.

One of those APCD stations is located just west of Erie, in Boulder, and another is placed in Greeley, about 40 miles to the northeast. Both the Boulder and Greeley stations are well placed to measure emissions from natural gas development, as well as all the other forms of pollution that exist in a major metropolitan area.

Ground-level ozone levels have fallen at the Boulder and Greeley monitoring stations in the past five years, according to Colorado APCD reports and data. Boulder’s maximum concentration under the federal 8-hour ozone standard has dropped by 6 percent, and Greeley’s has fallen by 10 percent. During those five years, natural gas production in Weld County – which takes in parts of Erie – climbed 25 percent, according to data from the Colorado Oil and Gas Conservation Commission.

That’s some feat. It should be a source of pride for the companies that develop oil and natural gas in Colorado, and the state’s regulators, who have worked together for nearly a decade to reduce the industry’s VOC emissions even as production grows.

Nobody is arguing that Erie’s air quality is perfect – it’s not. In 2007, Denver and its suburbs were deemed an ozone “non-attainment” area by the EPA. Since then, ozone levels have fallen, according to the EPA, but the Denver area remains in non-attainment. That’s because in 2008, the EPA ratcheted down the national ozone standard from 80 parts per million to 75 ppm. Even so, Weld County’s air quality compares pretty favorably to other areas of Colorado. The American Lung Association keeps tabs on 17 Colorado counties, and only five score better than Weld County.

But one thing is crystal clear from all this data on VOCs, ozone, smog and natural gas production: Erie Rising and other activist groups don’t have a leg to stand on when they argue air quality in the Denver area is getting worse and new natural gas development is the culprit.

Denver is a major metropolitan area with many sources of pollution

By his own admission, Brown failed to explain why he blames oil and gas development for the VOC readings at the NOAA observation tower. Remember what he told the Board of Trustees – “I’m just going to ask you to believe what I tell you.”

As mentioned earlier, oil and gas development is but one source of VOC emissions. According to the EPA:

“VOCs are emitted from a variety of sources, including motor vehicles, chemical manufacturing facilities, refineries, factories, consumer and commercial products products, and natural (biogenic) sources (mainly trees)…” http://goo.gl/woJlX

As it turns out, nature is responsible for 72 percent of the VOC emissions in the air. Here are some of the sources that make up the remaining 28 percent:

“…coal-, gas-, and oil-fired power plants and industrial, commercial, and institutional sources, as well as residential heaters and boilers … cars, trucks, buses, and motorcycles … construction equipment, lawnmowers, chainsaws, boats, ships, snowmobiles [and] aircraft.” http://goo.gl/woJlX

Nationwide, the largest source of VOC emissions are cars, trucks and other mobile sources. That’s also true in Colorado, where mobile sources generate 13 times more VOCs than oil and natural gas development, according EPA data.

That should have mattered a great deal to Brown, because Interstate-25 is located about one mile east of the NOAA observation tower. According to Erie town officials, 91,000 vehicles a day use the stretch of I-25 nearest to the tower site. Even NOAA has warned of the impact of I-25 on the readings from the observation tower:

“I-25 lies to the east of the tower so winds form [sic] the NNE to SSE are likely to influence the tower measurements, depending on boundary layer conditions.” http://goo.gl/XR13Y

That’s hugely important, because besides propane, Brown also says the VOC benzene was detected at the observation tower. He calls benzene a “natural gas tracer,” and concludes it must have come from oil and gas development.

Care to guess what the biggest source of benzene is, according to the EPA?

“…most of the nation’s benzene emissions come from mobile sources. People who live or work near major roads, or spend a large amount of time in vehicles, are likely to have higher exposures…” http://goo.gl/SOuqd

That’s right – the biggest sources of benzene are cars, trucks and the major roads they use. A major interstate highway with a traffic count of close to 100,000 vehicles a day more than meets that definition. Hopefully, the experts who peer review Brown’s presentation – if it ever gets that far – will ask some tough questions about this.

