Broomfield and the Allied Local Governments had many successes in the flowline rulemaking at COGCC.
Broomfield and the Allied Local Governments had many successes in the flowline rulemaking at COGCC. We were successful in:
- Advocating for no automatic exceptions for removal of flowlines; all requests are subject to Director review and input of local governments
- Requiring local notice of all flowline abandonment notices and opportunity to weigh in
- Third party inspections of all off-location flowlines prior to being placed into active service
- Records required to demonstrate compliance with all 1101 rules
- Operator to submit verification of proper abandonment in place, if allowed. In addition COGCC requiring 3rd party inspection of abandonment in place
- Leak detection/redundant methods of integrity management got lots of discussion during deliberations and will be taken up during the February mission change rulemaking.
- Removal of flowlines is the presumption. There is a list of exceptions for abandonment in place that can be considered by the Director to determine if the proposed abandonment is least impactful to public health, safety, welfare, and wildlife.
Many thanks to Broomfield's outside counsel, Elizabeth Paranhos, for her hard work and to our fellow local governments for joining us on these efforts.