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The implementation of SB 19-181 has shifted the mission of the state’s Colorado Oil and Gas Conservation Commission (COGCC)'s from promoting fossil fuel activity to a more reasonable goal of regulating this activity.

As a physician, I strongly support the commission's planned new rules to extend the minimum distance between wells and occupied buildings from 500 feet to 2,000 feet given the extensive scientific literature demonstrating the health harms of fracking at substantial distances from well-sites. We should understand that there is no magical distance at which all of the health risks from fracking will be avoided; roughly 30-40% of air pollution suffered by residents of the Denver metro-area likely arises from distant oil and gas activities predominantly in Weld County, but a 2,000 foot setback is a step in the right direction.

However, I oppose the commission's plan to include a large number of waiver categories that would allow active well sites closer than 2,000 feet of an occupied building as this means that future oil and gas activity will have a disproportionate impact on lower-income neighborhoods and people of color.

A brief review of a map of recent oil and gas activity in the state (visible through an excellent online tool at the COGCC's website) makes systematic inequality in Colorado's recent oil and gas activity plain as day. Recent wells and applications are not distributed based solely upon the existence of fossil fuel resources, but instead conspicuously avoids areas of economic, racial, and social privilege. Neighborhoods of privilege are more successful in using the state's bureaucratic machinery and courts to fight off the damaging impacts of new wells and in turn, oil and gas operators avoid areas of privilege in hopes of maintaining their tenuous social license to continue operations in Colorado.

It is self-evident that allowing waivers to a new 2,000 foot rule will make the state complicit in continuing to impose the negative health impacts, annoyances, and external economic damage of fracking on those least able to accommodate it.

Additionally, fossil fuel operators' arguments regarding "necessary" future extraction within a 2,000 foot limit are absurd. Existing wells can provide decades worth of natural gas for Colorado's own use (and unfortunately will continue to spew climate damaging methane for many decades after discontinuing their useful life). Levelized costs for electricity from fully-renewable sources with energy storage are now easily competitive with fossil-fuel energy sources.

Sacrificing Colorado's local environment, climate goals, and the economic externalities imposed by poorly regulated fossil fuel activities in pursuit of products that are currently of little value and trending towards worthless on global commodity markets is a terrible strategy for the state government to pursue.

Elliot Dickerson, M.D.

Littleton

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