There are other sources of propane and the levels detected aren’t dangerous

 A bigger question for Brown’s reviewers, though, is how he managed to blame oil and gas development so quickly for the high propane readings recorded at the tower. As with benzene, Brown simply concluded that because propane can be released from oil and gas wells, it must have come from oil and gas wells. But, of course, propane is a widely used fuel and Brown failed to explain how he excluded other possible sources. We are all just supposed to “believe” he knows where it came from.

Brown may have overlooked the fact that the tower readings were taken during a month-long period during the heating season (Feb. 16 to March 13, 2011). Did he bother to check how many homes, businesses, industrial facilities, municipal buildings, universities and federal offices in the area are heated with propane, or use it in other ways? We don’t know because he didn’t bother to explain.

Among other sources he may have overlooked: propane-fueled vehicles. Erie is located right in the middle of two alternative-fuels programs spanning more than 40,000 square miles around Denver and Northern Colorado. Those programs promote the use of propane and other fuels. In fact, across the two programs, propane fueling locations are only outnumbered by electric charging stations and ethanol pumps. Within 50 miles of Erie, there are 34 propane fueling stations alone, according to the Department of Energy.

Of course, the failure to investigate the actual source of this propane wasn’t even most alarming part of Brown’s presentation. It was the levels he reported. They alarmed the Board of Trustees and no doubt many citizens of Erie, but in the notice it sent to the board, NOAA refused to put those levels into their proper context:

“Some VOCs have known health risks. NOAA’s Earth System Research Laboratory does not have health risk expertise. Health information is available through other agencies…” http://goo.gl/zWL6b

Thankfully, though, rather than let activists continue to scare people with tales of toxic propane pollution, Erie officials sought to end the speculation. Perhaps stung by their experience with Brown, they “engaged in an independent, peer-reviewed” analysis to “determine what (if any) health effects would result from exposures to the levels of propane as presented.” The result?

“The scientific analysis of the data concludes that: ‘The levels of Propane in the NOAA study are 1,000 – fold or more below those considered to be of a health concern.’ The average level of Propane as presented by NOAA was 20 ppb (parts per billion) and the maximum level was 115 ppb. According to the analysis: ‘Propane at 115 ppb (the peak level found) does not present a health concern to the citizens of the Town of Erie.’” http://goo.gl/nl7PZ

To review: A peer-reviewed, scientific analysis of the central finding in Brown’s presentation – high propane emissions – concludes they are 1,000 times lower than the level that would cause health concerns.

Was Brown’s collaboration with activist groups appropriate?

After Erie’s elected officials approved the six-month moratorium last month, Erie Rising sent out a press release taking credit for both “remarkably discovering an unknown NOAA study” and for the vote itself. The release had all the hallmarks of a fundraising pitch, and made it clear the group’s ambitions extend well beyond Erie’s town limits:

“Founded by accomplished women, mothers and business owners, Erie Rising is positioned to become an exceptionally effective national grassroots mom-powered organization bringing awareness to the issues at hand.” http://goo.gl/GVx1C

Separately, a spokeswoman also bragged to a reporter that the group was directly involved in the preparation of Brown’s presentation and in arranging his appearance before the Board of Trustees:

“The study was never made public and it’s only through [Erie Rising’s member April] Beach’s curiosity that it came to light at all.

‘I had no clue what I was looking for’ when she called NOAA asking if anyone had studied air pollution in Erie, she said. She called Brown, whose name she found on the NOAA website, on something of a whim. He sent back pages of technical data indecipherable to most laymen and it took some back and forth with him to have it interpreted. When she showed the study to Erie Town Administrator A.J. Krieger, she said he urged her to have Brown present the trustees with the results.” http://goo.gl/uYIwW

Are we supposed to believe that Brown was innocently and unwittingly recruited to serve the interests of Erie Rising? Are government scientists supposed to engage in a “back and forth” with activist groups as they create propaganda that scares the public and helps them bully local officials into making hasty decisions? Does presenting data that has not been peer reviewed to a government body, when that information will be used to make policy, breach NOAA’s standards or federal data quality guidelines? Should a federal employee use taxpayer-funded research to help an activist group lobby elected officials, and collaborate with members of the group on how the research is presented?

We don’t know the answers to these questions. Hopefully now, though, we won’t be the only ones asking.

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